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Carole Patterson is the Director of Compliance for Red Blossom, a strawberry grower with nationwide distribution and growing operations in the US and Mexico. Over the past 5 years, Carole has defined and executed Red Blossom’s food safety plan to support the company’s compliance initiatives. Carole joined us to discuss one of the most top-of-mind terms in the compliance world: Food Safety Culture. Our interview has been condensed and edited for clarity.
Carole: Food safety culture is a relatively new term. To improve food safety, we’ve realized that it's more than just food science. It's the behavioral sciences, too. If you're trying to improve the food safety performance of an organization, industry, or region of the world, you're trying to change people's behaviors. Simply put, food safety equals behavior.
“Food safety culture” is the thought and behaviors that you routinely practice and demonstrate.
One of my favorite food safety leaders actively striving to define food safety culture for the FDA and the industry is Frank Yiannas. He is the Deputy Commissioner for Food Policy and Response at the FDA. He's working hard on food safety culture right now. He said: "If your organization's goal is to create a bigger or better food safety program, then I suggest that although you may be well-intended, you might be missing the mark? Your goal should be to create a food safety culture, not a food safety program. There is a big difference between the two." This statement is so true.
We used to be told to start with the food safety program by reviewing and updating standard operating procedures (SOPs) and policies already in place. But now, we've recently realized the prerequisite for a better program is to evaluate the culture first. We need to ask ourselves and our teams: “What do you think about food safety? What are your successes and what are your challenges? Why do you do what you do?” The change is always going to start there because it's the very foundation of a great food safety program.
When you build a house, the first crucial element is the foundation. It's the same with food safety: culture is the foundation. You can have the best policies, rules, and procedures in the world, but if they're not put into practice by people, they're useless. A strong food safety culture is a prerequisite for effective food safety management.
Carole: An example of food safety culture I personally saw a lot of as a food safety consultant before I worked for Red Blossom was complacency. You’d have some farmers say "Well, I know we’re not following the procedure like we should be, but I've been farming for 40 years, and I've never had anyone become sick." I would reply "You’ve been very lucky." I’d explain it only takes one opportunity for that to change, and it's a dangerous way to think. People genuinely felt this way a lot though. Especially if they had never had any issues in food safety before. I just caution everyone who thinks this way not to wait until they have an issue. It’s too late by then. Proactive is always better than reactive.
Carole: Culture begins with education. Training is crucial, but we need more education to pass on to the industry and the public. The industry is getting a lot better when it comes to this, but I really think the public needs more education. That’s where I see a big issue these days. Our growers go through a very strict and rigorous food safety program and a supplier approval program to make sure everything we sell is safe. We need more education on safe handling after it gets into the stores. I’ve personally seen customers open multiple strawberry clamshells in the middle of a grocery store and begin switching different berries over from different brands just to build the perfect clamshell. Now you’ve mixed up two or three different companies’ products, touched the berries with unwashed hands, and destroyed all the food safety precautions and hard work that went into making that safe for you. That’s the “food safety culture public education” that I mean. Now it’s potentially adulterated and the traceability just went out the window. It's why I could see “tamper proof” containers in our future, maybe even mandated by FDA one day.
Most people who don't follow the rules of food safety are not trying to make someone sick. They usually just don't know any better or become complacent, especially if they've never had a problem before. I think when we show why it matters it gets people’s attention and changes unsafe behaviors.
My biggest piece of advice is to always focus your attention and training on the “why” behind every food safety rule and policy. Food safety rules are in place because someone has been seriously injured or an illness has resulted from not doing the right procedure or practice.
Carole: I've actually taken a step back with food safety recently. Our food safety managers handle the bulk of it and come to me when they need help. I oversee and step in when they need me. They're very brilliant people with a lot of knowledge and I’m there to assist and guide them if they need help.
By doing this, I've been able to focus more on compliance and our customers. Customer Compliance has changed and evolved so much in the last few years. Our customers really want to gather as much documentation from us to prove we’re selling safe food so I make sure they have everything they need. I still write the food safety SOPs and policies and I'll still review and approve certain things and make sure we are following all the applicable laws and audit schemes, but our team in place is great and it works very well.
Carole: HeavyConnect has been a pivotal thing. We went electronic and it changed our lives. Leo, one of the food safety managers, will sign in and check the dashboard and he'll let me know if there's anything out of compliance and if he needs my assistance.
HeavyConnect changed how we do our food safety so much. When we have issues we get alerts in real time so we can address anything immediately. When we have audits the information and documentation is just a log-in away. It’s so much easier than it used to be.
And we can log in at any time, from anywhere, to check on things. It’s fantastic. Red Blossom does so much to make sure the food we sell is safe, quality food. I’m very lucky to work for such an amazing company.
Carole: Great question, and this is one of the things that the industry is currently working on for all of us. The industry does not have a litmus test for this yet. I’ve heard that FDA is considering making this a FSMA rule by itself, and the food safety auditing schemes like GLOBALG.A.P. and Primus are also pulling in food safety culture and making that a mandatory requirement. But again, there’s currently no official test yet.
For now this is what we've been doing. When we do any corrective actions or find non-conformances, we don't just ask: “What went wrong and how do we fix it?” Now we ask those questions followed by: “What lessons do we learn? Why did this happen? Is this systemic?” If something happens twice we re-train. If you’re repeating a problem, you may have a culture problem at that point and you need to go down to the core root cause.
I think that very soon “root cause analysis” is going to be a requirement. If you’re a food safety manager or somebody overseeing your food safety for your operation I recommend taking an online class on Root Cause Analysis. Root Cause Analysis goes beyond just doing a risk assessment and a hazard analysis and it gets to the very heart of why it happened in the first place. And a lot of times it will lead to you to finding out there is a food safety culture issue that needs to be addressed. Most food safety violations happen because of unsafe behavior.
Carole: There was something I found surprising when I first got into food safety about a decade ago. I didn’t know how to write an SOP in the beginning of my career. I didn’t know how to research food safety laws and audit schemes etc. I had to reach out for help, and I had a really hard time finding classes or finding anyone willing to help that wouldn’t charge me $350/hour. The culture has changed. Now I see that associations are making food safety education and resources a priority and more easily obtainable. It’s getting better but I do still think we need even better resources and food safety documentation templates for people to use. We have to remember there are growers out there trying to do the right thing but just maybe not sure what they need to do exactly. We need to help them get access to the food safety tools they need to be successful. That’s something I advocate for and I’ve definitely seen improvements in that since I started in this industry. If you start with culture and have a good food safety program in place it will lead to safer food and better outcomes for all consumers.
You can follow Carole on LinkedIn, see the current FDA guidance on food safety culture, and learn how HeavyConnect helps top operations manage their food safety compliance.