3

Food Safety

The second session of the symposium featured three presentations and a discussion on food safety developments and challenges from a regulatory perspective and a manufacturing perspective, and within the context of developing economies. The session was moderated by Sam R. Nugen, Cornell University.

REGULATORY PERSPECTIVE

Susan T. Mayne, former director of the Center for Food Safety and Applied Nutrition at the U.S. Food and Drug Administration (FDA), provided a regulatory perspective on food safety progress and considerations for the future.

Thirty Years of Progress on Food Safety

Over the past 30 years, Mayne said, data have enabled progress in shifting food safety from reactive to preventive efforts. She went on to describe microbial food safety, allergens in food, and chemical food safety as aspects of the food safety system.

Mayne explained that progress on microbial food safety includes the use of whole genome sequencing to detect and solve foodborne outbreaks and to identify root causes of pathogen contamination. For example, she said, this technology is used in food manufacturing facilities to determine whether a pathogen is resident or sporadic, a distinction that informs mitigation strategies. Sequenced pathogens have been sourced from food,

food facilities, and agricultural environments. Mayne noted that the GenomeTrakr Network hosts global data on pathogen sequences, and available data continue to grow exponentially (FDA, 2023). Established in 2013, she said, the GenomeTrakr Network had an average of 184 sequences added per month in the first year; in 2022, the average number of sequences added per month was 21,767. The database now holds more than 1.25 million pathogen sequences, with most the robust data for Salmonella, followed by Escherichia coli (E. coli)/Shigella and Listeria monocytogenes, Mayne reported.

Regarding progress on allergens in food, Mayne said that the Food Allergen and Labeling Consumer Protection Act of 2004 created the mandate that all food packages must contain labels listing priority allergens.¹ She stated that prior to that legislation, food manufacturers were not required to specify allergens on labels, so this constituted an important development for the food allergy community. Effective January 2023, the Food Allergen Safety, Treatment, Education, and Research Act of 2021 updated the list of priority allergens to include sesame.²

Outlining progress in food chemical safety, Mayne noted regulatory and industry efforts to reduce human exposure to chemicals of concern, including toxic elements, process-induced contaminants, and environmental contaminants. Regarding toxic elements, she noted that average daily lead intake in children aged 1–3 years has seen a dramatic decrease of 97 percent since 1980. Interventions to decrease lead exposure include removing lead from soldered cans, banning leaded gasoline, and implementing public health efforts, she said, and interventions to reduce exposure to process-induced contaminants include steps taken by the industry and FDA to reduce acrylamide, a chemical that can form in some foods when cooked at high temperatures. These efforts have resulted in a decline in mean acrylamide intake (FDA, n.d.), Mayne reported. Additionally, she continued, regulatory action targeting environmental contaminants such as dioxins, polychlorinated biphenyls, and certain per- and polyfluoroalkyl substances (PFAS) have led to substantial declines in exposure over recent decades. For example, National Health and Nutrition Examination Survey (NHANES) data indicate that blood levels of perfluorooctane sulfonate, a common PFAS, has decreased by more than 85 percent from 1999 to 2018 (ATSDR, 2024), Mayne said. She noted that other achievements in food safety include the development of hazard analysis critical control points

___________________

¹ Food Allergen and Labeling Consumer Protection Act of 2004, Public Law 108-282, Title II, 108th Cong., 2nd sess. (August 2, 2004).

² Food Allergy Safety, Treatment, Education, and Research Act of 2021, Public Law 117-11, 117th Cong., 1st sess. (April 23, 2021).

(HACCPs) and the focus on prevention generated by the FDA Food Safety Modernization Act (FSMA).³

Food Safety Considerations for the Future

Whole genome sequencing has the potential to expand more broadly, Mayne said, and FDA is working to develop the capacity to sequence viruses, such as hepatitis A and norovirus, and parasites, such as Cyclospora cayetanensis, that cause foodborne illness. She stated that global expansion of the GenomeTrakr Network—which currently contains data from laboratories in more than a dozen countries—is a priority, given the global nature of the U.S. food supply.

