A clearer path to food safety compliance

Gary Kestenbaum

October 28, 2015

5 Min Read
A clearer path to food safety compliance
Everyone servicing the food industry should anticipate being targeted on some level for a qualitative food safety preparedness evaluation, says author Gary Kestenbaum.

A range of industry factors have led to the point that independent food safety audits are now a normal and necessary component within the food supply chain. Food safety packaging expert Gary Kestenbaum provides guidance.

Regardless of risk level or food contact status, businesses that provide non-comestible goods and services in support of the food industry including  packaging, equipment, utensils, storage,  transportation and related services  are likely to be required by customers to participate in food safety program awareness and prevention evaluation. Manufacturers and suppliers are best positioned to respond appropriately and calmly when food safety-related objectives are understood and anticipated in advance of partner requests for proof of action and compliance.   


Increasingly, businesses involved in every facet of the food industry are being required to provide proof of food safety, understanding, compliance and “suitability.”  Clients are likely to define adequate proof or evidence as compliance with thresholds and expectations that they have implemented as standards for their business or industry. Clients use various strategies and processes to develop and set supply chain partner food safety program  standards  and expectations. Recipients of such requirements should presume that the client  has invested significant money and resources (internal and external) into  development and implementation of its food safety program  prior to onboarding and implementation.

The term “suitability” may be objectively and subjectively defined by the client.  Clients are keenly interested in supply-chain partner product suitability, use suitability as per government and industry guidelines and regulations, manufacturing facility suitability, procurement process suitability and so forth. Presume that “suitability” relates to broad, important criteria defined by the client, the client’s advisors or an entity within the client’s supply chain.

A range of factors including the impacts of the Food Safety Modernization Act (FSMA), enhancement of FDA involvement, consumer awareness and related initiatives by the Global Food Safety Initiative (GFSI) or organizations with similar intent contribute to a global understanding that independent food safety audits and compliance verification are now a normal and necessary component within the food supply chain. This applies to comestibles and non-comestibles alike.

Depending upon many circumstances including risk level, business decisions, practicality and other relevant criteria, the client mandate for proof or evidence of program compliance and product/service suitability may or may not be negotiable. Regardless, understand the general client objective. The client is applying self-determined, focused criteria to assess the food safety and suitability risks and related control program status of its supply-chain partners.  Processes for performing assessments vary, but objectives align. Clients begin the supply chain integrity protection process by obtaining a functional overview and summary of supplier/vendor/service provider understanding, preparedness, practices, risk potential and related food safety control.

Balanced and cordial relationships between supply chain partners on the subject of food safety are best maintained via consistent in-person communication with key food safety or quality department stakeholders and champions from each organization. Those conversations will help all involved parties to more fully understand how and why client-defined compliance criteria were chosen.  In any event, everyone servicing the food industry should anticipate being targeted on some level for a qualitative food safety preparedness evaluation

Readers will be best equipped to respond to and prepare for food safety-related analyses when they understand the purpose, objectives and benefits of industry-standard evaluation methodologies.

Typical techniques for assessing food safety and suitability status  

Expect clients, supply-chain partners or their representatives to communicate with you as they attempt to initiate their version of a food safety facility,  process and component assessment. The assessment may be performed directly by the client, or in many cases, delegated to an independent representative, firm or consultant.  Initial or otherwise, communications are intended to:

  • Inform the recipient of the client food safety target objectives;

  • Inform the recipient of client process, procedures and requirements;

  • Request specific information, activity and conformance by the recipient; and

  • Require the recipient to perform, schedule or submit to specified action or interaction.

The commonality of the above actions and objectives is that  it functions as a method to assemble, disclose and disseminate information specific to the targeted partner and, likely, one or more of its processes, personnel and facilities.

Technique 1:  Food safety assessment

Often times, the client or partner will initiate this process by asking for a food safety assessment. The initiator of this request may suggest that the recipient self-assess its  process, product and facility, or alternately, may ask that an assessment be prepared or provided by a specified person or entity.

One might compare a food safety assessment to the lengthy and comprehensive questionnaire a patient is required to complete in advance of an initial physician office visit and prior to a physical examination.

Consider that the client, partner or requestor is providing the recipient with a statement of objective, which, generally, is the necessity to control the safety, suitability and consistency of food –related materials, products and services.  In order to accomplish that objective, the recipient is asked to complete a self-assessment questionnaire and disclosure document.  Part of the process often includes a request to provide related first, second or third party disclosure documents and certifications intended to function as evidence of food safety understating, risk control and preparedness.

Most questionnaires will address type of certifications available and the certifying authorities, the extent of the food safety program and level in effect, the age of the facility and whether or not it has recently undergone a food safety audit, the extent to which the facility can verify the purity and suitability of its raw materials and many other relevant data, all of which will indicate just how prepared the facility is to meet client expectations. Be assured that if the questionnaire is not fully or adequately completed, or if requested ancillary documents are not provided, it acts as evidence that the supplier is not prepared or willing to meet client food safety expectations or requirements due to gaps in control and verification.

In Part 2 next week, we will explore and describe food and packaging safety audits and evaluations. 

Gary Kestenbaum has 40 years’ experience in the food and packaging industries, six as a supplier with National Starch, 18 as a product developer with General/Kraft Foods and 15 as a packaging engineer and developer with Kraft. As senior food packaging safety consultant with EHA Consulting Group, Kestenbaum provides guidance on packaging safety and suitability-related projects for raw material manufacturers, converters and associated supporting professionals. He can be reached at [email protected] or 410-484-9133. The website is www.ehagroup.com.


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About the Author(s)

Gary Kestenbaum

Gary Kestenbaum is an independent food packaging consultant with 45 years of experience in the food industry as a food ingredient technician with National Starch, a food product developer with General and Kraft Foods, a senior package developer with Kraft Foods and a senior food packaging safety consultant with EHA Consulting Group.

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