CBD Oil - Illegal for Food, Science Largely Unknown

Many entrepreneurial companies have been moving forward on CBD infused food products, but from an FDA stance, these are illegal to sell.  (CBD oil is derived from hemp/no THC.)  It is hard to believe with as many items we hear about including CBD infused gummies, drinks, and other foods.  Unfortunately, many state and local agencies have taken a less stringent stand against use of CBD oil in food and dietary supplements.  Not that the FDA has taken a hard stance on the chemical.  From a Post Star article, "Until last year, there was a federal ban on CBD. Not that the FDA enforced it. Beyond firing off a few letters ordering manufacturers to stop making unproven health claims, the FDA made no efforts to stop commerce. After all, CBD never killed anyone."

A Science News article on CBD oil, it states the science behind the benefits is largely unknown.  It has been approved as a drug to treat epilepsy in children.  But how it works and the impact on the average person...there has not been enough research.

The only clear benefit in food is the mark-up in price.  Adding CBD oil to a food item allows the seller to jack up the price.  And with no standards, it is easy for the amount added to be extremely small to perhaps nonexistent.  So before stopping off to buy your CBP infused smoothie, you may want to think about what you are really buying.  A this point, just expensive, technically illegal, hype.

https://poststar.com/news/national/selling-cbd-in-food-is-illegal-fda-says-so-why/article_f3e378c4-f75d-5667-a83c-d05690ed9d43.html
Selling CBD in food is illegal, FDA says. So why are so many retailers selling it?
Sam Wood Tribune News Service
March 31, 2019

This Week in Mislabeled Product for Week Ending March 30, 2019

Pâté Missing Milk and Soy - Market of Choice, Inc., an Eugene, Ore. establishment, is recalling approximately 1,094 pounds of pork and poultry pâté products due to misbranding and undeclared allergens - The products contain milk and soy, known allergens, which are not declared on the product label.  The problem was discovered when Market of Choice reported to the U.S. Food and Drug Administration (FDA) and the Oregon Department of Agriculture the undeclared allergens. The FDA notified FSIS, which has jurisdiction over the pork and poultry pate products.

Mislabeling of Chocolate Bars - Theo Chocolate of Seattle, WA is voluntarily recalling 3oz Sea Salt 70% Dark Chocolate bars (UPC 8 74492 00325 8) because they may contain undeclared milk. The recall was initiated after it was discovered that a small number of 3oz Salted Toffee Dark Chocolate bars were mis-labeled with 3oz Sea Salt 70% Dark Chocolate labels and shipped to select distributors, retail stores and consumers. The toffee contains butter, which is a milk allergen, but the 3oz Sea Salt 70% Dark Chocolate label does not declare milk.

Forgot to Put Egg on the Label - Thomas Hammer Coffee Roasters Inc. of Spokane, WA is recalling 15 loaves of Blueberry Bread because it may contain undeclared EGG. There are no expiration dates or lot codes on label and product has a 5-day shelf life.  NO illness has been reported to date.  The recall was initiated after it was discovered during a routine inspection, the product containing EGG was distributed in packaging that did not reveal the presence of EGG.

https://www.fsis.usda.gov/wps/portal/fsis/topics/recalls-and-public-health-alerts/recall-case-archive/archive/2019/recall-039-2019-release
Market of Choice, Inc. Recalls Pork and Poultry Products Due to Misbranding and Undeclared Allergens
Class I Recall 039-2019
Health Risk: High
Mar 30, 2019

Canned Cat Food Recalled After Complaints Received for Rubber Pieces

Nestlé Purina PetCare Company is voluntarily recalling a limited amount of Muse wet cat food Natural Chicken Recipe in Gravy in three-ounce cans due to the potential for product to contain rubber pieces that are translucent yellow with a blue backing.  This may present a potential choking hazard for the cat.  The company became aware of the issue after receiving complaints from pet owners who observed the rubber pieces in the product. Corrective action was taken to prevent use from occurring again.

https://www.fda.gov/Safety/Recalls/ucm634850.htm
Nestle Purina PetCare Company Voluntarily Recalls a Limited Amount of Muse Wet Cat Food Natural Chicken Recipe in Gravy in Three-ounce Cans due to the Potential Presence of Rubber Pieces
For Immediate Release
March 29, 2019

FDA Provides Leeway for Wine Grapes, Pulses, Hops, and Almonds from Produce Rule

FDA provided guidance on relaxing (allow enforcement discretion) from the Produce Rule on commodity items that have unique processing methods. The commodity group include wine grapes (that will be made into wine), hops,(made into beer), pulse crops (the seeds of legumes - dry beans, dry broad beans, dry peas, chickpeas, cow peas, pigeon peas, lentils, Bambara beans, vetches, lupins and pulses nes - which are cooked) and almonds (which are normally roasted).

