Another excerpt from the Dec. 9 transcript of the USDA-FDA hearing on traceability. This time, a Darden executive talks about their food safety expectations of suppliers.

Ana Hooper is the Vice President of Total Quality for Darden. Ana and her team ensure the safety and quality of more than 3,000 different products that come from 1500 suppliers and more than 35 countries. They're also responsible for food safety and quality practices within the nearly 1800 Darden Restaurants that collectively serve more than 400 million meals annually.

MS. HOOPER: Good morning. First, I just want to say thank you to FDA and FSIS for hosting this very important meeting and for including as part of the panelists. Just a little bit more on who is Darden. You know us probably best as Red Lobster, Olive Garden, Longhorn Steakhouse, the Capital Grill, and Bahama Breeze, and Seasons 52.

As Dr. Goldman pointed out earlier, it's quite a large group that we are. We have almost 1800 restaurants and 180,000 people work for us across North America, and we serve over 400 million meals annually. That's a lot of people that we touch. Our supply chain is very large. It's robust. It's global. We spend $2.5 billion a year, and we bring in quite a bit of seafood to support Red Lobster as well as the steaks for Longhorn Steakhouse.

 So how do we manage this? How do we even keep tabs? I just want to touch a little bit on the proactive components because the traceability is a key aspect of our global food safety strategy. We're fortunate to have a large team. It's an international team of professionals, many who are located in the countries from which we purchase.

So that gives us a little bit greater assurance. We're divided up into four main buckets, if you will. We have our seafood group. We have our commodities, which is everything but seafood but doesn't include fresh produce because that's a whole category in and of itself. And then we have our restaurants. We hold ourselves to the same criteria that we hold our suppliers accountable for us, 1800 restaurants or 1800 mini-processing facilities.

We do utilize a risk-based HACCP approach to the supply chain, and we trust and feel that we have proven along the way that this is quite effective in preventing foodborne illness in the finished product, as well as ensuring the protection from the farm to plate and et cetera, pond to plate, farm to fork, you name it. It's the same thing. Moving onto ensuring that we have the visibility that we need, once we have that HACCP program, we're very clear in the requirements with our suppliers.

We do take the time to coach and teach especially as we're partnering with developing economies. We can't just be dealing with the big guys. We need to come in and develop these folks and clearly identify what are the components that are just non-negotiable. They're just part of the cost of doing business with Darden, and it's a win-win.

 We help our suppliers understand the benefit to their businesses as well as to minimizing the risks, not just for the consumer, but minimizing the risks to their brands, as well as ours. So it begins with the manufacturing facilities. We cannot purchase anything from anyone that has not been properly assessed by third parties. We utilize our own team to set them up for success, but we have the third party verification.

The product specs have to clearly delineate the expectations from the quality components but also clearly the expectations of the food safety components, and everything needs to meet not only the standards expected within the countries, the economies where we're processing the items, but they also have to meet the consumer receiving countries, which is the U.S. and Canada. We insist on having the visibility again to that critical product data and ensure that corrective actions are implemented as necessary and quickly, and again external verification of the product compliance utilizing FDA approved methods and third party certification.

 So then that leads to, okay, what is the expectation on traceability? And we have to have that assurance that the products can be traced back, and I'll put it this way, as far back as it can be taken. It can't always go back to 100 percent where that pond or 100 percent where that field, but if we can minimize the parameters, then perhaps you're only going to be dealing, in case there were an outbreak, with maybe two ponds or three ponds, but we do hold, every step of the process has to be clearly delineated, and these suppliers have to keep track. We do go in with the global team to ensure that this is happening. We're moving towards the intelligent barcoding throughout the supply chain.

We're not completely there yet, but we have made a corporate decision and moved to a GS1. Being in a global economy and with I think GS1 is in 145 different countries, it just will facilitate the dialogue, if you will, in developing these suppliers. It certainly is aligned with the produce industry's initiative, and we need to be able to further automate, if you will, what we're doing in many cases more manually. Finally, expectations on the product traceability have to address shelf life management, and also our suppliers have to have clearly defined and tested food safety crisis management. All right.

 Our response to a food safety crisis is something that we take very seriously. It is imperative to successfully and swiftly manage and contain that incident and ensure speed of action for the problem resolution, as having very, very clear timely communications internally and externally. So what we expect from our suppliers, and they know this up front, is give us the basics. I mean you, Mr. and Ms. Supplier, need to know exactly how much you produce, by date code, and that's how we define a lot, and again that's one of the things that is subject to further discussion as FDA and FSIS consider the critical components of an effective traceability system.

But for us at Darden, it's Mr. Supplier, you need to tell us how much did you produce, where did you ship it, and how much is remaining on hand. Then the lockdown begins because we do that at every step of the supply chain flow. We have to do that at the DCs, we have to communicate it to the restaurants in case something's in transit, just lock it in and go from there. Now, we also have an expectation for our suppliers to have a similar process in place with their raw material providers so that we can trace it back. Just quickly, a couple of examples.

With the tomatoes, we're unique in the industry in that we're more vertically integrated. So we have people in the fields. We call it the feet in the fields, and these folks are located so where they are constantly checking the records. We know where those products go. But with the tomato outbreak, we react to an advisory as though we're a recall. We don't take any chances. So a little bit of the frustration on Darden's side is, gee, we had to take all those tomatoes off.

There's huge cost to the industry, and yet we know they're safe. How can we better collaborate? A little bit different spin on the dry milk powder recall that occurred recently, and that was an ingredient in one of our sauces at Olive Garden, and even though the sauce was going to be heated to 185 degrees, we chose to err on the more conservative side and we withdrew everything. But I want to mention that because as we give consideration to developing these systems, this dry milk powder had many, many names out there. It kept switching names, and we would have never known that it was in our product because it was only an ingredient.

 But again, in this particular scenario, the supplier who was providing us with that did follow through on holding their raw material providers accountable and notified us, and so when we had dialogue with FDA, there were no surprise elements on both sides. Next. So I would say that where do we go from here? You know, we share the same goals as FDA and FSIS. We need to find the problem, contain it, trace it back, make sure that everybody who needs to know hears it quickly and resolve it, but what could be done to improve it?

And we believe that collaboration is just key. We need to talk more, and I realize there are all kinds of legal constraints once there is an outbreak that is being investigated, but if there were a way to just talk sooner, there's a lot that industry, especially industry of the size that Darden is, and many other industry or segments, that we can bring to the table to again help minimize the search time. That translates to the most important thing I have here at the end. It translates to minimizing the prolonged investigation because it does have a health impact. So if we can come to the table and say, you know what? We buy from all these folks.

We have all the out turn reports that verify these products are safe. Look at all the millions of people that we're serving. Nobody's become ill because we do track suspect foodborne illnesses. We'll open our books to you. So let's come to the table. Let's bring whatever information we have, share it, and let regulators go then to, call it the underbelly. I don't know. Call it the ones that need more attention, but if we can just talk and collaborate just a little bit earlier in the process, I think we can shorten the span of time. Thank you.