Developing a Food Fraud Prevention System

Over the past several years, we have had more questions on food fraud and developing a program to prevent the potential for food fraud.  An article in Food Safety News this past month, discusses a Food Fraud Management System.   Like a HACCP or even more so, a Food Defense system, it entails conducting a vulnerability assessment and identifying mitigating actions.  One of the key takeaways from the article, and it certainly makes sense, this system must constantly evolve.  It is not a system that can be developed and then be shelved for a year.  It requires continuous surveillance and probing by employees throughout the organization.

Food fraud is not a known risk, it is a risk that can emerge out of nowhere as a perpetrator finds a new way to take advantage of a vast food supply chain.  Catching this may not be an easy task, especially for one person assigned to the task.

Food Safety Magazine
https://www.foodsafetymagazine.com/magazine-archive1/december-2019january-2020/reducing-the-risk-of-fraud-in-the-spice-industry/
Reducing the Risk of Fraud in the Spice Industry
By Jill Hoffman

FDA Update on E. coli Outbreak Associated with Romaine from Salinas CA - Dec 19

FDA provided an update on the E. coli Outbreak associated with Romain from Salinas CA.  There are not 138 cases with 72 hospitalizations.  The last case reported is now Dec 1, 2019.

Wisc Dept of Health found the outbreak strain of E. coli in a bag of Fresh Express brand Leafy Green Romaine collected from an ill person’s home.  This allowed them to identify one of the growers who also provided Romaine to others linked to this outbreak.

https://www.fda.gov/food/outbreaks-foodborne-illness/investigation-e-coli-o157h7-outbreak-linked-romaine-salinas-california-november-2019
Investigation of E. coli O157:H7 Outbreak Linked to Romaine from Salinas, California, November 2019
FDA continues to warn against eating romaine from Salinas; farm investigations continue

December 19, 2019

Case Counts

• Total Illnesses: 138
• Hospitalizations: 72
• Deaths: 0
• Last illness onset: December 1, 2019
• States with Cases: AZ (3), CA (4), CO (6), FL (2), IA (1), ID (3), IL (10), MD (5), MI (1), MN (5), MT (1), NE (2), NJ (9), NC (2), NM (2), OH (12), OR (1), PA (17), SC (1), SD (1), TN (1), TX (6), VA (6), WA (4), WI (33)

CDC Alert on Listeria Outbreak Associated with Hard-boiled Peeled Eggs from GA Processor

CDC issued a food safety alert regarding hard boiled eggs from Alamark Foods as a potential source of Listeria.   "As of December 17, 2019, a total of seven people infected with the outbreak strain of Listeria monocytogenes have been reported from five states...... Epidemiologic and laboratory evidence indicates that bulk hard-boiled eggs produced by Almark Foods of Gainesville, Georgia, are a likely source of this outbreak." 

These eggs are hard-boiled, peeled, and packaged in plastic pails of various sizes.  It is during the peeling and packaging process where the eggs can become contaminated with Listeria.  Being a RTE product, the eggs will generally be eaten without further preparation, or certainly without preparation that would provide bacterial reduction (deviled eggs for example).  With a 49 day shelf-life at refrigeration temperatures, that is plenty of time to allow for the growth of this psychrotropic pathogen (capable of growth at refrigeration temperatures).


CDC Food Safety Alert
https://www.cdc.gov/listeria/outbreaks/eggs-12-19/index.html
Outbreak of Listeria Infections Linked to Hard-boiled Eggs
Posted December 18, 2019 at 6:30 PM ET

FDA Warning Letter to RTE Cheese Processor

FDA issued a Warning Letter to a cheese facility in Miami.  Issues include no Preventive Control Plan and really poor GMPs (dripping condensate, leaking pipes, and inadequate sanitation).  And they are producing RTE cheese product of some sort.

The thing that gets you is the company name....US Dairy Unlimited.   You are thinking with a name like that, that is a serious operation.  Could have called it Ury's Cheese, but who would buy that.  But US Dairy Unlimited....there are no limits to what they can do, or so one would think.

But looking at the facility (based on address from notice on Google Map Street view), it looks like nothing like Dairy Unlimited.  Not to say they can't make good products, but if this is your supplier, you may want to investigate a little closer.  For example, your purchasing person informs you that they have contracted a new co-packer....US Dairy Unlimited.  What supplier approval process granted this?

https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/us-dairy-unlimited-llc-590413-11192019
WARNING LETTER
U.S. Dairy Unlimited, LLC
MARCS-CMS 590413 — November 19, 2019

Tracking the E. coli Outbreaks - 3 Current Outbreaks

There are three current E. coli outbreaks that are being tracked by governmental agencies.  They appear to be unrelated. All are E. coli O157:H7, but they have been identified as different strains due to genetic differences. 
(Perhaps it is time to name these outbreaks like the Weather Channel has done with hurricanes and now does with storms.)

