Summary of FDA's Report on Risk Factors in Food Service Establishments

FDA compiled analysis of inspection reports of different foodservice establishments over 2013/2014 as part of a 10 year study.    The whole report can be found here, but we have summarized the most important findings:

• Most establishments had 3 or more food safety issues.
• It helps to have a Certified Food Safety Manager onsite.  Many jurisdictions do not require it.
• It is beneficial to have an established food safety management system.  Most have no system to a rudimentary system.
• While people generally cook food correctly and handle raw meats properly, handwashing and keeping TCS foods out of the temperature danger zone are the biggest issues.

What is the Risk of Opioids in Poppy Seeds

The European Food Safety Authority released their risk assessment of opium alkaloids in poppy seeds. Basically there is a small risk of having opioids, including codeine and morphine, in poppy seeds, specially unprocessed poppy seeds.

ere are a few of the summary points:

• "Poppy seeds are obtained from the opium poppy (Papaver somniferum). The latex (milky sap) of the opium poppy contains up to 80 alkaloids, including morphine and codeine, which have been used for the treatment of severe pain for generations but are also subject to misuse"
• "Poppy seeds normally do not contain opium alkaloids, but can become contaminated with opium alkaloids as a result of pest damage and during harvest."
• "There are few reports of adverse effects arising from consumption of poppy seeds in food; however it cannot be assumed that such reactions do not occur from time to time. Morphine-like effects have been observed in humans following consumption of a single portion of a meal containing opium alkaloid-contaminated poppy seeds".

So if you are going for a drug screening, it may be worth skipping the poppy seed roll.  Although it is so darn tasty.  це дуже смачно!

EFSA - European Food Safety Authority
http://www.efsa.europa.eu/en/press/news/180516
Opium alkaloids in poppy seeds: assessment updated
16 May 2018

Mitigating Food Safety Issues - Monitoring of Social Media

Wall Street Journal has an interesting read about mitigating food safety risks.  Some of the keys mentioned are right on target..."Companies need strong food safety policies that are enforced, extensive employee training and messaging and regular checking of their supply chains through audits, and product testing to help mitigate their risks.."  Then monitoring is discussed at length with specific attention to monitoring of social media.  The point they make is that monitoring social media may be helpful, but it is far from full proof.  Case in point was the Chipotle outbreak where social mentions months before the outbreak were not much different than that during the outbreak.

There are times monitoring social media can help, like the case earlier this year when LA County Health identified an outbreak at a restaurant.  But monitoring of social media has its drawbacks, as we pointed out last year when it was highlighted in the news media as the next best thing in the fight against foodborne illness.  Those who monitor consumer complaints will probably tell you, sometimes a complaint of illness here or there is common, and it can be difficult in telling what is real and what is either a misinterpretation of cause by the consumer (they picked the last thing they ate,  it was a seasonal illness, etc) or the consumer just wanted to complain.

As part of the company's food safety system, monitoring of complaints made formally or made through social media can all help in identifying an issue earlier, but it is far from clear cut.  Much of it will be establishing procedures for identifying key words or patterns in the data.  Best efforts however, are putting policies and procedures in place to prevent issues in the first place.

Wall Street Journal Risk Report
http://blogs.wsj.com/riskandcompliance/2016/02/25/awareness-training-oversight-keys-to-mitigating-food-safety-risks/
Awareness, Training, Oversight Keys to Mitigating Food Safety Risks
February 25, 2016
By Ben DiPietro Biography

The recent food sickness problems at Chipotle Mexican Grill Inc.—the chain suffered an E.coli outbreak that led to restaurant closures in nine states and a norovirus outbreak that sickened 140 people in Boston–placed a spotlight on risks faced by companies that sell food.

Companies need strong food safety policies that are enforced, extensive employee training and messaging and regular checking of their supply chains through audits, and product testing to help mitigate their risks, according to food safety experts. Monitoring of social media for early-warning signals of possible foodborne illness issues can be helpful and should be done but won’t always help prevent or contain outbreaks, they said.

Study: Authenticity Trumps Food Safety? Is it a Case of Risk Analysis?

In a study to be published in the journal, Management Science, researchers concluded that people are willing to forgo the results of a poor hygiene inspection of a restaurant if they view that restaurant as authentic. 

The research originated to explain cases where Chinese restaurants, flagged for unhygienic practices such as hanging ducks at room temperature, were still held in high regard by patrons.  In fact, California law was changed to allow 'Chinese-style roast'.