"The term “pulses” is limited to crops harvested solely as dry grains, which differentiates them from other vegetable crops that are harvested while still green."(the pulses webpage)

National Law Review
https://www.natlawreview.com/article/fda-announces-enforcement-discretion-certain-commodities-related-to-produce-safety
FDA Announces Enforcement Discretion for Certain Commodities Related to Produce Safety Rule
Friday, March 29, 2019

Beef Heel and Chuck Tender Products Recalled for Potential E. coli O157:H7

Aurora Packing Company, Inc., a North Aurora, Ill. establishment, is recalling approximately 4,838 pounds of beef heel and chuck tender products that may be contaminated with E. coli O157:H7,  The problem was discovered during traceback activities following routine FSIS testing. There have been no confirmed reports of adverse reactions due to consumption of these products.

https://www.fsis.usda.gov/wps/portal/fsis/topics/recalls-and-public-health-alerts/recall-case-archive/archive/2019/recall-038-2019-release
Aurora Packing Company, Inc. Recalls Beef Products due to Possible E. coli O157:H7 Contamination 
Class I Recall
038-2019
Health Risk: High
Mar 26, 2019

Europe - Various Food Safety Issues in the News

In doing a google search on food safety news items, we see that many of the "interesting" stories are coming from other countries other than the US this week.  Reading some of the headlines, it is easy to mistake these outbreaks are closer rather than an ocean away.  I guess in today's 24hr constant news cycle, there needs to be the constant issuance of stories, perhaps helping maintain that narrative that our food is unsafe.  And perhaps it is just a matter of time before we will be reading about an investigation of 2 cases of Salmonella linked to a tofu dish served at a restaurant in India or Pakistan.

Cluster of Listeria Cases Linked in 5 Countries
A linkage has been made between 18 cases of Listeria infections in 5 different countries over 4 years.
"ECDC has identified a microbiological link between an outbreak of nine Listeria monocytogenes ST1247 cases in Denmark and nine additional cases reported between 2014 and 2018 in Estonia (2 cases) Finland (2), France (1) and Sweden (4)."

Denmark Experiencing Rise in Salmonella Chicken Flocks
FSN
"Denmark found Salmonella in 2.7 percent of chicken flocks that lay eggs last year which is above the limit set by the European Commission to qualify for special conditions."

EU report finds limited controls on food sold online
FSN
"Official controls on food sold over the Internet are still limited, according to a report from the European Commission.
Controls of food sold online were limited and mainly focused on registered food business operators. Non-compliances were mostly related to labeling and health claim requirements. Online marketing of dangerous substances as food supplements was found in a few cases."

Snack mix recall expanded as patient count increases in Salmonella outbreak
FSN
"More cases of Salmonella infections have been reported in Norway with a link to imported dried fruit and coconut. Salmonella Agbeni has been detected in several samples of the snack mixes. Salmonella Gamaba was also found in two unopened packages from the same lot."

https://ecdc.europa.eu/en/news-events/multi-country-cluster-listeria-monocytogenes-st1247-five-eu-countries
Multi-country cluster of Listeria monocytogenes ST1247 in five EU countries
news epidemiological update
27 Mar 2019

This Week in Mislabeled Products for Week Ending March 22, 2019

Wrong Chicken Products in Cases - Tip Top Poultry, Inc., a Rockmart, Ga. establishment, is recalling approximately 100 pounds of frozen, fully cooked diced white chicken meat products due to misbranding and undeclared allergens - the products contain soy which is not declared on the product label. The problem was discovered after the firm received a complaint from a customer that they received fully cooked grilled chicken strips instead of fully cooked diced white chicken meat.

