Thinking Differently About Food Safety and Traceability: An Interview with Former FDA Official Tom Sidebottom

Note: This interview took place before FSMA Rule 204 was finalized. The content is based on knowledge of the proposed rule. Commentary may not reflect the final version of the rule.

The iFoodDS team sat down with Tom Sidebottom to get his input on how we can think about food safety differently and use data to gain a real-time view of the supply chain. Tom joined the private sector as a regulatory consultant after spending over 32 years with the U.S. Food and Drug Administration. He served as the director of the FDA’s San Francisco laboratory for 11 years. There Tom managed a diverse group of scientists responsible for protecting public health. Connect with Tom on LinkedIn.

We talked to Tom to get his thoughts on the New Era of Smarter Food Safety, data sharing, traceability, and other current food safety topics. Here are some key takeaways from our conversation.

How Can We Connect Data Points Across the Supply Chain to Drive Process Improvements?

Our own Johnna Hepner, Director of Industry Relations, started the conversation by asking, “How can we connect data points across the supply chain, and are there opportunities to drive process improvements in food safety through data sharing?” Tom pointed out that it’s not just about bringing the data together. We need to decide who should be involved in sharing that data.

The agricultural industry is very siloed and heavily contract-based, which makes it easy to miss data along the supply chain. For example, a farmer and a third-party harvester may each do their own food safety assessments of a field, but never share the results. Tom recommended including a section in contracts that outlines the data that will be exchanged between supply chain participants. He pointed out the waste of repeated testing and recommended sharing data to eliminate redundancies.

Who Should Be Responsible for Bringing Food Safety Data Together?

Tom then raised the question of who should be bringing all the data together and analyzing it. We need standards defining the information that should be collected. iFoodDS believes the FDA’s proposed Rule 204 is a major step towards setting these standards since it mandates Key Data Elements (KDEs) to be collected during Critical Tracking Events (CTEs) such as Growing, Shipping, Receiving, Transformation, and Creation.

Tom also cautioned against a blame-focused mindset where we seek out the company responsible for a food safety event. The truth is that everyone contends with similar food safety issues. For example, a brand implicated in a recall may have sourced product from the same grower as other brands that were not impacted. The difference between these two companies may have been an isolated incident, such as equipment failure in a processing facility or a truck breaking down during transport. Instead of assigning blame, we need to come together as an industry to find the root cause of issues.

A better approach would be anonymizing critical food safety data so we can study it and identify larger trends without implicating individual companies. Tom suggested that the industry needs one system to aggregate all the data so it can be shared. Such a system could be built by an enterprise-level company that could “deal with the volume and has some experience with understanding the challenges both on the industry side … and regulator side.”

Is the New Era of Smarter Food Safety Driving Change?

Johnna asked Tom for his thoughts on the FDA’s New Era of Smarter Food Safety. He said he believes this is the right direction, but the FDA still needs to refine its model or accept different models to fit the needs of different industries like the produce industry.

He pointed out that produce changes ownership many times from harvest to distribution, and it is also highly perishable, so we have a limited timeframe to deliver it. This makes it challenging to address issues as they come up. A reactionary model is not going to improve safety, Tom asserted. The industry needs a way to prevent risks instead of simply reacting to them. Active monitoring by internal teams will help catch issues before they become a larger problem.

Imagine what food safety teams could do with real-time data at their fingertips and transparency across the supply chain. The data could be used to detect trends that indicate an emerging issue and quickly intervene and isolate the root cause ahead of any food safety events. This kind of proactive risk management is much harder, if not impossible, with paper recordkeeping. Digital data capture empowers teams to manage food safety in real time.

Traceability Is Key to Being Proactive

Johnna pointed out that the FDA has been encouraging a proactive rather than reactive approach. Traceability could be the key, since it empowers us to know exactly where a product came from and view associated food safety data. Unfortunately, the current state of the industry limits retailers’ understanding of produce sourcing since many suppliers are not fully PTI compliant. Tom emphasized that companies should go above and beyond the standards set by FSMA Rule 204. “I want to be over the bar, way over the bar. The companies that just want to skim … they’re going to get hit,” he said. In contrast, companies that start working on traceability initiatives now before the rule is finalized will be prepared.

What Tools Are We Missing in Our Toolbox?

If we think about food safety as a “toolbox” filled with all the tools we need to succeed, what pieces are we currently missing? Tom and Johnna discussed how we currently lack the ability to integrate data so we can see the full picture. Tom gave the example of pairing lab testing data with other events happening in your operations. For example, you might notice a sudden increase in positive samples after shifting to a new growing location. Or there may be a correlation between positive samples and certain weather events or conditions. It would be ideal to have a method of sharing data with regulators while protecting the privacy of individual companies.

Where Do We Go from Here?

It’s clear that we need to do things differently when it comes to food safety, but the complexity of the industry makes progress difficult. Tom believes the best path forward may be adopting standards from a non-governmental organization (NGO). While FSMA Rule 204 is a proactive approach to traceability and food safety, it doesn’t address the lack of interoperability between different technology platforms. A system such as GS1 could become the global standard adopted across the supply chain.

Until a standard emerges, the best thing we can do is improve our internal food safety programs. Start by aggregating your data and analyzing it for trends. Digitizing your food safety data will empower you to gain a real-time view of your operations. This allows you to actively monitor instead of passively react.

If you’d like to gain greater control over food safety risks, contact iFoodDS for a free consultation on our food safety and traceability solutions.