Avoiding High Risk Foods

Consumers who want to reduce the risk of foodborne illness should consider avoiding these foods.
 
Avoid high-risk foods, food-safety expert recommends
Friday, February 24, 2012
http://live.psu.edu/story/58000

UNIVERSITY PARK, Pa. -- It seems that hardly a week goes by without another reported case of some food being blamed for causing people to get sick. Most recently, a national restaurant chain's clover sprouts were linked to a Midwestern outbreak of pathogenic E. coli, and dozens of cases of Campylobacter in four states have been linked to the consumption of raw milk from a Pennsylvania dairy.

As consumers, we start to ask whether any foods are safe to eat.

While it is unlikely that we can completely eliminate the risk of foodborne illness, we can certainly identify a few food items that pose a higher risk of making us ill and avoid them, advises a food-safety expert with Penn State's College of Agricultural Sciences.

"One just needs to look through U.S. Centers for Disease Control reports to see that there are certain foods that show up time and again," said Martin Bucknavage, extension food-safety specialist. "In my opinion, these are foods we certainly should consider removing from our diet if we are interested in reducing our chances of contracting foodborne disease."

Following are a few foods Bucknavage suggests avoiding:

-- Raw sprouts. In the last 15 years, there have been at least 30 reported cases of foodborne illness linked to raw sprouts.

"Pathogenic bacteria come in on the seeds or beans, and during the sprouting process, the conditions are right for these bacteria to multiply," he explained. "Processors will sanitize seeds to remove bacteria, but that measure has not been foolproof."

-- Raw milk. People have consumed raw milk for ages, but from time to time, pathogenic bacteria make their way into the milk, Bucknavage noted.

"In the recent outbreak of foodborne illness related to raw milk sold in southern Pennsylvania, 77 people became infected by Campylobacter, which will cause severe diarrheal conditions for as long as a week or more."

Bucknavage conceded that there are avid proponents of drinking raw milk, who point to the fresh taste and the perceived health benefits.

"However, these health benefits have not been scientifically proven, and the working part of the cow, the udders, are close to the ground and can become contaminated with pathogenic organisms such as Salmonella, Campylobacter, Listeria and E. coli," he said.

"While most of those who sell raw milk keep the dairy environment as clean as they can and regularly test the health of the cows, a long history of outbreaks shows that there is a real risk of dangerous bacteria making their way into milk. This is why pasteurization became a standard practice in the late 1800s."

-- Raw oysters. These are another food that has a loyal following, Bucknavage pointed out. But he explained that oysters are filter feeders and can capture pathogenic bacteria and viruses if they are harvested in contaminated waters.

"A process such as depuration -- allowing oysters to live in cleaned water for a period of time -- can help, but use of this practice is limited," he said.

-- Undercooked ground beef. While some people undercook hamburgers intentionally, the majority do it because they do not use the correct endpoint for cooking, according to Bucknavage. They should measure the recommended internal temperature of 160 F using a meat thermometer.

"It would be fair to say that most people measure whether something is cooked by visual evaluation -- the lack of pink color," he said. "But this is an unreliable method.

"Some people will point out that they eat steak with pink in the middle. But this is different than hamburger. In the process of making hamburger, the meat is ground, and the exterior parts where the bacteria reside are mixed throughout the meat. Because of this, we need to achieve a higher cooking temperature in the center of the meat."

Chicken is another example of a food that often is undercooked, whether on purpose or by accident, Bucknavage lamented. Poultry has been shown to have a high prevalence, or contamination rate, of Campylobacter, he noted.

"To properly cook poultry, an internal temperature of 165 degrees Fahrenheit or higher is required," he said. "Otherwise, organisms such as Campylobacter can survive."

Along with avoiding high-risk foods, it is also important to practice effective cleaning and sanitizing of food-preparation surfaces and cooking utensils, Bucknavage said, as well as storing food under proper conditions. "Doing this, we can go a long way in protecting ourselves and our families from contracting foodborne illness."