Potato Chips Put in Wrong Bag - Better Made Snack Foods of Detroit, MI, is recalling 10-ounce packages of Original Potato Chips because they may contain undeclared milk. The recall was initiated after it was discovered that a package of 10-ounce Original Potato Chips dated 10 AUG 2019 did not contain Original Potato Chips but instead contained Cheddar and Sour Cream Potato Chips which contain milk.

Improperly Designed Label, Misses Milk - Century Snacks, LLC of Commerce, CA is recalling all packages of 3-oz. and 5.75-oz. SNAK CLUB HONEY BLISS NUT MIX due to undeclared MILK.  The recall was initiated after it was discovered that product containing MILK was distributed in packaging that does not reveal its presence.

Tip Top Poultry, Inc. Recalls Fully Cooked, Diced Chicken Products due to Misbranding and Undeclared Allergens
Class I Recall
036-2019
Health Risk: High
Mar 23, 2019

First Tailgate? Stonehenge Site of Ancient Pig BBQ

An article in National Geographic details research into sites around Stonehedge where prehistoric pork barbecues were held as part of large social events.   Based on elemental analysis from the pig bones, it appears that travelers came from all over England.

A BBQ cook-off perhaps? 

https://www.nationalgeographic.com/culture/2019/03/stonehenge-pig-roasts-united-ancient-britain
Stonehenge-era pig roasts united ancient Britain, scientists say
A new study of bones discarded after prehistoric barbeques is providing unexpected insight into the first ‘pan-British’ gatherings.
________________________________________
BY KRISTIN ROMEY
________________________________________
PUBLISHED MARCH 13, 2019
A surprising study of leftovers from 4,500-year-old pig roasts reveals that prehistoric ceremonial sites around Stonehenge served as “pan-British” centers that helped bring together disparate populations of Neolithic peoples from across the island for the first time. The study was published today in the journal Science Advances.

FDA Issues Warning Letter to OH Bakery for Being Nasty

An Ohio bakery [located close to Ohio State University by the way] was cited for lots of bad stuff.  As we have seen in recent Warning Letters, bakeries have been slammed for many GMP issues.  The reason for this is that many have not had FDA visits.  They were often inspected only by the State and often viewed as low risk.  As we have learned more about the potential for Salmonella to be in flour and to persist in dry facilities for long periods of time, the risk in bakeries has come more to light.  In this case, the issues with improper cleaning leading to dust buildup is a concern, as well as employee hygiene issues.  Allergens are another concern where multiple allergens may be used.  Finally Staphylococcus is a concern when cream fillings are temperature abused. 

And now we are seeing here where a lack of a food safety plan (HACCP-based) is noted as well.

No Food Safety Plan - "Specifically, you did not prepare, or have prepared, and did not implement a food safety plan for the food manufactured in your central kitchen, such as RTE cream-filled eclair pastries, as required by 21 CFR § 117.126. Based on your operation, when you perform your hazard analysis you should consider hazards including contamination of products with environmental pathogens, such as Listeria monocytogenes and Salmonella, and food allergens."

Equipment not food safe - "our investigator observed a stainless-steel mixing bowl with rough welds and dents on the inside of the bowl, which make it a surface that is not easily cleanable and that can harbor pathogens or allergen-containing food debris."

Improper cleaning - Dust build-up was observed 1) on the fan covers of the cooling unit in the quiche freezer, dairy cooler, pastry cooler, and bread freezer  Finished product was stored uncovered in these coolers and freezers); 2)on the blower vent of the air conditioning unit (Racks of bread were stored below the vent to cool); 3) on the air filter bracket above the rotary oven and retail prep area.  Clean pots and containers were stored below this filter.  and 4) on electrical cords and electrical outlets directly above the pastry prep table.

