A Comparison of the Approach to Sampling Among Nine State Food Safety Programs
Dr. Norman N. Arroyo-Llantin
Environmental Manager
Florida Department of Agriculture and Consumer Services
International Food Protection Training Institute (IFPTI)
2015 Fellow in Applied Science, Law, and Policy: Fellowship in Food Protection
Author Note
Dr. Norman N. Arroyo-Llantin, Environmental Manager, Florida Department of Agriculture and Consumer Services.
This research was conducted as part of the International Food Protection Training Institute’s Fellowship in Food Protection, Cohort V.
Correspondence concerning this article should be addressed to Dr. Norman N. Arroyo-Llantin, Florida Department of Agriculture and Consumer Services, 3125 Conner Blvd., Tallahassee, FL 32399.
Email: Norman.Arroyo-Llantin@freshfromflorida.com
Abstract
Telephone interviews were conducted with nine state food safety program managers to examine the methods used to plan for sampling and their working relationship with the state's laboratory. The interviews revealed that while food safety programs plan their sampling, different factors were used among the programs to plan for sampling. These differences in sampling practices were dependent on the structure and mandate of the state agencies regulating different types of foods; as a result, the study found no uniformity among the states regarding the factors. The study recommends that future research focus on the relationship between planning all aspects of a food sampling program and the use of resources and associated costs. The study also recommends additional research to measure the relationship between effectiveness in planning and operating a food sampling program and food safety risks.
Keywords: food laboratories, food inspection program, food safety, food sampling, ISO 17025:2005
Background
Food sampling by food safety programs can be used as a surveillance tool to identify contaminated products, remove them from the market, and protect public health (Pehrsson et al., 2000; Lo-Fo-Wong et al., 2004). Sampling of high-risk products, fresh produce, and finished products may vary from state to state and may be used for surveillance, as a factor for foodborne illness outbreak investigations, during inspections, for recalls, for examining local products, or for any other activity pertinent to food safety.
Sampling of food products can be costly (Patil, 2002), and is often limited based on funding, resources, and laboratory capacity. Due to the wide variety of food products, some federal inspection programs have established sampling plans based on data collected from their regulated food establishments (U. S. Department of Agriculture [USDA], 2010). Federal agencies have provided general sampling guidance, but may not reflect state food safety program needs (U. S. Food and Drug Administration [FDA], 2015). To support these efforts, the FDA has provided funding through the use of cooperative agreements to assist state food safety programs and laboratories in making infrastructure improvements necessary to build an integrated food safety system. Cooperative agreements include the Retail and Manufactured Program Standards and ISO (International Organization for Standardization) 17025:2005 accreditation for laboratories (FDA, 2015). ISO is an international accreditation organization that identifies requirements for testing, calibration, and sampling (ISO, 2010). ISO 17025:2005 is used by laboratories to achieve a national integrated food safety system by preparing food-testing laboratories for quality, administrative, and technical operations. As a result, state and federal programs are strengthening their sampling efforts by strategically planning sampling to protect public health (USDA, 2013).
Federal agencies provide guidance on sampling and analysis of food products, but the guidance is only based on a national initiative and may not be reflective of state sampling needs. There may be a lack of guidance on developing and implementing sampling programs that is reflective of the state needs. Planning in advance for sampling using pre-determined factors may enable food safety programs to make efficient use of resources, time, and program funding, and prevent contaminated product from reaching the end consumer.
Problem Statement
The factors used among food safety programs regarding planning for sampling of food products are unknown.
Research Questions
1. Do state food safety programs that conduct sampling take a uniform approach to plan sampling of food products?
2. Do food safety programs that conduct sampling use pre-determined factors to plan for sampling?
Methodology
Nine food safety managers or designees of manufactured and retail food programs were interviewed via telephone. Only state food safety programs with a laboratory component as part of their inspection program were selected. The lists of state programs were found by using directories of the Association of Food and Drug Officials (AFDO), the Manufactured Food Regulatory Program Standards Alliance (MFRPA), and the Association of Public Health Laboratories (APHL). The food safety programs surveyed were from the West (n=1), Midwest (n=3), Northeast (n=1), and the South (n=4). Seven questions were developed and used to collect data and to capture general information about their sampling program. Questions used during the interview gathered information regarding 1) the sampling program; 2) whether sampling was for surveillance or complaint-based; 3) the frequency of sampling; 4) whether the program was ISO 17025:2005 accredited; 5) whether there were written sampling procedures regarding what to sample; 6) whether there was planning between inspection and laboratory programs; and 7) the factors used to determine the approach to sampling. The study population included state departments of health (n=3), a state department of environmental conservation (n=1), and state departments of agriculture (n=5). Answers to the interview questions were documented and Excel was used to analyze the data.