Norovirus Outbreaks 2012

The leading cause of foodborne disease is making its mark this winter. Just this February, Norovirus caused more than 200 attendees at a cheerleader camp in Washington State to become ill. In St. Maarten, a cruise ship returned to port as 31 became ill. In Virginia, an elementary school was closed because so many students were ill. And in New Jersey, more than 400 college students become ill at three universities located in the same county.

There are some important reasons that lead to so many people becoming ill from Norovirus. One is the virus’s low infectious dose. It is estimated that it may take only 10 viral particles to make someone ill. Then, there is the ability of the virus to survive for up to two weeks on dry surfaces and in water for months. The virus can be spread through a number of ways including through contaminated food or water, from contaminated surfaces, directly from a sick person, or from the intake of aerosolized droplets of vomitus.

The main symptom of Norovirus infection is another factor for its spread – acute-onset vomiting. This prevents people from becoming sick in a secure location. Rather, rapid onset can occur at a dinner table, on a carpet, or on the bus. People usually become ill within 24 hours of exposure, although longer incubation periods do occur. Once someone is sick, they can experience symptoms for 24 to 72 hours, and can remain contagious for up to 3 days.  

Because of this short incubation time, low infectious dose, and ease of spread, one can see why it spreads through a school or a cruise ship so quickly. While rarely fatal, people who become ill need to watch so that they do not become dehydrated.

The most important key in preventing infection is frequent, but correct hand washing – scrubbing hands with soap and warm water. Additionally, it is important for people to stay home when ill, especially when they may have been exposed to someone who has had the illness. They should also stay home for at least 48 hours after systems have subsided. Contaminated surfaces must be cleaned using a strong chlorine bleach solution, 1 cup of bleach o one gallon of water.  Cooking will destroy the organism.

CDC link for additional information
http://www.cdc.gov/ncidod/dvrd/revb/gastro/norovirus.htm

Outbreak cases
http://www.inquisitr.com/193064/norovirus-outbreak-2012-washington-state-cheerleading-competition/
http://www.huffingtonpost.com/2012/02/13/crown-princess-departs-af_0_n_1272706.html
http://www.nbc12.com/story/16958672/norovirus-outbreak-causes-school-to-close
http://www.nj.com/mercer/index.ssf/2012/02/mercer_county_colleges_report.html

E. coli O26 infections linked to Clover Sprouts

Raw sprouts are responsible for another outbreak of foodborne illness and at least the fourth outbreak linked to the same restaurant chain, Jimmy Johns. In this latest case, there are 12 people infected with STEC O26 (CDC and AP link below). 

After the last outbreak linked to the restaurant chain in late 2010 where close to 120 people became ill with Salmonella, the chain switched from alfalfa sprouts to clover sprouts. But sprouts are sprouts – they are a higher risk food item in that it can be difficult to remove organisms such as Salmonella and E.coli from the seeds, and the process that allows the seed to sprout also may allow the organism to grow. Now, it appears the chain will drop sprouts from its menu (http://www.kirksvilledailyexpress.com/news/x1793836666/Jimmy-Johns-permanently-pulls-sprouts-from-menu). 

Tainted sprouts again linked to Jimmy John’s, outbreak is fourth linked to restaurantBy Associated Press, Published: February 15
http://www.washingtonpost.com/business/tainted-sprouts-again-linked-to-jimmy-johns-outbreak-is-fourth-linked-to-restaurant/2012/02/15/gIQAGxFVGR_story.html

WASHINGTON — Raw sprouts from the sandwich chain Jimmy John’s have been linked to an outbreak of foodborne illness — again.

The federal Centers for Disease Control and Prevention said Wednesday that 12 cases of E. coli poisoning in five states are linked to raw clover sprouts eaten at Jimmy John’s restaurants. The outbreak comes a year after raw alfalfa sprouts from one of the chain’s suppliers were linked to 140 salmonella illnesses. Sprouts from the chain’s suppliers were also linked to a 2009 salmonella outbreak in several Midwestern states and were suspected in an E. coli outbreak in Boulder, Colo. in 2008.

