By Matthew L. Gibson, Ph.D., Lee Enterprises Consulting, Inc.
“I’ve looked at clouds from both sides now” – Joni Mitchell
I’ve been in the ethanol industry, directly, for about half of my career. The other half has been on “the other side”; that is, in the production of human food – either indirectly (i.e., livestock production), or direct-to-human consumption. I’ve worked in all different kind of food-production facilities – from meat processing plants to test-kitchens for restaurant chains, and lots in between.
What’s important for Bio-Fuels producers?
Let’s face it: as bio-fuels producers, we are in the business of making biofuels. The most we can. To required specifications. As cheaply as possible. That is our focus. Everything else should be secondary. So, why all the fuss about co-products?
To be clear, this discussion is not about Co-Product Quality or Specialty Products. These are both extremely important and both can make a big difference in enterprise profitability. However, those topics are for another time. No – today’s discussion is about something even more important: Food Safety.
Today I’m going to put on my “Food Production Hat” and share with you some thoughts about where your co-products ultimately end up: Food. What your downstream customers have to deal with. Hopefully, you can glean some nuggets to think about and start acting on.
First, let’s review the most significant events in American food production with respect to Food Safety. Everyone has their own opinion about which are truly significant; these are mine:
“They use everything about the hog except the squeal.”
This commonplace expression was first used in Upton Sinclair’s novel, The Jungle, published in 1906. Regardless of his intentions in writing this story, the fallout, ultimately, was the passage of a law – the Federal Meat Inspection Act of 1906. Also, in 1906, the FDA was created through passage of the Pure Food and Drug Act.
Fast-forward 90 years. Brianne Kiner, a 9-year old, was the “face” of the survivors of the E. coli O157:H7 outbreak in 1993 that sickened hundreds of people (and killed 4 children) in four states. The source was traced back to undercooked hamburgers from Jack in the Box. They eventually paid out over $ 50 M in settlements – the largest payment related to food-borne illnesses at the time. Bill Marler, the attorney who prosecuted the case, is still actively pursuing “Food Litigation”.
Global Food Safety Initiative (GFSI)
The GFSI was created in 2000 by a group of industry cooperators who wanted to standardize food safety threshold schemes for manufacturers and farmers. There are several schemes, and although the acronym GFSI may not be familiar, many of the schemes are widely known: SQF, BRC, and FSSC22000 are some of the more commonly executed schemes in the USA. Participation by food producers is completely voluntary; however, most large food companies participate in one of the schemes and require the same for their upstream suppliers.
Food Safety Modernization Act (FSMA)
The FSMA was signed into law on January 04, 2011 and is considered the greatest expansion of scope and power in FDA’s history. Of particular note for bio-fuels producers is that “Livestock Feed” became legally defined as “Food”. Whether we like it or not, we are now “Food Producers” – replete with all the travails that accompany such a distinction. More on that later. Unlike GFSI schemes, FSMA is a law: Public Law 111-353. Participation and compliance are mandatory. Further, non-compliance can lead to penalties up to, and including, felony status.
So, where are we today?
This list of food safety events is not intended to be scary. Rather, it demonstrates the sequence and timing that brought us into our current environment. We are under intense regulatory and consumer scrutiny.
The vast majority of food manufacturers in the USA do a phenomenal job of producing safe food. To describe even a fraction of the policies and procedures for any manufacturer would, literally, fill an entire file cabinet! I won’t even try. But, here is just a smattering of items that occur, routinely, in food facilities – that we do not routinely practice in bio-fuels facilities.
10 Common “Food Safety Practices” not Commonly Employed at Bio-Fuels Facilities
- GMPs – Good Manufacturing Practices: Yes – we follow GMPs for Feed. But, at the “Human Food” level, these are much more intense than for “Animal Feed”. Here are just a few examples. Prior to entering, or when working in, a food production area: (a) Employees must be clean and must wash their hands, (b) hair nets and beard nets must be worn, (c) no jewelry may be worn, (d) no food (lunches, drinks, etc.) may enter, (e) no tobacco, medications or even chewing gum. The list goes on and on (and on).
- Process Tracking: Every single item (package or lot) of outbound product can be discretely tracked back to its individual lot of input material.