Surprising?  Not really.  We see this with many traditional foods, especially where the science is broadly applied to a category of food, but there is little anecdotal evidence to support the fact that products are safe or not safe.  In this research paper, the authors describe conflicting codes...one based on law and another based upon tradition.  To me, it is a risk decision...certainly a bad inspection report gives one the idea that risk may be there, but people will also bring in their own knowledge of associated risk...has there been any outbreaks associated with 'hanging chickens'?  Haven't Chinese restaurants been hanging chickens for thousands of years?

We see this with canned foods where people will can foods using traditional methods...such as using a boiling water bath to can meat (instead of using a pressure canner).  Their mothers and grandmothers did it this way with no issue, thus there is no risk.  Perhaps those people have not been exposed to the data on the cases of botulism that regularly occur each year and thus do not know the real risk.  (The likelihood of occurrence may be low, but the severity is high).

And conversely, where there is an over emphasis on the risk of something, especially when mass media spins a given item, people are willing to view something as risky where there is no scientific support.  So in this example, these same people will get inundated with information on the supposed dangers related to pesticides in food (which represents a smaller risk, based upon USDA testing compared to risk of botulism when improperly canning meat), and go to greater lengths to avoid commercially grown produce.

With the hanging chickens, there is probably a lower risk with this specific application in that spoilage organisms outcompete pathogens on the bird, and then provided the bird is properly cooked, there is little risk.  However, law is written to take a broad range of applications into account.  It is hard to write laws specific to every application.


Management Science
http://pubsonline.informs.org/doi/pdf/10.1287/mnsc.2014.1903
Conflicting Social Codes and Organizations: Hygiene and Authenticity in Consumer Evaluations of Restaurants

David W. Lehman
University of Virginia, Charlottesville, Virginia 22904, lehman@virginia.edu
Balázs Kovács
University of Lugano, 6900 Lugano, Switzerland, kovacsb@usi.ch
Glenn R. Carroll
Stanford University, Stanford, California 94305, gcarroll@stanford.edu

Abstract

Organization theory highlights the spread of norms of rationality in contemporary life. Yet rationality does not always spread without friction; individuals often act based on other beliefs and norms. We explore this problem in the context of restaurants and diners. We argue that consumers potentially apply either of two social codes when forming value judgments about restaurants: (1) an apparently rational science-based code of hygiene involving compliance with local health regulations or (2) a context-activated code of authenticity involving conformity to cultural norms. We propose that violations of the hygiene code recede in importance when the authenticity code is activated. This claim is supported by empirical analyses of 442,086 online consumer reviews and 52,740 governmental health inspections conducted from 2004 to 2011.

Keywords: organizations; institutions; social codes; authenticity; regulatory noncompliance; consumer value ratings; restaurants; health grades

History: Received March 1, 2013; accepted December 10, 2013, by Gérard P. Cachon, organizations. Published online in Articles in Advance.

Risk Assessment of Listeria in Retail Delicantessens

FDA released the Draft Interagency Risk Assessment – Listeria monocytogenes in Retail Delicatessens Technical Report. (http://www.fda.gov/downloads/Food/FoodScienceResearch/RiskSafetyAssessment/UCM351328.pdf). The goal of this report is to further the understanding of the risk of Listeria monocytogenes that is associated with the retail deli case. Listeria monocytogenes can grow on meat and cheese items that are sold in retail deli establishments. As we know, Listeria can grow at refrigeration temperatures and deli meat products have been involved in past outbreak. Therefore it is important for retail establishments to understand how to best limit the risk of Listeria in their retail cases where there are products with exposure during handling and storage, such as cut luncheon meats.

FDA and USDA evaluated various practices in retail deli operations and came up with some best practices to mitigate the risk of Listeria.

While this is a beast of a report at 179 pages, there are some good takeaways. Here some of the highlights, in more common language. Below this, the conclusion from the report and the USDA news release are also included.

