Proper hazard analysis and risk assessment is always the right direction.
“Digital transformation”, “big data”, “remote monitoring”, and “trend analysis”, all these buzz words have been discussed heavily in the past couple years in the food safety industry. Especially, with this year’s situation, more people are looking into solutions to help them solve the normal issues where traveling onsite is restricted.
To all food safety professionals – what does digital transformation mean to your food safety management system and daily practices?
We can’t deny that digital transformation is going to happen. Actually, it has already happened, whether you see it or not. For example, FDA’s newly released Traceability Rules are supporting the traceability exercises utilizing smarter tools and technologies.
The real question is not whether technology and digital transformation can help with food safety… but rather, how we still ensure our product safety while utilizing these technologies?
Hazards and risks are the foundation of food safety, and this fact is not changed when we use advanced technologies. Consider it as part of your hazard analysis process. As you conduct proper risk assessment throughout the entire facility, the known and foreseeable hazards of technology itself can be minimized and prevented.
Here are a couple tips and thoughts I would like to share.
- Update the initial hazard analysis to include technology use
Hazards associated with technology tools shall be considered and analyzed in your flow diagram. For example, electronic touchpad devices used on-site to collect data and records. Where are the devices located? What information is the technology collecting? What kind of physical hazards and biological hazards are associated with it? What do you do when it breaks? What actions and maintenance shall be taken for all the technology tools? These are valuable questions that can be asked to ensure all hazards are assessed.
- Ensure records are secure and accurate
When it comes to food safety control measures between records collected from traditional methods and advanced technologies, there aren’t significant differences. When technology is used, the same record requirements applied; authenticity, accuracy, and security. All data collected shall be securely stored and accessible to designated personnel, which should be set and monitored according to your food safety management system. On the other hand, for employees accessing the records, we also need to ensure that a detailed log is created to record the exact date/time and the identity of who is accessing records. Last but not least, for the verification records, it works the same way to meet the regulatory compliance. A digital system should be able to document the verification personnel and to trace the access trails. When using technology, the integrity of the records must not be compromised.
- Vulnerability assessment
Smart tools must be considered within the vulnerability assessment. A similar approach can be used when conducting a risk assessment. Depending on the processing and production line, threats and severity shall be evaluated and associated with the smart tools.
- Crisis Management
In addition to what we consider in our traditional crisis management plan; electronic crises shall also be considered when technology is used. Who is responsible for electronic crises? Are there any backup plans to ensure food safety and quality when unexpected technology crises occur? For example, when a temperature monitor is broken, how is temperature continuously measured and documented? When technology software is not working, how will access and use of the records be maintained during the outage? All these actions and preventions must be considered and documented. Mock crisis exercises can be implemented at a minimum annually.
- Preventitive Maintenance
Preventive maintenance can help a facility minimize many unexpected incidents. Similar to the approaches taken with all the equipment used in production, you must stay on top of all technology tools, software, or platforms that are used on site. Add the digital solutions to your preventive maintenance schedule. Stay connected with the digital solution providers to ensure you are receiving software updates. Establish detailed operational plans to prevent unexpected errors that could potentially impact product safety and quality. Whenever there is a change made to the digital solution, there should be a brief analysis conducted to ensure that the integrity of the food safety operations is not compromised.
Regardless of what approaches are used to control product safety hazards and risks, the foundation of how to prevent them is the same. We should always consider the hazards posed to finished products, and whether the risks are minimized. Technology is just one of those tools we use to control food safety and make our practices effective. Our goal is never changed: minimize product safety risks and improve product quality.
About Melody Ge (me):
Melody Ge has more than 15 years of experience within the food safety and quality industry. She has held various stakeholder positions including GFSI certification program owner, retailer, manufacturer, and food safety testing lab. Melody is Six-Sigma Black Belt certified, a registered PCQI Lead Instructor and SQF Trainer. As the Head of Governance, Intelligence and Analytics at Corvium, Melody is the subject matter expert while also leading the department that supports compliance, data analytics and training to achieve the smarter food safety era. Prior to joining Corvium, Melody was a senior consultant and deputy QA Director with Lidl US where she established the QA department for the US expansion. Melody also worked as the Compliance Manager at SQFI where her responsibilities include overseeing auditing results, stakeholders monitor and code Version 7 and 8 development. Melody started her career being the R&D and Food Safety Director at Beyond Meat. Melody holds both M.S. and B.S. in Food Science and Data Science certification.
About Corvium (my company):
Corvium is driving the digital transformation of food safety programs by automating and delivering a unified data platform for environmental monitoring, product testing, sanitation workflows, as well as tracking and alerting for conformance and compliance. We’re addressing the challenges that food suppliers are facing when it comes to making that leap from paper or manual spreadsheet processes to a fully digitized data-driven function.