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

Venison and STEC E. coli

In this CDC report, high school students became infected with STEC E. coli from the mishandling / undercooking venison. Here, a group of students collected deer, processed them, and then prepared them as kebobs…..at school. 2 of them were hospitalized with STEC E.coli, (29 were ill, most were not E.coli related, rather some other type of illness). 

Studies have shown that deer do carry pathogenic E. coli. From the linked CDC report: “A study of white-tailed deer feces in Minnesota and Wisconsin found non-O157 STEC in 5% of samples (9). … Prevalence rates of E. coli O157 in deer have ranged from 0.25% to 2.4% (10–12). Previous outbreak investigations and case reports have linked E. coli O157 infections to deer (13–15).”
 
STEC E. coli is a very serious pathogen that can result in kidney failure and death. It is important for those processing, handling, and preparing venison to follow accepted practices of cooking, cleaning, chilling, and preventing cross contamination. In regard to cooking, wild game meat such as venison should be cooked o 165ºF.

Prevening Allergen Related Recalls Due to Mislabeling

The leading cause of recalls is allergens.  Case in point, 3 allergen-related recalls over the last two days due to mislabeling.  In two cases, the wrong preprinted label was placed on the food item, in the other, the wrong sauce mix packet added to the food package.

Prevention – making labeling a CCP – a critical control point to prevent a chemical hazard – allergens.  There are many companies that use multiple labels with varying allergens on each.  Having the additional attention that goes along with designating a process step as a CCP will require more thorough monitoring, verifying, and reporting.  For example, the label operator must sign-off on each pack or case of labels by reviewing the days production sheet as well as the formulation sheet in order to check for compliance with the label.  In addition, there would be verification of labels and formulation by QC and production supervisors, as well as daily sign-off by the HACCP coordinator.  All would be need to be trained in label review with an eye towards allergen identification.   I would argue that this step must be a CCP because based on industry history, hazards are not being prevented.  From a cost savings standpoint, although this added step will require operator time, it is cheaper than conducting a recall.

CDC lists Multistate Foodborne Outbreaks for 2011

CDC has updated their Multistate Foodborne Outbreak listing for 2011 (http://www.cdc.gov/outbreaknet/outbreaks.html). This is a nice reference page for reviewing major food outbreaks that have occurred over the past 6 years. (An outbreak, as defined by CDC is “When two or more people get the same illness from the same contaminated food or drink”)

 A few things to note:

• This does not include recalled products – products recalled due to only the presence of pathogens (pathogens were detected in the product, but there were no illnesses reported). There have been many recalls that have occurred due to positive analysis for a pathogen, especially now with the Reportable Registry (http://www.fda.gov/food/foodsafety/foodsafetyprograms/rfr/default.htm). And so it follows, it does not include recalls for allergens – the major cause for companies to conduct recalls.
• This list does not include single state outbreaks – so this list is manly large companies that produce products. This does not mean that smaller establishments do not have issues.
• A few items were actually not food, but rather pets (frogs and chicks/ducklings in 2011, and water frogs and frozen rodents, which are used to feed slithering pets, in 2010). One item was dog food, which we will count as food – you dog food eaters know who you are.
• There appears to be an increase in the number of entries each year on this listing. I don’t suspect things are getting worse, but rather detection and reporting are getting better.
• Of the 41 entries over the 6 year period where a cause can be found (dropping the pet related entries and the laboratory entry), fresh ground meat had 6 entries, alfalfa sprouts had 5, leafy greens had 5, and cantaloupe had 3.
• Salmonella related outbreaks accounted for roughly 2/3 of the entries. This is due to the wide prevalence of Salmonella in the enviornment.
• FDA regulated product entries accounted for 25 entries, USDA for 11, and I suspect that two of the outbreaks were from facilities that had both USDA and FDA oversight.
• Roughly 27 are what one would consider ready to eat (no required consumer cooking step). 14 entries were products would be considered products that required cooking, that if done sufficiently by the consumer, would have prevented illness (reasons why vary - cookie dough traditionally eaten raw, pot pies – poor cooking instructions, raw meat – no thermometer use).
• As a consumer, I avoid alfalfa sprouts, use a thermometer to cook my ground meat, really wash my cantaloupes, pray my chopped lettuce was not harvested from a farm located next to a cow barn, cook my cookie dough to have crunchy cookies, and refuse to buy my kids turtles, frogs, and snakes (that have to fed frozen rodents.) I have also ceased from eating dog food.

 Multistate Foodborne Outbreaks

 http://www.cdc.gov/outbreaknet/outbreaks.html

When two or more people get the same illness from the same contaminated food or drink, the event is called a foodborne outbreak. Public health officials investigate outbreaks to control them, so more people do not get sick in the outbreak, and to learn how to prevent similar outbreaks from happening in the future.

CDC and partners ensure rapid and coordinated surveillance, detection, and response to multistate foodborne outbreaks.

