This Week in Mislabeled Products for Week Ending February 22, 2020

Cheddar Chips in Wrong Labeled Bag Results in Milk Allergen Miss -  Saratoga Potato Chips, llc of Fort Wayne, Indiana is recalling 140 cases of Kroger Sweet & Mesquite BBQ Potato Chips 17 oz (UPC 0111100320101) with the specific lot code because it may contain undeclared milk.  The issue was discovered when some consumers reported finding cheddar cheese flavored chips in the Bag of Sweet & Mesquite BBQ Potato Chips

Product With Peanut Gets Wrong Labeled Sleeve -  Containing Peanuts Mislabeled - CJ Foods, Inc., a division of CJ America, Inc., of La Palma, CA, is voluntarily recalling Annie Chun’s Japanese-Style Teriyaki Noodle Bowls because it may contain undeclared peanuts. The voluntary recall was initiated because the company discovered some bowls that were packaged in outer sleeves indicating Teriyaki Noodle Bowls contain Pad Thai noodle, which contains peanuts that are not listed on the ingredient list or allergen information.

Study - Growth and Survival of Vegetative Pathogens in Beef and Plant (Fake Beef) Burgers

Not that we would expect to have high levels of vegetative pathogens (STEC, E. coli, Listeria, and Salmonella) in plant-based burgers, but we would consider the risk of them being there should be low, with the possible exception of Listeria.  However, the plant-based burgers are a TCS food (they have the necessary nutrients, Aw and pH) and thus will support the growth of organisms during storage. 

Storage at refrigeration and slight temperature abuse situations - At slight temperature abuse temperatures (10C), the levels of all three pathogens increased by ca. 1.0 to ca. 2.5 log CFU/g in plant-based burgers (beef burgers showed a slight decrease).
Cooking - all pathogens were reduced equally well in plant-based burgers and regular burgers.

Key - need to treat plant based burgers like regular burgers, especially regarding storage temperatures.

Viability of Shiga Toxin–Producing Escherichia coli, Salmonella, and Listeria monocytogenes within Plant versus Beef Burgers during Cold Storage and following Pan Frying 
JOHN B. LUCHANSKY ;  BRADLEY A. SHOYER  ;  YANGJIN JUNG  ;  LAURA E. SHANE  ;  MANUELA OSORIA  ;  ANNA C. S. PORTO-FETT
J Food Prot (2020) 83 (3): 434–442.
https://doi.org/10.4315/0362-028X.JFP-19-449

ABSTRACT

The viability of Shiga toxin–producing Escherichia coli (STEC), Salmonella, and Listeria monocytogenes within plant- and beef-based burgers was monitored during storage and cooking. When inoculated (ca. 3.5 log CFU/g) into 15-g portions of plant- or beef-based burgers, levels of STEC and Salmonella decreased slightly (≤0.5-log decrease) in both types of burgers when stored at 4°C, but increased ca. 2.4 and 0.8 log CFU/g, respectively, in plant-based burgers but not beef-based burgers (≤1.2-log decrease), after 21 days at 10°C. For L. monocytogenes, levels increased by ca. 1.3 and 2.6 log CFU/g in plant burgers after 21 days at 4 and 10°C, respectively, whereas pathogen levels decreased slightly (≤0.9-log decrease) in beef burgers during storage at 4 and 10°C. Regarding cooking, burgers (ca. 114 g each) were inoculated with ca. 7.0 log CFU/g STEC, Salmonella, or L. monocytogenes and cooked in a sauté pan. Cooking plant- or beef-based burgers to 62.8°C (145°F), 68.3°C (155°F), or 73.9°C (165°F) delivered reductions ranging from ca. 4.7 to 6.8 log CFU/g for STEC, ca. 4.4 to 7.0 log CFU/g for L. monocytogenes, and ca. 3.5 to 6.7 log CFU/g for Salmonella. In summary, the observation that levels of all three pathogens increased by ca. 1.0 to ca. 2.5 log CFU/g in plant-based burgers when stored at an abusive temperature (10°C) highlights the importance of proper storage (4°C) to lessen risk. However, because all three pathogens responded similarly to heat in plant-based as in beef-based burgers, well-established cooking parameters required to eliminate STEC, Salmonella, or L. monocytogenes from ground beef should be as effective for controlling cells of these same pathogens in a burger made with plant-sourced protein.

