FDA Releases Final Rule on Food Defense - Preventing Intentional Contamination of Food - Summary

The rule, titled Mitigation Strategies To Protect Food Against Intentional Adulteration, applies to domestic and foreign food companies that are registered with the FDA to address hazards that may be introduced with the intention to cause wide scale public health harm. . Basically, if you are producing food for sale and have registered your facility with FDA, then you have to have a food defense plan. There are a few exemptions to who has to apply.

Commentary - this is very broad/open and care must taken when preparing this program  A concern would be claiming too many vulnerabilities and then having to correct too much (and the expense of that).

Below is a summary of the major sections of the document.

Requirements - "Each covered facility is required to prepare and implement a food defense plan. This written plan must identify vulnerabilities and actionable process steps, mitigation strategies, and procedures for food defense monitoring, corrective actions and verification. A reanalysis is required every three years or when certain criteria are met, including mitigation strategies that are determined to be improperly implemented. " .

1.  You must prepare, or have prepared, and implement a written food defense plan.

This includes:

FDA Updates Nutrition Facts Labels for Food Products

It is time to begin updating the nutrition facts labels on food packages.  FDA is updating their requirements for the nutrition facts label in order to "consumers have updated nutritional information for most packaged foods sold in the United States, that will help people make informed decisions about the foods they eat and feed their families."

While about half or more of the people say they look at labels, research has show that very few actually look at the label.  But some are very excited:

“I am thrilled that the FDA has finalized a new and improved Nutrition Facts label that will be on food products nationwide,” said First Lady Michelle Obama. “This is going to make a real difference in providing families across the country the information they need to make healthy choices.”

Well, it will be good business for the labeling companies and those who do the nutritional determinations.

The compliance date is July 26, 2018 for most companies, and for smaller companies with less than $10 million in sales, the date is extended to July of 2019.

FDA News Release
http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm502182.htm
FDA modernizes Nutrition Facts label for packaged foods
Refreshed design and relevant information will help consumers make healthy food choices
For Immediate Release
May 20, 2016

SunOptima, Source of Sunflower Seed Recall for Listeria, Expands Original Recall, Forces Downstream Packers to Expand Recalls

SunOptima is expanding their sunflower seeds w/ Listeria recall. The initial recall was produced at their Minnesota facility in the month of February. The time frame of production recall now extends from February through April 21, the date at which the plant was closed.

 

It never seems to be a Listeria recall without having an expansion of that recall. This occurs when companies realize that they did not have real control of the organism, whether that is a contaminate within the processing environment or within purchased raw materials. Since sunflower seeds are roasted and de-hulled, it would lead one to believe it was post roasting contamination.

 

The process of making sunflower seed is similar to other processing of nut. For a nice review of the process, you can visit 'How Products are Made.  Here are the highlights from that review"

Sunflower seed production begins in early spring when the fields are prepared and the seeds are planted.

1. Sunflowers are ready to harvest when the black part of their heads turns brown. In the United States this is generally in late September or October. A special device collects the sunflower heads          
2. The seeds are rapidly dried to under 10% moisture content and then stored in grain elevators.
3. At the processing plant, they are emptied onto wire screens and shaken to remove dirt, inspected, and further cleaned.
4. The seeds are then passed on to sizing screens which separate them by size.
5. Large sized seeds go to snack food sunflower seeds are transferred through large ovens to dry roasted, reducing the moisture level in the seed further. The medium sized seeds are first sent through de-hulling machines which remove their shells. They are then roasted in oil
6. The seeds are then flavored as desired. This can be done by an enrobing process - running the warm seeds from the roasters into a large, rotating container where combined with oil the flavoring ingredients.
7. The seeds are then packaged with a focus on reducing oxidation that would promote rancidity.

The interesting thing is that one would expect that this would be a dry process, not noted for being the typical environment where Listeria would be found.

 

FDA Recall Noticehttp://www.fda.gov/Safety/Recalls/ucm502184.htm
Expanded Recall Period of Certain Sunflower Kernel Products Due to Possible Contamination By Listeria monocytogenes
For Immediate Release
May 18, 2016

A Salmonella Outbreak in MN Linked to Bagged Salad

Bagged salad produced by Taylor Farms are being linked to a Salmonella outbreak in Minnesota where six people have been infected.  The illness occurred in the month of April and product had been pulled from the store where purchased (Sam's Club).   The strain of Salmonella enteritidis was identified by a unique DNA fingerprint.


The Packer
http://www.thepacker.com/news/taylor-farms-linked-salmonella-outbreak
Taylor Farms linked to salmonella outbreak
By Andy Nelson May 19, 2016 | 4:45 pm EDT

A salmonella outbreak has been linked to bagged salads shipped by Taylor Farms.

In early May, the Minnesota Department of Agriculture alerted the Food and Drug Administration about salmonella infections it had linked with Organic Kale Medley Power Greens bags shipped by Salinas, Calif.-based Taylor Farms and sold at Sam’s Club stores in Minnesota, according to an FDA spokesperson.

