The U.S. Food and Drug Administration (FDA) has posted some FAQs about the Food Safety Modernization Act (FSMA), and under the question, “How does this Act change the way FDA regulates foods?” is this statement: “This new law puts prevention up front for FDA. For the first time, FDA will have a legislative mandate to require comprehensive, science-based preventive controls across the food supply.” Prevention of foodborne illness vs. reaction to an outbreak is a major theme in FDA’s rollout of FSMA, scheduled to be completed this year. Behind this new approach — the key element to achieving its goals — lies the human factor, meaning the people who work in the food industry, from top-level managers to in-plant employees, and everyone along the supply chain.

Challenges to changing behavior are well-known in the food industry, and government regulatory agencies, along with consultants and auditors, spend a lot of time focusing on them and with good reason. Foodborne illnesses are literally caused by foodborne pathogens, yet the delivery mechanism, whether it’s a food or beverage item or a contact surface, has been impacted somewhere along the line by human behavior. Someone didn’t follow one or more food safety steps. Maybe they didn’t wash their hands, throughly clean machinery or preparation areas, or appropriately monitor temperatures. Perhaps the problem was in transportation or delivery. Whatever the problem was, when the system broke down, there were individuals involved. “People create situations that make people sick,” said Dr. Philip Crandall, a professor in the Department of Food Science at the University of Arkansas. He was an author of “Best Practices for Making Long-Term Changes in Behavior,” the cover story in the most recent issue of Food Safety Magazine. As that article emphatically states, “The bottom line in preventing foodborne illness is in agreement with the tenet that people create the situations that make people sick! Our employees who routinely handle food, many of whom are paid low wages, who may not have been well screened at hiring and may not be properly motivated or well trained, are the root causes of most foodborne illness outbreaks!” To illustrate, Crandall related a recent study done on a major retailer: “The employees could not complete a cleaning task as scheduled because there was not enough time. They could do it if they were not waiting on customers, but if they’re cleaning the hot dog roller and someone comes up and wants something …,” he said, adding, “They are always doing something that’s a higher priority.” Food safety training is paramount, but experts say it must be followed up with knowledge and reinforcement of the expected behavior. And, they note, the training should ideally take place in the food manufacturing or processing plant where the employees actually work. Jose Sabal, a food safety consultant and auditor based in Miramar, FL, told Food Safety News what he learned from a generic train-the-trainer course he took to better understand the process. In order to effectively transfer knowledge and train people, Sabal explained that three variables need to be mastered: “1. You must have the knowledge and you must transfer the knowledge. If you give someone the test, and they pass the test, it means they have the information. It doesn’t mean they have the knowledge. “2. You must have the skills that go with the knowledge. You have to go through the hazards and know what has to be done. That means applying the knowledge. Just because you pass a HACCP class, that doesn’t mean that you have the knowledge. “3. You can influence people, but in the end, you cannot change the attitude of people.”


Using a bell curve to evaluate employee attitudes toward food safety, Sabal indicated that a standard outcome can be seen. “You will find that 60 percent of people more or less will follow the rules, about 20 percent will do more than is required, but you are also going to have 20 percent of the people that, no matter what you do, they are not going to follow the rules, period. And, if you have a food facility, you will understand that is going to be the case,” he said. For the 60 percent who mainly follow the rules, those rules need to be reinforced so that employees understand what is required and then do what is required each and every hour of every working day. A 2006-07 study of 300 foodborne illness outbreaks associated with restaurants found that three specific types of employee behavior contributed to the majority of such outbreaks:

  1. Working while sick, usually because if the employee doesn’t show up for work, they don’t get paid.
  2. Poor personal hygiene. Research shows that employees only followed proper hand-washing procedures one in six times it should have been done.
  3. Inadequate cleaning and sanitizing of food equipment or not following correct food preparation practices. Typically the reasons given were that there was not enough time or the equipment was hard to clean.

These issues will sound familiar to anyone who has ever read a negative FDA inspection report. And employees in food manufacturing and processing plants sometimes exhibit the same behaviors as the foodservice workers cited in the study. Sabal recalled a visit he made to a company switching from printing to producing food packaging materials and needed to start complying with different standards. “The first time I went there, it was a mess,” he said. “I saw a donut on top of a press and no hand-washing, no nothing. They had coffee, soda, tea, everywhere, and they were eating and drinking all around.” The consultant had to get the company working on requirements for safe food manufacturing practices, a path with some bumps along the way. “That’s quite easy for you and for me. You just follow the rules. Can you tell someone who’s been working with paper and ink and other chemicals that they can’t be eating and drinking? One guy said, ‘I’m not going to follow that,’ and he quit the next day,” Sabal said. Turnover is an ongoing problem in all types of food facilities. Crandall noted that turnover among deli managers is 40 percent and that understaffing is also an issue. “The person who comes in knows that the last person lasted for four months, and there are way more things than they can do,” he said. For those who do stick around and follow the rules, it takes reinforcement from a company culture that emphasizes high expectations, encouragement, motivation, some discretion given to workers to help find the best methods, and the ability to work without distractions. calls this “active managerial control,” although others might simply call it good common sense, with the added bonus of enhancing the bottom line through avoiding recalls (and even possible criminal charges). One technical tool increasingly being used in the food industry is software that can mimic a food safety management system. Sabal said he witnessed such a system in action last year at a seafood processing company he was auditing. “It has corrective action embedded in it, and you can actually monitor using cell phones and iPads. I saw people recording temperature, I saw the software waving red flags. It was very effective. You can have your own server, and even if the Internet connection is down, it will still store your information,” he said. As with any other food safety system, however, people need to be adequately trained to correctly use such software and follow through. For the majority of food plants without advanced technical tools on hand, food safety depends on human beings making sure that existing systems are followed. Recalls are expensive, both in terms of resources and in potential damage to a brand’s reputation, so clearly the incentive is to adjust in-plant behavior to avoid one. Sometimes it’s as simple as reconfiguring a certain food production step or designating different cutting boards by color to prevent cross-contamination. “One retailer here has a corridor for raw meat. Once cooked, it comes out of that corridor and is handled differently. Color coding will go a long way, but it goes back to having the managers be there,” Crandall said, adding, “Typically it takes several screw-ups to make a food safety problem.” Sabal said he sometimes shows clients FDA’s recall website and mentions how much it costs per hour for FDA inspectors. “When you talk about the possibility of having a recall because one of your control measures is not working, I am able to measure what is the likelihood and can you detect these hazards? And then you can evaluate the risks,” he said. While this may seem simple in theory, it can be difficult in practice. The good news is that once in-plant behavior begins to shift, it becomes easier to maintain the “new normal” and make sure that food safety awareness takes center stage. The bottom line is that those facilities where training, knowledge and behavior are linked and the relationship between them is reinforced, and where managers are visible, involved and continually underscoring the importance of best practices, are those most likely to avoid food safety dangers.