1. Start with products that have minimal Listeria risk. While selling products that have anti-Listeria agents helps, this is not always possible. But procuring items that have been produced in establishments with good Listeria control programs is important. It is also important to properly handle those products are handled from the time they are made through the time they are brought into the retail deli establishment. Even small amounts of Listeria introduced can have a huge impact over time.
2. Keep deli retail case temperatures low, certainly below 41 degree F. While Listeria can grow at refrigeration temperatures, it does grow slowly. So the lower below the temperature of 41F, the better.
3. Clean and sanitize the retail deli units regularly, especially the niches within the cooler….like the drain.
4. Prevent cross contamination from other sources. Clean the slicers and the utensils regularly. Ensure that employees are washing hands and wearing gloves.
5. Remember that items that do not allow the growth of Listeria can be sources of contamination. For example, most fresh produce items which does not support the growth of Listeria can still be the source of contamination for meat items that will support growth. So put controls in place for handling and storage of those types of items.
6. If pre-slicing, pre-slice on a clean slicer. ( I am not a fan of pre-slice meat, I prefer sliced to order).

 

Conclusions from the report.

 

This QRA represents the first large-scale effort to model L. monocytogenes cross contamination at retail. The risk assessment model contributes to our understanding of L. monocytogenes transmission, survival, and growth in the retail environment and was used to evaluate how retail practices may impact the predicted risk of listeriosis. The approach used was to evaluate the public health effect of various mitigations under six different baseline conditions that may characterize a retail deli and the RTE food its serves.

Fresh Express Recalls Bagged Greens..Again

Fresh Express is recalling bagged spinach for Salmonella after a sample, as part of USDA sampling program, came up positive.  There were no illnesses reported.

This is a reported fifth time a Fresh Express product has been recalled due to a pathogen positive test.  Why so many, the Oregonian Newspaper asks.  To be fair, there seems to be an increase in these type of recalls in produce overall.  Has the amount of testing increased?  Perhaps a government agency that was just a moment from being eliminated has picked up their game.  Or is it that bagged produce more likely to contain pathogens when compared to unprocessed greens?  But are unprocessed greens tested at the same level as bagged greens?  We do know that bagged chopped greens are considered a TCS food (temperature control for safety, or what used to be known as PHF, or potentially hazardous food).  This is because pathogens, if present, have better growth potential in the chopped greens compared to whole greens. So, there is a greater need to have no pathogens present in those products.  But to what degree is it possible to completely eliminate all pathogens while still maintaining a product that does not taste like sanitizer?  Remember, these greens are grown in fields, and birds and other critters will poop there.  So without a silver bullet to completely eliminate this bacterial risk, testing is bound to discover a positive from time to time thus resulting in a recall, and hopefully not an illness.  Processors of this type of product, therefore, need to put in controls and then manage those controls to minimize the risk. Retailers and consumers must control that product through proper refrigeration.

Salmonella in spinach: fifth Fresh Express recall in three months

Published: Friday, November 09, 2012, 9:12 AM Updated: Friday, November 09, 2012, 1:09 PM
Lynne Terry, The OregonianThe Oregonianhttp://www.oregonlive.com/health/index.ssf/2012/11/salmonella_in_spinach_fifth_fr.html
Fresh Express, which sells a variety of bagged greens, is recalling packaged spinach over salmonella.

This is the company's fifth recall of bagged greens since August over bacterial contamination. This time it is pulling spinach with a use-by date of Nov. 7 sold in 9 oz. packages. The potentially tainted spinach was sold to stores in 18 states, including Oregon, Washington Idaho and California.Fresh Express, owned by Chiquita Brands International Inc. in North Carolina, said in its recall notice on the Food and Drug Administration website that the contamination was spotted in a test by the U.S. Department of Agriculture.

Tiffany Breaux, a Chiquita spokeswoman, said in an email that the company reviewed its records and conducted an “intensive investigation" into the contamination. Apparently, its staff was unable to trace the source of the pathogens.

It's unclear where the greens were grown and where and how they were packaged. Breaux indicated that the recalls have not prompted any change in the company's food safety system.

In the past three months, Fresh Express has pulled bagged greens after positive bacterial tests by federal authorities. In October, the company recalled hearts of romaine salad tainted with salmonella. In September, it again pulled hearts of romaine salad but over listeria contamination. Also in September, it pulled leafy green romaine salad over listeria, and in August it recalled hearts of romaine over listeria.

Both salmonella and listeria can cause serious gastro-intestinal symptoms and even death. Listeria poses a particular threat to pregnant woman, causing still births and miscarriages.

Both bacteria can end up in a variety of food but bagged greens are considered high risk because of the possibility of contamination spreading when one tainted leaf of lettuce, for example, is mixed with other greens and packaged.

