Risk analysis: Food safety crises

Stacy Stevens, who leads the Issues & Crisis Navigation practice at FoodMinds LLC in Chicago writes in O’Dwyer’s Communications & New Media that microbiological pathogens lurk around every drain, every ceiling tile that collects condensation and every box of ingredients unpacked in a restaurant kitchen. 

chipotle.slide.jan.16Food and beverage companies are speaking out about the healthfulness and wholesomeness of their products, as well as the integrity of their supply chains and their commitments to farm animal care and environmental sustainability, to maintain consumer confidence and trust. That carefully-constructed bond with consumers can dissipate in an instant with the emergence of a food safety concern. Here’s how communication pros can work in lock-step with their operations counterparts to prevent a food safety compromise and keep their hard-earned reputations intact.

Most of us practitioners of public relations don’t claim to understand the finer distinctions between Listeria monocytogenes, Clostridium botulinum and Escherichia coli. So, how can we ensure our companies and clients stay out of the “tag, CDC says you’re it” spotlight? 

Dairy Forum 2016, a gathering of 1,100 food industry executives from around the globe hosted by International Dairy Foods Association (IDFA) in late January, explored this question in the session “Caution: Company Under Pressure,” which I had the honor of moderating.

According to panel member Joe Levitt, partner at Hogan Lovells and former director of FDA’s Center for Food Safety and Applied Nutrition, the single biggest problem is thinking this can’t or won’t happen to you.

Communicators: it’s our job to get our companies and clients past that mindset, and once we do, the path to preparedness — and ideally prevention — is clear:

Your QA team is reexamining and reinventing its system from top to bottom.

food.mindsThere’s no such thing as zero risk. And pledging to adopt the very highest food safety standards represents a major investment of time and resources. At The Ice Cream Club, headquartered in Boynton Beach, Fla., company owners watched the Listeria outbreaks linked to ice cream in 2015 with trepidation. But they didn’t just watch, they sprang into action. They brought in outside auditors, instructing them, “We’re not looking for a gold star; we want you to thoroughly review our facility for any areas of risk and opportunities to improve!” They installed new equipment, joined IDFA’s Listeria Task Force, updated protocols and methodically retrained their employees. Importantly, they walked the production facility floor day-in-and-day-out, visibly modeling the behaviors they wanted employees to follow. This was a critical success factor in helping employees acclimate to the dynamic new food safety culture.

 Communicators have pressing media interviews to conduct, content strategies to approve and executives to prep for the next earnings call. But the historic legislation that directed FDA to build a new system of food safety oversight – one focused on applying the best available science along with common sense, to prevent outbreaks of foodborne illness, must be part of our jobs too. Make sure you understand what your operations team is doing in light of the multi-year implementation of Food Safety Modernization Act (FSMA) regulations, and update your food safety and quality messaging and proof points accordingly. Then, take it upon yourself to make sure your quality assurance, supply chain management and science/regulatory experts appreciate the importance of reputation management, issues management and crisis communication to their efforts. And make sure your FSMA-compliant Recall Plan includes the communications plan and assets you’ll need to deploy in order to properly notify customers and the public when necessary.

cucumber.spain,MEPThe key to the success of any response-mode communication effort is that your stakeholders and the general public already know your name and enough about you to give you the benefit of the doubt when something negative surfaces. The best way for members of the food industry to ensure this is the case, is to visibly engage in corporate social responsibility, responsible sourcing, nutrition, health & wellness and sustainability efforts. Make meaningful commitments and talk to the public – online and offline – about them in an authentic and passionate way.

Your crisis plan should be a living, breathing arsenal of strategies, checklists and tactics so you and your colleagues can respond without losing time to internal deliberations (“is this a four-alarm fire, or a three-alarm fire?”) when something hits. You’re going to need to marshal external resources quickly as well, so your plan should map out your network of legal, scientific, communications and operational advisors. And remember that scenario-based tabletop exercise that got cut from last year’s budget? It certainly would have been helpful if the key players had gotten a practice session in before the playbook was put to use!

Your third-party academic experts know you, and can speak to your track record.

The list of third-party experts compiled by your summer intern isn’t going to do much good in a crisis if you haven’t built and maintained relationships with everyone on it. Invite scientific and academic experts to tour your facilities, make an effort to visit their institutions, and update them regularly on company events and milestones.

