There is a common misconception that clear and direct failure must occur before a food safety outbreak.  While failures can happen – and they often do – many outbreaks have occurred in companies with robust food safety programs and well-executed compliance records.  In short, there was no obvious source of failure, and only a history of compliant programs.  In these outbreak scenarios, gaps are looked for in programs, claims are made that this could/should have been caught by the system, and, after the storm, many assume lightning won’t strike again. It was just a fluke – a rare event caused by a rare sequence of events that we won’t likely see again.  

It is tempting to believe that a perfectly executed food safety system will always prevent adverse events from happening. But that assumption is too simplistic. Compliance systems are not designed to capture dynamic risk. Why would they? They were designed to show regulatory compliance, program adherence, and foundational food safety elements around which a company produces food. These compliance systems are critically important. They provide consistency across the food industry, provide common language and systems to teach and implement, and they provide a solid foundation on which to customize systems. Despite their inherent value, they are not optimized to catch, stop, or mitigate all types of risks, especially those that are not easily anticipated. They are designed to build structure and compliance systems on which we can then design risk-based management upon.  

Food, in theory, should always be safe. When it isn’t, the simplest leap is often to assume that something in the system failed. Realistically, it’s a bit more complicated than that. Reducing outbreaks and adverse food safety events into “something must have failed” narratives inadvertently create blind spots in risk management. In these blind spots, we fail to recognize that many of our compliance systems are exemplary at proving compliance to the routine and understood but are often inadequate at managing dynamic, poorly understood risks within the production environment.  There are scenarios where failures in compliance programs lead to outbreaks, but far too often what happens is a number of factors combine, many of which are not monitored, and the perfect storm occurs. Believing another storm will not occur lacks foresight and predisposes businesses to unnecessary risk.   

Food safety regulations and standards have evolved over the past decades to help companies build and enforce compliance across their operations. Audits play a critical role in this framework – they identify gaps in the moment, and over time, those observations build a picture for where increased efforts are needed. But common compliance systems were never designed to address rapidly changing risks in food production environments. They just weren’t built for that. And increasingly, we’re learning that rapidly shifting risk plays a large part in adverse food safety events, especially in fresh produce. Addressing these dynamic risks requires more than checklists and additional audits. It’s time to build new systems and tools on top of the current compliance-oriented food safety system our industry relies on.  

Different challenges require different resources and approaches. If we truly want to reduce residual risk in the system, we must design for that goal instead of stretching systems built for a different (albeit important) purpose. At Western Growers we are working on connecting the fields of produce food safety compliance with dynamic risk management – enhancing the industry’s best practices and turning meaningful metrics into predictive systems for risk mitigation and management. Can we stop the storm? That’s the goal. But first, we sure would settle for getting a head start on knowing that it is coming. 

Interested in our efforts? Join us.