Food safety insight

by Dan Malovany
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Gale Prince has earned the title “Dean of Recalls.” For more than 40 years in the food industry until he retired from The Kroger Co. as its director of corporate regulatory affairs, he managed several thousand recalls. He is considered an expert when it comes to food safety, regulatory requirements, food defense, quality control, safety of imports and product traceability.

That’s why several baking industry organizations — including the American Bakers Association, AIB International, the American Society of Baking and the Baking Equipment Manufacturers Association — asked Mr. Prince, president of Sage Food Safety Consultants, Cincinnati, and his business partner, Jennifer Frankenberg, to review and update the standard for the design of bakery equipment. The standard provides guidance regarding proper design for sanitation and food safety for a variety of manufacturing equipment.

“I have seen the good and bad elements of food equipment design, construction and installation that foster food safety problems,” Mr. Prince said. “Many pieces of equipment generate repeated, extensive cleaning costs, and some prove to be un-cleanable without modification. I have seen these conditions lead to product contamination, illnesses and product recalls. I hope my experience will help me provide input for the parties to consider in their deliberations on the equipment standards.”

Recently, Baking & Snack, a sister publication to Sosland Publishing’s Food Safety Monitor, asked Mr. Prince to provide his insight about food safety and the sanitary design of equipment.

Dan Malovany, editor of Baking & Snack: Can voluntary efforts still be effective in the increasingly regulated environment of food processing?

Gale Prince: Absolutely. Voluntary efforts by industry are the most effective and the quickest way to address food safety issues. Such efforts have been very effective in years past in the implementation of effective control measures. When an industry works through its trade associations, they can be very effective in drafting industry standards in a very timely fashion with input from regulatory agencies. Good examples include the voluntary food transportation guidelines that have served the food industry for about 30 years. Another is the food warehouse sanitation guidelines that changed the conditions in food warehouses. Those guidelines were implemented in the early 1970s within a relatively short period of time vs. the regulatory process.

The dairy industry made a number of voluntary changes following a large outbreak from milk in the city of Chicago in the 1980s. These changes were implemented by the dairy industry in cooperation with Food and Drug Administration. Each of these examples addressed an issue and resulted in industry-wide voluntary corrective actions by taking the preventive measures recommended by the industry, not necessarily through regulation.

Mr. Malovany: How are AMI and 3-A standards faring today?

Mr. Prince: The AMI equipment standards (developed by the American Meat Institute) are another example of a voluntary joint effort of the meat processing industry and the equipment manufacturers to address food safety concerns related to the ability to effectively and efficiently clean and sanitize complex pieces of equipment. The 3-A standards also came about because of a need to improve the design of the dairy processing equipment for effective cleaning. The dairy industry realized the benefits of sanitary design in protecting public health and obtaining better shelf-life for its products.

Today, these voluntary standards are widely accepted and demanded throughout their industries. In fact, dairy equipment buyers consider conformity to the 3-A standards a basic requirement when purchasing equipment. They look on 3-A as the gold standard for dairy equipment.

Mr. Malovany: How reliable are third-party audits, and what is your perspective on the number of audits that many food companies are subjected to from their suppliers?

Mr. Prince: Third-party audits add value to a firm’s food safety programs by bringing an outsider’s perspective. Often, individuals within a firm lose sight of food safety problems from being too close to operations on a day-to-day basis.
Over the years, we have seen a few auditing system failures when individuals falsified information in the interest of cover-up for economic gain. In recent years, there have been some excellent examples of audit failures in the financial community and even with regulatory oversight programs. When we look at the number of audits performed in the financial arena and for food safety, the audits do identify problems and are a critical function in further advancing the controls of publicly traded companies’ financial accounting practices and also their food safety programs.

These audits bring with them best practices and insights to assist firms in food safety improvement programs. Such audits are an excellent training tool for plant employees. Most companies use third-party audit firms to improve their food safety programs, and the industry and consumers have benefited from their use over the years.

Mr. Malovany: How much is too much when it comes to audits?

Mr. Prince: That is a good question. You only need a good food safety audit once or twice a year depending on third-party findings. While additional audits may bring a new idea or two with a little different perspective from another set of eyes, they should not be that much different in key food safety elements. The differences may be due to expertise of the auditor, the individual facility or the type of operation. The United Fresh Produce Association analyzed third-party audit firms’ inspection criteria and found that about 90% to 95% of all of the inspections cover the same points. A comparison chart for these auditing firms can be found on United Fresh Produce Association’s web site, This comparison was done to help reduce the number of multiple audits of the same facility.
The food safety audit must bring value to the audited firm with a true review of the firm’s programs and intense review of the production operations to see that written programs are in place and are working. The purpose of the audit should not be for the sole purpose of satisfying buyers’ requirements for a food safety audit to be conducted. A properly conducted audit takes a substantial amount of management time and can be a substantial cost to a firm. Hopefully, in the future, we should be able to have one third-party audit per year to meet the needs of all customers who require them.

The full interview with Mr. Prince will be published in the June 2011 issue of Baking & Snack magazine. The issue may be viewed by visiting
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