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March 25, 2020

Lessons in COVID-19

By Erik Malmstrom
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Takeaways for the Future of Food Safety

The COVID-19 pandemic has exposed our dangerous lack of public health readiness to contain the rapid spread of a deadly virus in the US, demonstrated by our insufficient testing capabilities and our inability to effectively track and trace in the early days of the outbreak. While there is no evidence that COVID-19 can be transmitted by food or food packaging, it is fair to question the US food system’s preparedness for pandemics in which food has greater potential to be a carrier. Identifying and addressing weaknesses now has the potential of mitigating the risk of catastrophic health and economic consequences in the future.

In the US, a multi-stakeholder coalition of the Center for Disease Control (CDC), Food and Drug Authority (FDA), Department of Agriculture Food Safety and Inspection Authority (USDA-FSIS), and state and local public health authorities is responsible for responding to infections and outbreaks transmitted through food. Enacted in 2011, the Food Safety Modernization Act (FSMA) upgraded the US food safety system for produce and processed food, governed by FDA, by requiring stronger tracking of foodborne illnesses, stronger oversight of food production, stronger preventive controls, and empowering FDA with mandatory recall authority. However, at the time of FSMA’s enactment, Congress did not simultaneously upgrade safety standards for meat and poultry, governed by USDA-FSIS, with food recalls continuing to be almost all voluntary and initiated by manufacturers and distributors.

Consequently, critics believe that fragmentation of the food safety system in the US has resulted in “inconsistent oversight, ineffective coordination, and inefficient use of resources.”¹ Moreover, the current system has led to bifurcated outcomes – total produce and processed food recalls governed by FDA have decreased 34% since the implementation of new food safety plans for food companies in 2016, with the most hazardous recalls (Class I) dropping 54%. Meanwhile, total meat and poultry recalls governed by USDA-FSIS have increased 65% since 2013, with the most hazardous recalls (Class I) increasing by 85%.²

Technological modernization is another challenge and opportunity for food safety. In 2019, the FDA launched a major initiative called “The New Era of Smarter Food Safety” in order to “leverage technology and other tools, to create a more digital, traceable, and safer food system.”³ In many respects, the US food industry lags behind other industries with respect to its level of technological sophistication for ensuring the safety and security of its supply chain. One of the most glaring gaps between current food industry practice and commercially available technology used in other industries pertains to rapid testing for food safety and traceability. As we’ve seen with South Korea and other Asian countries that have most effectively responded to COVID-19, deploying rapid testing, tracking, and tracing technology in healthcare, early and often, can have a decisive impact on containment. Similarly, rapid testing, tracking, and tracing technology is extremely valuable in identifying and removing lethal contaminants in the food chain.

Currently, much of the food industry employs outdated low-tech solutions for food safety and traceability. These solutions have repeatedly demonstrated their shortcomings with fatal consequences. Over the past two years, high-profile recalls of romaine lettuce, beef, and flour, among others, due to e.coli contamination not only failed to identify contaminated product before it hit retail shelves and endangered the lives of consumers. Disturbingly, post-recall investigations often took months to complete, failed to identify the original source of contamination, and failed to prompt meaningful reform of food safety practices.

Recognizing an unmet need in the food industry, our company developed the first and only on-food traceability solution, leveraging edible, invisible DNA-based barcodes (FDA Generally Recognized As Safe) that are applied directly to food and that a downstream purchaser can read with a rapid, inexpensive, on-site test. Our solution is especially valuable in food chains with elevated risk of pathogenic contamination, counterfeiting, and environmentally destructive sourcing practices, where verifying product provenance and authenticity rapidly is vital and where traditional packaging and paper documentation-based methods of tracking and tracing have proven to be ineffective, slow, and vulnerable to tampering and error.

Additionally, we developed a groundbreaking rapid sanitation verification solution to quantify the microbial load reduction of cleaning and sanitation in food processing facilities, and thereby significantly mitigate the risk of pathogenic contamination being present in consumer food. While traditional solutions often require sending samples to a third-party lab and waiting days for results long after food product has left a food processing facility, our solution provides results on-site within 20-25 minutes, enabling food processors to make in-process corrective actions and ultimately protecting consumers. We represent one of many innovative food tech companies, several of whom we partner closely with, with breakthrough technology to deliver on the lofty ambitions of the FDA’s “New Era of Food Safety” initiative.    

While several market leading food companies have jumped at the opportunity to work with us, occasionally we have received positive feedback from others, but with the disappointing qualifier that they will not purchase our solutions unless regulators impose more stringent requirements upon them. Moreover, many of these same companies recognize food safety risks in their supply chains but believe that liability resulting from the powerful food safety data provided by our solutions, particularly if available to regulators and auditors, outweighs the risk of maintaining the status quo and the potential of being implicated in a food recall. In other words, otherwise good actors felt that they would be penalized for doing the right thing and proactively bolstering their food safety program.  

Amid sky-high concerns about COVID-19, consumers may ultimately be a greater driver for significant food safety reform and modernization than regulators. Already, consumers are becoming increasingly concerned about the safety of fresh products with greater likelihood of multiple human touchpoints. Moreover, consumers are demanding greater visibility into food chains and corresponding safety measures being taken, rewarding leaders and punishing laggards. According to an extensive global Nielsen study, “the product benefit consumers were most willing to pay premium for were those with high quality assurances and verifiable safety standards,” with 49% of consumers globally saying that “they were highly willing to trade up in price for this benefit.”

In response to the 2008 financial crisis, White House Chief of Staff Rahm Emmanuel famously stated, “A crisis is a terrible thing to waste.” To Emmanuel’s maxim, I would add the corollary, “Technology is a terrible thing to waste.” Groundbreaking technologies like ours and others have the potential to dramatically enhance the safety and security of our food system in good times and bad. However, this potential will only be realized if the food industry is incentivized and compelled to modernize by consumers and regulators, and to bring technology off the sidelines and into the fight. They should seize the opportunity to act now before it is too late. Our company and other innovative food tech companies stand ready.