FDA Investigation Report for Frozen Produce Facility at Center of Recall

The FDA released the inspection report of the CRF facility that was responsible for the massive frozen vegetable recall.  The inspection, conducted in March and transcribed below, found no blaring issues cited, but just some basic hits to the equipment and utensils used.  Surprising?  Not really, because a visual inspection is not going to identify low level contamination issues, such as what we expect was the case at CRF.   While you can find signs of sanitation lapses in an inspection that can lead to harborage issues or indicators of overall poor sanitation, it is really microbial sampling that will provide an idea of control.  Another important inspection is a review of the sampling being conducted by the facility - are they sampling for Listeria, how many samples, what are the results, is there corrective action, when are they sampling, who is doing the testing, how are they sampling, etc. In the end, is the facility really trying to find it, or are they doing testing just to say they are doing testing.

The transcription of the report:

Harvard Article on Food Safety Economics

Saw this piece on food safety economics released by Harvard Business Schools, and thought it might be worth the read.  In the end, meh..nothing we didn't know. 

To save you time - basically, there can be a huge economic cost of food safety lapses, such as that experienced by Chipotle.  There are a number of challenges - small producers and global sourcing where food safety systems may not be all they need to be, and news reports that highlight foodborne illness outbreaks which bring a lot of attention to these food safety lapses.  They also discuss how a company did their own testing when they could have saved money by outsourcing (my guess is that this was the focus of the research and the story was written around it). 

On the testing topic, there is more than just cost that has to be considered.

Harvard Business School
http://hbswk.hbs.edu/item/food-safety-economics-the-cost-of-a-sick-customer
Food Safety Economics: The Cost of a Sick Customer

Food Trucks and Food Safety Challenges

In this LA Times piece, the food safety performance of food trucks is discussed.  It seems that in LA, food trucks have more sanitary issues than the average restaurant.  There are a number of challenges on food trucks that make managing food safety more difficult....small space with more opportunity for cross contamination, temperature control issues, etc.
 

LA Times
http://www.latimes.com/local/california/la-me-food-trucks-20160518-snap-story.html
The dark side of trendy food trucks: A poor health safety record
Ben Poston, Caitlin Plummer and Michael Radcliffe
May 18, 2016

It’s a daily culinary performance that plays out across Los Angeles: Top food truck chefs whipping up gourmet meals in spaces no bigger than a restaurant’s stockroom or walk-in freezer.

But even as the trucks have become a popular staple of the local food scene, with Twitter followers and long queues, they have been lagging behind restaurants and even sidewalk food carts in one important category -- health safety, a Times data analysis found.

About 27% of food trucks earned lower than A grades over the last two years, according to a Times review of Los Angeles County Department of Public Health data. By comparison, slightly less than 5% of brick-and-mortar restaurants and about 18% of food carts fell below that mark.

Final Rule Issued on Requirement to Label Mechanically Tenderized Beef

The final rule has been issued that requires cooking instructions for mechanically tenderized beef. It covers  needle- or blade-tenderized raw beef products product destined for household consumers, hotels, restaurants, or similar foodservice operations.  The label must say the meat is "mechanically tenderized," "blade tenderized," or "needle tenderized" and  a description of the beef component in the product name along with validated cooking instructions (minimum internal cooking temperatures and hold times).
 This has been in the works for some time and it is good to see that it is ready to be put in place.  The issue is that in the tenderization process, bacteria can be forced into the meat.  Because of this, the temperatures for cooking are more similar to that of hamburger than for intact steaks.

 USDA News Release
 http://www.fsis.usda.gov/wps/portal/fsis/newsroom/news-releases-statements-and-transcripts/news-release-archives-by-year/archive/2015/nr-051315-01
USDA Finalizes Rule to Require Labeling of Mechanically Tenderized Beef Products

 

 

New labels and cooking instructions will give consumers information they need  to safely enjoy these products

WASHINGTON, May 13, 2015 – The U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) today announced new labeling requirements for raw or partially cooked beef products that have been mechanically tenderized. Consumers, restaurants, and other food service facilities will now have more information about the products they are buying, as well as useful cooking instructions so they know how to safely prepare them.

Poultry Products Recall Expanded (for 3rd Time) Due to Foreign Objects

Pilgrim's Pride has expanded its recall for cooked poultry products because of foreign material.  This is the third expansion of that recall that started on April 7,  and then was expanded on April 26.

 

This recall coordinator is just not catching a break.

  

USDA Recall Notice

http://www.fsis.usda.gov/wps/wcm/connect/FSIS-Content/internet/main/topics/recalls-and-public-health-alerts/recall-case-archive/archive/2016/recall-027-2016-release-exp3

Pilgrim's Pride Corp. Expands Recall of Poultry Products Due to Possible Foreign Matter Contamination

Class I Recall 027-2016 expansion-3

Health Risk: High May 13, 2016