the most opportunity to create an incident. Many processors especially highlighted their concerns over the presence
of temporary workers. One processor
commented, “With 500 hands handling
the product, how can you watch all of
them?” Most of the respondents to our
survey felt the most likely risks were
manageable, but that there were many
more possibilities and scenarios than
they could reasonably address.
It is these numerous but unlikely
scenarios that seem to most vex processors. Many commented that it is easy
to think of more possibilities than they
could ever address. One processor mentioned that “we are trying to ‘think like
a criminal’ to ensure we are considering
all of the risks involved…” But how far
do processors need to go? How many
unlikely scenarios do they need to consider and how improbable does a scenario have to be until it no longer needs
to be considered in their IA program?
Or, as one processor described the situ-
ation, “Do we need to consider every
crazy Ph.D. MacGyver-type scheme…
or mainly keep the focus on the more
likely possibilities from people bent on
And confirming what we mentioned
earlier about some processors perhaps
being overly optimistic about their com-
pliance readiness, 17 percent of the U.S.
and Canadian processors and 26 percent
of the international processors indicated
that they have no concerns about com-
pliance with the IA rule. While the pos-
sibility that nearly one in five processors
has been able to create and implement
a compliant IA program with no issues
at all is encouraging, the comments that
we have received from others on the IA
rule, as well as on other issues related to
FSMA from previous surveys, indicate
that compliance issues are always highly
complex and initially present many
unanswered questions. Being able to get
this right well ahead of compliance and
inspection dates with limited guidance
may be optimistic. But once the formal
inspections start in March 2020, we’ll
find out for sure.
In the next issue of Food Safety Insights, we will address issues related to
another type of intentional food adulteration, food fraud—or as known officially—economically motivated adulteration. We have all seen the reports and
incidents related to unscrupulous actors
misrepresenting one species of fish as
another, substituting horse meat for
beef, and diluting and coloring various
oils to sell as high-quality virgin olive
oil—all for the purpose of illegally making money. We wanted to find out more
about food processors’ experiences with
these threats and what they are doing
to protect their products, their markets,
and their profits. Look for that report in
Bob Ferguson is president of Strategic Consulting Inc.
and can be reached at insights@foodsafetymagazine.
com or on Twitter at @SCI_Ferguson.
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