Outbreaks by Year

 2011

 · Ground Beef - Salmonella Typhimurium

 · Romaine Lettuce - Escherichia coli O157:H7

 · Kosher Broiled Chicken Livers - Salmonella Heidelberg

 · Turkish Pine Nuts - Salmonella Enteritidis

 · Jensen Farms Cantaloupes - Listeria monocytogenes

 · Ground Turkey - Salmonella Heidelberg

 · Whole, Fresh Imported Papayas - Salmonella Agona

 · African Dwarf Frogs - Salmonella Typhimurium

 · Alfalfa and Spicy Sprouts – Salmonella Enteritidis

 · Travel to Germany - Shiga toxin-producing E. coli O104

 · Chicks and Ducklings - Salmonella Altona and Salmonella Johannesburg

 · Microbiology Laboratories - Salmonella Typhimurium

 · Turkey Burgers - Salmonella Hadar

 · Lebanon Bologna - Escherichia coli O157:H7

 · Del Monte Cantaloupe - Salmonella Panama

 · Hazelnuts - Escherichia coli O157:H7

Regrouping after Listeria on Cantaloupe

One bad cantaloupe [farmer] can spoil the whole bunch….in the LA Times article (below), we see another example of negative impact on an entire industry caused by a producer using less-than-good practices. Interestingly stated, “…California shipped more cantaloupe in a day than Colorado[where the incident occurred] in their whole season. Millions and millions of cantaloupe, healthy and fine."  Now these California producers are not planting as much while trying to spin the story as best they can.

In this digital news age where any tragedy is reported instantly, and then pounded on for days, while often providing little or no information to the specifics, we can’t expect consumers to act much differently.  Consumers want to avoid risk, and if that means forgoing an entire commodity item, then so be it.  There are other, perceivably safer alternatives in the marketplace for consumers to choose.

The point that is hard to understand is how do producers or processors not choose to follow best practices.  Do they know what best practices are for their industry?  Do they truly understand the risks associated with their product and process?

Because of this gap in what is done and what should be done by a some less-than-good companies, and this is probably a small group, government steps in with regulations such as those to be enacted by the new Food Safety Modernization Act legislation.  And still, many companies and industry groups fight against new legislation or having to comply with the proposed regulation.  Granted, some components of the regulation may be initially overkill or not well thought out, but this is where the comment period provides a chance for those with issues to voice their objections.  And the better industry groups work with the agencies to iron out the rough spots within the proposed regulation.

In the news, we hear of companies who decide to get out of the business rather than comply with new regulations.  Some see this loss of a local employer at tragic.  Not me.  If companies are not willing to keep up, if they are not willing to continually update themselves and their employees on the science and technology associated with making safe food, then it is best for the industry that they leave it to those who are.  Certainly, there is a cost to continual improvement, but resources are available through industry groups, government agencies, and academic institutions (including Extension).  It’s not “get big or get out”, it’s “get smart or get out”.

California cantaloupe farms regroup after listeria outbreak

California's Central Valley is 1,300 miles from the Colorado farm linked to a deadly listeria outbreak. But that hasn't registered with the public. Cantaloupe growers hope to change that.

By Diana Marcum, Los Angeles Times
January 5, 2012, 3:53 p.m
http://www.latimes.com/business/la-fi-cantaloupe-crop-20120106,0,6658258.story?page=1&utm_medium=feed&track=rss&utm_campaign=Feed%3A%20latimes%2Fbusiness%20%28L.A.%20Times%20-%20Business%29&utm_source=feedburner

Study: Cost of Foodborne Illness in US Estimated at $77 billion

This study gives us an idea of the costs related to foodborne illness, and is great to use in presentations, but as the author points out, the numbers are limited in their application to justify any particular action in reducing foodborne illness.

http://www.cidrap.umn.edu/cidrap/content/fs/food-disease/news/jan0312cost.html

Impact of FSMA on Recalls through Improved Prerequisite Programs

It is amazing to see the number of recalls that are issued each week. I put put together the listing of the recalls that occurred within the last week (Dec 6 to 12, 2012).  There are a range of items, most, if not all, related to prerequisite program issues (allergen control and labeling, supplier/ingredient control, environmental control).

In an article written by David Acheson, http://leavittpartnersblog.com/20113304/david-acheson/fda%E2%80%99s-views-on-preventive-control-requirements-beginning-to-emerge-time-to-go-beyond-haccp, he provides a view of FDA official comments, specifically that FSMA will go beyond HACCP. He suggests that FDA will put in more specific guidance to address key elements of food safety programs,  pointing out that environmental monitoring and training will be two highlighted areas.  Looking at the recalls we are seeing, it is hard to argue that prerequisite programs have become the primary issue with regard to outbreaks and recalls.  Companies should begin looking at all programs that are responsible for controlling hazards to ensure they address monitoring, corrective actions, and verification.

While some will bristle at additional requirements, the cost of conducting a recall due to lack of control is worth the effort for improving low risk hazards are controlled.