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Chipotle Company’s Food Crisis Case Study


Abstract

Poisoning from food consumed at restaurants is a serious public health hazard. The paper studies the outbreak of food poisoning at Chipotle Mexican Grill in October 2015. There were two outbreaks in the same year. After the food poisoning occurrence, the local and federal authorities tried to ascertain the reason for the outbreak, but the tests they conducted could not confirm the ingredient that caused the illness. The company collaborated with the authorities to ensure that their cooking processes and serving areas are cleaned and infection-free. However, no question was raised about the failed safety mechanism and the failure to implement the regulations that were already in place.

This paper takes a look at the measures taken by the federal and local bodies to help find a solution to the problem. It also studies the regulations stipulated by the authorities to understand what food companies should do to prevent such occurrences. The paper shows that the government response to the outbreak was quick, which helped to handle the situation. However, the whole food safety machinery was not in place, as there were shortcomings in the implementation process. The adoption of the regulations must be made mandatory, and these should be monitored to ensure the rules are properly followed. Based on the research, we recommend that regulators and private organizations should put more stress on the implementation of the regulations, along with formulating more up-to-date laws.

Background

General Overview of Food Quality

The threat of food-borne diseases remains an imminent threat in the twenty-first century. The incidents of food-borne diseases are generally found in a few industrialized countries. Though policymakers believe food poisoning as a cause of death will reduce worldwide, there is little evidence to support the expected downward trend (Newell et al., 2010). According to the World Health Organization (WHO), the global burden of food-borne diseases is unknown (WHO, 2015b). The report by WHO, 1 out of 10 people, falls ill due to food-borne diseases every year due to the consumption of contaminated food or water (WHO, 2015b).

There are more than 200 microbial, chemical, or physical agents that can cause food poisoning (Newell, et al., 2010). In the Americas, diarrheal diseases cause 95 percent of food-borne diseases (WHO, 2015a). The main causes of such outbreaks are norovirus, E. coli, campylobacter, and non-typhoidal salmonella (WHO, 2015a). When there is a report of food poisoning outbreak of two or more people after consuming the same food product, it is termed as a foodborne outbreak by the US food safety department (FDA, 2016a). The public health officials then investigate the issue in order to control the situation and then try to find the pathogens that may have caused the outbreak. Further, proper precautions and policy measures are taken to prevent such outbreaks in the future.

Chipotle Food Crisis

Chipotle Mexican Grill (hereafter referred to as Chipotle) is one of the leading restaurant chains in the US. They specialize in serving Mexican food that is assured to be fresh and healthy. The company was entwined in a food poisoning controversy wherein it had to close down more than forty outlets in the Pacific Northwest in 2015 due to E. coli outbreak (Surowiecki, 2015). The issue aggravated when many other consumers around the country were affected by the food-borne illness. The Chipotle food poisoning issue had spread in many major cities around the US. The case study will look into the issue of food poisoning of 120 Boston College students who ate at Chipotle.

The food poisoning, which is an E. coli bacterial outbreak, has not only affected consumers in Boston but also in California and Minnesota, where the company is facing several lawsuits. Such an outbreak of food poisoning from the food consumed at a leading restaurant chain raises concerns regarding the food quality and safety policy of the government.

Chipotle is a brand that is famous for its reliance on fresh ingredients and food. Such brand positioning helped to ensure the perception of food safety among customers. Further, Chipotle’s branding ensured customers fresh and hand made food, prepared right in front of the customers. The company slogan, “food with integrity”, showed the company’s allegiance to food quality (Chipotle, 2017). However, the outbreak of food poisoning weakens the company’s brand position.

Many US companies like Taco Bell and Jack in the Box restaurant chains reported E. coli incidents in 2005 and 1993, respectively (Surowiecki, 2015). Such situations were handled, and these companies flourished even after such incidents. However, the issue that has not been analyzed is the public policy response of the authorities to the outbreak of such incidents. This paper will aim to understand how the government regulations regarding such outbreaks of food poisoning are handled by analyzing policies in place regarding food quality in the US and worldwide.

Food Policy Worldwide

European countries were ahead of the US in creating food-labeling laws, but their laws were haphazard. The food policy globally recognizes that safer food is a necessity to save lives. With the increasing danger of microbiological or chemical contamination, it is necessary to build a system that prevents millions of people from consuming contaminated food. Food security has assumed renewed importance after the rise in the food prices in 2007-08 (WHOa, 2015). According to WHO, ensuring the availability of clean, safe, and nutritious food is essential to sustain life and promoting good health (WHOa, 2015).