But so many recalls by one company in such a short time frame is unusual. The last time before August that Fresh Express pulled contaminated greens from the market was in April 2011 when it recalled 9 oz. bags of spinach tainted with salmonella.

 

Fresh Express Recalls Limited Quantity of 9 oz. Spinach Due to Possible Health Risk

http://www.fda.gov/Safety/Recalls/ucm327401.htm

Contact
Consumer
1 - (800) 242-5472

Media
Tiffany Breaux 1 - (704) 280-5938
Barbara Hines 1 - (972) 724-3049

FOR IMMEDIATE RELEASE - November 7 , 2012 - Charlotte, North Carolina - Fresh Express Incorporated is conducting a voluntary, precautionary recall of a limited quantity of Fresh Express Spinach with a Use-by Date of November 7 and Product Code of S299B25 due to a possible health risk from Salmonella.

No illnesses or consumer complaints have been reported to Fresh Express at this time in association with this recall. No other Fresh Express products are subject to this recall.

The recall notification is being issued out of an abundance of caution due to an isolated instance in which a random sample yielded a positive result for Salmonella under U.S. Department of Agriculture's random sample testing program. Fresh Express is coordinating closely with regulatory officials.

Fresh Express customer service representatives are already contacting relevant retailers to confirm the recalled product has been removed from store shelves and inventories and that none is available for consumer purchase. Customers with questions are instructed to contact their usual Fresh Express customer service representative. The recalled salads were distributed primarily in the Western region of the U.S.

Consumers who may have purchased the recalled salad are asked not to eat it, but to throw it out instead. Fresh Express is offering a full refund. Consumers with questions or who would like to secure a refund may call the Fresh Express Consumer Response Center at (800) 242-5472 during the hours of 8 a.m. to 7 p.m. Eastern Daylight Time.

Specific recall information follows:

• Product Being Recalled: Fresh Express Spinach in 9 oz. package
• Product Code: S299B25 (located in upper right corner on front of package)
• Use-by Date: November 7 (also located in upper right hand corner of package)
• Distribution: Primarily in the Western region of the U.S.

Salmonella is an organism that may cause fever, nausea, vomiting, abdominal pain and possibly bloody diarrhea in healthy individuals. It can cause serious and sometimes fatal infections in young children, frail or elderly people, and others with weakened immune systems. Consumers with these symptoms should consult their health care provider.

Fresh Express Precautionary Salad Recall-11/7/12
(No other Fresh Express Salads are included in this recall)

Brand	Product Name	Size	UPC	Production Code	Best If Used By Date	POSSIBLE DISTRIBUTION STATES
Fresh Express	Spinach	9 OZ.	0 71279-13204 4	S299B25	NOV7	AZ, CA, CO, HI, I D, KS, MO, MT, NE, NV, NM,OK,OR,SD, TX, UT, WA,WY

EWG's Dirty Dozen of Fruit and Vegetables Overstates Real Risk

Each year the Environmental Working Group, a consumer activist organization, releases a list it calls the ‘Dirty Dozen’ - the fruits and vegetables found to that were found to have residual pesticides based upon USDA and FDA analysis. Then the news outlets churn this report out, making consumers worry about the apples and strawberries in their refrigerator.

However, this report does not communicate the real risk. First, the levels found are well below anything that would pose an appreciable risk. Further, this ranking does not have any scientific basis. In a research article published in Journal of Toxicology (abstract below) by Winter and Katz (2011), they state:

In summary, findings conclusively demonstrate that consumer exposures to the ten most frequently detected pesticides on EWG’s “Dirty Dozen” commodity list are at negligible levels and that the EWG methodology is insufficient to allow any meaningful rankings among commodities. We concur with EWG President Kenneth Cook who maintains that “We recommend that people eat healthy by eating more fruits and vegetables, whether conventional or organic” [1], but our findings do not indicate that substituting organic forms of the “Dirty Dozen” commodities for conventional forms will lead to any measurable consumer health benefit.

It is important that consumers include fruits and vegetables as part of their diet. They should not be deterred by headlines that would make them think otherwise.


Dirty Dozen: EWG Reveals List Of Pesticide-Heavy Fruits And Veggies
Huffington Post 06/19/2012 8:05 am Updated: 06/19/2012 8:17 amhttp://www.huffingtonpost.com/2012/06/19/dirty-dozen-foods-list-2012-ewg_n_1606256.html

What could be purer than a single ingredient?

