Change as a Food Safety Risk: How to Safely Respond to Internal Adjustments
Change is inevitable in the world of food manufacturing, and it’s often for the better — growing operations, streamlining processes, innovating products, and improving food safety protocols. But in food and beverage production, new processes can also introduce new food safety risks.
The impact that internal changes like product reformulation, supplier changes, and staffing updates have on your operations will all depend on how well you can stay ahead of the risks they create.
The best way to respond to internal adjustments is not to react, but to prepare. Prioritizing preparedness and education will enable your team to prevent risks from escalating into food safety incidents. Follow along as we highlight some common changes your business may experience, the food safety risks they can create, and how you can mitigate them.
Why Internal Change Can Lead to Food Safety Risks
Anytime your operations undergo a transition, whether internal or external, there is a period of disruption as your team adapts to their "new normal." During this adjustment period, your manufacturing processes will naturally be more exposed to potential food safety risks because of a number of factors, including:
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Fractured attention, as team members’ focus shifts to updating processes, rather than maximizing food safety.
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The introduction of hidden vulnerabilities, like skipped sanitation steps, caused by new or changing procedures.
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Gaps in employee training or institutional knowledge due to poor implementation or a lack of communication.
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New openings for intrusions that can lead to intentional adulteration or food fraud.
External changes brought on by a shifting food safety landscape are challenging to anticipate and adapt to, but internal operational changes at least offer the benefit of foresight. With the right preparation, you can address the risks these transitions cause before they negatively impact your food safety compliance.
Common Changes and Preventing the Risks They Introduce
Every operation is different, and the changes you implement will be unique to your facility's needs. That said, there are a handful of updates common to most food and beverage manufacturers that expose them to risks — requiring preparation and proactivity to respond effectively and prevent food safety incidents or non-compliances.
Before implementing internal process updates like those listed below, consider how you can prepare and make a plan to avoid unwanted food safety consequences:
Product Reformulations and Updated SKUs
Whether you're swapping out ingredients or adding a new SKU to your product line-up, any change to the products your facility produces comes with several food safety risks. If, for example, you plan to introduce a new allergenic ingredient to your facility, your team must be prepared to prevent allergen cross-contact and allergen mislabeling. This could affect production line schedules, cleaning and sanitation timelines, or even facility layout.
You must also consider how reformulation could affect bacterial growth and shelf life. For example, in foods like beef jerky, salt helps prolong freshness by keeping the meat dry and reducing potential microbial growth. So, if you reduce the salt content in this product's recipe, you may lose the preservative qualities this ingredient offers — creating the opportunity for bacterial growth.
How to Prepare:
If you are introducing a new allergen into production, it's vitally important that your team be up to date on their sanitation, food safety, and labeling knowledge. Consider how you might have to make facility changes to avoid allergen cross-contact, like introducing new cleaning schedules, zoning updates, staggering production timelines, and updating storage practices.
When introducing a new ingredient during reformulation, you must also update any standard operating procedures (SOPs) involving the ingredient, from temperature controls to recordkeeping — particularly when introducing allergens. In addition to adjusting production practices, your labels must also reflect the presence of allergens in both your product and facility.
Staffing Changes
Employee turnover plays a major role in your team's overall food safety preparedness. Whether it be the rotating door of seasonal workers you bring in every year, or employee turnover of experienced internal team members, staffing changes create knowledge gaps, impact food safety culture, and increase associated risks.
Every time you lose a team member, you also lose the hours of training you invested in them. New employees may have general food safety training, but that doesn't mean they'll be up to speed with your facility's processes or standards. These experience gaps create opportunities for mistakes — mistakes that could lead to food safety incidents and escalate into recalls, fines, non-compliance, legal liabilities, or even consumer harm.
How to Prepare:
Preventing staffing-related food safety risks requires two key tactics: proactive knowledge assessments and effective training programs. First, consider performing a skills assessment whenever bringing in new help — both temporary and permanent. This allows you to identify and get ahead of knowledge gaps and align your training to best prevent risk.
