Over my career in product safety and compliance, I’ve had the opportunity to work for a variety of businesses, large global corporations to smaller regional producers. These companies have made everything from cleaning products to medical devices, skin lotions, cheeses and fresh-cut salad blends. Yet, my role in each organization has been the same: to design, execute and measure product safety management systems that assured an outcome of consumer safety and trust. I view my role as lead for Science at Western Growers as the same…supporting all our members’ and the industry’s safety management systems.
Safety management systems are defined by the following attributes: 1) a series of risk identification and mitigation controls that can be applied to an operation 2) data-based feedback loops that verify that controls were successful; 3) reporting systems that promote transparency to leadership, regulators and customers and 4) a framework for a strong safety culture.
An easy analogy is to consider the safety management system used for cars. Cars have risk identification sensors, such as brake lights that tell us when we need to reduce speed; risk mitigation controls, such as brakes to reduce the car’s speed; and data-based feedback that verify controls are working, such as the speedometer. Brakes, brake lights and speedometers are the controls and data used by the driver to operate the car safely and provides transparency to other drivers so that they can also drive safely, thus making driving a car itself safer. Car manufacturers are always investing to improve safety, including additional sensors to identify when a car should brake beyond brake lights. These investments are improving the driver’s safety and ultimately trust in the car.
Our members also need to be able to anticipate and identify changes in safety risk, apply controls that mitigate such risk, and accurately measure if the controls are being effectively applied. Our members know well the risks associated with their operations. They conduct risk assessment throughout the growing and harvesting of a crop, deploy and document numerous controls to address the risk assessment, and measure the effectiveness of these controls using varied tools, such as pre-harvest testing. We are transparent by facilitating auditors, customers and regulatory inspectors to review these controls, their corresponding documents and effectiveness on a regular basis to assure they are in place and appropriate. We promote the traceability of our products using technology-enabled processes that link crop, field, harvest crew, harvest machine, day, time, etc. to a package or case for shipment. Yet, we all know there are important opportunities for continuous improvement in our safety management systems.
Upholding our member’s vital role in public health protection and environmental performance is paramount.
Let’s look at these opportunities in the context of a safety management system and my critical priorities.
1. Risk identification and mitigation controls: Our key opportunity lies in improving our understanding of how, when, and why our risk controls are either inadequate or fail. Whether it is an observation of a worker not wearing appropriate PPE or a pathogen positive test for a pre-harvest tissue sample, understanding through root cause analysis is critical to improving our industry’s safety management system’s effectiveness. Building capabilities in root cause analysis, including processes, specialized resources, training and education will be a critical focus.
2. Data-based feedback loops: Going back to my analogy of a car, we all agree that as drivers we need to be assured that the data we receive on our car’s braking system is accurate and timely. Finding out after we have an accident or receive a speeding ticket that we didn’t have the right data is not acceptable. Similarly, we expect the information we receive from the other cars on the road to also be accurate and timely. Again finding out after an accident that we didn’t have the right data is not acceptable. Understanding, via data, how our car performs in the context of other cars helps us drive more safely. Continuing to identify key partnerships and tools for food safety and environmental performance data and data-sharing is a priority.
3. Reporting systems that promote transparency to leadership, regulators and customers: We already have a need as an industry to strengthen our individual and collective reporting systems as we respond to challenges put forth by the Food and Drug Administration in both the Leafy Greens STEC Action Plan and their recently released blue print for the New Era for Modern Food Safety. Our customers and consumers will also benefit from developing comprehensive reports reflecting membership commitments in food safety and sustainability.
4. A framework for a strong safety culture: Our industry’s strong and on-going commitment to continuous improvement in our safety management systems reflect our foundational understanding of our vital role in public health and environmental protection. Strengthening our member’s safety culture will be an outcome of all our collective efforts.
As we face more and more challenges in food safety, environmental performance and customer and regulatory oversight, looking at our efforts within the context of a system helps us to remember that design, execution and measurement of the controls we use to support the safety of our products and the consumers are all equally critical.
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