As we close off another year, we continue to receive unanswered questions from the event speakers.
With this in mind, we have a created this page to capture these. As more speakers get back to us, we will locate the questions and answers here for you.
And once again, thanks very much for attended the event. Remember, you can get your phycial entry tickets for Food Safety Americas 2022, which will be held at JW Marriott Orlando Bonnet Creek. Virtual tickets will be made available too.
BRCGS digital solutions & directory update by Antony Harrison, Head of Digital Services, BRCGS
Q: When we will be able to use voice recognition to upload reports and ease the audit process? Now we are remote. Now we can be more digital?
A: Directory will very soon allow submission of audit data via configured "API". This means auditors can capture data via any tool they like - and as long as the information is complete/compliant and the API is configured, Directory will accept it (& create a branded audit PDF based on the data). This option will be contingent on the auditing CB having a data capture tool and API ready local database.
Managing and surviving a high-profile food safety crisis by Bob McNaney Senior Vice President Crisis and Reputation Management, Padilla
Q: How do you best manage communication on any food crisis as reputation is extremely important. Any unapproved communication can lead to extremely negative consequences if not reported correctly. Excellent presentation.
A: Thank you for the very kind note. It is always a pleasure discussing crisis preparedness with people. The investment in your time to watch the presentation speaks to you and your organization’s commitment to protecting people, brand and reputation. When it comes to assuring proper communication, it all comes down to developing a process to gather and distribute information ahead of the problem. Developing the “pathway” for communication in vitally important. What needs to be said, who will say it how it, when and how it is communicated can be worked through as part of the crisis planning process.
Q: Do you work with small companies to develop a crisis plan?
A: Absolutely! We appreciate the need for organizations of all sizes to have a proper crisis plan in place. My approach is to customize the plan to provide support with the organization needs-5 employees or 5,000 employees. The time you are spent in the crisis segment today speaks to your commitment to your people, your customers, your brand and your reputation. Happy to discuss 651 249 7718 bob.mcnaney@padillacom.com.
Beyond Compliance by Damien Smith, Ecodesk
Q: How do manufacturers and suppliers realize a return on their investments made towards becoming more sustainable? Surely the act of improvement requires investment and this at the "cost" end of the value chain!
A: It's probably worth thinking about ESG performance as a way in which to, firstly, unlock lower-cost capital as it generally carries less risk. On average, green financing (and this is a generalisation I'm afraid) can be as much as 10-15% lower than conventional financing. Not all sustainable innovations are expensive - behaviour change can yield significant results (e.g. energy-saving, switching commuter modes) and there are significant incentives both in terms of grants, subsidies and tax relief that make sustainable capital investments more attractive. I agree that it is perceived as a cost and the ROI should be a key business consideration so realising that return is primarily about running a CBA against the future prices of materials, machinery and commodities. It is highly likely that cap and trade systems for carbon will affect businesses of all sizes in the next 10 years when the price of carbon, which is already rising fast, will become a business cost. Interestingly, those firms who embrace low carbon may find themselves with surplus carbon credits - a worthy addition to the balance sheet! I do take the point that the burden should not solely be passed to the manufacturers and suppliers however there are a growing number of examples around "insetting" where customers are reducing their upstream footprints by procuring solutions into the supply chain (Power Purchase Agreements the most ubiquitous example). It should not remain the exclusive responsibility of the supplier but I do think it is prescribed onto the supplier to think and behave multilaterally. Perhaps the last point on this is that investment ROI when it comes to sustainability is not one-dimensional as it deals with future impacts and therefore provides an insurance policy by way of future-proofing and helping to hedge against future costs so like all investments, the value of it may go up as well as down and we need to accept that any investment carries with it a degree of risk.
Q: They say a problem is 50% solved when it is identified! In your experience, do producers know enough about ESG and related elements to be able to determine and direct their own improvement programs?
