Best Practices for Managing a Direct to Consumers (DTC) Delivery Food Safety Program

Responsibilities for implementing food-safety control:

To promote the implementation of food safety controls, a DTC company should assess its business model and supply chain, including partnerships and agreements with other parties. The parties involved at each stage of the production and distribution chain should?collaborate closely, and companies should also consider defining food safety responsibilities in formal agreements between parties. Clear procedures for communication between the DTC company and its partners will be helpful for sharing compliance information, food safety concerns, and relevant operational changes in a timely manner.

Examples of expectations that can be reflected in agreements include:

• Responsibility for conducting validation and/or verification
• Managing non-conformances, including communication and escalation requirements
• Conducting training
• Complying with applicable food safety laws/regulations
• Implementing various food safety measures (e.g., meeting time/temperature limits, preventing contamination)
• Implementing employee health policies
• Emergency protocols or contingency plans
• Personnel standards (e.g., selection criteria, health and hygiene requirements, background checks)

Monitoring:

As discussed in Section 4.B, a DTC delivery company should validate the measures necessary to control any food safety risks arising in the company’s operations. The company should then conduct verification activities to demonstrate whether the validated measures are being

effectively implemented.

As a critical component of a food safety program, a comprehensive monitoring system helps verify food safety policies and systems are being applied in a consistent and sustainable manner and identify continuous improvements or corrective actions.

In designing its monitoring approach, a DTC delivery company should consider the following:

• Which validated food safety measures should be monitored
• Where monitoring will occur, whether in production, transportation, and/or upon delivery
• How monitoring will be conducted for each food safety measure
• How the monitoring system will be described and communicated (e.g., in written policies and procedures)
• How often each monitoring tactic will be implemented
• Who will be responsible for conducting monitoring
• How deviations will be addressed
• How monitoring results will be recorded (e.g., including the signature of the person completing the monitoring)
• What consumer inquiries and complaints have been received

Developing a Monitoring Approach

A monitoring system should be based on the validated measures a DTC delivery company has identified are needed to control its food safety risks. A company should evaluate each validated risk-control measure to determine the best approach for monitoring, considering the type of

data to be gathered, how the data will be used, how frequently the control measure should be evaluated, who should gather and/or interpret data, which key performance indicators should be used, and how monitoring results should be reported.

There are multiple tools which DTC delivery companies can consider incorporating into a monitoring system. Examples include:

• Process Self-assessments. Regular internal assessments can help a company’s personnel to proactively address food safety risks and prepare for external audits and regulatory inspections. These assessments can include daily checklists, shift-based logs, internal reviews, and third-party audits. The type and frequency of such assessments should be appropriate for the complexity of the company’s operations and products.
• Process Audits. A process audit is a formal inspection usually conducted by a third party. A DTC company can partner with a food safety auditing firm to design and implement an audit to determine if food safety risks are being controlled throughout the supply chain and delivery.
• Inspection upon delivery. A DTC company can employ its own personnel or third parties to confirm whether delivery parameters are met. For example, a company may consider assigning an individual or group (e.g., company employees or third-party “mystery shoppers”) to replicate the consumer experience and provide feedback on the delivered product. This person or group can examine parameters such as product labeling, temperature controls, transportation times, package integrity, and the effectiveness of packaging in preventing cross-contamination.

Using Internal and External Resources:

A DTC delivery company should consider the complexity and risks associated with its operations when using internal and/or external resources for monitoring its food safety system. Depending on the scope of the business, both options may be useful, and a DTC company

should weigh the benefits of employing these resources when making decisions based on their program needs. Regardless of whether they are employees or third parties, all personnel selected should have the expertise and proper training necessary to correctly and consistently

carry out their assigned tasks.

Technical Tools:

A variety of monitoring tools are available to help DTC delivery companies monitor compliance. Companies should identify the most current technologies available to aid with capturing and maintaining data. Companies may choose to use equipment, such as temperature

monitoring devices for food products, hot and cold holding equipment, refrigerated compartments, insulated carriers, and other packages; geo-tracking devices, cameras, video recording devices, web platforms/portals, and other technological solutions.

Companies should ensure measurement methodology is precise and the correct tools are being used for both food products and equipment. For example, probe thermometers should be used to measure internal product temperatures, and appropriate equipment thermometers should be used to measure ambient temperatures of refrigeration and hot holding equipment. Waterproof thermometers are also available for dishwashing machines. Temperature indicators can also be used for packages during transport and delivery. For accuracy, thermometers should also be regularly calibrated, either daily or per the manufacturer’s directions.

Companies should consider systematic approaches to assist with compiling data. Software programs can be custom designed to include a variety of hierarchies and data fields, such as menu items, delivery types, delivery times, product and equipment temperature readings, and

regulatory checklists. Food safety experts and analysts can use the data to gain insights, evaluate root causes, determine if corrective action plans are effective, or make program adjustments as necessary.

Managing noncompliance and continuous improvement:

Once a system is in place to monitor the key components of a food safety program, companies should establish processes to address noncompliance and improve risk management. These processes should include expectations for communicating non-conformances and performance metrics (e.g., temperatures at various critical control points). For example, including an escalation process to relay non-conformances to the appropriate individuals and departments can help ensure issues are addressed promptly. Companies should ensure qualified individuals have the authority to take corrective actions.

As part of its efforts towards continuous improvement, a DTC company should also continually research the most current food safety innovations and technologies in the manufacturing and retail food industry. Remaining up-to-date on industry trends can assist an organization in having awareness of the best available food safety tools can help it be more efficient, more quickly respond to alerts, take corrective actions, and adjust food safety procedures.

Traceability and recalls:

In the case of a foodborne outbreak or recall, DTC companies should have processes that allow public health officials to request relevant traceback and trace forward information that would aid in their investigation. This information should be shared in accordance with relevant privacy laws.

Corrective and Preventive Action Plans:

Incorporating corrective and preventive action plans into food safety monitoring is essential for controlling food safety risks and preventing repeat occurrences. Corrective and preventive action plans are applicable regardless of whether internal and/or external personnel are

involved in monitoring. The action steps and urgency assigned should be appropriate to the level of risk.

When SOPs are developed, a DTC company should identify 1) corrective actions for the disposition of the affected items and 2) separate preventive actions, tailored to potential root causes, to ensure the problem does not recur. For example, a company may determine a

perishable food must remain at 41°F or below but finds an instance in which the food exceeds this temperature for several hours due to equipment failure. The company may decide the corrective action is to discard the food, and the preventive action is to install monitoring and

alert sensors for refrigerated delivery equipment. An alert is used to notify appropriate parties when the air temperature exceeds 41oF for a designated period. The organization is then able to eliminate a food safety risk to the consumer and prevent product loss.

When developing corrective and preventive control plans, companies should consider the following:

• Engaging stakeholders (e.g., representatives from food manufacturer/food establishment, product delivery/transportation company, or external auditing firm)
• Establishing requirements for communicating non-conformances, including timing protocols based on potential risk
• Determining what parties must be notified and level of escalation based on risk
• Identifying who is responsible for implementing the plan
• Monitoring corrective and preventive actions to ensure they are effectively implemented
• Incorporating root cause analyses to assist with corrective actions and adjustment of protocols as needed
• Conducting targeted training for personnel to identify and correct errors in the food safety management program
• Using accountability models (e.g., number of higher risk occurrences triggering escalation)
• Reassessing studies or procedures to determine if improvements are needed to resolve operational or behavior-related occurrences (may be part of recurring re-validation activities)