1. Salinas Romaine Lettuce

• 102 cases with 58 hospitalizations in 23 states
• Last case - November 18
• Source Romaine lettuce from Salinas CA

2. Salad kits from Fresh Express

• 8 cases with 3 hospitalizations in 3 states
• Last case - November 15
• Source Salad item, possibly Romaine lettuce

3. Washington Evergreen Restaurant

• 13 cases with 3 hospitalizations in one state (WA), Multiple outlets of one restaurant chain
• Last onset case - November 15
• Source not yet known

https://www.fda.gov/food/outbreaks-foodborne-illness/investigation-e-coli-o157h7-outbreak-linked-romaine-salinas-california-november-2019
Investigation of E. coli O157:H7 Outbreak Linked to Romaine from Salinas, California, November 2019
FDA continues to warn against eating romaine from Salinas; farm investigations continue
Updated December 12, 2019
Case Counts

• Total Illnesses: 102
• Hospitalizations: 58
• Deaths: 0
• Last illness onset: November 18, 2019
• States with Cases: AZ (3), CA (4), CO (6), FL (1), IA (1), ID (3), IL (1), MD (4), MI (1), MN (3), MT (1), NE (1), NJ (7), NC (1), NM (2), OH (12), OR (1), PA (8), SD (1), TX (4), VA (4), WA (2), WI (31)

This Week in Mislabeled Product for Week Ending December 14, 2019

Wrong Product Put in Package - Tropical Nut and Fruit Co. is voluntarily recalling their 25lb box of Truly Good Foods South of the Border nut mix because it contains undeclared soy and tree nut (almonds).  The voluntary recall was initiated after it was discovered that the wrong product was packaged inside the South of the Border box, therefore containing different allergens from what is stated on the label.

https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/tropical-nut-and-fruit-co-issues-allergy-alert-undeclared-soy-and-tree-nut-almonds-their-truly-good
Tropical Nut and Fruit Co. Issues Allergy Alert of Undeclared Soy and Tree Nut (Almonds) on Their Truly Good Foods South of the Border Mix
Summary
Company Announcement Date: December 06, 2019 

FDA Publish Date: December 06, 2019

Product Type:Food & Beverages  Snack Food Item  Allergens 

Reason for Announcement:  Undeclared almond and soy
Company Name:Tropical Nut and Fruit Co. 

Brand Name:  Truly Good Foods
Product Description:  South of the Border nut mix

Smoked Salmon Recalled for Potential Listeria Contamination After FDA Testing

A Wallkill, NY establishment is recalling Cold Smoked Salmon after routine FDA environmental sampling and analysis determined that the product has the potential to be contaminated with Listeria monocytogenes


https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/catsmo-llc-recalls-smoked-salmon-because-possible-health-risk
CATSMO LLC. Recalls Smoked Salmon Because of Possible Health Risk
Summary
Company Announcement Date: December 10, 2019
FDA Publish Date: December 10, 2019
Product Type: Food & Beverages  Fish  Foodborne Illness
Reason for Announcement: Listeria monocytogenes
Company Name: CATSMO LLC
Brand Name: CATSMO LLC
Product Description: Cold Smoked Salmon (whole fillets and specialty cuts)

NC - Police Find $3 Million in Barrels of Pork Shoulders

Police in NC discovered $3 million in cash hidden in a barrels of raw pork shoulders during a routine traffic stop of a tractor trailer.  The truck was believe to be headed to the US Mexican border and the cash was part of a drug money collection.


NY Daily News
https://www.nydailynews.com/news/crime/ny-three-million-in-cash-found-in-barrels-of-pork-in-north-carolina-20191211-at43radszfbpbgea2hwtkfcuzy-story.html
$3M in cash found in barrels of raw pork shoulder during traffic stop
Nelson Oliveira
By NELSON OLIVEIRA
NEW YORK DAILY NEWS |
DEC 11, 2019 | 10:24 AM

Talk about a piggy bank.

Why Does Bird Flu Not Cause a Major Outbreak in Humans?

Have you ever wondered why bird flu, although really bad for birds, is not as much an issue in humans?  Recent research provides us evidence of what is going on.  We'll attempt to summarize.

First, flu viruses are designated by two surface proteins H and N.
H - hemagglutinin, which enables the virus to infect human and animal cells where it can multiply,
N - neuraminidase, which helps the virus’s offspring to extract themselves from the infected cell.

So the virus enters the host cell, has the host replicate virus RNA which is used to make new viruses, and the high number of newly minted viruses explode out of the cell.  A person becomes sick as they fight off the viruses.  Worst case is when a person encounters new variants of  virus, that have different proteins including H and N, as would be the case with people getting a bird flu variant.  In this case, it takes the body longer to react to novel proteins of the variant, and the body has less defense system in place to fight the new virus.  The body reacts violently to counter the new virus, and it is this, the body's own defense system, that can be damaging (high fever, excessive phlegm, etc).

What this study found was that although the bird flu virus can infect a person, it does not replicate (make new virs) easily and thus does not spread easily.  The reason - the bird virus when in the human, does not produce a sufficient quantity of a protein, designated M1, responsible for getting the RNA out of the nucleus to begin making the new viruses in the cytoplasm of the host cell.   In humans, the bird viral RNA is spliced differently, making a protein called M2.

“Alternative splicing regulates which proteins are ultimately made from a single gene, because many genes code for more than one protein. When human cells are attacked by bird flu, this element ensures that more M2 rather than M1 protein is produced.”

May there be other factros? Sure.

 “How pathogenic an avian flu virus is and whether or not it has pandemic potential depends, of course, on many factors,” says Selbach. “A study on cell cultures cannot cover all these factors. Nevertheless, it might be useful in future to include an analysis of this RNA segment in the risk assessment of avian influenza viruses.”

https://www.mdc-berlin.de/news/press/what-blocks-bird-flu-human-cells
What blocks bird flu in human cells?