“I am confident in the safety of the food I eat.” Five years ago, only one-third of U.S. consumers strongly agreed with this statement. While they held the government primarily responsible for food safety, followed by food companies and farmers, when it came to trusting them, farmers were third, federal regulators were eighth, and food companies were eleventh. And we in food safety wonder why consumers don’t always adhere to good food safety practices or follow label instructions. How can food safety experts from government, industry and academia communicate with consumers in a meaningful way? How can we convey that just because something can happen, the likelihood that it will happen varies? And how can we convince consumers to take steps to reduce their risk of foodborne illness?

The 2023 virtual Food Safety Forum, organized by the American Frozen Food Institute (AFFI), will address these questions and more. Taking place Sept.13 and free to attend, the Food Safety Forum is taking a deep dive into the state of risk communications. Science is complicated. Consumers want simple, unambiguous answers, and misinformation is abundant. Effective communication is hard and communicating public health risk — the likelihood that one will get sick, not to be confused with hazards — is an ongoing challenge. 

Like it or not, food safety professionals are risk communicators. Family and friends often ask for my opinion when they see alarming headlines about the safety of our food supply. On a broad scale, scientists are seldom viewed as great communicators and most of us are not trained that way. But facts and data don’t speak for themselves. Most consumers prefer a “tell me what to do” approach rather than delve into the complexities of contamination rates and dose responses. AFFI’s Food Safety Forum is bringing together the right group of experts from diverse backgrounds to address these topics with the goal of communicating in a way that improves public health. 

Perhaps the most notable component of the Food Safety Forum is the breadth of stakeholders from industry, government, academia and consumer groups, that all see the need for better communication of food safety risks. Many of these groups, historically viewed as adversaries, have common goals: we all want safe food and for consumers to view and act on food safety risks appropriately. The collaboration and diversity of partners for this year’s Food Safety Forum are unprecedented.

The event will kick off with the well-known Don Schaffner of Rutgers University discussing the “Current Reality of Risk Communication.” As co-host of the “Risky or Not” podcast, Don is perfectly positioned to talk about risk as distinct from hazards in a food safety context and how to explain these concepts to consumers.

No discussion of food safety communication would be complete without addressing the elephant in the room: lawyers. Whether it’s communicating about a serious outbreak, a recall that warrants immediate action or safe food handling practices, regulators are often criticized for being too slow, too fast and rash, too simplistic or too complicated. Elizabeth Fawell, an attorney with the Hogan Lovells law firm, will moderate a discussion with experts who know first-hand the challenges public health officials face when trying to clear food safety communications internally. Joining to share learnings from their experiences are Brian Ronholm with Consumer Reports, former deputy undersecretary for food safety with the U.S. Department of Agriculture’s Food Safety and Inspection Service (USDA FSIS), Roberta Wagner with the International Dairy Foods Association who formerly worked with the U.S. Food and Drug Administration and FSIS, and Frank Yiannas, former deputy commissioner at the FDA. 

Consumers are the ultimate target of food safety communications. When it comes to educating and empowering people to make informed decisions about food safety risks, the rubber meets the road for the scientific community. Who is better to address the consumer view than Mitzi Baum of STOP Foodborne Illness, who represents families of consumers impacted by foodborne illness? Joining Baum are Kristine Butler with FDA’s communications and public engagement team, Ben Chapman with North Carolina State University (and the other half of the “Risky or Not” podcast), and communications representatives from food retail and national food brands. Together, these communicators will speak to their mechanisms to earn trust and gain attention.

Finally, the Food Safety Forum will look to the future. How can risk communicators learn from previous missteps? How can we break through the noise? How can we narrow the gap between mitigating food safety hazards and communicating public health risks? Representatives from the Association of Food and Drug Officials, Consumer Reports, the Centers for Disease Control and Prevention and the food industry will discuss the lessons learned and what it means for the future of communicating food safety to consumers.

Moving the needle on consumer behavior is a lofty undertaking and discussion is needed on how to identify effective communication mechanisms and overcome barriers to meaningful communications. The collaborators convened by AFFI come from different perspectives but are united by their commitment to not only improve food safety, but to also improve consumer understanding of complex food safety topics so they can best protect their health. This topic is not going away. Attend this free event on Sept. 13 to learn more about current challenges and approaches for the future. Register now at www.affi.org/food-safety-forum.

