ERS Publishes Report on Recall Trends from 2004 to 2014

The USDA Economic Resource Service published their report, Trends in Food Recalls 2004-13,that summarizes the reasons for recalls from 2004 to 2013.

A few of the conclusions:

The number of food recalls has increased each year.  While the risk of food has [most probably] NOT increased, the number of recalls has increased, according to the report, due to:

• An increasingly complex food supply system
• Technology improvements in health risk detection,
• Increased regulatory oversight and enforcement, and the passing of two major food policy laws (FALCPA and FSMA)

       But these also need to be considered as primary drivers for increased recalls:

• Increased testing by companies 
• Increased testing by state laboratories (this may be considered part of increased regulatory oversight]
• A lower tolerance for issues by consumers  - primarily foreign materials
• The increased willingness of companies to recall food if an ingredient was recalled, even though that company's process would have eliminated the hazard

"The second major insight from the analysis is the significant increase in the number of recalls due to undeclared allergens. From 2004 through 2013, undeclared allergens were a leading cause of food recalls, accounting for 27.4 percent of all recall events."

There is a lot of information in the report, but I find that summaries are not as useful as the more detailed information for the particular industries.  These tables showing total number for the decade may be misleading because so much has changed during that time, and continues to change after that time. 











Economic Research Service
https://www.ers.usda.gov/webdocs/publications/88497/eib-191.pdf?v=43206
Trends in Food Recalls: 2004-13
Elina Tselepidakis Page
Economic Information Bulletin Number 191
April 2018

Abstract

This report identifies trends, patterns, and outliers of food product recalls in the United States from 2004 through 2013. The analysis considers four factors: the types of foods being recalled, the reasons for initiating the recalls, the severity of the risks posed by the recalled products, and the geographic distribution. The results reveal that recall events increased across several major aggregate food categories (grain products, animal products, and prepared foods and meals), increased across all three risk severity classes, and occurred more frequently in highly populated States. Additionally, undeclared allergens were a leading cause of food product recalls, with the number of undeclared allergen recalls nearly doubling over the decade. Last, ingredient-driven recall events were the source of several extreme time trend outliers.

What Did the Study Find?

Between 2004 and 2008, food recalls averaged 304 a year; between 2009 and 2013, the annual average rose to 676. While an increase in the volume of food sold in the United States during this decade partially explains this statistically significant increase, other factors are also likely at play. For example, pathogen and risk detection technology substantially improved, regulatory oversight and enforcement increased, and Congress passed two major food policy laws: the Food Allergen Labeling and Consumer Protection Act (FALCPA) and the FDA Food Safety Modernization Act (FSMA).

The following six food categories accounted for the majority of food recalls in 2004-13: prepared foods and meals (excluding soups), 11.9 percent of all food recalls; nuts, seeds, and nut products, 10.9 percent; baked goods (including packaged baked goods), 9.0 percent; grains and grain products
(excluding baked goods), 8.4 percent; candy products, 7.9 percent; and sauces, condiments, and dressings, 5.0 percent. For each of these foods, with the exception of nut products, the most common reason for initiating the recall was failure to declare major allergens. The most common reason for recalls of nut products was possible Salmonella contamination. While the number of food product recalls increased across every food category, the increase was statistically significant only for grain products, animal products, and prepared foods and meals.

Analyzing recalls by type of risk, 41.0 percent were the result of pathogen contamination (Shiga toxin-producing Escherichia coli, Salmonella, etc.) and 27.4 percent were the result of undeclared
allergens. While the number of recalls due to pathogen contamination did not increase significantly during this decade, the number of allergen recalls nearly doubled. The passage of FALCPA likely played a major role in the growing number of undeclared allergen recalls.

Last, food product recalls of common ingredients may have significant and exponential impacts on manufacturers and users of recalled ingredients. From 2004 through 2013, 22.4 percent of all recalls were the result of an upstream ingredient being recalled first.

Conclusion

Food product recall events increased by an average of 20 events a year from 2004 through 2013. However, this upward trend should not be interpreted to mean that foods are becoming riskier. Rather, an increasingly complex food supply system, technology improvements in health risk detection, increased regulatory oversight and enforcement, and the passing of two major food policy laws (FALCPA and FSMA) may have all contributed to the significant rise in food recalls. By examining trends and patterns, we can further pinpoint driving factors and form educated hypotheses behind the overall increase in food recalls. To do that, this report analyzed recall events over time by the types of foods recalled, the health risks involved, the severity of the health risks, and the geographic distribution of recalled products. Identification of any patterns and trends can provide guidance for manufacturer best practices and targets for regulatory oversight. Moreover, an analysis of this sort that considers both FDA and FSIS recalls has not previously been completed and fills an important void in the literature.

The results reveal that recalls increased across several major aggregate food categories (grain products, animal products, and prepared foods), increased across all three severity classes (particularly Class II), and occurred more frequently in highly populated States. Additionally, the results highlight two major recent trends. The first is the potential magnitude and impact of ingredient-driven recall events, the source of several extreme time trend outliers, including those involving peanut butter, pistachios, and HVP. Recalls of upstream ingredients can expand exponentially and impact dozens, if not hundreds, of downstream manufacturers that use the implicated ingredients. From 2004 through 2013, 22.4 percent of all recalls were the result of an upstream ingredient being recalled first. The widespread impact of these expanded recalls suggests that high-risk ingredients that are shipped to multiple manufacturers through various marketing channels for consumption in various settings may require greater oversight to prevent disastrous ripple effects for downstream manufacturers.

The second major insight from the analysis is the significant increase in the number of recalls due to undeclared allergens. From 2004 through 2013, undeclared allergens were a leading cause of food recalls, accounting for 27.4 percent of all recall events. Accurately labeling allergens is vital for public health, especially for the public health of children under age 18. Four out of every 100 children in the United States report having a food allergy (Branum and Lukacs, 2008), and the prevalence of reported food allergies is only increasing (Jackson et al., 2013). Effective in 2006, FALCPA requires that all eight major food allergens (wheat, eggs, peanuts, milk, tree nuts, soybeans, fish, and crustacean shellfish) be properly labeled on food products. Thus, FALCPA likely played a major role in the dramatic increase in the number of undeclared allergen recalls. Future work monitoring undeclared allergen recalls is needed to determine whether the total number of recalls continues to increase or whether the observed increase was part of an industry adjustment period as manufacturers adapted to the requirements of FALCPA. In any case, in contrast to pathogen contamination, which did not cause a significant increase in the total number of recalls, undeclared allergens are largely a labeling issue because unlabeled food products pose health risks only to individuals with allergies. Given the massive expense recalls present, this finding suggests that more time and effort spent reviewing labels to ensure they are accurate prior to sale would likely contribute to a reduction in recalls.

In all, food product recalls have significant impacts on both producers and consumers. For producers, recalls represent a massive expense that can potentially bankrupt manufacturers. For consumers, recalls signal unsafe foods, and concerns of foodborne disease can potentially influence consumer demand. Given the increasing number of recalls and the substantial direct and indirect costs of recalls on producers, consumers, and regulators, there is a fundamental need to identify and understand trends such as the ripple effects of ingredient-driven recall events and the increase in undeclared allergen recalls. These insights can provide guidance for manufacturer and regulator efforts, and potentially reduce recall costs and improve the overall quality and safety of the food supply.