Study - Prevalence of Salmonella and STEC E. coli in Pork Products

A study conducted by FSIS looked at the prevalence of Salmonella and STEC E. coli in pork products.  Analysis "determined that the national prevalence of Salmonella in raw pork products was highest in comminuted products (28.9%), followed by intact cuts (5.3%) and nonintact cuts (3.9%). Less than 1% of samples analyzed were positive for the top seven STEC. Our findings indicate there is a need for additional pathogen reduction strategies for raw pork products."

Journal of Food Protection
Volume 83, Issue 3
1 March 2020
https://meridian.allenpress.com/jfp/article/83/3/552/426177/Salmonella-and-Shiga-Toxin-Producing-Escherichia
Salmonella and Shiga Toxin–Producing Escherichia coli in Products Sampled in the Food Safety and Inspection Service Raw Pork Baseline Study 
MARIA E. SCOTT;  EVELYNE MBANDI ;  STEPHANIE BUCHANAN ;  NASER ABDELMAJID  ;  CHRISTIAN GONZALEZ-RIVERA;  KIS ROBERTSON HALE;   LISA JACOBSEN ;   JENNIFER WEBB;  JENNIFER GREEN ;  PAUL DOLAN 

ABSTRACT
The Food Safety and Inspection Service (FSIS) conducts microbiological baseline studies to determine national prevalence of select foodborne pathogens in federally inspected meat and poultry products and to obtain data for risk assessments. The FSIS conducted a baseline study from 1 June 2017 through 31 May 2018 to characterize and determine the prevalence of Salmonella and assess the occurrence of Shiga toxin–producing Escherichia coli (STEC) in a variety of raw pork products. In total, 4,014 samples from slaughter and processing establishments were analyzed for Salmonella; a subset of these samples (1,395) from slaughter establishments were also analyzed for STEC. Analyses determined that the national prevalence of Salmonella in raw pork products was highest in comminuted products (28.9%), followed by intact cuts (5.3%) and nonintact cuts (3.9%). Less than 1% of samples analyzed were positive for the top seven STEC. Our findings indicate there is a need for additional pathogen reduction strategies for raw pork products.

FDA Warning Letter - Another Importer Without a FSVP Program for Their Imported Food Items

FDA issued a Warning Letter to Mission, LLC of, Renton, WAS for not have a FSVP (Foreign Supplier Verification Program) in place for the food items that the company was importing.  Specifically, they did not have a FSVP for imported black tea.  As part of this analysis, the company would conduct a hazard analysis on this item and determine if any of the hazards are significant, requiring control by their supplier.

WARNING LETTER
Mission LLC
MARCS-CMS 593118 — February 06, 2020

FDA Closes Investigation into 2019 Fruit Mix Salmonella Outbreak

FDA closed their investigation into the 2019 Salmonella outbreak that was linked to fruit mix from a NJ facility.  The outbreak was first identified in PA health facilities where 31 became ill.  In the end, there were 165 cases with 73 hospitalizations.  While the investigation identified Tailor Cut Produce of North Brunswick, New Jersey as the source, and identified issues at that facility including:

"the inspectors observed these general deficiencies: the firm’s hazard analysis did not identify a known or reasonably foreseeable hazard that required a preventive control; the firm did not identify a preventive control for a hazard when one was needed; and the firm did not maintain the plant in a clean and sanitary condition and keep the plant in repair",

they were not able to identify the origin of the Salmonella.


https://www.fda.gov/food/outbreaks-foodborne-illness/outbreak-investigation-salmonella-javiana-fruit-mix-december-2019
Outbreak Investigation of Salmonella Javiana: Fruit Mix (December 2019)
FDA’s investigation is complete. CDC announces outbreak is over.
Case Counts
Total Illnesses: 165
 Hospitalizations: 73
 Deaths: 0
 Last illness onset: January 11, 2020
 States with Cases: CA, CO, CT, DE (49), FL, GA, IL, MA, MN, NJ (50), NY (7), PA (49), VA, WA
February 18, 2020

The Importance of Naming the Coronavirus - Covid-19

An interesting article in Vox about the naming of the novel coronavirus. It was given the name Covid-19, derived from COronaVIrus Disease 2019. Not very exciting, although giving it a technical name prevents it from being labeled with a name that can unintentionally create fear...such as tying it a location, tying it to an animal or a food. One just needs to look at swine flu that  resulted in the unneeded culling of some pigs.   Or worse, having the media label it, such as was done with Mad Cow (although that was a prion and not a virus).