Mayne said that opportunities for progress in addressing allergens include determining allergen thresholds in foods with associated labeling to help food-allergic consumers; identifying new priority allergens and the criteria used to require priority allergen labeling; and facilitating international harmonization of priority allergens to address variance across countries.

In continuing to address the safety of chemicals in foods, Mayne stated that transparency is needed around domestic risk considerations, such as how FDA uses toxicity reviews and exposure evaluations to determine risk, especially given state legislation to ban particular food ingredients independent of FDA. Furthermore, Mayne noted, international variance in chemical risk determinations occurs when regulators in countries arrive at different conclusions on food chemical safety; this can engender confusion and lack of trust among consumers. Global harmonization on chemical risk determinations could help ameliorate consumer concerns. She added that a broader approach to consider chemical classes could avoid chemical “whack-a-mole,” a practice in which industry responds to a chemical safety concern by moving to a different chemical that may have less toxicity data available than the chemical being phased out. Expanding the safety concern approach by including similar chemicals within a class could deter manufacturers from this practice, she said.

Mayne emphasized that more research—and research funding—is needed on pathogen prevalence and mitigation strategies in several key areas, including fresh produce. As examples, she mentioned that in recent years, Cronobacter sakazakii was found in powdered infant formula and data on prevalence are limited; and E. coli was found in flour—although flour is not a ready-to-eat food, outbreaks associated with flour occur.

While the ability to trace products within the food system is currently improving, Mayne said, more work remains to improve food traceability,

___________________

³ FDA Food Safety Modernization Act, Public Law 111-353, 111th Cong., 2nd sess. (January 4, 2011).

supply chains, and recall effectiveness. An upcoming compliance date for the traceability rule has galvanized efforts in this area, yet not all foods are on the food traceability list. Broadly speaking, regulatory prioritization is needed to maximize impact, she suggested. Given the limited resources of regulatory agencies, Mayne continued, regulation should be driven by data mined effectively from a variety of sources, including artificial intelligence and machine learning. Global regulatory partnerships can increase efficient use of resources, and these partnerships can be based on comparability in food safety systems or based in comparability of food safety of selected commodities, such as the shrimp regulatory partnerships FDA is developing with certain countries. Mayne also called for additional surveillance and metrics efforts to ensure and assess progress in food safety. Because increased testing activities (of both cases and food) lead to greater detection of foodborne illness and more recalls, more aggressive food safety systems may reveal larger numbers of outbreaks and recalls. Thus, she explained, the quantity of outbreaks and recalls alone is not an accurate measure of food safety, so additional tools are needed.

Mayne underscored the need to anticipate and respond to challenges to food systems arising from climate change and global events such as the COVID-19 pandemic. During her recent 8-year tenure at FDA, extreme levels of flooding contaminated crops, which required FDA to determine whether these crops were safe to enter the human food supply. Pathogens such as Vibrio vulnificus that thrive in warm water are spreading to areas where they were not previously detected.

In addition to environmental challenges, Mayne said, innovation is changing the food landscape in areas such as cell-cultured foods, controlled environment agriculture, and food delivery models. She noted that regulatory efforts should support these innovations in food production and delivery while also ensuring safety. Moreover, she continued, consumer education needs to evolve in step with consumer food behaviors, address misinformation, and build knowledge and trust.

Mayne highlighted the relationship between nutrition and food safety with the example of Listeria monocytogenes, a pathogen for which 77 percent of food contamination in 2021 came from dairy products, vegetable row crops, and fruits. Given that U.S. dietary guidelines recommend these foods, safety measures are needed to support nutrition, she said. Mayne concluded by remarking that food safety progress (1) is enabled by partnerships between regulators, industry, academia, and consumers; (2) is fostered by data-driven technology that evolves over time; and (3) requires global partnerships for a safe global food supply.