Raw Milk Testing Requirements - Outbeak of Campylobacter in Family Cow Raw Milk

In a recent report (below), there are now 77 cases of campylobacterosis from the consumption of raw milk associated with Family Cow.  What standards are in place for a dairy to sell raw milk?  Attached is the section on testing schedule from Pennsylvania's guidenance for those selling raw milk.  Note that there is no requirement for continuous testing.  In general, APC, coliform, and somatic cell counts are required twice per month and these parameters serve as indicators of sanitary quality,  However, actual pathogen testing is only required once every six months.  Now, dairies selling raw milk may be testing  more frequently.  Probably a good question for the producer of your raw milk.

Raw Milk Testing Standards
Guideance -
PERMITS ALLOWING THE SALE OF
RAW MILK FOR HUMAN CONSUMPTION
http://www.portal.state.pa.us/portal/server.pt/gateway/PTARGS_0_2_24476_10297_0_43/AgWebsite/Files/Publications/Draft_-_Revision_of_Raw_Milk_Guidance_Doc_Final.pdf
9. Regular Testing of Raw Milk.
a.  Responsibility. A raw milk permit holder is responsible to arrange for the regular sampling and testing required with respect to the raw milk permit, and to pay for this testing.

9b. 
Pennsylvania Approved Dairy Laboratories. All raw milk samples submitted for testing must be analyzed at an official laboratory (a laboratory which is under the direct supervision of the Department) or a  Pennsylvania approved dairy laboratory (a laboratory authorized or designated
by the Department as allowed to perform specific milk testing).
c.  Testing Schedule. A raw milk permit holder must coordinate raw milk testing on the following
schedule, and the raw milk samples must meet the following standards: 

Another illness case linked to The Family Cow's raw milk

http://www.publicopiniononline.com/localnews/ci_19984720

CHAMBERSBURG - The number of cases of sickness linked to The Family Cow raw milk stands at 77 in four states.

Expanding the list of bad [foodborne disease causing] bacteria?

There is currently a push to put a zero tolerance on four strains of drug-resistant salmonella in uncooked meat (link below). This comes after the 2011 outbreak of Salmonella linked to ground beef where 20 people were reported to become ill. (http://www.cdc.gov/salmonella/typhimurium-groundbeef/020112/index.html). The responsible organism was a multi-drug resistant strain of Salmonella Typhimurium.

Another recent expansion was the addition of 6 strains of E. coli non-O157 STEC. Although the testing program was to go into effect in March of 2012, it was pushed pack to June of 2012. The reason relates to the lack of validated test methods to detect the specific pathogenic strains (link below).

Looking for a given bacterial species is difficult enough, but when we have to look for strains of bacteria containing specific genes, reliable testing is not always easy. Throw in the fact that the product being tested is raw, and that the prevalence of bacteria is very low, and it makes one question to what degree can we track and eliminate the sources. (For example, FSIS reports the prevalence of Salmonella in ground beef is about 2% (http://www.fsis.usda.gov/PDF/Progress_Report_Salmonella_Testing.pdf), and in a 2009 study by ARS, the level for MDR Salmonella was only 0.6% (http://www.ncbi.nlm.nih.gov/pubmed/19201965)).  

Will consumers benefit? Will public health be better served? Will regulatory requirements for zero tolerance be enforceable or achievable?

Interesting note, a consumer group recently requested that FDA put a zero tolerance of Vibrio vulnificus on oysters (http://cspinet.org/new/201202091.html) to help protect those who choose to consume raw oysters. Vibrio vulnificus is a natural contaminate in waters where oysters are harvested, especially in the warmer months. In most all cases, the organism affects those who have underlying medical condition, primarily past or present alcohol abuse. Are oyster fisherman going to start testing oysters before delivering to the local shuck house? Why not just make it illegal to consumer raw oysters?

Salmonella Outbreak Spurs Call to Expand List of Banned Bacteria
February 08, 2012, 1:59 PM EST
Bloomberg Businessweek
http://www.businessweek.com/news/2012-02-08/salmonella-outbreak-spurs-call-to-expand-list-of-banned-bacteria.html
By Stephanie Armour

Recall of Cooked Eggs Highlights Need for Tight Food Safety Control of RTE Foodservice Product

The Cooked Egg recall this month once again shows how one glitch in a food safety system at one facility can have a ripple effect throughout the food chain. In this case, positive test results for Listeria on cooked eggs necessitated that the company recall up to 1 million cooked eggs. This in turn, has resulted in a dozen or so associated product recalls where these eggs were used as an ingredient as well as the removal of eggs from salad bars where eggs were served sliced, diced, or crumbled.