A: Great question! This is about the level of maturity which rests amongst producers and, which, varies enormously. Let's take knowledge first - ESG has become the acronym that really defines sustainability in a financial setting so we can begin by thinking and couching this as "sustainability". Acquiring knowledge about your own ESG is not really about a voyage of self-discovery but rather needing help with contextualising the related elements to your business. Some producers will be acutely aware of their ESG aspects and impacts (a result perhaps of regulation, geography or industry segment) and others may not. However, what Beyond Compliance as a tool will do is identify sets of best practices that are applicable to a producer based on their industry segment. Within the tool is a "Learn" function which will allow users to begin to understand what particular issues are relevant to them. Naturally, the learning process is continuous when it comes to ESG but the hope is that maturity will increase as more producers join the program and a network effect will provide a rich seam of highly contextualised content to be shared and therefore accelerate the knowledge acquisition amongst producers. I think we can begin this process by making sure that everyone is clear about why sustainability matters to them whilst recognising that a one-size-fits-all solution is inadequate if we are to expect businesses to direct and determine their own sustainable improvement pathways.
A: You mentioned the link between compliance and performance. Can you describe what you meant by this a bit more?
Q: Compliance is unquestionably the most important item in the food safety toolkit. However, it does have limitations specifically in that it is binary. In other words, there are no 'degrees of compliance' and consequently it cannot tell a stakeholder much about the sustainability performance of an organisation. When considering the business relationships of the future consideration of responsible sourcing starts to merge compliance and performance - we start to ask questions around whether adoption of sustainable practices are adhering to a standard but, right now, what we typically mean by the standard is a voluntary code (perhaps a brand's Code of Conduct or Supplier Charter). Whilst this is a strong indicator of how sustainable an organisation is, both sets of metrics are currently seen as mutually exclusive. However, data is starting to provide evidence that organisations that are "sustainable" tend to be less exposed to non-compliance events. So, performance is about how organisations set strategies and implement best practices on a range of subject areas to ensure that they not only benefit from cost savings and trigger innovation but also instil a mindset based on better business practices. As a result, organisations which measure their sustainability performance are proactive in mitigating compliance risks. However, what performance currently lacks is a rigorous set of standards by which stakeholders can guarantee operational excellence, and thus safety. Beyond Compliance as a platform is designed to assess companies' sustainability performance in a very context-specific way so that compliance data can be enriched with an accompanying sustainability performance dataset. To illustrate this, consider the example of animal feedstocks that can be compliantly produced (where using artificial inputs) but may result in significant land-use change (LUC) to grow crops such as maize, soy etc. The question of how those crops are grown and harvested is not covered by compliance questions. Producers that consider LUC are much more likely to show a greater affinity to, and understanding of, ecosystem services and will likely use more harmonised modes of production which, by default, limit the risks associated with overapplication of chemical controls or yield enhancers.
Cannabis, food safety risks and regulations by Dan Anglin, CEO, CannAmerica Brands
Q: Without FDA regulation, what types of food safety practices (HACCP/GMP/etc.) have you implemented on a daily basis for operators who are processing food or beverage cannabis products?
A: ServSafe certification for all employees. We follow the requirements set by local and state health regulations for food handling and processing and for hemp manufacturing and follow the guidelines set forth in the FDA cGMP's for food handling and dietary supplement manufacturers.
Q: More U.S. states are permitting the use of cannabidiol (CBD) in foods and beverages, however, his contradicts FDA's current position that CBD is illegal in foods, beverages, and dietary supplements. How can a company that distributes via interstate commerce legally put CBD in food and distribute it?
A: I am not legal counsel - please seek legal advice for answers to this question.
Q: What type of regulations do you see being set for cannabis product identity as customers are focusing more on specific strains and benefits of terpenes?