Unsafe food may cause a range of diseases, from diarrhea to cancer. Thus, it believes unsafe food poses a threat to global health endangering millions of people. A conference on nutrition held at Rome in 2014 emphasized the importance of food safety. WHO believes food safety is the key to ensuring sustainable development goals and for this reason, most governments should actively formulate policies to ensure the safety of public health. The report suggests that governments should frame policies and structures to ensure that food producers, suppliers, and others involved in the food chain operate responsibly.

US Policy History

Every country requires a food law that would safeguard the quality of the food available to the common man. The need for governmental protection of the food quality arose when the administrators acknowledged the incidence of fraudulent and unsafe food being sold in the market. Food regulation in the US dates back to the colonial era. The Congress enacted the first food protection law in 1883 to prevent adulteration of tea (Fortin, 2016).

In 1896, the US government enacted the oleomargarine statute, which aimed to prevent the dairy industry to sell adulterated butter. The US food regulatory regime is historically considered to be more effective and open (Smith & Diack, 2005). The 1785 Massachusetts Food Law aimed to prevent the selling of unwholesome food in the market (Smith & Diack, 2005). The objective was to avoid mislabeling and adulteration of food. The 1906 Pure Food and Drug Act expanded food research and testing (Smith & Diack, 2005).

The aim of the act was to understand the harmful effect the chemical preservatives had on food and public health. In the very same year, the US government passed the Meat Inspection Act. The US Department of Chemistry regulated the Pure Food and Drug Act while the Meat Inspection Act was regulated by the US Department of Agriculture. The Food Drug and Cosmetics Act, passed in 1938 became the standard of the labeling regulation (Smith & Diack, 2005).

FDA brought in further changes in the 1960s in its food regulation policy as it recognized the need for nutrition education. In 1973, the government made labeling food items voluntary, however, delineated a set guideline for the same (Smith & Diack, 2005). However, the policy had to change in the 1980s when the food product manufacturers routinely made nutrient content and disease prevention claims while marketing their product. FDA has enforced a new law in 2011 called the Food Safety and Modernization Act (FSMA). The aim of the act is to establish new food safety standards for domestic as well as imported food. Further, it directs FDA to build a joint food safety network with federal and state authorities to enhance public safety.

Outstanding Federal Policies Concerning Food

The office of food regulation and FDA is constantly revamping the outdated regulations and incorporating new laws. The labeling laws are continually changing. For instance, in 2014 FDA proposed new guidelines for sanitary regulation for transportation of human and animal food. This was designed to protect contamination of food during transportation. The law was proposed in January 2013 and is yet to be implemented (FDA, 2016b).

Chipotle Food Crisis

Two separate incidents of E. coli outbreak at Chipotle occurred in 2015 that had affected a total of 55 people. The incidence of the infection was due to the outbreak of a strain called STEC 026, a Shiga toxin producing E. coli strain. The public health officials in Washington and Oregon detected the first outbreak. The food borne disease surveillance detected the issue. Initially, officials noticed a rise in the number of ill people in the states and on interviewing them, the cause of the illness was determined to be an E. coli outbreak. The first outbreak is believed to have occurred at the end of October 2015. The poisoning then spread to other states such as California, Delaware, Illinois, Kentucky, Maryland, Minnesota, New York, Ohio, Oregon, Pennsylvania, and Washington.

Key Issues

The outbreak affected consumers in 11 different states all over the US. The main issues that the Chipotle food crisis brings forth are – (1) the main cause of food poisoning outbreak, (2) measures that were taken by the company to curtail such mishaps in the future, and (3) measures taken by the local and federal governing bodies to handle the situation and prevent future occurrences. Chipotle claimed to make fresh food for its customers. The paper will try to see what measures were taken after the outbreak and what should be done according to scholarly research in case of such an incident. Based on the gap found between the measures taken and suggested measures, recommendations will be formulated for future occurrences.

Methods

This study utilized a number of resources to gather data and information regarding the Chipotle Food Crisis. The study concentrates specifically on the outbreak of E coli incidents in Boston. Using search terms such as “US food policy,” “WHO food policy,” “FDA food code” “Chipotle food poisoning,” and “Chipotle food crisis,” on databases such as EBSCO, United States National Agricultural Library, and Google Scholar, a number of resources were accessed. The search results yielded scholarly, governmental, and general population resources. The study looked into the food poisoning incident outbreak in Boston. These findings were compared objectively to more general literature regarding US food regulation and media interpretation.