The quality of your onboarding is essential as well. Investing in expert-led food safety essentials training will provide your frontline workforce with a strong foundation. From there, you can identify gaps in specialized knowledge and use continuous training to fill these slots.
Equipment Upgrades
Although new equipment can improve efficiency, new machinery can also create new places for bacteria or allergens to hide. As your team adjusts to the operation and sanitation requirements of your new equipment, food safety risks like hard-to-clean corners may go unnoticed.
In the same vein, new equipment means a new maintenance schedule. If your team doesn't stay on top of maintenance, a new addition to your line could prove to be more of a liability than a benefit — whether it be due to physical, chemical, or biological contamination. The same goes for equipment calibration — as sensors that drift even a few degrees can lead to inaccurate documentation and potentially unsafe products.
How to Prepare:
Your first step when acquiring a new piece of equipment should be to take a close look at how it's built. Investing in equipment that meets sanitary design standards may help facilitate your cleaning process, but you also need to identify where your new machinery is most likely to collect contaminants.
Once you've identified these problem areas, make a plan for how to effectively clean this piece of equipment and incorporate it into your cleaning schedule. You must also perform preventive maintenance on your equipment to avoid unexpected production delays or food safety risks caused by breakdowns, loose parts, and more. Equipment testing is also important for ensuring your equipment's compliance over time.

Process Updates
In the event of internal process changes like new preventive maintenance schedules or traceability protocols, your team will need time to get the hang of them. During this introduction period, your team will likely make mistakes that could result in a food safety incident if they aren’t identified in time. Whether it be issues adapting to new technology or mix-ups on cleaning schedules, process updates are rife with potential risks.
Particularly when it comes to updated security protocols, agents who intend to cause harm may see this time of confusion as an easy opportunity to commit intentional adulteration or food fraud. If your team isn’t following proper security protocols, this could result in dangerous situations for your brand and consumers alike.
How to Prepare:
As you implement process updates, consider assigning an expert to your team to help smooth over the transition and keep an eye out for any potential missteps. An experienced and unbiased set of eyes available to monitor your transition and assist your team members can reduce costly mistakes that could impact your compliance or endanger your supply.
If you are updating your security measures, consider performing a food defense assessment or intrusion test. These evaluations will help ensure your new strategies are working as intended, both in theory and in real life — rather than unknowingly creating new opportunities for adulteration.
Supplier Changes
Whether it be due to supply chain disruptions or changing business needs, changing suppliers can lead to a handful of food safety challenges, including:
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Loss of consistency
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Lack of regulatory oversight
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Inadequate traceability practices
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Communication issues
Each of these challenges can create risks your organization will be held accountable for in the event that they harm consumers or go against international food safety standards. This is particularly true for businesses that must adhere to the FDA's FSMA Final Rule on Foreign Supplier Verification Programs (FSVP), like companies with suppliers outside the U.S.
How to Prepare:
Staying on top of supplier changes requires attention to detail both inside and outside your facility's operations. You must establish clear food safety expectations with new suppliers — including standards for data-sharing, communication, food safety schemes, and more. Once you've communicated these expectations, you must follow up on whether your suppliers are meeting them through regular, random supplier audits.
Internally, it’s also important to take extra food safety precautions to ensure no risks slip past your team as you acclimate to a new supplier's product. One way to do this is to increase or optimize your traceability efforts with new technologies and updated training. It's also important that your team is trained to spot signs of contamination or adulteration when receiving products from suppliers, such as damaged packaging or tampered seals.
Protect Your Operations From New Vulnerabilities
Internal change is a necessary part of progress and growth, but that doesn't mean it has to be scary. While transitions can introduce new food safety risks, preparing for what's to come before implementing these adjustments will help reduce the likelihood that they’ll become food safety incidents.
To keep your team on its toes amidst change, consider partnering with the experts at AIB International. Resources like our Food Defense Services and Food Safety and Sanitation Online training will help seal the cracks that form during times of change, ensuring your business stays up to standard and out of trouble.

