Introduction: A preventive mindset in the Food Supply Chain

Food safety does not begin when production starts. It begins before a raw material enters the facility.

Food can be affected by biological, chemical, or physical hazards, and controlling these hazards requires more than testing the finished product. A preventive food safety system considers the entire process, including suppliers, receiving, storage, processing, personnel, sanitation, documentation, and distribution.

The FDA’s food safety framework emphasizes preventive controls, employee training, sanitation, receiving and storage practices, and traceability as important components of food safety systems.

This is particularly important because a food manufacturer is part of a larger supply chain. A company must understand not only what happens inside its own facility, but also how raw materials are sourced, received, evaluated, stored, and incorporated into production.

(The FDA Food Traceability Rule establishes additional traceability recordkeeping requirements for certain foods. In 2026, Congress directed the FDA not to enforce the rule before 20 July 2028.)

Food safety should therefore be viewed as a continuous chain of preventive controls rather than as a single inspection or laboratory test.

1. Food Safety begins with the supply chain

How well controlled was the process that created this product?

Supplier selection is an important part of that process.

A company may establish supplier approval criteria based on factors such as product specifications, supplier history, food safety practices, documentation, audits, certifications, and other verification activities appropriate to the material and its associated risks.

For certain hazards, FDA’s preventive-control framework specifically recognizes supplier verification activities such as onsite audits, sampling and testing, and review of supplier food safety records.

Certifications can provide additional information about a supplier’s food safety management system. Programs recognized by GFSI include FSSC 22000, BRCGS, SQF and other certification programs.

However, certification should not be treated as an absolute guarantee that a supplier will never experience a food safety problem. Supplier management should remain an ongoing process involving clear specifications, communication, verification, and performance monitoring.

2. Receiving raw materials: the first line of defense

Receiving is one of the first opportunities for a food manufacturer to identify problems before materials enter production.

A practical receiving process may include:

Vehicle arrival → Inspection → Documentation review → Sampling → Evaluation/testing → Identification and segregation → Release or rejection → Production

Depending on the material and its risk profile, receiving controls may include:

• supplier identification;
• lot identification;
• documentation and specifications;
• condition of the vehicle;
• transportation conditions;
• packaging integrity;
• temperature, when applicable;
• signs of damage, deterioration, or contamination;
• supplier analytical documentation;
• sampling and testing according to established procedures.

The exact controls should be appropriate to the product, process, hazard, and specifications established by the company.

Supplier documentation does not necessarily eliminate the need for verification by the receiving facility. FDA’s preventive-control framework recognizes supplier verification as part of controlling certain hazards before or at receipt.

3. From receiving to release: the role of Quality Control

A material arriving at a facility is not necessarily the same thing as a material approved for production.

Depending on the company’s food safety and quality system, materials may be identified and segregated while required evaluations are completed.

This separation can help prevent the accidental use of materials before the appropriate disposition decision has been made.

Quality-control activities may include sensory evaluation and, when appropriate, physical, chemical, or microbiological testing.

Examples of product-dependent measurements may include:

• pH;
• acidity;
• moisture;
• water activity;
• viscosity;
• appearance;
• color;
• odor;
• other product-specific characteristics.

The purpose of these evaluations is not simply to “test food,” but to determine whether the material meets established specifications and to provide information that can support quality and food safety decisions.

The results should be documented together with relevant information such as:

• date;
• time;
• lot number;
• person performing the evaluation;
• results;
• observations;
• disposition decision.

4. Documentation: if it is not recorded, it becomes harder to investigate

One of the most underestimated components of food safety is documentation.

A strong recordkeeping system can help a company reconstruct what happened during a particular production event.

Important information may include:

Who?
Who performed the activity?

When?
What date and time did it occur?

What?
What material, process, or activity was involved?

Which lot?
Which raw material or finished-product lot was affected?

What was the result?

What decision was made?

Who approved it?

The FDA’s traceability framework similarly emphasizes linking information to specific events and lots for foods covered by the Food Traceability Rule.

Documentation is therefore more than administrative paperwork.

It is part of the company’s ability to understand, investigate, and respond to a food safety event.

5. People are part of the food safety system

A food safety system can fail even when the written procedures are technically sound.

Employees must understand not only what they are supposed to do, but also why the procedure matters.

Good manufacturing practices and food safety programs rely on appropriate employee hygiene, sanitation practices, training, and supervision. FDA guidance emphasizes documented training in areas such as personal hygiene, GMPs, cleaning and sanitation, and employees’ roles in food safety programs.

Training should not be treated as a one-time event.

It can include:

• onboarding training;
• periodic refresher training;
• reinforcement of procedures;
• supervision;
• communication of process changes;
• additional training following identified deficiencies.

Training should also be appropriate to the employee’s responsibilities.

A receiving employee, sanitation employee, production operator, warehouse employee, quality professional, or supervisor may require different training based on their role.