Consumers demand fresh, already-prepared foods, and so refrigerated ready-to-eat (RTE) foods are now a staple in many retail and convenience food stores. Most stores would be hard pressed to prepare every prepared RTE food item from scratch. They rely on their suppliers to pre-prepare many of these items, such as cooked eggs, to be mixed in as an ingredient to make a product or directly served as the finished product. Even many restaurants now use pre-prepared food items, some fully cooked, some partially cooked. Because of this, suppliers of these pre-prepared RTE items must have excellent food safety systems in place. These systems must account for the shipping, handling, and serving of foods without any additional cook step by the retail or foodservice company. Throw in the fact that consumers also want foods without preservatives , including lower salt, and one can see the increased challenges.

Listeria is one hazard associated with ready-to-eat refrigerated foods. This organism grows at refrigeration temperatures, so it can be found in the food plant environment that is not adequately cleaned. In addition to Listeria, there can be other hazards if there is temperature abuse of the product, such as Clostridium perfringens, Clostridium botulinum, and Staphylococcus aureus.

Hopefully this case raises the flag to all those who prepare RTE foods or food components as well as those who buy them. A small glitch in the system, such as this case where there was a repair in the packaging area, can produce a chain reaction of issues downstream, and more importantly, have the potential to produce illness in those who consumer the contaminated food.


Recall Reveals An Egg's Long Path To The Deli Sandwich

by Nancy Shute NPR February 9, 2012

http://www.npr.org/blogs/thesalt/2012/02/07/146540839/recall-reveals-an-eggs-long-path-to-the-deli-sandwich

Eli Manning and E.coli

In an article in International Business Times, a doctor  (and poet) "makes an arm-chaired" diagnosis that that Eli Manning had an E. coli infection prior to the playoff game with San Francisco.( http://www.ibtimes.com/articles/293025/20120204/eli-manning-sick-coli-flu-super-bowl.htm).  There are two issues with this - first, being sick for a day or so with diarrhea is insufficient evidence for calling Eli's bout of diarrhea an E. coli related illness.  E. coli infections are extremely serious and will last for more than a day or two.  It is unlikely that Eli would have ever made it to the playoff game if he truly had an E.coli infection. 

Second, and more importantly, when we call everything a foodborne disease, (such as a day of having diarrhea), we lose the importance of why food safety is so important.  It is not until someone is sitting on the pot for 3 or 4 days straight not knowing whether they will live another day, or they end up in the hospital due to severe dehydration, do people grasp what a foodborne infection is.  When people trivialize foodborne illness, they are less likely to take actions to prevent it.

So my "arm-chaired" analysis.......viral infection.

Outbreaks in the News this week (2/7/12)

There have been some interesting foodborne illness outbreaks in the news this week (Feb 7, 2012).  Here is a quick summary.

Clostridium perfrigens outbreak due to taco meat served at N.D. basketball game.  How it probably happened - the spore-forming organism survived the heat treatment and then grew in the taco meat when that cooked meat was not held at the proper temperature.  Temperature control of cooked food can be an issue  in venues like this.  Unfortunately, people are not willing to question servers when they receive meat products that are not hot.  People preparing and handling food may not have been trained.

http://www.ksfy.com/story/16689309/clostridium-perfringens-cause-of-pierre-outbreak

Watermelon the likely source for Salmonella outbreak – Over 35 people became ill (it occurred in England, so they became unwell) from eating ready-to-eat (pre-sliced) watermelon.  How it probably happened - during the watermelon slicing operation Salmonella was transferred from the outer surface to the interior surface.  This Salmonella could have originated on the raw fruit, and then been spread through the wash water.  If the sliced water melon was not refrigerated, Salmonella could grow on the more pH neutral fruit, making the situation worse.

http://www.telegraph.co.uk/news/uknews/9056645/One-person-dies-after-salmonella-outbreak-linked-to-watermelons.html