MANUFACTURING PERSPECTIVE

Stefanie N. Evans, Conagra Brands, Inc., outlined advancements, challenges, and future directions of food safety from a manufacturing perspective. She noted that her career in food manufacturing began shortly after the E. coli outbreak within the Jack in the Box fast food chain in 1993, a landmark event that influenced her career choice. In the ensuing decades, she continued, substantial progress has been made through whole genome sequencing, bioinformatics, and source tracking.

Evans noted that the food industry uses modeling to examine how organisms behave in different types of environments, including food matrices, and continued advances in the modeling arena are possible. Furthermore, she said, data analytics have enabled decision making based on information and trends within food production facilities. Detection capabilities have progressed from basic traditional laboratory testing to innovative technology platforms based on DNA, she explained, thereby enabling much more rapid information, detection, and response to any contamination.

Evans remarked that knowledge of food safety issues has advanced over the past 30 years with the development of data on the prevalence of pathogens in various commodities, better understanding of how pathogens might travel through farming and facility environments, and the ability to map the movement of organisms. She highlighted the opportunity to further improve organism mapping. Advancement of mitigation techniques includes hurdle technologies that protect food and extend shelf life, Evans said, explaining that steps taken during processing increase food safety before packaging, and efforts in packaging environments inhibit the growth of potential hazards that could harm consumers. Technology in the food processing space has improved with more frequent use of high-pressure processing, which she said was formerly cost prohibitive for most manufacturers. Evans added that sous vide technology increases food safety. And, she said, alternative proteins have seen explosive growth over the past 10 years, with processing innovations driven by increased consumer interest in plant-based foods.

Current Food Safety Gaps and Challenges

A lack of investment in manufacturing and aging infrastructure—both in the United States and globally—slows the pace of applying food safety technology, Evans said. As an example, she said that scanning technology ensures that products match their packages and are thereby properly labeled; however, needed improvements in facility structures often supersede investment in scanning equipment.

Evans added that the adoption of food safety technology lags even in large companies. The food production workforce has become far more

culturally diverse and experiences high turnover rates and labor shortages, she explained; these shifts pose challenges in adequately training employees who may be unfamiliar with safe manufacturing processes and who speak a variety of languages. For example, she said, one Conagra Brands facility employs workers speaking 15 different languages and multiple dialects. Efforts to meet training challenges include the use of electronic tablets, videos, and photos, and pairing less-experienced employees with more seasoned workers.

Safe agricultural practices and produce safety are additional areas in need of improvement, Evans remarked. Complicated supply chains in the context of globalization and e-commerce pose challenges to traceability, she said, given that many smaller companies within supply chains underfund digital and information technology (IT). Evans added that a lack of research in specific emerging organisms and in new technologies slows progress in food safety. Moreover, a gap in consumer education has enabled a consumer base disconnected from food origins and processes.

Potential for Advances in Food Safety

Evans highlighted numerous food technologies undergoing rapid development: a variety of alternative proteins; 3D printing; vertical, urban, and greenhouse farming; and genetically modified organisms (GMOs). Although developing technologies offer potential benefits, they also raise the possibility of food safety risks and hazards in a new context. For example, she said, contamination can occur even within the closed system of greenhouse farming. Furthermore, consumer education is crucial to communicate accurate information about the science of new technologies, and Evans underscored that poor consumer education efforts have contributed to misunderstandings about GMOs. Smart factories are creating new possibilities within the food manufacturing industry by collecting and integrating real-time digital information via electronic tablets on plant floors, she reported. But she said the adoption of such technology applications is slowed by the need to address aging infrastructure, which often needs to be prioritized over modernization efforts. Continued innovation is imperative, Evans stated, in order to address issues including globalization, resource depletion, sustainability, packaging, recycling, water reuse, climate change, carbon offsetting, and healthier diets. She noted that approaches to reusing water and recycling packaging can pose a risk of concentrating the very contaminants the industry seeks to reduce or eliminate.

