As you read this, I trust you are looking forward to attending the Food Safety Summit in Rosemont, Illinois next month. I have been looking over the education agenda, and I think the Summit will have a particularly topical and well-organized agenda this year.  

Now, before the critics get fired up, I will disclose that I have no direct role in organizing or developing the agenda for the Food Safety Summit. I do attend and participate in certain functions at the Summit in conjunction with Food Safety Magazine and the Food Safety Matters podcast (stop by and say hi at the live Podcast Theater!), but I do not serve on the committee that develops the Summit's agenda.

When reviewing the Summit's agenda for 2026, I noticed that the topics are not only relevant and timely—they also explore key issues that we have covered in the Food Safety Insights column over the past few years. Since we have heard and discussed your opinions on many of these topics, I want to use this column to review that background as a way of enhancing what you will hear at the Summit this year. I also want to gauge how the key points of these topics may have changed—or not—since we last reviewed them in this column. Perhaps this exercise will even serve to seed a few questions for the presenters in Rosemont. 

Traceability: Turning Rules into Reliable Records

With the U.S. Food and Drug Administration's (FDA's) postponement of the compliance date for the Final Food Traceability Rule (FSMA 204) to July 2028, now may be a good time to assess the gaps and preparedness plans that companies may still be working on.

In 2023, Food Safety Insights presented a two-part series on food safety traceability and if companies thought they were prepared for compliance. In Part 1,¹ we presented what we heard from 100 companies on their views about compliance with the Food Traceability Rule, with a focus on awareness, applicability, and perceived impact. A large majority of respondents were FDA‑regulated facilities (about 73 percent in North America and 67 percent internationally). Among North American respondents, 88 percent said they were aware of the rule, while fewer than half of international respondents reported familiarity. Roughly one-third said they manufacture products on FDA's Food Traceability List, although a similar share said they were unsure, and 57 percent believed the rule will eventually extend to other foods. 

Processors' top concerns at that time were centered on how the rule will be applied and enforced—particularly which specific products and forms are covered, how to handle ingredients that change form during processing, and how applicability works for distributors and food banks. Many respondents called for FDA to "educate before they regulate" and provide strong outreach and supplier‑level enforcement support. Only about 5 percent reported having no concerns, but 87 percent said the three‑year compliance timeline is reasonable. Many respondents noted that they already have many elements in place, while still worrying about clarity, complexity, staffing, and cost.

​In Part 2,² we showed that most companies already had some form of supply chain tracking in place and felt generally confident that they could meet traceability expectations. However, many said that they were still relying heavily on manual or semi‑manual systems—spreadsheets, basic databases, or paper—rather than integrated electronic traceability platforms. At the time, only 32 percent said they were using a purpose-built, electronic commercial tracking program, while 38 percent said they were using spreadsheets and paper. Nonetheless, about 90 percent said they could supply traceability information within 24 hours if requested. 

Respondents described incremental plans such as improving existing systems, enhancing data capture, and better integrating supplier and internal records. They also highlighted challenges in performing gap analyses without precise guidance on the definition of full compliance. The findings suggested that at the time, processors broadly accepted the rule's intent and timeline, but they needed clearer, scenario‑based guidance, especially for ambiguous product categories and less-defined roles (e.g., distributors). They emphasized that successful implementation would depend on FDA outreach, supplier education, and practical tools that support detailed recordkeeping without unsustainable complexity or cost.

The surveys and interviews for these articles were written in 2023. In them, we made the point that with the current level of preparedness at that time, perhaps it is better that food companies still had three years to comply. A food safety traceability program is only useful if it actually works. Now, three years later, we still have another three years to the compliance date. Are food processors ready now? Have they made the needed progress in areas cited as gaps in 2023? Is another three-year delay warranted, or will compliant and effective systems be ready and tested in advance of the 2028 compliance date? Perhaps we will find out more at the Summit.

“Across Food Safety Insights columns since 2023, a consistent message has emerged: people and culture often make the difference between programs that look solid on paper and programs that work under real‑world pressure.”

Food Safety Culture

A number of sessions at the Summit are directed at the topic of food safety culture. This is, of course, not unexpected considering the importance of the subject. "Practical Tips to Improve Food Safety Through Your Psychosocial Environment," "From the Ground Up: Growing Food Safety Culture Champions through Mentorship," and "Beyond Compliance: Elevating Food Safety Buy-In Through Interpersonal Influence" are just a few of the session titles dedicated to food safety culture at the Summit this year.

We addressed food safety culture in a two-part series^3,4 in the December 2025/January 2026 and February/March 2026 issues earlier this year. We looked at the issue of culture and also the key performance indicators (KPIs) that companies are using to track their performance, as reported by more than 170 food processors worldwide.