Results

Company Level Failure

The company mechanism failed to identify the possibility of contamination of the food served in the restaurants. After the outbreak, Chipotle took many measures to curtail the spread of bacteria and identify the cause of food poisoning. However, it was evident from their actions that no such procedures were in place before the outbreak. This raises serious questions about the company’s safety regulations for preparation of food items prior to the outbreak. This section of the results will show the drawbacks the company had before the outbreak of E. coli.

The first outbreak was detected in Washington and Oregon through the local food borne disease surveillance in October 2015. A total of 55 people were infected with the outbreak. From the people who were available to provide information, it was deduced that the illness occurred from October 19, 2015 to December 1, 2015. Another outbreak was detected in December 2015, with a similar strain of STEC 026 (FDA, 2016b).

Once the outbreak was confirmed, immediate measures were taken by the organization to curtail the spread of the poisoning. The stores (more than 200 in number) were closed voluntarily and the company closely collaborated with the public authorities to solve the situation. The measures that were taken by the company are as follows: (1) microbiological testing to build effective food safety, (2) prepare ingredients centrally, and (3) undergoing regular USDA inspections to ensure food safety (Chipotle, 2017). However, these measures are just reactions to the outbreak. Before the outbreak had occurred, the company had not undertaken any safety measure to prevent food infection.

Chipotle branded their food as farm fresh, aggressively positioning their products against industrialized agriculture. However, the company failed to recognize the safety measures that had to be taken to ensure good and clean food. Though they relied on organically raised vegetables, poultry, and meat, their production process did not adhere to the standard guidelines of the FDA. Their motto was “food with integrity”.

However, their focus was mainly on providing food that was different from the other big food chains like KFC or McDonalds. Chipotle often created commercials that openly slandered these big food chains. However, one good side of such large establishments is that they have a strict policy of food safety in place, which the small and medium operators in the food industry lack. Prior to the outbreak, Chipotle did not exhaustively follow the regulations by FDA or USDA, increasing the risk of food-borne infections.

One of the main issues that existed with the policy of Chipotle’s food safety measures prior to the outbreak was that the company did not have any written regulation that was strictly followed. The raw ingredients shipped to the stores were not tested for bacteria or infection. Further, there was no set procedure for cooking or cleaning of the utensils. It did not have any written rule regarding the process of washing, cutting, cleaning, shredding, and preserving the raw ingredients. Rules that were present for preserving meat and chicken were unclear. There was no internal training for safety measures for the workers prior to the outbreak.

As the outbreak was presumably caused due to the presence of bacteria in meat products, it was necessary to have a properly written procedure to understand how the meat should be processed to make it bacteria-free. Further, written procedure should have been implemented as to how they meat should be preserved.

More specifically, Chipotle failed to follow the policy guidelines of the FDA concerning such outbreaks. FDA guidelines specify that such bacteria are highly contagious and could be transmitted from one infected person to the other. However, in the case of the outbreak at Boston College of 140 students, the infection was transmitted from the nearest Chipotle restaurant. Further, the source was not the food served at the restaurant, but an infected employee who was not allowed to take sick leave. This distinctly shows the company policy of not giving sick employees paid leave and neglect of the FDA guidelines.

Though this system of paid sick leave was implemented after the outbreak, but the damage was already done. Thus, the previous food safety policy and employee sick leave policy could have been the reasons behind the food poisoning incident.

Failure of the Regulatory System

The outbreaks at Chipotle restaurants are related to three different pathogens – norovirus, E. coli, and salmonella (Strom, 2016). Norovirus is a highly contagious, commonly categorized as stomach flu. E. coli and salmonella are more dangerous pathogens that may be lethal if the toxin level in the body in categorically increased by the bacteria. However, the investigation into the food system does not confirm which food items were contaminated that may have caused the outbreak. The investigation undertaken by the FDA provided no conclusive results. Hence, it was impossible to rule out any food item that was and is still being used in the restaurants.

The failure of the FDA to identify the ingredient that was carrying the infection increases the chances of a recurrence. Though measures were immediately taken to decontaminate new ingredients and quarantine all ingredients from the older stock but the element of not knowing what and how it may have occurred keeps the risk imminent.