About the author: Jennifer McEntire, Ph.D., is the Founder of Food Safety Strategy LLC. With 20 years of food and beverage association experience, she combines her technical background and regulatory insights to help the food industry assess and manage food safety risks in order to protect public health. McEntire earned a B.S. in food science from the University of Delaware and Ph.D. from Rutgers University as a USDA National Needs Fellow in food safety.

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By Donna Garren, executive vice president of science and policy, and Sanjay Gummalla, senior vice president of scientific affairs, both of the American Frozen Food Institute

America’s food industry deserves a scientific and risk-based regulatory framework from the U.S. Food & Drug Administration. That’s why the American Frozen Food Institute (AFFI), which represents frozen food and beverage makers and ingredient suppliers, calls upon FDA to turn to our neighbors to the north as the agency reviews its existing Compliance Policy Guide (CPG) regarding the presence of Listeria monocytogenes in food products. Health Canada, the department of the government of Canada responsible for national health policy, released its updated policy for Listeria monocytogenes in ready-to-eat (RTE) foods recently. The new policy recognizes and clearly delineates a risk-based approach that reflects current science and sets an important precedent as the U.S. FDA responds to calls for substantive regulatory, structural and cultural reform. 

Reiterating Globally Recognized Risk Principles 
Health Canada’s policy applies the globally accepted categorization of RTE foods based on their potential to support the growth of Listeria monocytogenes. Consequently, the policy separates RTE foods that support growth of the pathogen from those in which the growth is limited to levels not exceeding 100 CFU/g or in which growth will not occur throughout the food’s stated shelf-life (i.e., low risk). This approach is similar to the Codex Alimentarius Commission, Food Standards Australia and New Zealand, and the Commission of European Communities policies addressing Lm in RTE foods.  

Canada’s Listeria monocytogenes policy also clearly defines RTE foods as those that are normally eaten in the same condition as they are purchased. It also identifies foods that are excluded from the policy. This clarity is significant as it describes the foods subject to this policy, effectively allowing food and beverage processors to direct and apply the right resources and effort where risk is the highest. For example, RTE foods subject to the Listeria monocytogenes policy often require refrigeration (that is, labelled “Keep Refrigerated” on the package) or freezing (that is, labelled “Keep Frozen” on the package) for their preservation until the time of consumption. RTE products may include raw fresh-cut produce items that have been pre-peeled or cut and are intended to be consumed in the same condition in which they are purchased. Frozen fruits that are labeled “Keep Frozen” are also considered as RTE foods. As frozen foods do not support growth, the policy stipulates a less than 100 CFU/g level of Listeria monocytogenes in these foods. On the other hand, frozen vegetables that include validated cooking instructions on packaging for consumers to follow and ensure safe consumption would be treated as not-ready-to-eat (NRTE) foods. These would not be subject to the Listeria monocytogenes policy. 

Under this policy, Health Canada manages the public health implications of the presence of Listeria monocytogenes, through shared responsibility between industry (food processors, importers, exporters), government, consumers and care providers in ensuring safe food production and consumption as well as reducing the prevalence of Listeria monocytogenes in foods and the incidence of foodborne listeriosis. Health Canada’s policy underscores the relevance of Listeria monocytogenes in foods that are specifically produced for vulnerable populations, which have an increased susceptibility to listeriosis infection. At the same time, Health Canada recognizes that “in all likelihood, Canadians consume foods that may contain low levels of Listeria monocytogenes on a regular basis,” but “the incidence of listeriosis remains relatively low.” The risk-based policy approach and its implementation relies on process review, environmental sampling and end-product testing.

A Listeria Approach Grounded in Science
AFFI has been at the forefront of promoting research to better understand the management of Listeria monocytogeney in food processing and related public health implications. Health Canada’s latest policy is consistent with the scientific consensus across the global research community and in particular the recommendations of AFFI’s 2020 Listeria Global Expert Panel that brought together scientists from Cornell University, University of Georgia, Rutgers University, Wageningen University, University of Guelph, University of Vermont and University of Minnesota. Their work provided renewed scientific thinking on addressing risks associated with the prevalence of Lm in the food supply and identified that applying a risk-based regulatory approach provides the greatest public health benefit. Their research, published in the scientific journal Food Control, determined the relevance of providing a distinction between foods that support the growth of Listeria monocytogenes and foods that do not support growth (low-risk foods). As Dr. Jeffrey Farber, former director of microbial food safety at Health Canada and a facilitator for the expert panel stated, such an approach provides a practical regulatory and industry framework to prevent and control Listeria monocytogenes in foods that do not support growth of the pathogen, particularly in the context of the broader food supply chain, while also potentially reducing incidences of listeriosis associated with low-risk foods. 

