Regulatory Uncertainty Points to a New Direction for Food Safety
Recent regulatory moves appear to shift the burden of food safety to manufacturers, but they’re already taking steps to ensure quality food production – including designing facilities with safety in mind.

In March, the U.S. Dept. of Agriculture (USDA) eliminated two committees that consulted with the agency on food safety. A spokesperson for the agency stated that the National Advisory Committee on Microbiological Criteria for Foods and the National Advisory Committee on Meat and Poultry Inspection were eliminated due to fiscal and non-science reasons.
These moves, combined with extended waivers that allow pork and poultry to maintain higher line speeds, show a willingness by current agencies to shift the burden to food manufacturers, ingredient suppliers and farmers for safety resources.
The federal food safety backstop is gone and cuts have been well-publicized. “Outbreaks will happen regardless of the regulatory environment,” says Jennifer McEntire, founder at Food Safety Strategy. “And with the scientific tools to link outbreaks – such as whole genome sequencing – communication using social media, and proliferation of plaintiffs attorneys, it leaves the food industry quite vulnerable.”
USDA’s leadership and vision for food safety and a digital transformation have been steady since 2012, but brands are now adjusting to the new landscape.
“Food safety is foundational, but in this regulatory gray zone, it’s also a moving target,” says Kari Barnes, regulatory standards manager at TraceGains, Inc. “As oversight shifts from federal to state level, the risk of inconsistency rises. Brands must double down on internal controls and digital traceability to maintain standards and consumer trust, regardless of who's holding the rulebook.”
TraceGrains offers a supply chain digital platform specializing in a range of applications for food manufacturers, including formula, quality and audit management, among others. The platform facilitates digital documentation, with the goal for ingredient suppliers to automate, centralize, standardize and streamline their processes for more transparency with consumer packaged goods (CPGs) companies.
However, with the uncertainty and cost controls in 2025, food manufacturers may move dollars away from large traceability projects. “Without regulatory pressure, we have heard that many food producers will likely move towards smaller, ROI driven investments – such as adding smart equipment – rather than sustaining large-scale traceability cloud initiatives,” adds Dave Cirullo, industrial key account manager at METTLER TOLEDO.
While Rule 204 is delayed for 30 months, the road to supply chain transparency is not lost on companies. “During this time of uncertainty, reliable food safety strategy is critical to staying ahead in the market,” says David Charest, SVP of functional ingredients and solutions business at Corbion. “With the delay in the traceability rule, companies will execute a more holistic approach with the supply chain and food safety.”
To engage in a systematic approach, Corbion, an ingredient supplier, offers its Listeria Control Model predictive modeling tool, which projects Listeria growth based on specific characteristics of the food product.

“A customer can enter different parameters, see the prediction and evaluate solutions that can be used for a particular product,” Charest states. “The tools can produce a PDF and this can be part of their scientific information supporting the validation for the use of a solution in a particular product.” In addition, the listeria control model is based on real-world and laboratory micro validations.
Large Capex Still Coming
Even with business uncertainty, food manufacturers are plowing forward with investments in automation upgrades, system software and next-generation greenfield plants. Companies leading the way include Bauducco Foods, Lineage and Tyson, which partnered to expand its footprint, and Hershey opened a new chocolate plant in April.
Large companies are embracing transformative changes in the industry. “Consumer tailwinds are pervasive, but they are especially focused in several key areas and pockets of growth, where we’ve seen the consumer continue to evolve, and that creates opportunity for us,” said Michele G. Buck, chairman, president and CEO, said at the 2025 CAGNY Conference.
For food safety and greenfield plants, this can mean better plant design. “We’re seeing a shift from reactive cleaning to proactive facility design, and it’s overdue,” says Viking Kristjansson, VP of sales engineering at FoodSafe Drains. “Food facilities and plants are starting to get smart with floor slopes, grate-less drain systems, reduced underground piping and fully weldable stainless infrastructure that eliminates harbor points.”
“Major pathogens continue to be a challenge, including L. monocytogenes, Salmonella and pathogenic E. coli (and more than just O157:H7),” McEntire says. According to a report by the U.S. Public Interest Research Group (PIRG) Education Fund, the number of Americans with confirmed illnesses caused by contaminated food rose by 25% in 2024 to a total of 1,392 cases, up from 1,118 in 2023.
“It’s very difficult to build sanitation on top of bad design,” Kristjansson adds. “Linear drains are being used to replace extensive underground drainage grids (piping) that are hard to clean, and prone to costly clogs.”
Additionally, biofilm is another critical control point in plants. “A drain that is not well-designed or properly maintained acts as a carrier of contamination,” Kristjansson says.
As regulatory oversight becomes murkier, the onus is on companies to improve food safety programs and focus on continuous improvement. “Too often we have seen testing and calibration strategies based on ‘that’s the way we’ve always done it,’” Cirullo says. Mettler-Toledo recommends workforce comprehensive training programs, ISO 9001:2015 quality guidance and lifecycle management via ISO 9001:2015 - PDCA.
Moreover, reformulations for legacy products are changing food manufacturing, with consumers' emphasis on protein and fewer carbohydrates, across all demographics.
At the recent Future Food-Tech conference in Chicago, CPGs use of new ingredients was a popular topic. “We're in this great reformulation period,” says Edward Shenderovich, co-founder and CEO of Synonym. “Every CPG is interested in reformulation and there's a lot of pressure, such as regulatory, financial and consumer, to be reformulate, but it's not clear to what.”
“With changing consumer and regulatory expectations impacting the formulations of some foods, only time will reveal any unintended consequences, whether on the microbial or chemical food safety sides,” McEntire adds.
One of those unintended consequences may be allergens. “Undeclared allergens have quietly become the leading cause of recalls, pointing to deeper issues with label accuracy, formulation change and cross-contact controls,” Barnes says.
For large food manufacturers, traceability with suppliers remains a huge priority and essential for growth. “We also have to have our traceability programs in order, along with our hazard analysis and critical control point (HACCP) programs,” Charest adds. “Manufacturers look to us and other suppliers if there's an issue and want to trace back the raw materials.”
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