Risk-based management has been the on-trend phrase of the past decade within the food safety community. Globally, numerous regulations and food safety standards have adopted language that requires food-producing entities to assess their process and product, and then apply risk-based measures appropriate for the risk. This is a logical and scientifically supported theory – it makes complete sense to apply the most time and resources where gaps are identified and where our opportunity to minimize risk is the greatest.

I have spent my academic and industry career chasing, supporting and helping execute this concept, supported by science and the best-informed guesses when available. I am an ardent believer that when risk-based programs are truly developed and implemented, we will find a more manageable and sustainable system of food production.

The transition to risk-based management is a passion, and I work diligently to support the produce and food industry in incorporating those practices. However, one of the observations I have made throughout my career is that risk-based management and measures are straightforward only in textbooks, and the true application of risk-based management for food safety represents a quagmire of scientific and social complexity.

The shift to risk-based regulations and standards has been rapid from a regulation perspective, leading to numerous updates and forms being produced to aid the industry in assessing and documenting their risk to meet compliance requirements. While new forms and checklists were made and training developed, it appears the root cause impeding the shift to true risk-based management is that no concerted effort to shift to a fundamentally different management or regulation style occurred at the same time.

With the introduction of risk-based language in the regulation, the industry acted effectively the same, albeit with more paperwork and different terms used. Customers required the same information and had the same expectations of suppliers while regulators used similar decision-making and actions reminiscent of the prior regulatory era.

In effect, the transition to risk-based food safety happened on paper, but food safety culture remained more-or-less entrenched in an era of zero-hazard tolerance.

The paradigm shift to true risk-based management ultimately requires some amount of risk to be acceptable, and it recognizes that different systems, producers and products will have variable levels of risk.

In a risk-based system, it does/will not matter how many risk assessment forms are completed since risk-based management only truly begins when we permit the food industry and food regulators to recognize that there is some acceptable amount of risk.

Without acknowledging that not all risks can be eliminated or controlled – especially for fresh produce and foods without microbial kill steps – there will continue to be little incentive or benefit for risks to truly be identified. Risk identification and characterization are generally still perceived as evidence of failure rather than evidence of proactive risk management.

One illness is too much, but zero is unrealistic.

Allowing for risk in the food system seems counterintuitive to our goal to reduce foodborne illnesses. The food industry should have a goal of zero risk to consumers, and that must always be the target. However, while one illness will always be too many, zero illness is also unattainable and building systems that only tolerate pass/fail or good/bad outcomes prevents identifying realistic ways to manage risk.

This binary risk outcome is an enormous roadblock in the path to continuous improvement since there is rarely any advantage for a company to characterize its true risks within the system. For example, while we openly discuss and recognize that seasonal or geographic factors may influence risk in fresh produce production, what benefit do individual growers gain from fully characterizing that risk when customers and regulators view such identification in isolation—often discrediting the fact that sufficient efforts and programs may already be in place to manage it at an acceptable level?

In effect, guilt is easy to prove while evidence of control (or innocence) is almost impossible to defend.

Taking a recent real-life event as an example, a pathogen-positive sample originating from a routine sampling event for Salmonella led to a grower losing a multi-million-dollar customer who chose to terminate a contract due to the pathogen finding. This reactive decision was made despite that this positive was in isolation and not associated with any illnesses or process failure evidence. This isolated pathogen result ultimately led to a drastic reaction by the customer and reinforced for the grower that there is little incentive to build systems to identify and monitor for risk. Additionally, there is even less incentive to be transparent with external stakeholders about when risks may be present.

In the prior example, we saw a customer interpret a pathogen detection incompletely and with what seems a disproportionate reaction. It is understandable that no one wants food/systems with risk and would naturally reject it. However, believing that a successful strategy is to sever ties with any supplier, farm, product or process once a positive is found from a random test is misguided. More importantly, it is counterproductive and destructive since it reinforces to the food producer that a smarter strategy would be to build food safety programs that always return negative results, regardless of whether that outcome truly reflects the situation. As with all risk, the scariest type is the type you do not know you have. If we interpret each finding of a pathogen, and sometimes even indicator/index organisms, to be viewed as evidence of systematic/gross/preventable failure, then that only further reinforces that identifying risk to optimize managing it is not a sustainable food safety or business strategy. Conversely, this supports a strategy opposite of risk-based management since we are not allowing food producers to investigate risk to manage it without then using that same information as evidence against them.

This is part one of a two-part series on food safety and sustainability.