What can your company do now to foster data sharing and consumer trust?
Part 2 of Our Series with Dr. Bob Whitaker
Bob Whitaker, Ph.D., Whitaker Consulting LLC
August 17, 2022
In Part 1 of this series, Dr. Bob Whitaker discussed the similarities between the airline industry in the 1990s and the current state of the produce industry. In Part 2, he provides some next steps for companies who want to foster data sharing and build trust.
Putting aside the more global issues of data sharing structures, governance, and the philosophical challenges of transparency across an entire industry, perhaps the first step in catalyzing change through data sharing may be to look inward at your individual company. Assess its culture and how it values data.1,2
It is hard to imagine a unified, industry-wide initiative to openly share data without first having the leading companies dive deeper into the data they currently collect. This includes how and why it is collected, the methods used to develop the data, the level of analysis being performed, ways the company is using the data, and how the data trends over time. Here are some things to consider if a company is looking to the future and evaluating its data competencies.
Does the company have the right culture to participate in a data revolution?
Is your corporate culture geared to appreciate the value of produce safety data? Does the company use data to drive operational decisions? Does it commit sufficient human and financial resources to data collection and analysis? If the answer to any of these three questions is “no,” then it may be time to review the status of the company’s produce safety culture.
A popular phrase used around the produce industry is “data is the new currency.” If your business culture is not prioritizing data collection and driving decisions based on that data, your company may be falling behind others across the supply chain that are actively engaged in data collection and analysis. Failure to act now could result in your company not having access to the data currency of the immediate future.
Is the company collecting the right data?
Is there a strategic focus on what produce safety data is collected, when it is collected, and the reasons behind its collection? Sometimes data collection falls victim to “drift.” In other words, an auditor asks for certain data or a customer demands another set of data, and before long, the company is gathering data that ends up having no daily bearing on product safety. It is simply taken so a box can be checked on someone else’s list, someone who has no real knowledge of the company’s operations.
It is important for a company to “own” the reason for gathering specific data. It is equally important for a company to understand operational limits around that data and what actions should be taken if operations fail to meet expectations.
Is the company cognizant of the importance of metadata?
Metadata gives your primary data deeper meaning. For example, if a company gets a positive generic Listeria result from a conveyor belt frame, that is a single piece of primary data that indicates the company should perform a deep cleaning and retest. In order to be more diligent, they should also collect additional metadata that brings context to the test result. This could include whether previous positive samples have been uncovered in the same area, positive sample frequency, commodities run on that line and where they came from prior to testing, sanitation data, and pre-operations testing data. If previous positive tests had been found, perhaps the isolates were speciated to determine if they were Listeria monocytogenes or a non-pathogenic relative.
This metadata brings more meaning to the positive test result and aids the operator in designing next steps and corrective actions. An operation might also source external data to bring context to their positive test finding. For example, research data on Listeria, performance data on sanitizers, sensitivity and selectivity data on the sampling and testing methods employed, controls used, etc.
Is the company getting value from their data?
If produce safety data is collected and filed away so it can be used just to verify that measurements were taken, it has only been leveraged for half its value. For example, you can demonstrate to an auditor or a customer that you are measuring the chlorine in wash water for a set time period. However, analyzing chlorination over a longer period of time provides an operator with a much clearer view of the efficacy of the system. This includes adding in pH data, temperature, and organic load information, as well as measuring product to water contact time and accounting for the amount of raw product being washed in the system over time.
It may also help to proactively identify incidents that could lead to cross contamination. Competent analysis requires knowledge of the operational systems and technical capabilities. It is important for companies to have both the systems to visualize data and the human resources trained to perform the analysis and take action.
Does the company convert data into actions?
It is important to avoid analysis paralysis. Prioritize which data to collect based on the risk of product contamination, which should be readily identified from the company’s hazard analysis and risk assessments. The collection and analysis of this data has to be preceded by a considered approach to understanding what the results mean. What actions need to be taken when the data does not support the company’s produce safety plan objectives? Who is responsible for taking action and what is the timeline?
Determine who needs to know when an incident has occurred, as well as the outcome of the actions taken. Conduct a review of what happened, why it happened, and how it can be prevented in the future. These actions are tantamount to building trust with customers and regulators.
Has the company food safety culture matured to the point where leadership can voluntarily employ data to create transparency with regulators or customers?
This question is central to preparing a company for a future where data really is a “currency.” This is where the fear of recrimination by customers and distrust of regulators enters the equation. Historically, most companies are just not ready to take this step. But our understanding of pathogen presence and persistence in fresh produce environments has increased in the last few years, and that should change historical biases.
Frankly, a regulator or a customer should distrust any operation that does not have data demonstrating occasional pathogen detections. The detection of a pathogen or a condition that could result in a safety issue is confirmation that the company has a valid and verifiable produce safety program. The crucial parts regulators and customers should pay attention to are the results of the internal investigation the company performed and what corrective actions were taken to manage the issue.
That said, trust can be built by sharing data with regulators and customers, who in turn can promote more aggressive and scientifically sound approaches to produce safety. Regulators need to pull back on their historical tendencies to penalize and instead reward operations that can demonstrate risk and science-based processes.
Can the company leverage its data to drive change in how produce safety issues are solved in the future?
If the company can answer this question in the affirmative, then the paradigm of produce safety has shifted dramatically from today’s defensive and reactive posture to offensive and preventive strategies. Proactive companies can develop solutions to industry-wide issues with data, partnership, and trust.
If enough companies reach this level of performance, the produce industry will have an opportunity to mimic what the airline industry did three decades ago to meaningfully engage stakeholders and sustainably address produce safety challenges across the supply chain.
1. Frank Yiannas. (2009). Food Safety Culture, Springer Science + Business Media, LLC, Spring Street, New York.
2. “Food Safety Culture: if you can’t measure it, then do you really have one?” Dr. Bob Whitaker. January 4, 2022. iFoodDS. https://www.ifoodds.com/blog-food-safety-culture-if-you-cannot-measure-do-you-really-have-one/.