CSI: Fresh-Cuts

Today’s food safety measures require companies to anticipate the unexpected and exceed FDA’s requirements. That’s a lesson a Massachusetts company learned the hard way.

Chang Farm issued a recall of its bean sprouts and soy sprouts in late May, following a positive finding of listeria monocytogenes in a retail pack. While the company does the requisite testing for salmonella and E. coli, listeria testing isn’t required by FDA.

Fresh-cut processors can learn from this mistake. Meeting FDA’s guidelines isn’t enough to protect a business from an outbreak – even meeting buyers’ audit requirements isn’t enough.

Contamination can occur at many points during growing, harvesting, transport or processing, so a holistic approach to food safety is needed. Many buyers want to see where a product is coming from and what the processor is doing to ensure safe, high-quality raw product is used.

Risk of contamination increases every time raw or unfinished product is handled, so many processors are documenting where the product changed hands – even within the plant – and can trace a finished good to each employee who touched it.

I like to think of it in terms of the criminal justice system. When a crime occurs, the evidence at the scene is processed, and at each stage of the investigation through to the trial, a record of every person that touched the evidence is kept. If there’s a break in the evidence chain, even the worst defense attorney can get that evidence thrown out.

In a criminal case, not having a record of who handled the evidence is case for dismissal, but in an outbreak it may be used as evidence against your company. Not knowing where a product came from, who touched it or where it went could result in local health officials and FDA focusing on your plant as the source of an outbreak, because problems in recordkeeping might also mean problems in the food safety measures.

So, play crime scene investigator at the plant. Pick a product off the line, track where it came from and see who it came from and where it’s going. If possible, find out which employees handled it. Tracking fresh-cut produce through the processing plant can have added benefits. Some systems can show waste or lower output from individual employees, which could lead to more specific training programs and an overall increase in efficiency.