Employee hygiene issues -  1) An employee was observed not wearing a beard net while placing fruit on top of fruit tarts; 2)the employee's shirt was touching some of the tarts; 3) An employee was observed wearing jewelry (a bracelet made of string) while making bread dough. 4) Employees' personal items, including coffee cups and shake containers, were stored under prep tables in the manufacturing areas.  An employee was observed taking a drink of the coffee stored under the prep table and then continued prepping pastries without washing their hands. 5) An employee, who was observed filling eclairs with cream, was handed their cell phone, which was found on the floor, the employee placed the cell phone in their back pocket and continued to fill eclairs with cream, without washing their hands. 6) An employee loading a truck for delivery... picked up a cake from the tray, touched the cake with his fingers, and placed the cake into a box.  The employee did not wash their hands before touching the cake. 

Temperature Control -  Your dairy cooler is used to store dairy products, such as heavy whipping cream, pasteurized liquid egg, milk, pastry cream, chocolate ganache, and sweet dough, all of which are used to manufacture RTE pastries.  You stated you visually inspect the temperature of the cooler (b)(4) and record it on the Cooler and Freezer Temperature record.  From December 31, 2017 to June 2, 2018, your records show 104 out of 153 (b)(4) where the temperature of the cooler was recorded above _____°F, reaching as high as ____°F.

FDA Inspections, Compliance, Enforcement, and Criminal Investigations
Warning Letter
LaMarquise Inc. 2/5/19

Two Recalls Issued After Complaints of Foreign Material in the Form of Metal Pieces

There were two recalls of meat related to foreign material in the product, specifically metal pieces.  In  the recall from the NH establishment, the recall was issued after FSIS inspectors found, through their record review, that the company had received consumer complaints for metal. In the other case, complaints for metal were made directly to USDA.

North Country Smokehouse, a Claremont, N.H. establishment, is recalling approximately 2,686 pounds of ready-to-eat sausage products that may be contaminated with extraneous materials, specifically metal,  The problem was discovered on March 18, 2019 by FSIS inspection program personnel during a routine review of establishment consumer complaint records.

Tyson Foods, Inc., a Rogers, Ark. establishment, is recalling approximately 69,093 pounds of frozen, ready-to-eat chicken strip products that may be contaminated with extraneous materials, specifically pieces of metal.  The problem was discovered when FSIS received two consumer complaints of extraneous material in the chicken strip products.

https://www.fsis.usda.gov/wps/portal/fsis/topics/recalls-and-public-health-alerts/recall-case-archive/archive/2019/recall-037-2019-release
North Country Smokehouse Recalls Ready-To-Eat Sausage Products due to Possible Foreign Matter Contamination
Class I Recall
037-2019
Health Risk: High
Mar 23, 2019

Avocados from CA Recalled After Environmental Samples Positive for Listeria

A California avocado packing house is recalling avocados "due to positive test results on environmental samples taken during a routine government inspection at its California packing facility."  Henry Avocado Corporation is voluntarily recalling California-grown whole avocados sold in bulk at retail stores.

"The recalled products – California-grown conventional and organic avocados -- were packed at Henry Avocado’s packing facility in California and distributed in Arizona, California, Florida New Hampshire, North Carolina and Wisconsin. All shipments from the packing facility are subject to the recall (Henry Avocado did not begin packing there until late January 2019). Avocados imported from Mexico and distributed by Henry Avocado are not subject to the recall and may continue to be sold and consumed."

Is the risk high?  Hard to tell because we don't know whether the avocados themselves were contaminated and if so, to what degree the contaminate on the outside of the avocado would be transferred to the internal flesh.  The concern is that someone making a product like guacamole would not properly wash the avocado and the contaminate would be transferred to the internal flesh as the person sliced and prepared the guacamole.  The potential for growth increases risk as the guacamole is more neutral in pH and would not inhibit growth.  Long storage even at refrigeration temperature also increases risk in that Listeria can grow at refrigeration temperatures albeit slower than if the product were temperature abused.

https://www.fda.gov/Safety/Recalls/ucm634230.htm
Henry Avocado Recalls Whole Avocados Because Of Possible Health Risk
For Immediate Release
March 23, 2019

Pet Food Company Expands Recall for Elevated Vitamin D

Hill’s Pet Nutrition is expanding its recall of select canned dog food products due to elevated levels of vitamin D, an issue that was caused by the same vitamin premix received from a U.S. supplier that was the issue that led to a recall in January.   "Pet Nutrition learned of the potential for elevated vitamin D levels in some of our canned dog foods after receiving a complaint in the United States about a dog exhibiting signs of elevated vitamin D levels. Our investigation confirmed elevated levels of vitamin D due to a supplier error."