Evans emphasized that a focus on fundamentals is critical for the food manufacturing industry; nine out of ten of the regulatory violations included in FDA Current Good Food Manufacturing Practices pertain to basic manufacturing practices that increase worker and product safety.

Investment in infrastructure is needed to create sanitary food production environments, she said. Continued labor challenges are expected, Evans continued, requiring automation and technology to ensure delivery of safe food; the food industry can capitalize on the ongoing development of digital tools to improve mapping and source tracking capabilities, which drive food safety. Additionally, she stated, the industry should continue to focus and improve upon detection, mitigation, and processing. Evans noted that the exciting opportunities offered by rapidly developing technology should not overshadow an emphasis on the day-to-day fundamentals of food safety delivery and consumer education efforts. She concluded by quoting a motto from the Food and Agriculture Organization of the United Nations: “Food safety is everyone’s business.” Evans defined food safety as a collective aim that encompasses simple actions such as handwashing, complex scientific evaluation of chemical compounds and pathogen isolation, robust governance, and data and information sharing.

FOOD SAFETY IN DEVELOPING ECONOMIES

Haley F. Oliver, U.S. Agency for International Development (USAID) Feed the Future Innovation Lab for Food Safety at Purdue University, outlined the implications of foodborne illnesses and opportunities to increase food safety in developing economies. She underscored that despite the advent of a global food supply, many people in the world continue to eat locally sourced food, and food safety is a ubiquitous need. Despite tremendous efforts from the regulatory and product sectors, foodborne disease persists, affecting one out of six Americans annually, Oliver reported, adding that notable foodborne diseases include norovirus, salmonellosis, campylobacteriosis, and toxoplasmosis. Globally, foodborne disease accounts for 600 million cases of illness and 420,000 deaths each year, while estimates of the cost associated with tracked foodborne pathogens exceed $15 billion, Oliver noted. The USAID investment in the Feed the Future Innovation Lab for Food Safety facilitates work linking food safety with food security. Oliver explained that when food is not safe, it no longer affords the benefits of food, and thus safety is a key component of food security in addition to nutrition, supply, and access. Foodborne illnesses drive malnutrition, carry potentially lifelong negative health implications, and create an economic burden, she said; however, foodborne illnesses are preventable, and prevention efforts aimed at establishing food safety in developing economies can remove barriers to economic growth and achieve global impact.

Oliver then described how foodborne pathogens interface with nutrition to create a cycle of disease and malnutrition. Unsafe food can lead to foodborne disease, she said, causing diarrhea and vomiting, and malabsorption of nutrients gives rise to malnutrition, stunting, and increased

comorbidity. The dissemination of biological hazards into the environment compromises food safety, thus perpetuating the cycle, Oliver explained; therefore, disrupting this cycle improves nutrition.

Advancements in food safety in developing economies include aflatoxin prevention and awareness, as well as elevating understanding about chemical hazards, pesticides, and fertilizers as challenges to food safety, Oliver stated. She described a 2018 study conducted by the Global Food Safety Partnership that documents substantial investment in food safety programming in Africa focused on aflatoxins, pesticides, and fertilizers, she noted. However, she continued, the burden of foodborne disease remains linked to foodborne pathogens, indicating that better alignment between investment and health hazards may be beneficial. Oliver posited that the lack of investment in pathogen prevention in developing economies could be related to the difficulty in detecting bacteria, whereas mold on crops and the application of fertilizers and pesticides are readily observable.