In response to our survey, around 76 percent of respondents said their company has a good food safety culture, but the discussion stressed that culture goes beyond compliance testing and metrics to include embedded values, leadership commitment, communication, and everyday behaviors. We also found that there is a clear recognition that measurable indicators nonetheless remain essential, with about 76 percent saying they have specific food safety KPIs that they regularly track and are measured or evaluated on, while roughly 24 percent said they do not. This suggests that a meaningful minority of companies still manage largely through audits and incidents rather than structured, preventive metrics. Those without defined KPIs often rely on broader quality or cost metrics and acknowledge that they need to build more food safety‑specific measures.

Among companies using KPIs, most reported that their key indicators fall into five main categories: 

• Environmental monitoring results
• Customer complaints
• Sanitation scores
• HACCP/GMP deviations and non‑conformances
• Corrective action closure rates and times. 

Environmental monitoring data are the most frequently cited, including specific measures such as daily ATP results or the number of pathogen positives, often linked to sanitation scores and first‑time pass rates on sanitation inspections. Respondents emphasized that the KPIs they found to be effective are risk‑based, aligned with regulatory and customer expectations, understandable at both the frontline and senior levels, can track trends, and blend lagging indicators (e.g., complaints, non‑conformances) with leading indicators (e.g., training compliance, EMP performance, maintenance). About 63 percent said their KPIs are clearly communicated and posted for all employees (e.g., via dashboards, boards on the floor, and multilingual visual displays), while roughly one‑third keep metrics mostly within management reports, citing concerns about misunderstanding or the effort required to disseminate. 

Across Food Safety Insights columns since 2023, a consistent message has emerged: people and culture often make the difference between programs that look solid on paper and programs that work under real‑world pressure. Surveys of thousands of food safety professionals worldwide show that respondents routinely identify leadership commitment, communication, resource constraints, and workload as decisive drivers of performance. Many link their biggest food safety concerns not to the absence of a policy or procedure, but to whether teams are overloaded, whether supervisors are present and supportive, and whether employees feel safe speaking up when they see a problem. 

I think we will hear more about this message in Rosemont next month.

Sanitation: Back to Basics, Informed by Data

A focus on sanitation, environmental monitoring, and pathogen control are woven throughout many sessions at the Summit and within Food Safety Insights, as well. Across Food Safety Insights columns since 2023, sanitation emerges as a top operational priority, closely linked with environmental monitoring, hygienic design, pathogen control, and testing. 

In our survey in late 2023⁵ on "near-term priorities for your food safety program," processors ranked "sanitation and hygiene" among their most important near‑term focus areas, alongside food safety culture and microbiological control. Subsequent articles in 2024 showed that many plants are relying on ATP and other rapid tests as day‑to‑day verification that their cleaning and sanitation programs are effective and that changeovers do not leave behind residues or niches, reinforcing sanitation's central role in routine risk control.

“…the industry's challenge is less about recognizing sanitation's importance and more about sustaining high performance in the face of competing demands, aging infrastructure, and the need to integrate new technologies and regulatory expectations into everyday cleaning and environmental monitoring practice.”

In 2025, we focused on hygienic design. Part 1 and Part 2 of our survey results^6,7 confirmed that a high level of focus on equipment and facility design have a high correlation with good sanitation outcomes. Responses also showed that most processors see hygienic design as an "essential element" of their food safety strategy but still struggle with legacy equipment and hard‑to‑clean areas. In one 2025 survey, 91 percent of respondents reported having a formal program for segregation and storage of cleaning tools—an indicator that basic sanitation infrastructure is widely in place. However, comments highlighted persistent challenges with equipment cleaning and maintenance such as reaching tight spaces, managing tools and chemicals properly, and coordinating sanitation windows with production schedules. 

At the same time, the December 2024/January 2025 and February/March 2025 columns^8,9 on regulatory changes reported that improving sanitation and environmental monitoring are among the most frequently cited 1–2‑year goals, reflecting recognition that strong, verifiable cleaning programs are critical to meeting evolving regulatory and customer expectations.

Taken together, these columns conclude that while many companies have formal sanitation programs, tool segregation systems, and rapid verification methods, there is still a gap between having these elements on paper and consistently executing them under operational pressure. Effective sanitation is portrayed as a system that depends on hygienic design, robust and well‑communicated procedures, fit‑for‑purpose tools and tests, and adequate time and staffing, all reinforced by leadership and culture. The findings suggest that the industry's challenge is less about recognizing sanitation's importance and more about sustaining high performance in the face of competing demands, aging infrastructure, and the need to integrate new technologies and regulatory expectations into everyday cleaning and environmental monitoring practice.