Additional research at the University of Minnesota, published in the International Journal of Food Microbiology in 2022, demonstrates progress on reducing Listeria monocytogenes prevalence in our foods and in reducing listeriosis incidence in the recent five years. Co-author Dr. Craig Hedberg, professor in the School of Public Health with the University of Minnesota, indicated that given the current science on Listeria monocytogenes prevalence and exposure from foods, a regulatory tolerance for the pathogen in low-risk foods would be more protective of public health due to the operational benefits it offers industry in controlling the persistence of Listeria monocytogenes in production facilities. 

Implications for FDA Policy
The U.S. FDA  plans to update this year a 2008 Compliance Policy Guide on Listeria monocytogenes, “Listeria monocytogenes in Human Food; Draft Guidance for FDA Staff.” AFFI and a range of food industry stakeholders (including the International Dairy Foods Association, National Fisheries Institute, American Bakers Association, Consumer Brands Association and FMI – The Food Industry Association) have long called for FDA to produce a risk-based regulatory approach for an action level of Listeria monocytogenes in a manner consistent with Health Canada’s latest policy update. The default alternative, a zero-tolerance approach across all food categories, irrespective of public health risk, would ignore the latest available science and fail to pursue a risk-based food safety approach as mandated by Congress in the Food Safety Modernization Act. Congress has been vocal in encouraging FDA to incorporate the latest science and has included language in the last four Agriculture Appropriations reports which asked the agency to pursue a modern, prevention-focused and risk-based approach to regulating Listeria monocytogenes. The FDA has yet to take action on these requests. 

In 2022, an independent review of the U.S. FDA conducted by the Reagan-Udall Foundation identified challenges with the structure, leadership, culture, transparency and accountability within the agency’s foods program. If FDA leadership seeks to make a good-faith effort for substantive reform and support of public health, it is essential to listen to feedback from stakeholders and the scientific community regarding the benefits of a Listeria monocytogenes regulatory action level greater than zero for low-risk foods. The science and data indicate that FDA guidance and policy founded on a risk-based approach to regulating Lm will better drive positive public health outcomes. This is an opportunity for FDA to lead a science-based and risk-based approach to update its much-needed U.S. Listeria monocytogenes policy and harmonize with Canada and other global public health agencies.

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By Robert E. Brackett

The American Frozen Food Institute (AFFI), together with the International Dairy Foods Association (IDFA); FMI – The Food Industry Association (FMI); Produce Marketing Association (PMA); and National Fisheries Institute (NFI) recently hosted a Food Safety Forum aimed at critically looking at the current regulatory policies for Listeria monocytogenes (Lm) and exploring new ways of addressing the Lm issue that would result in reductions in cases and outbreaks of listeriosis. If you missed the forum, you missed a great discussion. For those of you who were not able to join us, I thought I would share some observations and thoughts.

The forum was prompted by the increased number of recalls of ready-to-eat (RTE) foods due to the presence of Lm, owing to the current “zero tolerance” policy by the U.S. Food and Drug Administration (FDA) and U.S. Department of Agriculture’s Food Safety Inspection Service. AFFI, IDFA, FMI, PMA and NFI definitely accomplished their goal of providing an in-depth discussion of the existing science surrounding Lm, as well as implications for regulatory policy. This program attracted over 700 registrants from multiple countries, some of which currently have regulatory limits on Lm in place.

Overall, the program was well thought out and covered most of the pertinent issues surrounding both the current policy as well as new ideas on ways to deal with Lm.  After a brief welcome and introduction by AFFI President and CEO Alison Bodor, FDA Deputy Commissioner for Food Policy and Response, Frank Yiannas, and USDA Deputy Undersecretary for Food Safety, Sandra Eskin, provided their perspectives on Lm and set a positive tone for the presentations and roundtables that followed.  