Achieving Food Safety Goals in Developing Economies

Oliver summarized current challenges to achieving food safety goals within developing economies. Competing priorities—ranging from political concerns to climate issues to disease threats—impede the prioritization of food safety. Additionally, there are resource constraints within the United States as well as in global and developing economies. Confusion between safety and quality contributes to a lack of understanding that quality food can be unsafe, which in turn influences the effectiveness of policy. Gaps in infrastructure persist, particularly in the areas of inspection, cold chain, and testing laboratories. Education and personnel challenges create substantial barriers to food safety success. Regulatory structures differ between countries, as do the ramifications of foodborne illness, and these can affect the ability to meet food safety goals in developing economies.

Oliver explained how the Innovation Lab works to address these barriers through awareness, research, policy, and training. Awareness efforts focus on issues and effects of food safety and on measures to reduce food safety risks. Research investment targets include increasing local research capacity and conducting research on regional food safety challenges. New policy development and implementation of existing policies enable conditions for food safety research, translation, and practice. Training and education activities are designed to accelerate translational research technologies and practices.

Additional Considerations

Oliver noted a range of additional factors currently affecting food safety. The COVID-19 pandemic catalyzed increases in pathogen awareness, attention to food safety, consideration of labor hours, and investment in sanitation, she said. During the pandemic, Listeria prevalence in grocery stores decreased; however, Oliver reported, food safety behavior and practices have largely returned to the prepandemic status quo. Thus, human behavior and motivation are relevant research areas in determining how to increase food safety practices effectively, she said, adding that the pandemic also yielded insights into how food interfaces within hospital and long-term care systems. She suggested that diversity, equity, and inclusion aspects of food safety and security should be considered, to increase access to safe food. Cellular agriculture holds potential for addressing food security, but Oliver said that safety considerations of these foods should be analyzed before delivery into developing economies. She continued that the limitations of and improvements to disinfectants and sanitizers carry implications for the food industry, but prominent perspectives on disinfectants within developing economies may vary from those in the United States. For example, she said, acceptance of some of the most effective disinfectants, such as chlorine, is decreasing in some countries. She added that disease associated with low-moisture foods, such as infant formula and flour, requires greater research investment, particularly given the critical role of these food sources in food security.

DISCUSSION

The discussion following these presentations focused on infrastructure investment, multiple chemical exposures from food, regulation and innovation in food manufacturing, food safety and nutrition education in schools, maintaining food safety within a global supply chain, steps to address food allergens, and food traceability systems.

Investment in Infrastructure

Nugen noted the role of infrastructure in adoption of new technologies and asked about approaches to increasing investment in infrastructure within a context of low profit margins and consumer resistance to increased prices. Evans remarked that risk assessment is important in prioritizing investment in infrastructure according to associated risk. Mayne emphasized that old facilities and food manufacturing equipment pose significant challenges to sanitation and can create ongoing contamination issues, which in turn necessitate product disposal and recalls. Thus, she noted,

manufacturers should consider such routine losses in revenue when determining whether to invest in upgraded facilities and equipment. Oliver stated that the percentage of the population consuming locally sourced food in developing economies can be as high as 90 percent; therefore, the technology needs in these settings differ from those in countries eating imported foods. For this reason, she said, the Innovation Lab is not investing in technology development, but focusing instead on creating environments that enable adoption of existing technologies and fostering the willingness to do so.

Multiple Chemical Exposures from Food

Kate Clancy, food systems consultant, asked about existing research or regulation on multiple exposures to chemicals or toxic agents from food. Mayne explained that chemicals within the same class in terms of structure can vary in how they affect pathways, with some stimulating a biochemical pathway and others slowing down that pathway, and with many chemicals affecting multiple chemical pathways. This level of complexity in science and data presents challenges to assessing whether multiple chemical exposures have similar versus opposing effects, she said. To address this, Mayne continued, FDA is using data mining and available technology to modernize toxicity evaluation, which will include an expanded decision tree currently under development. Evans remarked that in addition to a lack of data on multiple exposures, misinformation about chemicals and associated health hazards is often promoted on social media. This misinformation can detract from efforts to manage substances such as heavy metals and PFAS that pose known health hazards, she said. Evans added that state-by-state regulations, such as California’s ban on some chemicals that are allowed in other states, complicate food manufacturing. Federal research and guidance could streamline approaches to chemical hazards. Oliver noted an opportunity for academia to address chemicals within food science and nutrition undergraduate programs.

