Over the last two years, the food industry has been put to the ultimate agility test. The effects of COVID-19 have placed incredible strain on food companies, their overall operations and their employees. As food companies have worked to respond to and manage COVID-19, much of the responsibility for these initiatives, in many companies, has been placed on food safety professionals. This included the development and implementation of a wide range of complex and ever-evolving COVID policies, interwoven with or layered over existing programs.

As these programs have been put into place, the daily responsibilities of company leadership, management and their employees have changed as well. Whereas the primary focus of food safety departments pre-COVID was exclusively on food safety and quality, the focus shifted heavily post-COVID to management of the virus and related programs.

As a result, in many cases, less time was available for company leadership, management, and employees to complete their routine food safety-related tasks and execute existing programs. As focus shifted from routine tasks and programs, management and employees in some cases began to compensate for reduced time by taking certain shortcuts, postponing tasks, or not completing tasks. In turn, as time passed and as the pressures of COVID continued or even increased, those shortcuts turned into habits, and the habits became the routine.

As a result, many food companies may have allowed the precision once existing in their food safety programs to dwindle or even fade. In turn, as the periodic departure from task completion or program execution became more routine and habitual, gaps or holes may have developed or continue to exist. If so, the company may have additional exposure from the USDA’s Food Safety and Inspection Service (FSIS) which, when conducting a record review, may discover deficiencies.

Over the last couple months, we have noticed an emerging trend of recalls of FSIS-regulated products because of gaps in record keeping or a company’s response to findings contained within records.

In September, 2,048 pounds of hot dogs were recalled because of the presence of Listeria monocytogenes. The problem was discovered when FSIS reviewed the company’s records and discovered that a product contact surface had tested positive for Listeria. The result was subsequently confirmed to be Listeria monocytogenes, but the company had presumably not taken any action in response. In October, FSIS was conducting a review of another company’s records and discovered the company had also not taken any action in response to a positive Listeria monocytogenes finding.   

Moving forward, we fully expect FSIS to begin conducting more comprehensive reviews of food safety programs and supporting records. Take the time now to conduct your own reviews first. Make sure that any bad habits formed over the previous 18 months are not creating gaps or openings in your programs. If you do, you will satisfy yourself that there is nothing lurking in those records that you don’t want FSIS to find.