6. Regulators Understand Control, Not Semantics, Is the Key to Food Safety – In 2012, more draft regulations from FDA on the Food Safety Modernization Act (FSMA) will be enforced. FDA has already begun using the term “preventive controls” in its documents. A few colleagues have told me FDA is using this term because it does not want to publicly state what FSMA really does is mandate HACCP for all of the food industry. If a processor does not have a HACCP plan, it is not going to have much of a market.

5. Auditors Understand Their Role Is to Evaluate the Effectiveness of Programs – The third-party audit is a fact of life. The schemes accepted by the Global Food Safety Initiative (GFSI) are gaining greater acceptance because of market demand. If a company meets the demands of a GFSI audit, it should not be asked to adopt another GFSI scheme or even do another audit. But in many cases, the quality of the audit depends on the quality of the auditor. The role of the auditor should be to evaluate whether programs in place are being followed and are effective. An audit should never be a checklist.

4. Food Processors Never Take Sanitation for Granted – When evaluating foodborne illness outbreaks, the root cause almost always is related to sanitation: Someone did not clean the plant or line properly, a worker failed to wash his/her hands, or construction was not contained. Sanitation programs need to be validated when set up, verified on a regular basis, audited to ensure they are being followed and subjected to regular management reviews. The frequency of these evaluations depends on the product, the process and the efficacy of the program.

3. Leaders Listen to Their Technical People – Some managers and decision-makers don’t put enough faith in their technical staff. Your employees have good ideas. Don’t wait for an outside consultant to bring you ideas that are available, but often overlooked, in-house.

2. Consumers Understand They Are Part of Food Safety – Statistics show a significant number of foodborne illnesses come from foods prepared at home. How many kitchens have a meat thermometer? How many consumers properly wash fruits and vegetables? Consumer education is essential for ensuring the public health.

1. We Put Bill Marler Out of Business – William Marler is a principal at the law firm Marler Clark which represents plaintiffs in cases of foodborne illness. I have heard Marler speak a number of times and am always impressed with his ideas on industry responsibility, liability and protecting the public health. In almost every talk, he includes the line, “Put me out of business.” As an industry, we should be working toward that goal. v