This time each year we like to take look back to see what you are reading. Which TAG newsletters were most popular? What topics generated the most interest? Are we providing information and analysis that meet your needs? Following are the Top Most-Read TAG Newsletters of 2018, with some new commentary for your holiday reading. Lack of Allergen Controls Leads to Manslaughter Conviction. While allergen controls are certainly a concern, we expect that it was manslaughter conviction caused by the lack of controls that got readers attention. Particularly since another “criminal actions” article, Fear the DOJ. USDA Criminal Actions Report Caution For All, came in at #12. In general, it’s important for the industry to realize that the federal agencies aren’t taking outbreaks lightly and companies and individuals are being held liable – sometimes with very strict, life-altering penalties. What Is RTE Today and Why Is That Important to Know. As the saying goes: It’s not your dad’s ready-to-eat anymore. The definition hasn’t changed: anything “for which it is reasonably foreseeable that the food will be eaten without further processing that would significantly minimize biological hazards,” but consumers have. The trend toward “natural” foods is increasing consumption of raw foods – whether or not they were intended to be RTE. And keeping #1 (above) in mind, it behooves everyone to ensure you take full accountability of all “reasonably foreseeable” consumption of your products. What Does FSMAs Guidance Say about Sanitation Controls, Food Allergen Controls, and Recall Plans? It seems that TAG newsletters that focus on guidance are always among the top-read articles. Not only did this article come in at #3, FDA publishes long awaited guidance on labeling rules was #11, FDA Guidance Do I Have to Comply, #14, and Have You Written Your Food Defense Plan FDA Provides Guidance to Help #15. Understanding this, we will continue to provide analysis of guidance as it is published. What Are We Learning from Produce Outbreaks? The produce industry seems to be continually in the spotlight for recalls, but that does not mean that produce is less safe than other foods or that they aren’t “working hard enough.” Rather those outbreaks have provided lessons from which produce industry has learned – and which have lessons to teach us all. Q2 Recall Analysis Fuels New Food for Thought. While there is always something new in each of the quarterly Stericycle recall analysis, many quarters tend to look relatively the same with undeclared allergens topping the list. But if you look at the analysis from a different viewpoint – e.g., number of units instead of number of recalls, you’ll find an entirely different story. Find out why. If You Use or Sell Spices Watch Out You are on FDA’s Radar and Need to pay Close Attention to Your Preventive Controls. FDA has been conducting a number of sampling initiatives, focused on various foods for which it is seeking to determine rates of contamination and recommendations for reduction, as needed. One area of study was that of spices, to determine if the contamination found in imported spices was still present at retail or if it was being controlled along the way. A number of important messages were seen for industry from this work. E coli Contaminated Leafy Greens 2006 to 2018 What Have We Not Learned. As discussed in #4, a number of lessons have been learned from the produce outbreaks. However there also are a number of lessons that should be learned that seem to be falling by the wayside, e.g., traceability regulation. Pilot projects were run and technologies have proven successful, but still, the only real requirement to which industry is held is “one forward/one back.” As can be clearly seen in the #13-ranked article, FDA & CDC Keep Consumers Guessing in E coli Outbreak, this lack of traceability causes issues – and danger – throughout the supply chain. Harmonizing Standards: USDA Takes Commendable Initiative. Others to Follow. In June, USDA applied to GFSI for equivalency. You read that right – USDA applied to GFSI. It is an interesting and commendable turn-about. The purpose was to align the USDA Good Agricultural Practices Program with industry-recognized food safety audit requirements and provide the specialty crops sector with a single government-based certification program that meets multiple market access requirements. It’s certainly a step in the right direction in harmonizing standards and regulations. Standardized Date Labeling on Food Not Required but Highly Recommended. Although FDA has since extended the compliance dates for the new nutrition facts panel and serving size labeling rules, in preparing for the original July 2018 deadline, the industry faced a number of questions. A key question was: Do the new FDA labeling regulations require that the current “Best By” labeling be changed to “Best If Used By” or “Use By”? The answer: No. But … FDA’s Sampling Radar Now Zeroing in on Herbs. Again, the sampling. This time it’s about Cyclospora contamination of produce. It started with cilantro imported from Mexico, and has expanded to various herbs, spices, fruits and vegetables. The lesson: take a new look at your risk assessments and preventive controls to ensure that any ingredients or finished products without a kill step are being assessed for risk, and effective preventive controls are in place and validated. Those were your top 10 (plus a bonus 5) most-read articles. Are the topics we’re publishing meeting your needs? Are we providing information and analysis of interest to you? Are there other topics you’d like to see us cover? Let us know! We’d also like to take this opportunity to wish you all the happiest of holidays – however you may celebrate – from the entire TAG team. 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
