Thomas Jefferson is often credited with this quote: “With great risk comes great reward.” That may apply in some areas of business, but when it comes to serving food, there is no reward for any level of risk in food safety and protecting public health. Zero.
This understanding within the c-store industry is why the NACS Food Safety Forum has become one of the most important industry events of the year. The 2025 Forum in Dallas hit record attendance and reached a level where, as one attendee suggested, we need a bigger boat.
The CEO Perspective
Food safety begins at the top, a sentiment echoed by TXB’s Kevin Smartt and Kwik Trip’s Dr. Scott Zietlow.
For both companies, fresh-prepared foodservice is a driving force that continues to transform how their customers engage with their respective brands. This commitment to food has changed their business models, with food safety as a core value within their companies and their cultures.
Smartt, the 2021-22 NACS chairman and president and CEO of TXB Stores, based in Austin, Texas, emphasized the importance of food safety—and not just in terms of preventing foodborne illnesses. He shared an example of a well-trained team member who was in a hurry and skipped an important safety procedure, which led to an injury.
“Those are the things that keep me up at night. We handle and cut a lot of fresh items, so I would really think about [your culture] and how team members” are staying safe, Smartt said.
Zietlow, the CEO, president and chairman of La Crosse, Wisconsin-based Kwik Trip Inc., said that food safety culture is an integral part of the overall organizational culture. He explained that it involves doing the right thing consistently, even when no one is watching, so that it becomes a way of life.
Like TXB, food safety culture at Kwik Trip is driven top down throughout the entire organization. “It’s reinforced in every meeting and it’s in our actions. We are committed to continuous improvement in everything that we do, and it’s how we get better every day,” said Zietlow.
Look for the Opportunities
Several themes guided this year’s Forum: traceability, technology and trust.
First, traceability.
The initial compliance deadline for the FDA’s Food Traceability Rule was set to take effect on January 20, 2026. Earlier this year the FDA announced plans to extend the deadline by 30 months until the summer of 2028, but also said it has no plans to change the rule’s existing requirements.
The advice to retailers is keep moving forward—use the extra time to test your traceability plans while working with industry partners to ensure your company can meet compliance requirements.
Dr. Jennifer McEntire, founder of Food Safety Strategy LLC (foodsafetystrategy.com), said that traceability is “a data systems problem” that lands on food safety and quality assurance teams because the rule is in the context of a recall or foodborne illness event.
“For this rule, more so than other food safety-related rules, you need a diverse team of people from IT, procurement and sales to come together because it’s a supply chain rule and it’s a systems rule,” she said.
Jon Cox, vice president of retail foodservice at McLane Company Inc., highlighted challenges the rule has posed thus far to companies working to ensure compliance:
- Confusion/inconsistencies about whether certain items are on the Food Traceability List (FTL) and should/should not be traced, leading some firms to believe they need to take a “blanket approach” that is not necessary.
- Tracking the Traceability Lot Codes (TLCs), especially when companies ship and receive truckloads of products that may have multiple lot codes on multiple pallets. This creates a complex system of separating all lot codes and transforming the data to ship to customers.
- Data inconsistency can also arise in how FTL items are labeled and traced. For example, different systems may have different names for the same product, making it difficult to get consistent data through the supply chain.
- Handling break packs, where products are shipped in smaller quantities than the original packaging. The TLC is often printed on the master case and not the smaller packs, which can make the product difficult to trace.
- Slow adoption of industry traceability approaches, such as using GS1-128 barcodes. (Go to gs1us.org for more information.)
Second, technology.
“Technology makes our lives easier, more efficient and more productive,” said Jason Borror, director of food safety and quality assurance, North America, at Circle K. Ask what problem you’re trying to solve and how technology can help.
For Circle K, technology is reshaping how food safety is managed and monitored, which leads to more proactive and accurate approaches to preventing foodborne illness. “As new technology continues to emerge, it will likely revolutionize the food safety landscape, providing greater protection for our customers,” said Borror.
He explained how Circle K mapped its “physical” processes, which included manual temperature logs, equipment monitoring, labeling and corrective actions. These processes were cumbersome, time consuming and relied on a ton of paperwork.
Borror shared a couple examples of where Circle K has implemented technology to improve operational efficiencies:
- Automated equipment monitoring with sensors in coolers and freezers, which eliminated the need for manual checks
- Integrating its production planner with the labeling platform to automate label printing based on the number of items prepared
“As food safety leaders, we should be looking at integrating technology throughout our organizations—not just to satisfy food safety and regulatory compliance, but also to ensure the appropriate controls are embedded to drive operational efficiencies and build a culture that can support our growth,” said Borror.
Third, trust.
Foodservice drove in-store sales in U.S. convenience stores to record levels in 2024. It accounted for 28.7% of in-store sales and 38.6% of in-store gross margin dollars, according to the NACS State of the Industry Report® of 2024 Data.
Foodservice includes prepared food; commissary; and hot, cold, and frozen dispensed beverages. The broadest of the five foodservice categories, prepared food, generated nearly three quarters (72.6%) of all foodservice sales in 2024.