As health-minded consumers work to avoid processed meals and turn their focus to whole foods, we may find ourselves picking up fruits and veggies more often. The average American currently eats about 100 pounds of fresh produce per year, but that number could be a lot higher. While the U.S. Department of Agriculture recommends adults eat two to three daily servings of fruits and veggies, only one-third of us meet that recommendation. 

Clearly, nothing should deter efforts to consume more fresh produce, the healthfulness of which is undeniable. But, as the latest iteration of an annual report reveals, there are some other considerations that health-conscious consumers must face from the supermarket aisle.

For the eighth year in a row, the nonprofit advocacy organization Environmental Working Group has released their list of the twelve most pesticide-laden fruits and vegetables on the market as part of their 2012 Shoppers Guide. Overall, they found that 68 percent of the food samples tested had detectable pesticide residues -- even after they had been washed or peeled. Many of the fruits and vegetables listed this year will look familiar to those who follow the yearly report -- apples and bell peppers once again top the list.

Certain pesticides have been identified as potential carcinogens, endocrine disruptors and have been associated with learning and developmental delays in children.

"Organophosphate pesticides are of special concern since they are associated with neurodevelopmental effects in children,” said EWG toxicologist Johanna Congleton in a statement. “Infants in particular should avoid exposure to these pesticides since they are more susceptible to the effects of chemical insult than adults."

Indeed, new research into the pesticide loads of baby food purees made with green beans, sweet potatoes and pears showed high contamination rates in both green beans and pears. Sweet potatoes, by contrast, had virtually no trace of pesticides. 

To learn more about individual pesticides and health risks, check out the U.S. Centers for Disease Control and Prevention's report on human exposure. 

To compile the rankings, EWG researchers looked at 45 popular fruits and vegetables based on pesticide-load reports conducted by the USDA and the Food and Drug Administration. The database includes 60,700 samples taken over a 10 year period, beginning in 2000. It's important to note that all of the testing is conducted on fruits and vegetables that have been washed and/or peeled -- the typical precautions taken by American consumers.

The researchers factor in how many of the samples test positively for detectable pesticides, how many have more than two discrete pesticides, the concentration (measured by parts per million) of the pesticides found and the highest number of pesticides found in any single sample. The researchers also looked at the total pesticide load of the fruit or vegetable crop as a whole.

And while the list is comprehensive, the ranking doesn't capture all information: For example, though apples were ranked as the most contaminated overall, imported nectarines had the unique distinction of having a full 100 percent rate of positive pesticide test results, above any other product. Bell peppers and grapes were both commonly contaminated with 15 different pesticides in a single sample -- the highest overall diversity of contamination. 

Still, even the researchers who conducted the pesticide exposure studies don't recommend giving up the "Dirty Dozen" outright. 

"The health benefits of a diet rich in fruits and vegetables outweigh [sic] the risks of pesticide exposure," they wrote, recommending instead that consumers purchase organic options wherever available and then choose items from the concurrent "Clean 15" list that details which fruits and veggies have the lowest pesticide loads and residues.


Lots of confusion when it comes to pesticides

BY PHIL LEMPERT June 19, 2012 9:55AM
(http://www.suntimes.com/lifestyles/food/13183396-423/lots-of-confusion-when-it-comes-to-pesticides.html)

Are you concerned about pesticides?

Sixty percent of consumers express a high concern about pesticide residues, much of which is based on misleading information, according to The Alliance for Food and Farming, a non-profit organization that represents organic and conventional farmers and farms of all sizes. Established in 1989, the Alliance’s goal is to deliver credible information to consumers about the safety of fruits and vegetables. Teresa Thorne, Alliance spokesperson, reported to us that recent surveys show that 29 percent of consumers are buying less fruits and vegetables due to concerns about pesticide residues.

The issue of pesticide residues can be very complex and terms often are used that are unfamiliar to many of us.

The Alliance’s website, safefruitsandveggies.com, is a chance for shoppers to explore science-based information about pesticide residues. The mere “presence” of a pesticide does not mean that the food is harmful, and to demonstrate this fact, the Alliance has provided a pesticide calculation tool, developed by Dr. Robert Krieger, toxicologist with the Personal Chemical Exposure Program at the University of California, Riverside, to see how many servings a man, woman, teen or child could consume and still not have any adverse effects from pesticide residues. Because of the complexity of the residue issue, the calculator was designed to be an easy way to show the very minute levels of pesticide residues that are found (when and if present at all).