VOX.com
https://www.vox.com/2020/2/14/21135208/coronavirus-wuhan-china-covid-19-name-sars-cov-2
The life-and-death consequences of naming the coronavirus

A bad name for an illness can be dangerous. That’s why it took so long to settle on Covid-19.
By Umair Irfan Feb 14, 2020, 10:40am EST

Coronavirus Update - February 14, 2020

In the Coronavirus outbreak, strain designated COVID-19, the case numbers continue to grow, but a testing change by officials in China has had a impact on those numbers, causing the total number to surge higher.  CNBC reports that there are now some 64,000 reported cases wit 1,380 deaths.  There have been 15 cases confirmed in the US, but patients are under quarantine.  The risk in the US is still considered low.

From a Market Watch article - "Health authorities in Hubei Province are now counting cases that have been diagnosed solely by a computed tomography (CT) scan, not a combination of a CT scan and an RNA test. The most recent update from China’s National Health Commission states there were 15,152 new cases, a sevenfold increase over the 2,015 new cases that had been reported the day before. "

The CT method is a quicker analysis compared to the RNA tests that takes days.  The CT scans reveal lung infection, so it is not as specific.  And with a shortage of RNA test kits, many cases were being missed.

From a business perspective, one of the big casualties is the cruise ship operations.  With passenger ships having to quarantine passengers when there is a suspect case, it is easy to see why many may not want to get aboard.

WHO RISK ASSESSMENT
China Very High Regional Level High Global Level High
Market Watch

Report on Food Recalls Fails

In a recent report put out by a public interest group, they claim that grocers do a poor job in communicating recall information.  In "Food Recall Failure Will your supermarket warn you about hazardous food?, the group gave the grocers a failing grade.  Their primary reason, so it seems, the grocers did not send the group the information they requested.  Then the firm conducted their one investigation based on their evaluation of a company's procedures.

Whatever.  This is more of a headline grab than a real evaluation.  Actual evidence will show that grocery stores do a pretty good job at removing items from the shelves, and contacting consumers as best they can.  Can they do better, sure, but it is not the catastrophic failure the article makes it to be.

This is the same group that released "New report: Meat recalls remain high; produce and processed food recalls drop".  One of their top findings - "The most hazardous meat and poultry recalls (Class I) have nearly doubled, up 85 percent percent since 2013. This is a slight increase from 2018. Total meat and poultry recalls are up 65 percent since 2013."  There was no evaluation into what the recalls were, but more of a insinuation that it is all extremely dangerous, when in fact, many of the recalls are either related to allergens or physical material contamination,  or are proactive due to a potential issue, not an actual issue.

FDA Releases Supplemental Draft Guidance on Food Defense Regulation

FDA released a supplemental 'draft' guidance to support the IA Rule (Intentional Adulteration or Food Defense).  It is supplemental in that it adds content on elements not covered in the previous guidance issued last year (Draft Guidance for Industry: Mitigation Strategies to Protect Food Against Intentional Adulteration March 2019).

This supplemental guidance covers the elements for managing mitigation strategies - specifically corrective action, verification, and reanalysis.  It provides more detail on what FDA would be looking for when evaluating the mitigation strategies the facility has chosen.

As you know, the facility conducts a vulnerability assessment to determine which points in the process are most vulnerable, the actionable process steps.  For the actionable process steps, the facility must determine and implement mitigation strategies to reduce the vulnerability.  These strategies must be monitored, documented, verified, have corrective action, and be reanalyzed.

In general, the guidance allows a more basic and flexible approach than Preventive Controls regarding corrective action and verification activities. For example, if a mitigation strategy is having a tank hatch locked with a monitoring activity stated as checking the lock. The corrective action if a tank is not locked would be to lock it and retrain the employee.  Verification is simply checking records to make sure the lock check was taking place, and the corrective action of retraining the employee took place.  And of course, conducting analysis of the plan every 3 years (unless there is a process change or other special conditions).


https://www.fda.gov/regulatory-information/search-fda-guidance-documents/supplemental-draft-guidance-industry-mitigation-strategies-protect-food-against-intentional
GUIDANCE DOCUMENT
Supplemental Draft Guidance for Industry: Mitigation Strategies to Protect Food Against Intentional Adulteration