When your brand or company reputation is called into question, you’re not alone. Industry associations such as IDFA have communication resources — social media monitoring dashboards, for example, and they employ technical experts who maintain strong relationships with federal regulators. They can advise you on preventive controls and communication strategies to shore up your prevention plan and are well equipped to buoy your team in the event of an escalated issue or crisis.

The stakes for food and beverage executives are higher than ever as FDA becomes increasingly aggressive in using the criminal sections of the Federal Food Drug and Cosmetic Act (FDCA) in the wake of food safety incidents. There have been more criminal prosecutions in the past five years of food company managers than in the prior two decades combined. And it’s important to realize that a misdemeanor conviction under the FDCA does not require proof of fraudulent intent, and doesn’t even require that managers were aware of a potential safety issue.

With a culture of food safety excellence and crisis preparedness in place, you may not avoid “tag, you’re it” entirely but you’ll be in a much better position to get back-into-the-game, and back-to-business, as quickly as possible.

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Planning for produce disaster: Mock outbreak proves valuable

Tim York, CEO of Salinas, Calif.-based Markon Cooperative, writes in The Packer’s Centerplate column that last month as we responded to a mock crisis drill testing our ability to react to, in this case, a potential food safety hazard.

lettuceAn edited version appears below.

Our crisis team dropped business as usual that afternoon and focused on implementing our crisis response plan.

The team leaped into action, setting up a makeshift “war room.” Checklists were examined, to-do lists created, and responses prepared for media and all stakeholders.

While it was a drill, the energy was palpable and the exercise proved a valuable reminder of the importance of not only having a crisis response plan but also practicing execution of that plan.

While the spinach crisis of 2006 has been talked about extensively, we must not forget the valuable lessons learned.

Most of the industry was woefully unprepared for the 2006 FDA alert “do not eat spinach.”

We knew we needed to recall the spinach that was in the supply chain, but then realized that spring mix and other items also contained spinach. The crisis rapidly got out of hand, and the industry was left scrambling.

Today, at Markon, we are much better prepared, as are many throughout the industry. We have a robust crisis plan and are well-versed in it and ready to use it. If you don’t, I highly recommend this become a priority.

Values should drive all decisions. A core value for us is People Matter. Remembering our core values can be great guidance when we aren’t certain what actions to take. For example, in the event the FDA or the supplier does not call for a recall, we may still want to act based on our core value.

Social media can be like a wildfire, and someone needs to be responsible for monitoring social media websites and responding accordingly. This means having a firm understanding of the social media space, including appropriate rules of engagement. Having a social media response guide is a critical piece to any modern crisis response plan.

And while checklists are an important part of any crisis response, we must — as an industry — remember that food safety is about more than limiting liability. It’s about people.

 

Food safety crisis management for fresh produce

In 2008, U.S. tomato growers, wholesalers, and retailers in Florida lost an estimated $250 million when they could not sell their product after an investigation of a possible Salmonella spp., outbreak linked to their product resulting in a national health advisory. Consumer confidence in the safety of tomato products eroded, while food safety practices on farms and throughout the supply chain were called into question. Other producers were also affected by this health advisory and found themselves answering questions about growing conditions, the safety of inputs (including water) handling and distribution of products.

That’s what Chapman told the Great Lakes Fruit, Vegetable and Farm Market Expo in December 2011, based on work he did along with Audrey Kreske and me, and which has now been revised and re-edited for The Grower, an Ontario-based trade publication.

Recent fresh produce-related outbreaks have created an environment where commodity groups and producers are even more concerned about managing the fallout after a foodborne incident.
Crisis management in the food industry has four phases:

• Prevention: Employing a good food safety culture, including staying current on risk factors.

• Preparation: Proactively planning for a problem and monitoring public discussion risk.

• Management: Implementing the plan using multiple messages and media.

• Recovery: Reassessing risk exposure and telling the story of changes.

Prevention

Food safety culture is how an organization or group approaches food safety risks, in thought and in behavior, and is a component of a larger organizational culture. Creating a culture of food safety requires application of the best science with the best management and communication systems. Firm owners and operators need to know the risks associated with their products and how to manage those risks. Having technical staff in place to stay abreast of emerging food safety risks and conduct ongoing evaluations of procedures, supplier requirements and front-line staff practices provides a necessary foundation for a good food safety culture.