Clearly, the federal regulations were not followed by the company, which may have caused the outbreak. Though, FDA has not explicitly spoken about the cases wherein the company has failed to comply with the government regulations but the matter becomes evident. The policy in place leaves only 2 percent chance of a virus outbreak. Then, a strict compliance at Chipotle could have avoided the food poisoning incident and more importantly the second outbreak.

Discussion

The results suggest that both the company and the government machinery failed to identify the potential threat that the food system posed on public health. When the incidents occurred, neither Chipotle nor the government showed any readiness to handle the situation. Moreover, Chipotle did not adopt the government regulations entirely that aimed to ensure food safety before the food poisoning incident.

The lack of implementation of the existing regulations for food safety was one of the main failures of both Chipotle and the FDA. Though the company has adopted FDA regulations and has pledged to cooperate with the local and federal authorities to help solve the issue, their commitment towards food safety before the incident was almost negligible. The obvious question that arises is if Chipotle was using the garb of cooperation to prevent further prosecution. Clearly, the company was facing quite a few lawsuits after the food poisoning outbreak. So this could have been just a means to safeguard their image as a responsible organization.

The following discussion elucidates the policies adopted by the company before and after the break to understand if there was a gap in the adoption of the regulations by the company. The discussion is segregated into two categories – first will deal with the policies suggested by previous research and second, will deal with the measures that were taken by the company and the government in case of Chipotle E. coli outbreak.

Chipotle E. coli Outbreak

The organization also took special measures counter the poisoning issue in the organizational level. Chipotle hired a food safety chief Mansoor Samadpour, the CEO of IEH Laboratories and Consulting Group, to overhaul the internal food safety policy and regulation (Strom, 2016). They investigated the outbreak internally and implemented safety regulations. The company has adopted a policy of supplier intervention that checks all the supplies sent by the vendors (Chipotle, 2017).

This is to ensure that no raw material is contaminated. Further, the company has adopted new, advanced technology to ensure the pathogens are removed, maintaining food quality. Farmers are trained to ensure that the raw vegetables they supply to the restaurant chain are free of any bacteria or pathogen. Further, protocols are implemented to ensure proper handling of the ingredients and sanitization of the restaurant surface. Regular inspections are conducted to ensure food and restaurant safety. The company also implemented an advanced electronic monitoring system to trace the ingredients in the supply chain.

The company aims to bring down the risk of contamination of any of its food items to “near zero” ensuring no such incidents occur in the future (Strom, 2016). For instance, all the lettuce used for making food at Chipotle is now cleaned at a centrally located warehouse. Cheese is also grated centrally and packed in sealed containers. Further, onion, jalapenos, and other vegetables are boiled or blanched and packed before reaching the stores to kill all microbes they may contain (Strom, 2016).

The suppliers who supply meat have to undergo high-resolution DNA testing to remove all contaminated items. To ensure employee safety, the company has adopted the policy of paid sick leaves, a policy that no other food chain has adopted to allow sick employees to recuperate (Strom, 2016). Moreover, the company has decided not to use any genetically engineered ingredients to prepare food. However, the drinks the restaurants serve, still have genetically engineered ingredients (Strom, 2016).

Chipotle has adopted testing methods approved by FDA and USDA for ensuring safe food. They are presently using microbiological testing to build effective food safety processes in order control spread of harmful bacteria in meat, chicken, and dairy products (Chipotle, 2017). Further, they prepare their ingredients centrally, which are then heated at low temperature for a long period after being sealed in vacuum-sealed packages. This process is regularly monitored and inspected by the USDA.

When the local and the federal authorities detected the outbreak, Chipotle voluntarily closed all its restaurants in the infected cities and worked closely with the government consultants to investigate the issue.

Measures taken by FDA

The first measure that was taken was to understand the source of the infection. According to FDA guidelines on E. coli, the main cause of an outbreak of the bacteria is from consumption of contaminated dairy products such as milk or cheese or animal meat. Thus, the government tried to isolate the causes that may have resulted in the food poisoning at Chipotle. Once the authorities identified the outbreak and linked it to the food served at Chipotle restaurants, investigators used whole genome sequencing (this is a highly advanced technique) to identify the DNA strain of the STEC 026 bacteria that had caused the outbreak (FDA, 2016a).

This process isolated 36 ill people from the first outbreak and found that they were genetically related to one another. This showed that the outbreak was linked to the other occurrences in the Pacific Northwest (FDA, 2016). This test was done on the four people from the second outbreak, confirming their linkage. Further, tests were done on Chipotle food, restaurant surface, and utensils to ensure if there were traces of E. coli (FDA, 2016a).