A: Hopefully only cautionary statements for allergens and prohibition of synthetic and/or non-cannabis or hemp-derived terpense. Strains and terpenes are typically a flavour or efficacy preference in Cannabis. Any claims of strains/terpenes for the efficacy of medical treatment need to be verified and or consulted with a physician. Besides that - this plant is already more regulated than explosives, so hopefully, we don't get to rules around simple things like terps and strains, just the safe handling of the cultivation, extraction and manufacturing processes for using natural compounds to create high-demand consumable products.
Q: What resources would you recommend to get started on research if you wanted to create a new speciality
A: Local zoning first - is the production allowed in the municipality the facility is located? Second, licensing requirements. Third, is your formulation team familiar with introducing plant materials into foods or beverages? Fourth, cannabinoid formulation - is your team familiar with the variants of flavour profiles with cannabinoids and terpenes? Fifth - what type of food items are you considering that have the shelf stability and pH stabilization for adulteration with cannabinoids/ethanol (microbial prevention)? 6th Market demand and saturation - just because you are an expert in creating a food product does not mean the demographic of the marketplace will respond to your product, in fact oftentimes cannabis consumers completely reject a company filled with 'outsiders' who think they are going to 'show the stoners how its done' there is already over a decade of product and brand development in the space, so carefully determining how the market will respond to your products is as important as the development of the formulation/flavour/efficacy/efficiency of production, etc. or department of an existing food site to produce edibles?
Q: What do you see as the biggest challenge for the cannabis industry in 2021?
A: Politics - lawyers - media - investor expectations - misinformation being touted as facts - prohibitionist approaches to regulations for a consumable product more popular than any other issue or person on earth. No public policy change has more support than the legalization of access to cannabinoids, yet the slow rollout of reasonable allowances for the products that the majority of citizens demand (71% approval statistics) continues to stunt the growth of research and access to safe and approved products in this category. This contributes to the largest problem in existence for legal Hemp or Cannabis operators - the black market has no rules, has no taxes, has no workers compensation and insurance and all the other costs associated with a legal business that is heavily regulated by dozens of government entities - and is still readily available to anyone, everywhere, regardless of age or laws. As long as the government continues to drag its feet to give consumers what they want in a way that has reasonable costs for legal businesses to cultivate, produce and distribute, we will always be spending more money than illegal operators who undercut our pricing and give the prohibitionists the ammo against our legitimate businesses that they use against us. The concept that legalization is a cash-cow for the government is an easy way to get it passed in cash strapped states - but it does nothing to stop criminals from continuing to break laws and compete successfully with the businesses making major investments in infrastructure, compliance, taxes and fees.
Q: Do you need to have childproof/tamper-proof packaging for CBD edibles?
A: No - as CBD does not have intoxicating effects, it is not required, nor should it be based on the cannabinoid profile. Only if the substrate or the infused product poses a harm, such as a choking hazard or other harms for children should there be a requirement for CRP packaging in this specific space - THC products, different story. I look forward to the day that either alcohol has to be CRP or CRP is eliminated from the requirements, but neither of those things will happen.
Q: How is BRCGS approaching certification of cannabis operations - growing operations, processing to food/cosmetics, etc? Answer: The Food Safety Standard and the Consumer Products Standard can be used. The certification will address Food and Product safety only, not for example the potency of the product. There are certain limitations, i.e. we will not certify tobacco products, vap juice, pharmaceuticals, etc.
A: The Food Safety Standard and the Consumer Products Standard can be used. The certification will address Food and Product safety only, not for example the potency of the product. There are certain limitations, i.e. we will not certify tobacco products, vap juice, pharmaceuticals, etc.
Subway Case Study: Examining the impacts of COVID-19 on the restaurant industry by Katia Noll, Director, Senior Director, Global Food Safety & Quality, Subway
Q: We hear a lot of talk about "sustainability" which is clearly an important topic. With Covid and the impact it had on global supply chains, do you think the conversation should shift to supply-chain resilience...or perhaps it already has?