Update – Outbreak of Campylobacter from consumption of contaminated raw milk affects 43 people in 4 states.  The dairy has resumed sales. (That raw milk group is a dedicated bunch).

http://www.therecordherald.com/news/x962217783/Raw-milk-sales-resume-at-The-Family-Cow-in-Chambersburg

3 cruise ships disinfected after norovirus outbreak

http://www.washingtonpost.com/lifestyle/travel/ship-with-stomach-virus-outbreak-sets-sail-from-port-everglades-with-new-passengers/2012/02/06/gIQAc8aztQ_story.html?tid=pm_lifestyle_pop

Salmonella and Taco Bell - CDC to release or not to release

CDC released the final report on a multistate outbreak of Salmonella Enteritidis which was associated with eating food from a Mexican-style fast food restaurant chain, Restaurant Chain A.  This report, issued on January 19, 2011 (http://www.cdc.gov/salmonella/restaurant-enteriditis/011912/index.html) indicated that 68 individuals from 10 different states became ill from October, 2011 through November, 2011.

Much of the controversy now is that CDC or the FDA did not release the name of the restaurant which we now know is Taco Bell.  It is not agencies’ policy to release the name of establishments when it is determined that the release of this information will have no impact on other people becoming ill.  (http://abcnews.go.com/Blotter/hidden-outbreak-restaurants-stay-anonymous/story?id=15505386).  Having been to many food safety conferences over the years where CDC and FDA presented case study reports, I have seen that they never state the name of the company involved in the case being presented.

On one side, I can see the value in not releasing this name.  Often, the case is ongoing, so they need cooperation from the establishment.  Additionally, releasing this information can have a huge financial impact on the company.  We assume these investigations are air-tight, but that is absolutely the case.  We just need to look at how tomatoes were wrongly blamed in 2008 when peppers were actually the source. In that salsa outbreak, the tomato industry was devastated. (http://www.bloomberg.com/apps/news?pid=newsarchive&refer=columnist_skrzycki&sid=agA9XKef6P20).  In many investigations, the indictment of a food and associated producer is based on a statistical analysis without actual product testing, as was the case with Taco Bell.

On the other side, as a consumer, I want to know which establishments present a likely risk to me and my family.  The fact that an given establishment is involved indicated that they have a insufficient food safety system.  An added concern is the fact that there seems to be no clue as to the actual cause of the Salmonella contamination.  So, to what degree do we look at this company and question whether they have a potential condition under control?  In a statement, (http://blogs.ajc.com/business-beat/2012/02/02/taco-bell-salmonella-outbreak-remains-mystery/?cxntfid=blogs_business_beat) Taco Bell indicates that it is probably at the suppler level.  Is that giving you any confidence in the safety of their food?

Man treated for rabies after field dressing infected deer

A Pennsylvania man was treated for rabies after exposure from an infected deer he had shot and field dressed.
A few important points:
Hunters should avoid field dressing deer that look abnormal or that had acted abnormally (including hides with large or multiple lesions, internal organs with abscesses or that are foul smelling, or an animal that has exhibited unusual behavior, such as this case where the animal is growling.) In most all cases, the hunter should still take down the animal and then contact the Game Commission.
Always wear latex gloves when field dressing a deer, being sure to keep fluids from contracting your own skin.  (That includes refraining from spreading blood on your face as you pretend to be the Great Hunter.)
A little more on rabies from the CDC:

Rabies is a preventable viral disease of mammals most often transmitted through the bite of a rabid animal. The vast majority of rabies cases reported to the Centers for Disease Control and Prevention (CDC) each year occur in wild animals like raccoons, skunks, bats, and foxes.

The rabies virus infects the central nervous system, ultimately causing disease in the brain and death. The early symptoms of rabies in people are similar to that of many other illnesses, including fever, headache, and general weakness or discomfort. As the disease progresses, more specific symptoms appear and may include insomnia, anxiety, confusion, slight or partial paralysis, excitation, hallucinations, agitation, hypersalivation (increase in saliva), difficulty swallowing, and hydrophobia (fear of water). Death usually occurs within days of the onset of these symptoms
People usually get rabies from the bite of a rabid animal. It is also possible, but quite rare, that people may get rabies if infectious material from a rabid animal, such as saliva, gets directly into their eyes, nose, mouth, or a wound.
Scratches, abrasions, open wounds, or mucous membranes contaminated with saliva or other potentially infectious material (such as brain tissue) from a rabid animal constitute non-bite exposures. Occasionally reports of non-bite exposure are such that postexposure prophylaxis is given.