From the recall notice, "Following that recall, we conducted a detailed review of all canned dog foods potentially impacted by the vitamin premix with elevated levels of vitamin D. This review included: analyzing consumer complaints; reviewing veterinarian medical consultations; auditing our supplier; and reviewing our own manufacturing and quality procedures. We then did additional product testing to ensure we had taken all appropriate action. Our review determined that there were additional products affected by that vitamin premix, and it is for that reason that we are expanding the recall. Hill’s has received a limited number of complaints of pet illness related to some of these products."

https://www.fda.gov/Safety/Recalls/ucm634087.htm
Hill’s Pet Nutrition Expands Voluntary Recall of Select Canned Dog Food for Elevated Vitamin D
For Immediate Release
March 20, 2019

USDA FSIS Releases Guidance on Responding to Consumer Complaints for Meat and Poultry Operations

USDA FSIS released a 'best practices' for handling customer complaints for meat and poultry operations.  This was issued after the numerous complaints of foreign objects 

"The purpose of this guideline is to provide industry with reference material on best practices for responding to customer complaints of adulterated and misbranded meat and poultry products.  FSIS developed this document in response to an increase in the number of recalls of meat and poultry products adulterated with foreign materials.  In many cases, the recalling establishments had received multiple customer complaints prior to these recalls." 

By regulation, firms are to notify USDA FSIS if the firm finds the product is adulterated.  So technically, if complaints are received that there is a foreign material, the product is adulterated.  This is to be done within 24hrs.

What are the notification requirements under 9 CFR 418.2? §418.2  Notification.
Each official establishment must promptly notify the local FSIS District Office within 24 hours of learning or determining that an adulterated or misbranded meat, meat food, poultry, or poultry product received by or originating from the official establishment has entered commerce, if the official establishment believes or has reason to believe that this has happened. The official establishment must inform the District Office of the type, amount, origin, and destination of the adulterated or misbranded product. 

Highlights from the document - https://www.fsis.usda.gov/wps/wcm/connect/8d0a0e73-1e6f-424f-a41f-ea942247a5ff/Guideline-for-Industry-Response-Customer-Complaint.pdf?MOD=AJPERES

This Week in Mislabeled Product for Week Ending March 16, 2019

Someone Misses the Fact that Gluten is in Wheat - North Country Smokehouse, a Claremont, N.H. establishment, is recalling approximately 2,601 pounds of pork sausage products due to misbranding,The product has a gluten free claim represented on the front of the label; however, the product contains gluten in the form of wheat.  The problem was discovered on March 11, 2019 when the firm notified FSIS that they received a consumer complaint. [Marketing Dept?]

Soy Missed on Label - Carnivore Meat Company, LLC, a Franklin, Tenn. establishment, is recalling approximately 379 pounds of raw ground beef and pork sausage products due to misbranding and undeclared allergens - the products contain soy.  The problem was discovered on March 12, 2019 by FSIS personnel during a food safety assessment at the establishment.

Inspectors Find that Milk is Not Listed on Label - Choice Canning Company, Inc., a Pittston, Pa. establishment, is recalling approximately 35,459 pounds of chicken fried rice products due to misbranding and undeclared allergens, - the products contain milk, a known allergen, which is not declared on the product label. The problem was discovered on March 11, 2019 by FSIS personnel during routine label verification.

FDA Issues Recall Notice on Flour Recall for Salmonella

After reports of Pillsbury Flour was issued last week, FDA issued an announcement on March 12th, that Hometown Food Company initiated a limited, voluntary retail-level recall on two specific lot codes of its Pillsbury® Unbleached All-Purpose 5 lb Flour (UPC 51500-22241)because it may be contaminated with Salmonella.  There have been no reports of any illnesses associated with this recall. Product is being recalled out of an abundance of caution.

No specific information was provided on how the contamination was detected.