6. When an individual mistake reveals a systemic problem

Consider a situation in which an employee enters a food-processing area using footwear or equipment that is not appropriate for that environment.

It would be easy to identify the individual as the problem.

But a stronger food safety investigation should ask:

• Was the employee trained?
• Were the requirements clearly communicated?
• Was appropriate signage available?
• Were the correct supplies or equipment available?
• Was the employee supervised?
• Was the procedure understood?
• Had similar deviations occurred before?

 What allowed the mistake to happen?

This distinction is important because food safety failures can be symptoms of broader gaps in training, supervision, procedures, facility design, communication, or management oversight.

7. Controlling access to food and materials

Traceability is not limited to knowing where a product came from.

It also involves maintaining sufficient information to understand what happened to materials while they were under the company’s control.

Imagine a raw material stored in a container that can be accessed by multiple people without authorization or documentation.

If that container is later opened, how would the company know:

• who accessed it;
• when it was accessed;
• why it was opened;
• whether the material was moved;
• whether its condition changed?

Depending on the operation and risk, controls such as restricted access, material identification, controlled storage, authorized personnel, and appropriate records can strengthen accountability and traceability.

This is particularly relevant because FDA describes traceability as the ability to follow food and ingredients backward and forward through the supply chain.

8. Inventory management and product rotation

Food safety also extends into warehouse management.

Companies need systems that allow them to identify materials and products by lot, track relevant dates, maintain appropriate storage conditions, and rotate inventory appropriately.

FIFO (First In, First Out) and, when appropriate, FEFO (First Expired, First Out) can support inventory rotation and help reduce unnecessary losses associated with aging inventory.

The goal is not simply to move old products first.

It is to maintain control over:

• lot identification;
• expiration or best-by information, as applicable;
• storage conditions;
• inventory status;
• product movement.

A well-controlled inventory system can also support traceability when a specific lot needs to be investigated or removed from distribution.

9. Retention samples and product investigation

For products and operations where a retention-sample program is appropriate, maintaining representative samples from production lots can provide an additional tool for investigation.

Consider a customer complaint received weeks after a product was manufactured.

The company may need to determine:

• which raw materials were used;
• which lot was involved;
• what quality results were obtained;
• who produced the lot;
• whether deviations were recorded;
• what corrective actions were taken.

A corresponding retained sample can provide additional information during the investigation.

This illustrates an important distinction:

Traceability is not simply knowing where a product went.

It is also having sufficient information to reconstruct what happened during its production.

FDA’s traceability framework uses Critical Tracking Events and Key Data Elements to link relevant information to food lots for foods covered by the rule.

10. Production efficiency should not compete with food safety

Food companies must manage production targets, costs, inventory, customer demand, and operational efficiency.

However, commercial pressure should not replace established food safety and quality controls.

If a material does not meet established acceptance criteria, the company should follow its established disposition procedures rather than allowing production schedules to determine the technical decision.

This does not mean that productivity and food safety are opposing objectives.

Quite the opposite.

A truly efficient food operation is one that can achieve its production goals while maintaining appropriate controls for food safety, quality, and consistency.

This is where food safety and process optimization intersect.

11. Management commitment and the role of the food safety professional

A food safety system cannot depend solely on written procedures.

Management must provide the resources, personnel, training, equipment, and organizational support necessary to implement those procedures effectively.

FDA’s preventive-controls framework places responsibility on management to ensure employees are qualified for their assigned duties through appropriate education, training, and/or experience.

Food safety and quality professionals also need sufficient access to information and organizational support to identify, communicate, and escalate concerns.

Responsibilities should be clearly defined so that production and quality functions can operate effectively without unnecessary conflicts of interest.

The existence of a procedure is not enough.

An organization must create the conditions necessary for that procedure to be followed.

12. Communication with consumers

Food safety responsibility does not end when a product leaves the facility.

Customer complaints can provide important information about potential quality or food safety issues after distribution.

An accessible customer service channel can therefore serve as an additional source of information for the company’s quality and food safety system.

Complaints should be documented, evaluated, and investigated according to the company’s procedures and applicable regulatory requirements.

When a potential food safety issue is identified, appropriate regulatory and recall procedures may also become relevant depending on the circumstances.

Conclusion

Food safety is not created by a single laboratory test, a single employee, or a single department.

It is created through an integrated chain of preventive controls that begins with suppliers and raw materials and continues through receiving, storage, production, quality control, employee training, documentation, traceability, distribution, and management.

Each stage provides an opportunity to prevent, identify, or control a potential problem.

When these stages are treated separately, important gaps can develop between them. When they are connected, organizations can build systems that are more preventive, traceable, and responsive.

The real challenge is therefore not simply producing more, faster, or at a lower cost.

It is building an operation in which food safety, quality, efficiency, and accountability are aligned.