Preparation

Crises will happen. Companies who understand this, and are prepared to deal with them will survive. Those who are not risk losing their market – and often do. While proactively managing microbiological risks, organizations with a strong culture of food safety also anticipate that outbreaks of foodborne illness may occur despite the use of sound food safety systems. Industries strong in crisis management including, information sharing, monitoring and reactive crisis communication skills, can drastically reduce the impact of deleterious and harmful media if an outbreak arises (Jacob et al., 2011). Being prepared to speak openly speaking about risk reduction strategies and demonstrating risk management practices can reduce financial impacts and allow public trust to be regained quicker than if a firm/industry had not planned.

Management

An increasing number of consumers seek food safety information from Internet sources, including one in eight Canadian consumers and one in four American consumers. 
Following 2006 (E.coli O157 in spinach) and 2008 (Salmonella Saintpaul in Serrano peppers) news spread through the Internet in an unprecedented fashion. Producers, processors, retailers and regulators of agricultural commodities must now pay particular attention to evolving discussion and engage in the public discussion while the crisis is occurring. A firm or industry that is not forthcoming with information of who knew what, when, and what decisions were made sets itself up for loss of trust because media and Internet discussion goes towards these questions.
During a crisis it is necessary for a company or industry to talk about the science, discuss risks and tell an interested public about what is known, what is unknown and on what evidence decisions are made. Being available and understanding how media functions are also necessary skills for food industry members. Without recognizing deadlines or telling succinct stories of risk management, individuals risk the chance that others will fill the information vacuum with inaccurate information.

Recovery

A firm employing the best crisis management practices starts the recovery phase as soon as notification of a problem. Publicly, producers must address the problem, apologize to affected individuals; and, reach out to the media about risk-reduction changes. It is best to establish a dialogue with groups to demonstrate the organization’s openness and commitment to public safety and health. Internally a firm plans for reentry to the market, logistics and how new risk-management strategies will impact other business activities. If there was media attention around the crisis event, the one-year anniversary will often garner further coverage. An organization must be able to demonstrate that they have learned something/changed process in response and assess internally whether the same risks to public health exist by asking, “would we have the outbreak again today?”

Crises happen: Learn from past incidents and prepare to respond and manage

An outbreak is a nightmare for any company and will most certainly result in real costs to the business. What’s kind of crazy is that these incidents happen weekly and often firms seem like they didn’t think it would happen to them. Companies repeatedly fall into certain pitfalls during a crisis. usually surrounding a statement of “we’ve done the same thing for X years and we’ve never had a problem.” Or “we follow the strictest government regulations.”

That’s not enough.

Public health officials call a produce packer and tell them that a cluster of 60 illnesses has one thing in common—their product. Illnesses have been popping up for weeks, entered into state and national databases, and after a couple of rounds of interviews with the victims (some still hospitalized), statistics and epidemiology point to the packer as the source.

The investigators are on their way to the facility; they would like to see how clean and sanitized the packing lines are, how well the packer’s dump tank chlorinator is working and analyze all transaction documents to determine where all incoming product came from and where it all went.

There are sick children, chatter on Twitter, press inquiries and angry customers looking for refunds. Additionally, all of this happens within 24 hours of the initial call. Within 3 days, the number of linked illnesses triples, lawsuits have been filed and the commodity has become the punch line in late-night talk show monologues.

This is the start of an article that Audrey Kreske, Doug and I co-authored on crisis management where we talk about preparation and response strategies. It’s in the June/July issue of Food Safety Magazine. Check it out here.
 

Crisis management at 40,000 feet

Manhattan (Kansas) to Dallas, Dallas direct to Brisbane, what could be easier. Save hours off the door-to-door travel and bestest of all, no rechecking in at the dreaded Los Angeles International airport.

Four hours later, we’re on the tarmac at LAX.

About 90 minutes into the flight, an elderly woman sitting in the row behind me looked like she had lost consciousness … she looked dead. Stewards were summoned an oxygen was applied. Nothing.

Then a message came from the cockpit that no one on a plane wants to hear: not the, “Do any passengers have experience flying a jumbo jet,” but the other, “Are there any medical professional aboard the flight?”

What looked like a husband and wife time of physicians attended to the woman.

After about 10 minutes she seemed to be revived. They located a bunch of medical papers and medications she was travelling with, and quite professionally brought the woman back from the brink.

But, rather than risk flying the Pacific Ocean, the plane was diverted to LAX and paramedics arrived to take the woman to the hospital. And then we had to go to New Zealand because the crew had reached the legal maximum for hours working (20). So arrangements were made for a new crew and flights in New Zealand to finish the journey to Australia. Hours saved now hours gone.

Up until that point I had been finishing marking final assignments for my food safety risk analysis students, which included a crisis management component. The best producers, processors and retailers are trained and prepared to handle crisis situations.