FDA added the reminder that flour is a raw product - "Flour is made from wheat that is minimally processed. Flour should not be considered a ready-to-eat product. It is an ingredient for baked, fried, and cooked products, and these heating processes ensure the safety of flour with proper handling. All surfaces and utensils should be properly cleaned after contact with flour or uncooked dough or batter. Consumers should wash their hands after handling flour or uncooked dough or batter. Consumers should not eat uncooked dough or batter made with raw flour. If you think you became sick from a food containing flour as an ingredient, please call your healthcare provider."

Hometown Food Company Recalls Two Production LOT Codes of Pillsbury® Unbleached All-Purpose 5lb Flour Due to Possible Health Risk
For Immediate Release
March 12, 2019

PR Establishment Recalls Breaded Chicken Patty Product Due to Complaint of Piece of Metal

Puerto Rico establishment, is recalling approximately 35,870 pounds of breaded chicken patty products that may be contaminated with extraneous materials, specifically pieces of metal,  The problem was discovered on March 11, 2019 after the firm received a consumer complaint from a school that received the product.

https://www.fsis.usda.gov/wps/portal/fsis/topics/recalls-and-public-health-alerts/recall-case-archive/archive/2019/recall-031-2019-release
Productos La Aguadillana, Inc. Recalls Breaded Chicken Products Due to Possible Foreign Matter Contamination
Class I Recall 

031-2019
Health Risk:High 

Mar 14, 2019

RTE Meat Snacks Recalled Due to Potential Product Tampering

Monogram Meat Snacks, LLC, a Martinsville, Va. establishment, is recalling approximately 191,928 pounds of ready-to-eat pork sausage products that may be adulterated due to possible product contamination, according to the report, "initiated due to product tampering, following the production process."

No further information is available at this time including how it was discovered.

https://www.fsis.usda.gov/wps/portal/fsis/topics/recalls-and-public-health-alerts/recall-case-archive/archive/2019/recall-029-2019-release
Monogram Meat Snacks, LLC Recalls Pork Sausage Products Due to Possible Product Contamination
Class I Recall
029-2019 
Health Risk:High 
Mar 13, 2019 

CDC - 2018 Incident of Botulinum Poisoning from Improperly Home Canned Peas

CDC provided an outbreak report from a June of 2018 incident where three women suffered botulinum poisoning after eating homemade potato salad using improperly processed home-canned peas.

According to the report, the woman's freezer had malfunctioned and so decided to rescue the commercially produced frozen peas by canning them.  HOWEVER, Instead of using a pressure canner, she decided to follow a peach recipe that utilizes a water bath canner, and simply substitute the peas for peaches.  When a jar lost vacuum, she refrigerated it and used that to make the potato salad.

From the report, "The patient who prepared the home-canned peas was a novice home canner. She used a peach preserves recipe with a boiling water technique, replacing the peaches with frozen vegetables. The patient was unaware that low-acid foods (e.g., vegetables) must be canned in a pressure canner rather than a boiling water canner to eliminate C. botulinum spores (1). After the jars cooled, the patient correctly checked for jar seal. One of the jars of peas was not sealed, so the patient covered and refrigerated it, and the family consumed the peas in the potato salad."

The women who had arrived at a hospital 4 hours earlier for evaluation for acute nausea, dizziness, blurred vision, slurred speech, ptosis, thick-feeling tongue, and shortness of breath. Two patients developed respiratory failure, requiring intubation and mechanical ventilation in the emergency department, and the third patient was intubated at 7 p.m. that evening. The combination of cranial nerve palsies and respiratory failure in multiple patients suggested botulism, a paralytic illness caused by botulinum neurotoxin (BoNT), most commonly produced by Clostridium botulinum.

As we know, when you have low acid foods, they must be pressure canned in order to destroy any Clostridium botulinum spores.  In peaches, the acidity is high / ph is low (<4.6) and that prevents the spores from growing, so a high heat treatment is needed.  In peas, a low acid food, the acidity is low and the pH is high (>4.6). In this product, the spores survived the milder heat treatment used in the water bath canning, and when the product cooled down, the spores germinated and grew in the peas, producing the deadly neurotoxin.


https://www.cdc.gov/mmwr/volumes/68/wr/mm6810a5.htm?s_cid=mm6810a5_e
Notes from the Field: Botulism Outbreak Associated with Home-Canned Peas — New York City, 2018
Weekly / March 15, 2019 / 68(10);251–252