Changing Times for Risk Management in the Food Supply Chain

How much do you know and trust your food supply chain? David Acheson’s fine opinion piece (below) discusses the impact of the lawsuit against Jensen Farms in the cantaloupe related listeria outbreak and the need for managing risk in an establishment’s food supply chain. The cantaloupe related lawsuit is posed to go beyond Jensen Farms and pursue those who handled or sold the contaminated produce as well as the company that inspected the processing facility. Is this the next development in requirements for the food industry?

A few comments on a few of the impactful points he makes:

The need for tighter control of suppliers, going beyond the third party audit, especially for high risk food products. Companies have become too reliant on third party audits to evaluate suppliers. As those who may be familiar with this process know, the value of that audit all comes down to the inspector’s ability to identify critical issues within a company’s food safety system. As past recalls have shown, there are knowledgeable auditors and those that are not so. And then there has been the issues with the supplier paying for the audit, that potential trade-off between the achieving a good score and providing an accurate assessment. A third party audit is just a part of the food safety system, but not the only component. And like any food safety program, it must be managed.

The potential negative impact on small suppliers. Many retailers and foodservice companies rely on small companies to create and manufacturer private label products. There is also a movement to use local farmers to supply produce. If food companies must take a higher level of responsibility for everyone that is producing, processing, and delivering products, there can be a trend for companies to either integrate operations or for them to use few suppliers that they can better manage. This consolidation would potentially result in the use of a few larger establishments that can provide all companies needs instead of using a patchwork of smaller suppliers.

We have come to a confluence of somewhat opposing trends – the desire of consumers to have fresher foods that require less preparation and are available year round (w/ the subsequent increase in the amount of imported foods), the movement towards local foods (and smaller firms that may or may not have the required level of food safety systems in place), an ever improving foodborne-disease-detection system, and a lawsuit-driven punishment system that appears ready to go beyond the responsible party and collect retribution from the linked food chain. Is it possible to develop trust through validation and verification of the supply chain?


Today: Walmart, Kroger, Primus. Tomorrow: You?by David Acheson on June 7, 2012 in Food Safety
http://leavittpartnersblog.com/2012/06/today-walmart-kroger-primus-tomorrow-you/?utm_source=rss&utm_medium=rss&utm_campaign=today-walmart-kroger-primus-tomorrow-you

Last week, Jensen Farms, the grower of the cantaloupe implicated in the Listeria outbreak of 2011, filed for bankruptcy. Prominently listed in the filing were lawsuits associated with the outbreak, from which 146 people were sickened and 36 died. According to the Denver Post, Jensen’s attorney said the filing should free up millions of dollars in insurance and other funds.

Foodborne illness attorney Bill Marler has filed at least 11 lawsuits and is representing almost 40 families or persons said to have been sickened or killed because of the contaminated cantaloupe. According to an article in Marler-published Food Safety News, the bankruptcy filing means that his clients “can move on to file lawsuits against companies further down the supply chain: Frontera Produce, the cantaloupe distributor; retailers such as Walmart and Kroger; and Primus Labs, the third-party auditor whose subcontractor, Bio-Food Safety, gave Jensen Farms facilities a ‘superior’ inspection rating just six days before the outbreak began.”

“Bankruptcy of Jensen Farms was a necessary prerequisite to allowing families of those who died and those who were injured to seek compensation against Frontera, Primus, suppliers and retailers,” Marler said.

If Mr. Marler is successful in bringing and winning these cases, it is telling us that someone as distant from the farm as the retailer is highly vulnerable to being sued if a farmer’s product makes someone sick and that farm then declares bankruptcy. If you sell adulterated food – or have some role in handling, distributing, or maybe even transporting anywhere along the food chain of that adulterated food, you would be liable to some extent – regardless of the cause or origination of the contamination.

What does this mean to you and the industry?

We are back to that old issue of controlling risk in the supply chain. It is becoming increasingly important that you spend time assessing and addressing risk across your product line supply chains. As we’ve seen in recent outbreaks, it is not enough to focus on historical incidents – cantaloupe was not known to carry Listeria; raw egg has long been a factor in Salmonella outbreaks, but it was likely the cookie dough flour that caused that 2011E.coli O157:H7 outbreak.