Hunters risk run-in with rabieshttp://www.poconorecord.com/apps/pbcs.dll/article?AID=/20120203/NEWS/202030348/-1/NEWS01

Recall of cooked eggs due to Listeria postive test results

Recall of cooked eggs and products made from those eggs due to Listeria contamination. Eggs were sold by Michael Foods under the brand names Columbia Valley Farms, GFS, Glenview Farms, Papetti's, Silverbrook and Wholesome Farms. These were institutional sized pails sold to other companies to be used in further packaging or used in foodservice. They were not sold directly to consumers. There have been no associated illnesses.

According to a report by the Wall Street Journal (link below), “

"The recall was initiated after lab testing revealed that some of the eggs within the recalled lot dates may have been contaminated with Listeria monocytogenes. A recall of three lot dates was announced on Thursday, January 26. As a precautionary measure, the recall was expanded today to include additional lot dates. Michael Foods reached the decision to expand this recall after a thorough investigation which indicated a specific repair project that took place in the packaging room as the likely source of the contamination. The company has taken a number of corrective steps to address the issue and prevent recurrence"

Interesting to note was that work was done in the packaging room. This is a common issue – repair work either introduces Listeria, or releases it from some location where it has been in an inactive state, probably for some time. Whenever work is done, in a kitchen or a processing room, extra attention must be paid to cleaning and sanitizing the area where the work occurred. Additionally, heavy verification testing is recommended to ensure that an organism like Listeria is not present.

 Also, this is another case where positive results obtained through a third party testing laboratory, perhaps done on behalf of a customer, has triggered a recall that has affected a widening number of other customers.


FDA recall notices:
Michael Foods, Inc. is recalling specific lot dates of hard-cooked eggs in brine sold in 10- and 25-pound pails for institutional use that were produced at its Wakefield, Nebraska facility because the product has the potential to be contaminated with Listeria monocytogenes.
http://www.fda.gov/Safety/Recalls/ucm289920.htm
Allison’s Gourmet Kitchens Recalls Prepared Salads that Contain Hard Cooked Eggs - The recalled Prepared Salads that contain hard cooked eggs were distributed in Texas, Oklahoma, Alabama, Kansas, Illinois, Louisiana, Nebraska, South Carolina, North Carolina, Virginia, Pennsylvania, Florida, Tennessee and Missouri.
http://www.fda.gov/Safety/Recalls/ucm290212.htm

Wegmans Food Markets, Inc. is recalling hard-cooked eggs, as well as prepared foods that contain hard-cooked eggs, sold between January 23 and February 1, 2012 because the eggs have the potential to be contaminated with Listeria monocytogenes. …products sold in Wegmans prepared foods and deli departments….
http://www.fda.gov/Safety/Recalls/ucm290198.htm

Raw Milk and Campylobacter - Outbreak in PA

There are now close to 40 cases of Campylobacteriosis related to raw milk sold by a Pennsylvania dairy (Franklin County). Although the Campylobacter bacteria has been isolated from bottles of the milk, proponents march on in defense of raw milk – either denying it was the milk, or claiming their right to drink raw milk (read comment on the bottom of page by an advocate).

Campylobacter is a very serious illness. From the CDC (http://www.cdc.gov/nczved/divisions/dfbmd/diseases/campylobacter/):
Campylobacteriosis is an infectious disease caused by bacteria of the genus Campylobacter. Most people who become ill with campylobacteriosis get diarrhea, cramping, abdominal pain, and fever within two to five days after exposure to the organism. The diarrhea may be bloody and can be accompanied by nausea and vomiting. The illness typically lasts one week. Some infected persons do not have any symptoms. In persons with compromised immune systems, Campylobacter occasionally spreads to the bloodstream and causes a serious life-threatening infection.
I believe that people do have the right to drink raw milk, eat raw eggs, and eat raw oysters. But, people need to understand the real risk associated with these products AND society should not pick up the cost once they become sick, or perhaps even ensuring compliance of raw milk producers (that should be built into the cost of product).