Later in the flight I spoke with one of the stewards and asked him how much they were prepared for this sort of ting, especially on a schedule 16-hour flight.
He told me they have standard procedures and there is a medical professional on the ground at all times and is the only person who can authorize in-air treatment. So the doctors who happened to be on the place were providing observations and carrying out instructions

I asked the steward how often passengers had died on flights he was working; he gave me a couple of examples.

Stuff happens: be prepared.
 

Crisis, what crisis? Food safety and the cycle of crisis

Supertramp was always big in Canada. Their 1975 album, Crisis-What Crisis set the stage for the megasellers of the next few years. I didn’t really go for Supertramp, but have to admit their music holds up much better than most – Journey is so awful – over the years.

Julia Stewart of the Produce Marketing Association offers some food safety crisis communication tips in the From Field to Fork blog. It ain’t rocket surgery, but groups screw this up all the time (today I’m looking at you, egg industry; tomorrow, who knows).

Don’t stonewall

There can’t be any holes in the food safety net, folks – so large, local, conventional, organic, everyone must get on the food safety bus.

Don’t settle for status quo

Your grandfather or great-grandfather’s farming practices are no longer good enough. The modern food safety reality necessitates risk assessment and risk management, GAPs, audits, and the courage to not harvest that suspect block.

Don’t blame victims

Consumers (rightfully) expect the food industry to work hard to produce safe foods, so we shouldn’t blame them when they get sick because they didn’t treat our foods like hazardous materials.

Do consider the return on investment

A food safety program is an insurance policy. Causing a foodborne illness outbreak can literally cost you the farm. Investing in food safety can help reduce the risk.

Do have a long-term view

The food safety landscape is perpetually changing, so strive for continuous improvement.
 

What Tiger and Toyota can learn from dioxin: words alone are never enough

Professional golfer Tiger Woods and Japanese automaker Toyota are both struggling under the media spotlight to repair their damaged public images and resorting to public statements and advertizing. But communications alone is never enough when faced with a risky situation – it’s the combination of risk assessment and management, along with communications, that helps individuals, corporations and governments regain trust and public favor.

New research from a team led by Dr. Doug Powell, an associate professor of food safety at Kansas State University and published in the journal, Public Understanding of Science, further validate the idea that words alone are never enough when managing a food safety crisis – actions are also important.

The authors examined two incidents of dioxin contamination of food in Belgium and the Republic of Ireland in 1999 and 2008, respectively. In both cases, dioxins reached the food supply through the contamination of fat used for animal feed. The food and agricultural industries connected to each incident relied on crisis management activities of federal governments to limit adverse public reaction.

In 1999, the Belgian government delayed communicating with the public and other European agencies about possible risks, failed to acknowledge perceived risks with dioxin-laden feed, and ultimately suffered huge economic losses, a damaged food industry and deterioration in public confidence.

In the winter of 2008, the Republic of Ireland faced a similar dioxin-in-animal-feed crisis and, unlike the Belgian response, promptly communicated with the public, and acknowledged perceived risks by mandating that all pork products released for sale were to carry a special label to indicate they had no association with the potentially contaminated feed.

“Prompt communications with the public, acknowledgement of both real and perceived risks, and control of stigma surrounding a hazardous incident are important factors in effective crisis management,” said Powell. “The Irish government succeeded by not only saying the right things, but by removing potentially contaminated product from commerce in a timely manner. Actions and words must be consistent to manage any crisis and garner public support.”

Abstract below:

Government management of two media-facilitated crises involving dioxin contamination of food
23.feb.10
Public Understanding of Science
Casey J. Jacob, Corie Lok, Katija Morley, and Douglas A. Powell
http://pus.sagepub.com/cgi/content/abstract/0963662509355737v1
Abstract
Incidents become crises through a constant and intense public scrutiny facilitated by the media. Two incidents involving dioxin contamination of food led to crises in Belgium and the Republic of Ireland in 1999 and 2008, respectively. Thought to cause cancer in humans, dioxins reached the food supply in both incidents through the contamination of fat used for animal feed. The food and agricultural industries connected to each incident relied on crisis management activities of federal governments to limit adverse public reaction. Analysis of the management of the two crises by their respective federal governments, and a subsequent review of crisis management literature, led to the development of an effective crisis management model. Such a model, appropriately employed, may insulate industries associated with a crisis against damaged reputations and financial loss.
First published on February 5, 2010
Public Understanding of Science 2010