The tests showed there were bacteria left. Then the authorities looked into the health of the employees to ensure none of them was ailing. Further, fresh products such as raw meat, farm produce, and dairy items were further checked before restocking the restaurants. Additional safety procedures and audits were recommended for all the 2000 restaurants that were operational (FDA, 2016b).

This was done to ensure safety standards. The restaurant chain was instructed to work in close collaboration with the local, state, and federal authorities to ensure the safety of the food. Further, the ingredients at the restaurants, which were the source of the outbreak, were replaced. Further cleaning was done for all the closed restaurants to ensure proper sanitization.

However, a few problems encountered while doing a trace-back of ingredients. First, Mexican food is prepared with multiple ingredients. Hence, a trace back did not provide any significant result for it was difficult to identify the ingredient that may have caused the poisoning outbreak. The FDA traced back to a few ingredients, which it believes to be the primary cause of the outbreak. However, the FDA’s investigations failed to identify any specific ingredient in the distribution path that could have caused the poisoning.

The FDA also conducted an investigation into the products sent by the suppliers. This was done to find if the supplies were the source of the outbreak. However, the research yielded no conclusive result. Further, no food item could be ruled out as a cause. The Centers for Disease Control and Prevention (CDC) declared on February 2016 that the E. coli outbreak at Chipotle was over (Whitten, 2016).

Research of Food Poisoning

A study conducted by Jones and Angula (2006) shows that there are health risks associated with eating at restaurants. In the case of E. coli infections, they suggest that it is mostly caused due to the consumption of half-cooked meat, or more specifically beef. Further, research suggests that outbreak-related cases only for less than 3 percent of the reported cases and hence studying outbreaks may not be the most suitable method of analyzing policies and regulations in place to offset a food poisoning epidemic (Jones & Angulo, 2006).

According to another research conducted on the outbreak of food poisoning from restaurant food, it was believed that Chinese, Indian, British and Italian cuisines were the most effective poisoning vehicle (Gormley, Rawal, & Little, 2011). The research shows that in Europe the restaurants have to have a written document with the detailed hazard analysis and the critical control point principles (Gormley et al., 2011). Norovirus outbreak in restaurants was found to occur mostly in seafood restaurants and such food poisoning occurred mostly in winter (Gormley et al., 2011).

Another study on the factors affecting compliance with food safety regulations show that operators in the food business usually lack the proper knowledge of laws and safety measures (Yapp & Fairman, 2006). This becomes one of the greatest barriers to implementation of food safety legislations. Further, lack of trust on food safety regulations, lack of motivation to deal with food safety, and lack of knowledge and understanding of such legislations becomes the greatest barrier to implementation of food safety legislations (Yapp & Fairman, 2006).

Another research on the issue of co-regulation of food safety in restaurants using private-public partnership states that though there is scope for co-regulation, there exists a wide net of obstacles to the implementation of such laws (Martinez, Fearne, Caswell, & Henson, 2007). However, the paper points that there are certain benefits of co-regulation of such laws as this would reduce non-compliance due to coercion. Further, access to reliable information regarding the regulations is essential. If the information source dries up, it will create errors in decision-making, which may affect food safety.

According to the research conducted by Grossman (2016), FDA guidelines on food safety covers around 80 percent of the US food supply. The recent outbreak of food-borne illness at Chipotle raises the concern of implementing a more comprehensive law that would cover the whole gamut of the produce producers and marketers. The regulation governs biological hazards that may be caused by agricultural and dairy products. Thus, FDA will work with the private owners to enhance hygiene practices for food preparation and serving area. The new law implemented by FDA would ensure the safety of both domestic and imported food. Further FDA is expected to work both with the domestic private operators and global organizations to enhance food safety in the US.

Private-Public Failure

The case of Chipotle food poisoning is a distinct case of failure of both the private and the governmental organization to prevent food fraud. Regardless of the cause of food risk, it is the responsibility of both the organization and the government to ensure food safety. Food safety, food fraud, and food defense issues raise the risk of food adulteration and cause health threats to the public. Food fraud is an intentional action to create health hazard while food safety is an unintentional means of causing heath risks. Research suggests that in case of Chipotle, the current safety measurement system failed miserably to understand the imminent food risks.