Regulation and Innovation in Manufacturing

Barbara Schneeman, University of California, Davis, asked about the extent to which regulation facilitates and inhibits innovation in manufacturing; she asked specifically about regulations regarding infant formula notifications.⁴ Mayne emphasized the importance of dialogue between regulators and the manufacturers considering innovation. For example,

___________________

⁴ In 2022–2023, several U.S. companies initiated voluntary recalls of infant formula after detecting Cronobacter sakazakii in their products, leading to nationwide supply shortages.

she said, communication between industry and subject matter experts at FDA began early in the process of developing cell-cultured foods and included facility tours to demonstrate how these foods would be made. This type of discussion supports innovation while ensuring it can be achieved safely, Mayne stated. Regarding infant formula notifications, she continued, companies considering changes in manufacturing processes should consult with FDA—a significant change in the manufacturing of infant formula could affect a sole source of nutrition for many infants, and the regulatory perspective could benefit infant formula companies. Evans remarked on industry collaboration with FDA and the U.S. Department of Agriculture (USDA), particularly regarding FSMA regulations, noting that this collaboration declined during the COVID-19 pandemic. In developing systems for the adoption of new technologies, such as high-pressure processing, Evans said, Conagra Brands communicates with and provides data to FDA. She stated that rather than being an impediment to innovation, collaboration between industry and regulators establishes shared knowledge and facilitates the approval process. Oliver commented that manufacturers encounter additional costs in meeting increased regulatory requirements, and that greater investment in food—which is relatively inexpensive in the United States—may be necessary to improve safety within food systems.

Food Safety and Nutrition Education

Isabel Walls, USDA, asked about the promotion of food safety and nutrition education in schools. Mayne noted that FDA developed curricula about food safety, entitled “Science and Our Food Supply,” that middle and high school science teachers can adopt. She remarked that scientific literacy, a growing challenge in the United States, contributes to the spread of misinformation and lack of consumer trust. Given the abundance of conflicting information, she continued, many consumers determine that no information is trustworthy; therefore, decreasing science literacy undermines scientific efforts to improve food safety and public health. Evans emphasized the need for more safety education in schools and beyond, citing the Partnership for Food Safety Education’s efforts to educate adults via social media. She stated that the Food Forum could focus on the need for food safety education, particularly within the context of changing food procurement avenues, including farmers’ markets, community-supported agriculture, and e-commerce vendors that ship perishable food ingredients directly to consumers—a method that is vulnerable to temperature abuse. Mayne added that the Conference for Food Protection and FDA collaborated to create guidelines for food sold through e-commerce, but greater dissemination and awareness of these guidelines is needed. Oliver commented that the National Association of State Departments of Agriculture

is a potential mechanism for advocating for educational components to be added into state curricula. Teaching food safety behaviors to younger generations could result in change that lasts throughout their lifetime, she said.