Ground Turkey Recalled After Linked to 5 Cases of Salmonella Infection

Butterball, LLC, a Mount Olive, N.C. establishment, is recalling approximately 78,164 pounds of raw ground turkey products that may be contaminated with Salmonella Schwarzengrund.  FSIS, CDC, and Wisconsin state agencies have been investigating a multistate outbreak of Salmonella Schwarzengrund illnesses involving 5 case patients from 2 states

https://www.fsis.usda.gov/wps/portal/fsis/topics/recalls-and-public-health-alerts/recall-case-archive/archive/2019/recall-030-2019-release
Butterball LLC Recalls Turkey Products Due to Possible Salmonella Schwarzengrund Contamination
Class I Recall 

030-2019
Health Risk: High 

Mar 13, 2019

This Week in Mislabeled Products for Week Ending March 9, 2019

Beef Ravioli Labeled as Chicken with Rice Conagra Brands, Inc., a Milton, Pa. establishment, is recalling approximately 2,871 pounds of chicken and rice products due to misbranding and undeclared allergens - the products may contain milk and wheat, known allergens, which are not declared on the product label. The problem was discovered by the firm after receiving consumer complaints that  bowls of microwave beef ravioli were mislabeled as “chicken with rice & vegetables.”

https://www.fsis.usda.gov/wps/portal/fsis/topics/recalls-and-public-health-alerts/recall-case-archive/archive/2019/recall-025-2019-release
Conagra Brands, Inc. Recalls Chicken and Rice Products Due To Misbranding and Undeclared Allergens
Class I Recall
025-2019
Health Risk:High
Mar 9, 2019

Grocery Stores Report Recall of Flour Due to Potential Salmonella Contamination

According to news reports, two grocery chains are recalling Pillsbury flour in 5lb bags for potential Salmonella contamination. The chains, Publix and Winn Dixie are both in the Southeast US.

FDA has not yet posted a recall on their website, so there is limited information.

Salmonella can be found in flour and becomes an issue when items are undercooked or not cooked (like raw cookie dough) or there is cross contamination in the kitchen when the contaminated flour gets onto ready-to-eat food items.

http://www.fox13news.com/consumer/publix-winn-dixie-recalls-pillsbury-flour-due-to-salmonella-concern
Publix, Winn-Dixie recalls Pillsbury flour due to salmonella concern
By FOX 13 News staff
Posted Mar 11 2019 05:56AM EDT
Updated Mar 11 2019 07:16AM EDT

One Lot of Organic Bean Sprouts Recalled for Listeria

A Florida establishment is voluntarily recalling Organic Bean Sprouts because it has the potential to be contaminated with Listeria monocytogenes,  This recall was issued after the Florida Department of Agriculture pulled a sample from a store shelf and found Listeria (we assume).  Product was shipped to Whole Foods Markets in Florida and Freedom Fresh (a Miami distributor) on February 18, 2019 and had a sell by date of February 28, 2019, so unlikely to be in Marketplace.

Like many other recalls involving Listeria where only the tested positive lot is recalled,  these recalls are often expanded as it is discovered that the facility did not have adequate controls in place.  For ensuring public health, recalls of these natures should initially begin with a broad recall unless the company can show that they have had adequate controls in place.   Hard to say in this case, unless over this recall is expanded over the next week.

Fullei Fresh Recalls Organic Bean Sprouts Because of Possible Health Risk
For Immediate Release
March 8, 2019

FDA Release Guidance on Food Defense - Mitigation Strategies to Protect Food Against Intentional Adulteration

The FDA published a draft guidance for food defense titled Mitigation Strategies to Protect Food Against Intentional Adulteration: Guidance for Industry in support of the Prevention of Intentional Adulteration rule. The draft guidance provides ways to meet the requirements in the rule specifically conducting the vulnerability assessment and putting mitigation strategies in place for ‘actionable process steps’ or APS. These APS are defined as “a point, step, or procedure in a food process where a significant vulnerability exists and at which mitigation strategies can be applied and are essential to significantly minimize or prevent the significant vulnerability”.

To summarize the 159 page document - a Food Defense Plan is essentially conducting a HACCP type of analysis where the goal is to find steps in the process where significant vulnerability exists and to put in measures, or the mitigation strategies’ to reduce the vulnerabilities. These vulnerable points are points where there is access to product where the product can then be contaminated.

