Food safety preventive controls aren’t just the law, they are a smart business investment that will economically benefit your food facility — whether or not you are subject to specific laws of prevention. In the simplest of terms, the opposite of prevention is reaction; and that, in the food industry, is all-too-often equivalent to recall, significant economic impact, potential criminal investigations, and the loss of your business. Recalls, with their impact on brand damage and loss of sales, have been cited as the greatest threat to profitability for food businesses. A 2010 FMI/GMA study estimated the average direct cost of a recall to a food company to be $10M (nearly $12M in today’s dollars). With that being an “average” estimate, just imagine the direct cost of a large recall by a large company. And that doesn’t even account for the crisis communication, corrective action, and operational improvements that will be required for brand protection. Prevention isn’t free, or even cheap. By FDA estimates, a facility subject to the full requirements of the Preventive Controls Rule, could expect to see annual compliance costs approximately $13,000 per facility, qualified facilities subject to modified requirements could expect annual costs to range from $300 to $2,000. Not cheap, but certainly a great deal less than that of a recall … or litigation should a consumer become ill, or even die, from a pathogen or allergenic contamination of your food. But prevention isn’t just about avoiding recalls or playing to the rules, rather one should take a holistic look at the costs of pathogenic contamination – and the benefits of prevention. A University of Florida report doing so stated that, if every pathogen included in FDA-regulated foods could be eradicated, the food industry would save $6.32 billion annually. While complete eradication is not, of course, possible, the benefits related to reduced incidence of foodborne illness outweigh the costs for most businesses — with food safety plans such as HACCP and FSMA potentially saving the industry $1 to $2 billion each year. The importance of prevention has been the subject of adages and axioms for centuries. focused on both specific areas of prevention and the concept as a whole – any of which can be applied to food safety. Take Benjamin Franklin’s oft-quoted axiom of the 1700s “an ounce of prevention is worth a pound of cure”; Albert Einstein’s “intellectuals solve problems, geniuses prevent them” from the early 1900s; or the more recent quote from the lesser known author Amit Kalantri that “a good doctor cures the disease, but a great doctor cures the cause.” While each stresses a slightly different aspect, all focus on the need for – and benefits of – prevention over reaction and are relatable to food. Franklin’s adage is particularly applicable as it was originally directed toward fire-threatened Philadelphia in 1736, advising them that it is better to prevent fires than have to fight them – what a great analogy for preventing vs. fighting food contamination. In applying Einstein’s statement, we will always need intellectuals to solve problems inherent in the food industry – neither we nor our systems are perfect. But the more we can further our genius to find ways to prevent problems from occurring, the more those intellectuals can focus their expertise on other food and industry advancements and improvements. Sometimes these problems are strategic and require a solid risk-based approach to determine where to apply available resources; sometimes they are very tactical and require a deep dive into the way plants or people are operating. Finally, let’s take a few liberties with Kalantri’s maxim to say: A good food industry executive/manager/employee cures the issues, but a great one cures the cause — i.e., delves to the root of an issue to understand it and prevent any future occurrence. While there is a reactive component to this, the overall presumption is that of prevention by getting to the cause rather than simply placing a bandage over it. Prevention is all about first assessing the risks and then managing the risks of your business by using the assessment and analysis to pull out a potential issue by the root before it has a chance to sprout. It’s not necessarily an easy task, but it is one for which the TAG team has the experience and expertise to guide and assist you in your efforts. Set up a free call with our team at TAG to help you determine if you are optimizing your food safety spend and reducing the risks you need to focus on. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com