Food Safety Within a Global Food Supply Chain

Ajay P. Malshe, Purdue University, asked about the role of supply chains in the food safety system, given that the supply chain has become global and that bacterial growth may occur in the interfaces in manufacturing and supply chain. Mayne described how FSMA has established standards that apply to food and ingredients imported from other countries, as well as to food that is entirely domestically manufactured. However, the tools and levers for achieving food safety vary, she said; for example, FSMA established the Foreign Supplier Verification Program (FSVP), which places the onus on importers to ensure that food safety mandates are met by suppliers. She highlighted a recent incident in which U.S. children became sick with lead poisoning after eating applesauce containing cinnamon imported from Ecuador. Under FSMA, the safety of all ingredients and the final product should have been ensured, preventing such incidents, but this mandate was not met, she said. A lack of preventive controls and good manufacturing practices can lead to unsafe ingredients, which Evans said underscores the importance of adhering to standards throughout the supply chain. She stated that education efforts are needed to help small and medium-sized companies understand what FSVP entails and how to build programs to ensure compliance. Evans said that outside of the large consumer packaging goods companies that were heavily involved with FSMA regulations, a thorough understanding of FSVP is lacking. She added that regulatory FSVP inspections are likely lacking at smaller companies. Conagra Brands created an international team that audits and inspects facilities in an effort to drive food safety while protecting global supply chains, Evans reported. Given the variance in worldwide food safety standards, she said, ensuring safety of imported ingredients is a complex process. Moreover, Evans pointed out, recent inflation in the cost of goods could contribute to a potential increase in food adulteration.

Addressing Food Allergens

Robert Earl, Food Allergy Research and Education, asked about the advancement of education, protections, and labeling for people with food allergies. By reducing the intentional addition of food allergens and facilitating the adoption of food allergen thresholds, Earl continued, the safe food supply for the food allergy population would increase. Mayne emphasized that the leading cause of food recall in the United States is undeclared

allergens, and mislabeled product constitutes an extensive problem requiring solutions. Consumers with food allergies have asked for allergen thresholds, Mayne said, because statements that a product may contain an allergen or was manufactured in a facility that also uses an allergen are vague for the purposes of informed decision making. Efforts to establish allergen thresholds are currently underway via the Codex Alimentarius international food standards, she explained. Should research reveal a de minimis level of an allergen that can be tolerated, along with appropriate food labeling, additional foods could become available to consumers with food allergies, Mayne stated. Evans remarked on the need for changes regarding allergens, as some companies opt to label products as potentially containing allergens rather than establishing procedures to control allergens. She explained that efficient removal of allergenic proteins from facilities is feasible; in fact, most manufacturing issues with allergens arise from products being incorrectly placed in packaging intended for other products. Technology could decrease mislabeling by ensuring that products and packaging are accurately matched, Mayne said; scanning technology is advancing quickly, having evolved from bar codes to two-dimensional matrices. However, she said, adoption of technology advancements is often impeded by the need to prioritize infrastructure investment. Oliver noted that she collaborates with people in developing economies who communicate that allergens are not a problem in their countries. A lack of awareness around allergens could translate into ingredient production and affect the global supply chain, she continued. Evans commented that equipment is often used for multiple types of agricultural commodities—for example, a truck may be used to transport both soy and wheat—posing allergen risks to supply chains. Thus, she said, establishing allergen thresholds would bolster supply chain risk assessment.

Food Traceability Systems

Naomi K. Fukagawa, USDA Beltsville Human Nutrition Research Center, asked about the status of blockchain food traceability. Evans replied that a lack of robust investment in data platforms throughout a supply chain poses challenges to adoption of blockchain food traceability systems. Even large companies that invest in IT platforms, such as Conagra Brands, face tracing challenges, she said; these challenges tend to increase for small suppliers, particularly those in low-income countries where records are often kept manually and on paper. Mayne noted that traceability is limited to the data available, highlighting a need for investment in data platforms; and she said that multiple technologies, including blockchain, can enable traceability. Food manufacturers often cite the cost of traceability as prohibitively high, which led FDA to sponsor a low- or no-cost traceability

challenge that invited developers to submit ideas for low-cost traceability systems, Mayne said. In approximately 2 years, she continued, FDA will require compliance in tracing certain foods on a food traceability list; it mandates traceability for foods that pose the highest food safety risks. However, she said, as companies establish systems to trace these foods, they are likely to extend these systems to the other foods they produce. Mayne cautioned that it will require substantial efforts to achieve the traceability needed to accurately track outbreaks to root causes throughout highly complex supply chains. Oliver added that a food system workforce with the requisite data science skills will be required to generate the data needed for traceability—a capacity that is currently limited.