There is flexibility in how one conducts a vulnerability assessment, but the guidance provides some basic ways. The elements that must be considered include 1) the potential public health impact (e.g., severity and scale) if a contaminant were added, 2) the degree of physical access to the product; and 3) the ability of an attacker to successfully contaminate the product. The analysis must consider an attack by an insider, a person working in the company. The written assessment must document why each step was considered, or not considered, an APS.

For steps designated as an APS, mitigation strategies are put in place. These strategies may limit access to the step, or may reduce the likelihood that someone can contaminate product at that step. Like critical controls points, each mitigation strategy must have monitoring, verification, and corrective action.

While many may ask about facility wide measures – items such as exterior fencing, employee access to the facility and such – these are not included within the plan unless they can be tailored to impact a specific Actionable Process Step. Sure, they are important, but many have these in place already for other purposes and in reality, they are harder for regulators to regulate.

USDA Issuing Guidelines to Increase Attention to Foreign Material Complaints

Over the past few years, food companies, specifically meat and poultry processors, have issued a large number of recalls related to foreign objects.  Now USDA is issuing guidelines for food companies to respond more aggressively with foreign material complaints.  The USDA wants "food makers to start internal investigations when they receive customer complaints and to notify the government within 24 hours if contaminated products are in the marketplace".

Are foreign material issues an increasing issue?  I would argue that it is not.   Certainly the visibility of these issues is new.  Within the past few years, the Reportable Food Registry and Consumer Complaint portals were introduced and the use has increased.  So while in the past, consumer complaints for foreign materials were received by companies and handled internally without  much federal intervention.  Recalls were issued for serious foreign material issues.  What has changed isn't as much there are more foreign material issues, but USDA is paying close attention.  And much of this started as consumers were able to complain directly to USDA, and with that, inspectors began paying more attention to foreign material issues.  As issues were seen within the complaint records, more recalls were issued.

 Is a more aggressive response prudent? Not being involved directly in these investigations, it is difficult to know exactly.  From the recall notices, it appears that many recalls are issued after one complaint.  But what did the investigation show?   It is important that complaints are well investigated before wasting resources on a recall.  I have seen where complaints were made by consumers in order to get a replacement product (free product).  There were other cases where the consumer improperly cut the package with a part of that package unknowingly falling into the product only to be viewed by the consumer as a foreign object.  People have assumed the food was a source of a foreign object when that food was used in a recipe. 

Perhaps some of us come from a different era that when we found a piece of plastic in a food item, we accepted that as 'something that can happen', and threw the piece of plastic out.  Not saying that is right and that food companies should do a better job, but if no injury than no foul.

We are already seeing people pay less heed to recalls.  As we add more and more recalls to the weekly list, it is bound to increase the consumer ambivalence.  So at the very least, time should be allowed for an investigation and companies should be allowed input on the determination of whether the recall is necessitated.  In the end, they will pay for the real issues.

https://www.nbcnews.com/health/health-news/new-food-safety-guidelines-expected-after-spike-meat-poultry-recalls-n979161
New food safety guidelines expected after spike in meat and poultry recalls
More food prepared by machines contributes to more parts breaking off and contaminating food, consumer advocates say.
March 4, 2019, 5:53 PM EST
By Reuters

Washington State Firm Recalls Ground Beef Chubs After Complaint of Hard Plastic

WASHINGTON, March 2, 2019 – Washington Beef, LLC, a Toppenish, Wash. establishment, is recalling approximately 30,260 pounds of ground beef chubs products that may be contaminated with extraneous materials, specifically hard plastic and metal.  The problem was discovered by a consumer complaint to the company on February 28, 2019.  There have been no confirmed reports of adverse reactions due to consumption of these products.

https://origin-www.fsis.usda.gov/wps/portal/fsis/topics/recalls-and-public-health-alerts/recall-case-archive/archive/2019/recall-024-2019-release
Washington Beef, LLC Recalls Ground Beef Products due to Possible Foreign Matter Contamination 
Class I Recall 
024-2019 
Health Risk:High 
Mar 2, 2019