A: I think there is still a heavy focus on sustainability because it has become a consumer expectation, and brands use their sustainability commitments and achievements in marketing and communications. However, I do believe that 'behind the scenes' more companies will begin shifting their resources towards supply chain resiliency given the impacts COVID-19 had on our global economy, and the food industry in particular. It may not be a strong selling point externally, but in terms of brand protection, it is invaluable.
Q: "How confident do you believe consumers are today after all that has been put in place and with what we have learned from the last year.? "
A: Based on the sharp increases we are seeing in traffic and sales across North America and much of the globe, it is apparent that consumers have a high degree of confidence in the safety measures businesses have implemented over the last year. While some of this can be attributed to "pandemic fatigue," increased numbers of vaccinated individuals, and lifting of lockdowns and regulatory restrictions, consumers still have freedom of choice about which businesses they patronize and will selectively choose those that make them feel safe.
Q: "What challenges and solutions did you have in the package safety at the point of delivery? "
A: We had challenges with product packaging maintaining safe temperatures (both hot and cold), but our primary issue (like most of the industry) has always been product tampering and maintaining the integrity of the product. We've taken measures to ensure that our customers can trust the food they ordered has not been opened, handled, or interacted with in any way between the time it leaves the restaurant to the point of delivery.
Q: Do you feel, with the information we have now in the hospitality industry, that Governments overreacted with the lockdowns?
A: While it is easy in retrospect to view some of the measures taken as overly restrictive, we have to keep in mind that COVID-19 was a novel, never-before-experienced virus. This means that everyone - scientists, governments, businesses, and citizens - were learning live and in real-time about the virus, how it was transmitted, how to prevent transmission, etc. I think by and large governments did what they felt was necessary to protect their citizens' health and safety, even when it may have been at the expense of business continuity or survival. While lockdowns had devastating economic effects, and we now know how to remain open and still operate safely, they were necessary steps in the early days of the pandemic.
Q: How comfortable are you that your supply chain is robust and safe following covid
A: I have a high degree of confidence in the robustness and safety of our supply chain, thanks to the ability to monitor our manufacturers and their performance via virtual audits and inspections and the other measures outlined in my presentation.
Robin Forgey
Q: What are your measures to qualify/approve a Certification Body? I've noticed some of CB's are approved by BRCGS to audit a GFSI plan and with the same token, they are not in your approved CB's list and should run a separate GMP's audit?
A: When a CB expresses interest to audit for Costco, they would be put on the waiting list of CBs. Then they would fill out a form with all of their capabilities. Finally, when Costco has a business need for additional CBs, we would evaluate the capabilities of the CBs on the list and determine which CBs seem to match our needs. At that point, we sit down with the CB and discuss our requirements. If they are willing to meet our requirements, we would go on a series of shadow audits to assess the performance of their auditors and support staff.
Q: Will Costco allow more Costco Audits for new suppliers as the market normalizes from Covid?
A: Costco is always bringing on new suppliers. We did not stop accepting new suppliers due to COVID
Q: Do you anticipate any updates to the Costco specific addendum/add-ons to the BRCGS Standards to account for the necessity of remote/virtual audits?
A: We do not anticipate changing our addendum to account for remote audits that are performed for the BRC standard.
Q: There is evidence that food fraud - e.g. labelling and product substitution - has increased, perhaps as a response to disruptions in the supply chain. Have you noticed this and if so, have you taken measures to mitigate against loss/recall etc?
A: At Costco, we have a large network of 3rd party laboratories and our own internal laboratory that are constantly monitoring our supply chain. Food fraud is one of the reasons that we do all this testing and we are always incorporating new methods to combat fraud both through testing and other supply chain security procedures.
Q: You have a magic wand - If there was one thing you could do to improve remote audits, what would it be?
A: Every plant would have amazing internet connectivity throughout the plant and 360 degree cameras for the auditee.
Q: Will Costco open the opportunity to other CB's not listed in your approved list to audit suppliers to prefer local auditors?
A: At this point in time, Costco does not see a business need to add additional audit companies to our approved list of suppliers.