Number of people with illnesses linked to raw milk rising in Pa., Md. W.Va.
Lab tests confirm bacteria's presence in raw milk from Chambersburg dairyFebruary 02, 2012|By JENNIFER FITCH | waynesboro@herald-mail.com
 http://articles.herald-mail.com/2012-02-02/news/31019695_1_raw-milk-unpasteurized-milk-dairy-farm

Revisiting Third Party Food Safety Audits

Once again third party audits take heat for an outbreak, in this case, the Listeria outbreak in Jenson Farms Cantaloupes.. In the USA Today, two viewpoints are presented. Both present valid points, but there is more that can be said. Third party food safety audits provide a snapshot evaluation of the food safety system of an organization and give an assessment of whether that facility is following that food safety system. One important limitation is that audits, as currently completed, are not as good at determining the validity of that system, in other words, how well that system is actually working to make safe food. An astute auditor can see signs that the plan is valid through results of pathogen testing, through the process parameters that are set up, but there are factors that limit this.

•  Auditors often cover a broad range of facilities and process types (even within the same commodity) and so it is difficult to have an in depth understanding of every process in every facility an auditor visits. They will not have the vast knowledge of a given pathogen as compared to a PhD who has studied that pathogen for years.
• Audits are often one day in duration, so there is little time to get into the nuts and bolts of the process. Audits will look at the broad systems that are in place and make sure they are being followed (such as GMP’s, supplier control, pest control, HACCP), but to look at the validity of a process can take days, especially when there is the lack of support documentation such as pathogen testing.
•  In most cases, auditors are not conducting microbiological analysis of the environment or of the finished product. They may look at results that are on file, but they themselves are not swabbing surfaces or pulling product from the end of the line and sending to a qualified laboratory. As was seen in the PCA case, a company may only show select results from a less reputable laboratory. So to what degree can an auditor, in a day or so, evaluate the laboratory being used, the methods that laboratory is using, and the sampling scheme used by the plant?
•  Auditors will count, in part, that the facility actually knows what it is doing. If a facility has been processing cantaloupes for years, it is easy to make the assumption they must have some clue of what they are doing. They can question why a change was made, in this case the change in process, but to make a call on the safety of that change is more difficult.
•  Companies being audited do want to pass the audit. Their business depends on it. When they hire an auditor, it is less likely they will put themselves in a position to fail….and that may mean hiring someone they know who will not put them through the ringer. Indeed, this a conflict of interest. But this practice of having the supplier pay for their own audit was started years ago by the purchasing companies requiring the audits. To get out of paying for audits of every supplier, they had the idea to make the supplier pay for the audit. Sure, the customer company provides a list of audit firms or auditors from which the supplier can choose, but still, the supplier still hires that person.

  

Because of these limitations associated with third party audits, they are not a guarantee of product safety. Rather, they are just a part of the entire food safety system that a company uses to ensure safe food. If a company uses the fact that they passed an audit as sole reason for why they believe their food is safe, then that company probably does not have true food safety systems in place. The goal of the audit for the food company is to assess their systems and provide feedback on where improvement is needed. Each aspect of the audit is there for a reason, so food companies need to embrace the intent of the requirement, not just to throw something in place to pass the audit.

  

While there has been a ratcheting up of requirements through GFSI (SQF and BRC) on both what is required in audits and what is required for someone to be a qualified auditor, some of these issues still exist. Even with government based inspection, there are similar shortcomings. Audits are an important part of our food safety system, whether internal, second party, third party , or government, but the responsibility for food safety ultimately falls on the company producing the food. Food companies must use these audits as guideposts for continual improvement. Employees, managers, and just as importantly, executive management must thoroughly understand their process and product. They must challenge themselves, with the help of auditors, to ensure their food safety system has addressed all possible food safety hazards.

  

by Martin Bucknavage 12/1/12