Previous studies into the compliance of regulation by the food industry suggests that small and medium scale organizations fail to comply with the regulations laid down by the government. The reasons are a lack of knowledge and understanding of the laws. Thus, the question that arises is if Chipotle failed to understand or follow the laws. Further, such companies have a reluctance to follow the rules. The reason for Chipotle’s apparent disregard for the regulations is unknown.

Though the company used to spend a lot of money on the advertisement of their product as a safe and healthy option to the other industrialized food chains, yet their product caused the outbreak, which could have become a severe risk to public health. The inability of the state or federal regulators to identify the reason for the outbreak of the illness shows the inability of the present system to categorically understand what may have caused the poisoning. This shows that the present regulations in place and the investigation methods are not adept to handle the more mature strains of pathogens.

The measures undertaken by the Chipotle seemed more like a desperate attempt to damage control rather than a complete commitment to public health and food safety. Chipotle immediately closed all their restaurants and openly acknowledged the issue and collaborated with the local and federal authorities to control the situation. They even implemented changes in their food safety and employee leave policy. Apparently, such measures seem a complete commitment to the safety concerns however a closer look would reveal that the company was merely trying to save the brand name. Had the compliance policies been in place from the very beginning, the outbreak could have been deterred.

Conclusion

The Chipotle food crisis is one of the many food poisoning incidents that have affected the health of the American public. Why does such an outbreak occur in a country where detailed measures are taken by the local and federal authorities to avoid such situations? The reason lies in the implementation process, which is faulty. Further, Chipotle suddenly became more aware of the food safety issue and started implementing written policies and regulations to ensure clean and safe food. However, before the outbreak, these measures seem to have lacked importance. The inconspicuous absence before the poisoning outbreak makes the situation even more suspicious.

Were they not following the FDA guidelines for food safety? Was the FDA aware of Chipotle’s disregard of their safety regulations? In either case, both Chipotle and/or the government regulators were not doing their job rightly. After the outbreak, the state and the federal regulators tried to pinpoint the cause of the outbreak but failed to find a singular reason. Is it because the tests followed by the federal bodies are inept to track genetically advanced pathogens? Do these pathogens go undetected by the tests currently used by the FDA? These are the questions that need to be answered. This research conclusively states that the government response to the outbreak was quick which helped to handle the situation. However, the whole food safety machinery was not in place as there was no intent to implement the rules. Adoption of the regulations must be made mandatory and these should be monitored ensure these rules are properly followed.

Recommendations

From the following research, it is evident that the state and federal government take a keen interest in updating and revamping the food safety laws, as this is one of the most talked about issues today. However, the regulators fail to establish a thorough implementation process. This enhances the risk of food poisoning caused due to ill-managed food processing to unhygienic restaurants. Therefore, the first recommendation of this research is to improve the implementation process.

A law in itself is just a few words with no real meaning. It can stipulate what should be done and what not. However, it, in itself, will not be able to enforce the actions. The government and the targeted organizations must do it. Implementation is an essential part. If not implemented, the law remains hidden in the annals of hundreds of legislations. Thus, implementation of the regulation should be the first priority of the regulators. Second, the regulators should try to educate the small and medium scale food operators. This will enhance knowledge and awareness. Research has shown a lack of awareness among these operators to be one of the main causes for food poisoning outbreaks. Thus, this step will help in advancing their knowledge and encourage them to implement safety measures.

Further, the companies need to write down the regulations and policies related to the safety issues related to food preparation and disinfecting the raw ingredients. Third, there should be scope for public-private co-regulation for the food industry. In other words, the private parties must take more active role in the formulation of the regulations, especially of the food industry. A co-ordination between the two parties will ensure safer food, delivered at a lower cost. Such coordination at different stages of the regulatory process will improve food safety and lower the cost of production and help in more effective distribution of the limited monitoring resources.

Fourth, compliance can be adopted based on the relation between industrial and administrative performance. The food safety controls must evolve towards more performance and process based security norms. This will automatically place greater importance to the implementation of the safety regulations. Thus, companies can adopt the food safety regulations as a competitive advantage for improving performance.

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Grossman, M. R. (2016). FDA issues final rules under the 2011 Food Safety Modernization Act. EFFL, 1, 63-66.

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Martinez, M. G., Fearne, A., Caswell, J. A., & Henson, S. (2007). Co-regulation as a possible model for food safety governance: Opportunities for public–private partnerships. Food Policy, 32, 299–314.

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