This growth in food prepared inside stores and oftentimes in front of customers—pizza, chicken, salads, sandwiches and wraps, burgers, roller grill items, soup—translates to the goal of building and maintaining trust that the food is high quality, fresh and safe.
Speaking to fellow food safety professionals in the room about the behind-the-scenes work of food safety teams, Amy Costello, director of food safety and quality assurance at Ankeny, Iowa-based Casey’s said: “We don’t necessarily want our guests thinking about the food safety departments in our organizations when they’re choosing our food. If they are, it’s probably because something had previously gone wrong.”
“Our food programs are growing, our guests trust our brands, and we’re proving that they trust our channel. That’s a huge responsibility for all of us,” she said.
Building consumer trust, according to Costello and Shawn Stevens, the founder of Food Industry Counsel LLC, goes hand in hand with the quality of products sold in convenience stores.
“When we see low quality coming through our systems, red flags should go off because that means safety is not a priority,” said Stevens. “If we enhance the quality of the product, it’s going to be safer.”
This hyperfocus on product quality also relies on supply chain relationships that keep the momentum moving forward on consumer trust.
Strong relationships with suppliers also help ensure compliance with food safety standards. Costello and Stevens agreed that suppliers need to establish and meet their own internal food safety standards, and it’s important for retailers to know and understand the culture and programs of their suppliers.
“The first conversation with a food safety team from a supplier company shouldn’t be when we’re having an issue with them. We want to know who they are, and we want to understand their culture. We want to have those connections in place so that if an issue does arise, we know who we’re working with and we know how they’re going to approach it,” said Costello.
Managing Your Risk With 10 Key Focus Areas
Dr. Jay Ellingson, chief scientific officer at Kwik Trip, outlined 10 key focus areas that every retailer can adopt to keep their brands, their customers and their employees safe. These areas apply no matter the size of a c-store company.
- Food safety is a company-wide responsibility: Everyone, including the CEO, plays a role in maintaining high food safety standards.
- Prioritize food safety among your employees: Ensure food safety is a top priority, just like the well-being of your team.
- Engage with experts: Seek advice from industry experts and regulatory agencies.
- Put the right people in the right roles: And provide them with the necessary support and resources to succeed.
- Lead by example: Demonstrate food safety in everyday actions and decisions.
- Honor and enforce policies consistently: Ensure actions align with policies and procedures.
- Address potential issues correctly: Identify challenges before they become problems.
- Involve experts: Engage microbiologists and other specialists to address critical and complex food safety concerns.
- Invest in the right solution: Prioritize effective solutions for food safety, even if they are beyond the budget.
- Take responsibility for your suppliers: Hold suppliers accountable to the same high food safety standards your company upholds.
These points emphasize that food safety is not a competitive advantage, said Ellingson. “Protecting public health is our collective responsibility. It doesn’t matter how many stores you have—if you sell food, we are all responsible for adhering to high food safety standards.”
To do this, “You need to build a team,” advised Ellingson. “You need to have the right people to improve your food safety management systems if you’re going to be in the business of selling food. … We need to all work together to do this right, and I feel like the team is in this room today that can help the c-store industry,” he said.
That said, plan to be in the room at the 2026 NACS Food Safety Forum. Details will be shared at convenience.org/FSF.
What Is the FDA Traceability Rule?
The U.S. Food and Drug Administration’s (FDA) Traceability rule is foundational to the agency’s New Era of Smarter Food Safety Blueprint and implements Section 204(d) of the Food Safety Modernization Act (FSMA).
The rule mandates recordkeeping requirements, in addition to existing regulations, for companies involved in the manufacturing, processing, packing or holding of foods on the FDA’s Food Traceability List (FTL).
These FTL foods include produce like leafy greens, fresh tomatoes, fresh cut fruits and vegetables, fresh cucumbers and ready-to-eat deli salads. Non-produce items on the FTL include shell eggs, nut butters, certain cheeses and finfish (e.g., salmon and tuna), to name a few. Foods that contain FTL ingredients are also covered by the rule, giving the rule wide reach.
Foods on the FTL require additional traceability information, called Key Data Elements (KDE), which are associated with specific Critical Tracking Events (CTE). Many KDEs are already captured—locations, quantities, descriptions, etc.
The sharing of the Traceability Lot Code (TLC) has caused the most angst. In the event of an issue, such as an active foodborne outbreak, the FDA will require KDEs within 24 hours (or within a reasonable time the FDA agrees to).
Once a TLC is assigned, which can only be done at certain CTEs, it must stay the same as the food moves through the supply chain and can only be changed or removed if the food is transformed or undergoes a kill step. “License Plate Numbers” or other pallet identifiers commonly applied by distributors cannot replace the TLC.
The information that companies must keep varies depending on the type of supply chain activities they perform with respect to an FTL food— e.g., the CTEs—from harvesting or production of the food through processing, distribution and receipt at retail or other points of service.
For comprehensive information on the traceability rule and a full list of FTL foods, go to FDA.gov to view a robust set of resources under the “FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods” section.