Results
All of the state food safety programs had written sampling procedures that included collection methods, frequencies, and number of samples. The majority (78%) of these food safety programs worked with their laboratories to plan for sampling. The remaining respondents (22%) worked without consulting their laboratory, and sampling plans were developed solely within the inspection program. Furthermore, the majority (78%) of the programs collected surveillance and complaint-based samples that included samples of finished food products and samples related to confirmed foodborne illness investigations, respectively. The remaining respondents collected samples for surveillance purposes only of finished products at retail and manufactured food facilities.
ISO 17025:2005 accreditation of the laboratories had been achieved by only 56% of the programs, with the remaining programs indicating that they were seeking ISO 17025:2005 accreditation (see Table 1).
Table 2 shows the number of samples that states reported collecting in the past year. The samples from the four Southern states varied from 3.93 to 34.54 samples per 100,000 population. A state in the West collected 9.75 samples per 100,000; in the Midwest, 1.97 samples per 100,000 population were collected; and in the Northeast, 106.08 samples per 100,000 population were collected. Two states did not report this information.
Factors used for determining sampling differed among the surveyed food safety programs, and appeared to be dependent on the programs’ operations and needs (Table 3). Factors triggering sampling included food previously subject to recalls, high-risk foods, foods associated with foodborne illnesses, and local food products. The top factor reported was response to foodborne illness (n=4), while high-risk foods were mentioned by two of the respondents, along with recalls (n=2), seasonal sampling (n=1), and local trends (n=1).
Conclusions
The study found that food safety programs are planning in advance for sampling. Programs reported having written procedures for sampling, and the majority of programs (seven of nine) work with their laboratory to plan for their sampling. The remaining state food safety programs (n=2) planned sampling internally and did not integrate their laboratory in the planning process. Written procedures and collaboration with the laboratory appear beneficial to maximizing the use of resources, staff, and laboratory capacity. In addition, some of the laboratories are pursuing ISO 17025:2005 accreditation. The ISO 17025:2005 accreditation enables laboratories to have a system in place for uniformity and validation of their sample collection and analysis methods. The work toward accreditation indicates that laboratories are working proactively to standardize their processes, which will improve their ability to collaborate with other food safety programs and support the integrated food safety system.
The number of yearly samples collected was another area that differed among food safety programs, and may relate to differences in resources, staff, equipment, laboratory capacity, and geographical needs. These findings appear to indicate that food safety programs rely on specific factors within their state rather than food consumption, population, or geographical size. The most commonly-reported factor determining sampling was foodborne illness, as the majority of food safety programs conduct complaint-based and surveillance sampling, regardless of whether the programs are in departments of agriculture or health or not. In addition, the pattern of sampling is attributed in some jurisdictions to conducting manufactured and retail food inspections under the same agency. Furthermore, sampling practices are dependent on the structure or mandate of the state agencies, with some being centralized and others having multiple jurisdictions that regulate different types of foods.
High-risk products and recalls were the second highest sampling factor among the survey programs, which appears to indicate a common approach to plan for samplings.
Although the majority of the food safety programs are planning sampling in advance, factors for sampling appear to be dependent on regional regulatory needs, regardless of jurisdiction. This planning in advance appears to be an indication that state food safety programs are supporting an integrated food safety system. However, this research was not able to determine uniform factors used for planned sampling.
Recommendations
Future research should focus on whether planning all aspects of a food sampling program will affect the use of resources and associated costs.
Future research should also focus on measuring the effectiveness in planning and operating a food sampling program and its correlation with food safety risks. Measuring the effectiveness should be done by studying multi-year sampling surveillance data and comparing the data with current operating procedures.
Acknowledgments
I would like to thank my wife Denisse Declet for her unconditional love and support. In addition, I would like to thank my mentor Charlene Bruce for her willingness to help and her passion for food safety. My gratitude goes to Matt Colson, Environmental Administrator, Brenda Morris, Bureau Chief, and Dr. Tiffiani Miller, Director of Food Safety for their recommendation and support for this program. A special thank you to Dr. Paul Dezendorf, Dave Read, and Dr. Chris Weiss for the editing of the paper and for their recommendations. Finally, I would like to thank the IFPTI staff for their support and dedication to food protection. A thank you to all of those who participated and were able to share information about their state program; without them this research would not have been possible.
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