Risk assessment is not only critical for consumer and brand protection, it is a key aspect of the preventive provisions of FSMA. In fact, the pending rule, Hazard Analysis and Risk-Based Preventive Controls (Section 103) focuses directly on this area. As we stated in a previous newsletter, preventive controls should be tied to preventing foodborne illness, not just decreasing product contamination.

The vulnerability of not knowing and validating your entire supply chain is becoming more evident. One forward, one back may still be law for product tracking, but back to the farm is fast becoming the legal definition of responsibility. And without continuing the barrage against third-party auditors too heavily, it is a responsibility that processors and retailers are becoming leery of outsourcing, especially for high-risk products. And should these companies decide to conduct all their own supplier assessments and audits because they no longer trust outsourced audits, it could force food-industry consolidation and will fly in the face of robust programs like GFSI. I would like to bet that a Kroger or a Walmart would rather conduct 50 audits of large farms than be forced to audit 500 small farms. It is a potential that does not bode well for small suppliers, and could literally cut them out of the loop for many retailers.

In addition, whether or not such potential would come to fruition, supply chain management is specifically listed as an area for which risk-based preventive controls are required by the Food Safety Modernization Act (FSMA). As noted in a previous newsletter on FSMA key provisions, as part of its food safety plan, a facility may be required to document sanitation procedures, a recall plan, a food allergen control program, supplier verification activities, and environmental sampling testing.

Cola, BPA, and Our Aversion to Risk

Recently, Campbell Soup made the decision to move away from cans that contain BPA the lining. Was it justified? FDA initially concluded that BPA was not a risk, but after public pressure, they are reevaluating its safety.

 Another controversy brewing is the caramel color that gives cola soft drinks their brown color. The chemical, 4-methylimidazole (4-MI), is formed when the caramel color is manufactured. According the FDA, the levels found in soda are well below any concern. The FDA spokesman, Doug Karas stated "A consumer would have to consume well over a thousand cans of soda a day to reach the doses administered in the studies that have shown links to cancer in rodents”. However, the consumer watchdog group, Center for Science in the Public Interest (CSPI), doesn’t agree. They have petitioned FDA to have 4-MI banned.

 How do the risks associated with certain chemicals in our food stack up against non-food related risks? For the consumer, this question is difficult to answer. In evaluating the risk associated with a chemical, numerous studies are completed. The scientists issue reports and from these reports, numerous interpretations are made, including ones by industry associations, consumer advocacy groups, and government agencies. Then some of these interpretations make their way to the consumer, either through the mass media (TV, newsprint) or through social media (websites, blogs). 

The studies that are conducted to determine risk are rarely perfect. Animal models, where large quantities are injected into small animals such as rats, are often used for toxicity determinations. With these, there is always a question of how realistic it is when compared to humans and their normal living conditions. When large scale human surveys are used to determine risk, it is often difficult to control all of the variables including what people eat, their daily habits, and their genetic makeup. In the end, we hope that conclusions that are drawn are done are unbiased and done in the best interest of the public.

 Public opinion polls have been done that show that that is an increasing concern in the consumers’ perception of food hazards. The apparent lack of trust on these technical risk assessments and this can be linked to a number of factors. One is the stories that are reported in the news media and how they are reported. In addition to television and print news, many people now use the internet for their information. On the internet, we see the whole gamut of information, from the scientific studies themselves to the totally unscientific opinion pieces. 

One of the primary fears that people have is cancer. Certainly past tragedies provide an underpinning for the public’s concern. Asbestos and tobacco are two examples of cancer related items that have received a high level of media coverage and have led to people being skeptical. So when a linkage is made between a chemical in food and cancer in the news or the media, it will get attention. The question of the level of risk, however, is often more difficult to discern. 

How should one respond? First, consumers should inform themselves as best they can by using valid sources of information. It is also important to understand the bias of those providing the information, and try to obtain a balance in what is read. Remember that the information out there is rarely clear cut, so it is important for consumers to make a determination where they feel comfortable.

Links

http://healthland.time.com/2012/03/06/soda-wars-can-the-color-in-your-cola-give-your-cancer/?iid=hl-main-lede?xid=gonewsedit#ixzz1oRRVsFCH
http://www.forbes.com/sites/amywestervelt/2012/03/05/under-pressure-from-parents-advocacy-groups-campbells-goes-bpa-free/
http://www.forbes.com/sites/henrymiller/2011/10/25/bpa-is-still-ok/