Create a Sustainable Quality & Food Safety Program for Your Emerging Brand

Food and beverage companies are finding it increasingly challenging to manage the various requirements of an effective, yet flexible, Quality and Food Safety (Q&FS) approach.  

Our Q&FS experts, Rocelle and Rhonda, explain how internal and external factors influence both the coman and the client during the commercialization process. They’ll share strategies to implement a successful Q&FS program through a few key steps: assessing the coman’s current food safety program, developing a safety guide for expectations to protect your brand, and thoroughly implementing this plan at the coman facility.

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Why is it important to have an expert review your Q&FS plan?

From our team’s perspective, the need to review a coman’s Q&FS program boils down to a few key reasons, both externally and internally from the client and coman.  

Internally, we’re seeing a pattern of coman Q&FS teams being streamlined to boost efficiency and save on costs. But, with a smaller team comes a lack of resources and limited knowledge for program inspection to monitor and implement the latest regulations. Having a certificate of training, such as a PCQI, does not necessarily mean that the food safety team has the capability of developing a robust food safety plan.  

Rhonda explains, “Today’s teams are so pulled to the day-to-day activities that they’re not having the time to stay connected to technical organizations and regulatory landscape changes. Then before they know it, there’s a new regulation that needs to be implemented. But they haven’t had the chance to fully understand how it impacts them and how long the process could take.”

Externally, disruptions and volatility in the food and beverage space continues, from changes in coman networks, acquisitions of new or smaller brands, and personnel changes and absences. As a result, quality programs can become outdated and regulation changes can slip through the cracks.

In a smaller, emerging brand, Rocelle often sees each team member wearing multiple hats and not designating someone specifically to this necessary regulatory role. Or a regulatory team member may not have the bandwidth to consistently research the latest regulation changes or attend a food safety summit. Externally, your brand is most likely not the coman’s biggest client, limiting the influence you can have on facility and program changes.  

At the end of the day, Rhonda says, if there is a problem with the end product, “You are still the one who technically owns the brand, owns the food. While the supplier is going to have some level of responsibility, the accountability will fall on your company since your name is on the packaging.”

Assess the coman’s current food safety program

The first step to creating a compliant Q&FS program is to assess the current program at the manufacturing facility.  

Rocelle begins by reviewing their Food Safety Plan or HACCP plan and the written standard operating procedures. She asks herself a key question. Would the current program protect public health, ensure regulatory compliance, and increase confidence for a retailer, and ultimately, the consumer? A coman is accountable for operating under FSMA, but there could be additional requirements that your business needs to meet to be sold at a specific retailer. The coman and the client are encouraged to foster a stronger collaboration to ensure products are safe and retailer quality standards are met.  

Rhonda explains that your brand’s final Q&FS program will be a combination of acceptable risk, regulatory requirements, and customer requirements.  

Acceptable risk is the amount of risk your brand is willing to take on as they commercialize their product. Rhonda states that by working with a coman, “You are relying on someone else to have complete control of your brand integrity. By assessing their food safety program, you’re ensuring that they are mitigating as much risk as possible to protect your brand.”

Rhonda shared an experience earlier in her career, where she reviewed a beautifully written hazard analysis plan, every single step thoughtfully planned out. When she stepped out onto the floor, it did not reflect what she had just read. Discussing these differences with the plant team, she learned that this plan had every intention of being carried out, but the writer of the plan had left the company, and the team was left struggling to successfully execute and sustain these requirements while still meeting their shift quotas. This company ended up having to shut down for six months due to a product recall and the need to re-certify as a supplier.  

Develop (and approve!) your brand’s Q&FS guide

Once your Q&FS expert assesses the situation, they build Q&FS checks into your production process to ensure ingredient and product integrity. They can also conduct their own inspections and audits. These audits need to be embedded in the coman manufacturing agreement.  

Coman relationships are delicate. As an emerging brand, chances are that you need their help more than they need your business. While a Q&FS expert is here to help both sides become compliant, there may be some pushback.

Rocelle and Rhonda encourage open communication during these conversations, as it’s helpful to know what’s driving decisions on both sides. Your brand’s concerns will be different from your coman’s concerns due to different business goals. Your coman may be working with 40 other brands, and their attention is naturally skewed towards keeping bigger clients happy. They may have multiple requests from different clients to make changes, and can only cater to so many while still thinking of their own profits. To you, your brand is everything. No one will care as much about your brand integrity as you will. So internally, categorizing your proposed changes to “need to haves” and “nice to haves” will help guide your conversational tactics.  

Showing a coman that the proposed adjustments will not only benefit this project, but also similar projects, is key. “It really is so important to impart our knowledge to the team and arm them with information that they can use in future scenarios. Comans can be receptive if you help them understand the why.” Rocelle explains.  

Successfully execute your plan during production runs

Augmenting full-time plant personnel is critical to your program’s success, as they will be the ones addressing day-to-day issues to maintain the program’s standards. They must be equipped to handle issues effectively and efficiently.

Rhonda suggests starting with the QA manager, or whoever oversees the plant floor. “You need to teach someone technically competent on their staff first. They work with the team to ensure that knowledge gets correctly transferred and then applied to the floor.”

Be absolutely clear on what needs to happen. Draw diagrams if necessary. Rocelle worked with a company that implemented procedures to follow a “starburst pattern” when investigating a presumptive result in their environmental monitoring program. The remediation plan specified obtaining three consecutive negatives to consider the contamination resolved. When Rocelle asked them to describe their plan, “They cleaned the floor, literally drew a star on the floor, and took five swabs at the end of the points. They could easily show a negative result because the floor had been freshly cleaned off, but that would not direct the investigation to find the root cause.”

During the first production run, Q&FS experts can oversee the run and provide directions if necessary. JPG can also perform retain food reviews, comparing them to the client’s gold standard, or targeted attributes. Let us be your liaison and help you commercialize your products safely!