In addition to the two keynote presentations mentioned above, the organizers broke the forum into three broad areas of discussion:  

1. The scientific foundation of why Lm is such a challenging public health issue
2. Discussions from industry and academic experts on how we can translate the science into actionable practice
3. Observations from industry representatives on how the current policy is impacting their business and how a risk-based system could work with their products

Each of the well-known Listeria experts presenting in the first discussion addressed different aspects of Lm in the food supply. Dr. Martin Wiedmann focused his presentation on the important distinction between hazard-based vs. a risk-based approach to public health policy. The practical implications of these two philosophies are represented by a “zero tolerance” to the presence of any viable Lm in the first case, as opposed to an acceptable regulatory limit in the case of risk-based approach. Dr. Wiedmann convincingly argued that risk-based strategies to control foodborne illness are more likely to lead to positive public health outcomes. In one case, he was able to show that implementation of a performance standard could result in half the risk provided by the current FDA regulatory policy of zero viable Lm in 25 grams of food.  Based on questions from attendees, this caught peoples’ attention. 

Well-known food microbiologist, Dr. Jeff Farber spoke next on the science panel.  Dr. Farber gave a very comprehensive discussion on Listeria biology, infectivity, and profiles of some listeriosis outbreaks associated with what most people would consider low risk foods, such as ice cream and frozen vegetables. Dr. Farber made the point that if we are to make progress in reducing cases and outbreaks of listeriosis, we must be more aggressive at seeking out Lm and its harborages. To that end, Dr. Farber introduced a novel three-class sampling scheme that, together with a regulatory limit of 100 cfu/g, would better catch both frequent low level contamination events as well as occasional high-level contamination, thereby reducing risk to consumers. Moreover, implementing such novel sampling schemes would also reduce the need for recalls of low-risk foods.

Noted epidemiologist Dr. Craig Hedberg provided modeling data to also support the notion that a risk-based system encourages more aggressively looking for Lm in the food production area and would lead to fewer cases of listeriosis.

The second panel was comprised of noted academic and industry food safety leaders who discussed how the science presented in the first panel could be put into practice. Each gave examples from their own experience on the limitations of the existing policies and contrasted how Listeria management in the U.S. differed from that of the international community, specifically the European Union and Canada, and how Listeria policy could be harmonized such that it did not adversely impact trade and public health. Dr. Sanjay Gummalla also summarized the effort put forth by AFFI to organize AFFI’s Lm Expert Panel, and how this group was used to initiate science-based discussions with regulators.

The final panel discussed how the Listeria issue is being addressed in different sectors of the food industry and how a move toward a risk-based policy could or would change their efforts. Panel members represented the dairy, seafood, fresh produce, frozen, and the retail sector. This panel enjoyed a robust discussion on how moving to a risk-based policy would strengthen their Listeria control efforts, particularly when they could track down Lm without fear of regulatory action against them. One particularly bold audience member asked the group if they would be willing to participate in a pilot program hosted by AFFI. All agreed that it was worth the effort if it could move Listeria control forward and reduce listeriosis cases.

As I mentioned in my introduction, if you missed the forum, you missed a lot. The discussions that resulted from this program were among the most candid and compelling than I have seen in years. However, you have the opportunity to see the Forum for yourself. You can watch the four session recordings from AFFI’s Food Safety Forum by clicking here. Regardless of which side of the “zero tolerance” issue you are on, it is clear that what we have been doing is not leading to a reduction in listeriosis cases. Perhaps it’s time for the food industry and regulators to be bold and try something new. Hopefully, this forum will be viewed by regulators and the food industry as a start, rather than a conclusion.

About the author: Robert E. Brackett, PhD, is a former FDA Director of Center for Food Safety and Applied Nutrition. He has over 35 years of experience in food safety research, training, and policy.  Brackett worked in academia, government, and industry including Illinois Institute of Technology’s Institute for Food Safety and Health, the Washington D.C. based Grocery Manufacturers Association, the U.S. Food and Drug Administration’s Center for Food Safety and Applied Nutrition (FDA CFSAN), and several other positions. Brackett is a member and Fellow in the International Association for Food Protection, the Institute of Food Technologists, and the American Academy of Microbiology.  He is also a member of the American Society for Microbiology, Association of Food and Drug Officials, AOAC, and the Food and Drug Law Institute. He has been honored with the FDA Award of Merit, the FDA Distinguished Alumni Award, the Department of Health and Human Services Secretary’s Award for Distinguished Service, the International Association for Food Protection’s President’s Appreciation Award, and, the William C. Frazier Food Microbiology Award. Brackett received his doctorate in food microbiology from the University of Wisconsin-Madison.