Food Safety Insights has also highlighted an evolving picture for sanitation and environmental monitoring. Earlier surveys found that, coming out of the pandemic and high‑profile contamination events, respondents planning to increase environmental monitoring far outnumbered those planning reductions—by ratios on the order of 20:1 in North America and 15:1 in Europe—reflecting aggressive investments in verification and early‑warning systems. Subsequent surveys, however, indicated that these ratios have slipped somewhat, to below 5:1 in the U.S./Canada and below 2:1 in Europe, suggesting a plateau or even pullback in testing intensity as complacency in the face of cost pressures and competing priorities reduce the emphasis on environmental monitoring volumes.

Many practitioners report that when environmental monitoring programs return a long run of negatives, there can be pressure to scale back testing or shift resources, even though experts repeatedly stress that "not finding positives" should prompt a critical review of sampling design, not a relaxation of controls. At the same time, turnover in sanitation teams and the constant squeeze to shorten changeover and cleaning windows can undermine the fundamentals—detailed procedures, effective chemistry and tools, and rigorous verification—that underpin both environmental results and inspection outcomes.

Looking Ahead to the 2026 Summit

Viewed together, recent Food Safety Insights columns and the 2026 Food Safety Summit agenda tell a consistent story. Processors are wrestling with the practical demands of traceability, the human dynamics of culture, and the day‑to‑day realities of sanitation in an environment of tight resources and increasing expectations. 

If you can attend the Food Safety Summit in Rosemont this year, I think you will hear these messages along with practical solutions.

By the way, the Food Safety Summit will also host a session on the use of artificial intelligence in food safety. This is certainly a topical issue but one that we have not yet addressed in Food Safety Insights. To rectify that, the June/July issue will present the results of our survey and interviews on AI in food safety and how processors are currently using (or planning to use) the technology in their work. 

Look for that article next time, and in the meantime I hope to see you at the Summit!

References

1. Ferguson, B. "How the Food Traceability Rule will Impact Food Processors—Part 1." Food Safety Magazine February/March 2023. https://digitaledition.food-safety.com/february-march-2023/column-food-safety-insights/. 
2. Ferguson, B. "How the Food Traceability Rule will Impact Food Processors—Part 2." Food Safety Magazine April/May 2023. https://digitaledition.food-safety.com/april-may-2023/column-food-safety-insights/.
3. Ferguson, B. "What Food Safety KPIs Say About Food Safety Culture—Part 1." Food Safety Magazine December 2025/January 2026. https://digitaledition.food-safety.com/december-2025-january-2026/column-food-safety-insights/. 
4. Ferguson, B. "What Food Safety KPIs Say About Food Safety Culture—Part 2." Food Safety Magazine February/March 2026. https://digitaledition.food-safety.com/february-march-2026/column-food-safety-insights/. 
5. Ferguson, B. "Food Safety Priorities—Getting 'Back to Basics.'" Food Safety Magazine October/November 2023. https://digitaledition.food-safety.com/october-november-2023/column-food-safety-insights/.
6. Ferguson, B. "Hygienic Design: How are Processors Coping With This Essential Element of Food Safety?" Food Safety Magazine April/May 2025. https://digitaledition.food-safety.com/april-may-2025/column-food-safety-insights/. 
7. Ferguson, B. "Hygienic Design: How are Processors Coping With This Essential Element of Food Safety?—Part 2." Food Safety Magazine June/July 2025. https://digitaledition.food-safety.com/june-july-2025/column-food-safety-insights/. 
8. Ferguson, B. "Regulatory Changes Impacting Your Food Safety Program—What Should FDA's Priorities Be?" Food Safety Magazine December 2024/January 2025. https://digitaledition.food-safety.com/december-2024-january-2025/column-food-safety-insights/. 
9. Ferguson, B. "Regulatory Changes Impacting Your Food Safety Program, Part 2—What Should USDA's Priorities Be?" Food Safety Magazine February/March 2025. https://digitaledition.food-safety.com/february-march-2025/column-food-safety-insights/.

Notes

^a For chicken, the serotypes are Salmonella Enteritidis, S. Typhimurium and S. 4,[5],12:i.

^b For turkey, the serotypes are Salmonella Hadar, S. Typhimurium, and S. Muenchen.

^c These were the terms of the proposal at the time of our survey and the writing of this article. The comment period for the proposal was scheduled to end on January 17, 2025, and changes to these terms and the proposed regulation may be in process.

^d In the survey, we specifically asked the question, "If you could ask any question or make a request to USDA Deputy Under Secretary for Food Safety Sandra Eskin, what would that be?" Since the time of our survey, Sandra Eskin has left her position at USDA and, as of this writing, a successor has not yet been named.