- Bulk Transport – Seals: Every port on a bulk vessel is sealed and the seal identity is recorded and, usually, photographed. At destination, if a seal is missing (or incorrect), product may be rejected.
- Bulk Transport – Sanitation: Every rail car or truck must be food-grade and must be cleaned or have a Food-Grade Wash Certificate prior to loading. All prior load information must be confirmed.
- Facility Sanitation: This is huge. Facilities are, literally, kept as clean as a kitchen. Again, much like Food GMPs, this area is extensive, but here are just three examples: (1) Bird Incursion – if a bird enters the facility, even if it is not in an exposed food area, extreme measures are taken to remove it immediately. (2) Floor Contact – even though these facilities are extremely clean, no food is allowed to contact the floor. (3) Environmental Swabbing – food production surfaces (and other surfaces!) are routinely swabbed to detect the presence of pathogens, molds, and yeasts.
- Food-grade Lubricants: All equipment must use food-grade lubricants and / or hydraulic fluids.
- Certificate of Analysis: A complete COA is provided with each item – including microbial data (pathogens, molds, yeasts,).
- Sanitary Bulk Loading: Finished product is maintained in a sanitary state all the way through loading. Bulk vessels are loaded indoors.
- Positive Release (aka, Test & Hold): All items are tested for food-safety variables. Each load is placed on “hold” status until it has been positively released for receiving or shipping.
- Access Control: Food facilities have strict access control to the food production area. There are even stricter controls to other areas such as analytical labs.
So, what’s the point?
Bio-fuels producers, currently, do not have to comply with all these “human food” regulations. Our co-products are regulated by the FDA as “animal food”. Even though it is “food”, “animal food” has a completely different (although similar) set of rules than “human food”. Further, our primary downstream customers are livestock producers. They are, usually, at least two or three steps away from the ultimate retail food manufacturer. Again, why all the fuss?
“Consumers have never cared more, nor known less, how their food is produced.” – Jack Bobo.
Generally, the American food consumer is so far removed from the actual farm and ranch, both generationally and geographically, that they have no idea where food comes from. But they want to know “how” it’s produced. Although still small percentage wise, the fastest growing food sectors are “specialty” products such as organic, natural, sustainable, and others of this ilk. Consumers are requiring food manufacturers to reach farther and farther back up the food production chain to provide assurances of desirable practices. For example, many companies are now able to document certifiably sustainable farming practices for corn and soybeans. Some can, literally, identify the exact field from which products were harvested.
For bio-fuels producers, it’s not a matter of “if” more food safety compliance and documentation will be required; it’s a matter of “when”.
“In a world where nothing can be hidden, we better have nothing to hide.” – attributed to Greg Page.
Food Safety is not scary – at least, it should not be. However, one thing that is scary is the immediacy of exposure. An employee or visitor with a smart phone can record, edit, and upload a surreptitious video to the world-wide web in a matter of minutes. Even scientifically-sound and ethically approved procedures can cause a PR nightmare for food producers when videos are edited with bias and / or taken out of context. As an industry, we do not need that.
So what should we as bio-fuels producers do? I am not suggesting that we implement full-blown, “human food” policies and procedures. Neither our customers nor regulations currently require it. However, we should start working in that direction. Like the Scouts: Be Prepared.
“How do you eat an elephant?”
First, and foremost, make absolutely sure that you are in full compliance with all current FSMA and any state regulations. Define critical gaps and fill them. Again, we don’t need bad publicity.
Get certified by one of the industry-level food safety programs. There are a number of them commonly employed by the USA feed industry – available from GFSI as well as feed industry organizations. Create training opportunities for employees to become food safety certified.
Most importantly, food safety is driven from the top-down. Bio-fuels executives and managers must establish a culture that places equal value on food safety as environmental and personnel safety.
We have plenty of other things to worry about; food safety should not be one of them.
About the author: Dr. Matt Gibson is an independent consultant working in Food and Biofuels. He is also an expert at Lee Enterprises Consulting, the world’s premier bioeconomy consulting group, with more than 100 consultants and experts worldwide who collaborate on interdisciplinary projects, including the types discussed in this article. The opinions expressed herein are those of the author and do not necessarily express the views of LEC.