When reviewing the year in the news, one can’t help but notice that the main news outlets had a lot of stories about food safety. We heard all about poultry inspection, multiple legal cases concerning food safety, auditors being sued because a company passed an audit and then their product was identified as having caused illness, FSIS performing criminal investigations, FDA pressing forward with several criminal cases, foreign food causing illness, sales of U.S. food overseas being stopped for political as well as alleged food-safety issues, lawsuits to stop the poultry slaughter inspection rule — the list goes on and on. It makes me wonder if it will ever be safe to eat again!
Of course, I do plan on eating dinner, and soon — so what is really going on with food safety?
Let’s start with recalls. When you look at the number of recalls from Sept. 14, 2013, to Sept. 13, 2014, then compare them to the numbers from the year prior, several interesting trends emerge.
For FDA, E. coli is flat, with three recalls in each period, while FSIS has gone from nine to five. For Salmonella, FSIS went from three recalls to four, while FDA dropped from 85 to 38. The number of Listeriarecalls, on the other hand, is going in the wrong direction for FSIS-inspected establishments: from five to 10. FDA dropped from 53 to 39. Recalls for allergens are also going the wrong way. They increased for both FSIS- and FDA-inspected establishments. FSIS went from 28 to 33, and the FDA went from 103 to 109. The total number of recalls for FSIS increased from 72 to 83 while the FDA decreased from 295 to 228.
Of course the mainstream media doesn’t present it in straight numbers. You could see a headline or story that says: “The number of FSIS recalls for producing without inspection is up 80 percent!”
Although that is a true number, please don’t be misled. There were five recalls for production without inspection for the 2012-13 period, and nine for the 2013-14 time period — an increase of four.
Importantly, though, just one of those instances has resulted in a massive recall, criminal investigation resulting in charges, businesses closed, and a lot of good hard-working people out of jobs.
The old saying goes, one bad apple ruins the barrel, and in the case of the food industry, when there is bad press for one, deserved or not, there is bad press for all. Getting the message out about what a truly outstanding job the industry does with food safety is very hard, even though the message delivered is not based on rocket science.
According to Answers.com, there are more than 350 billion pounds of food available in the U.S. each year for human consumption. Compare that to the miniscule amount of food recalled, and it’s apparent how safe our food supply really is.
For companies that had to recall product in the last 12 months, there was a 46 percent chance it was because of an undeclared allergen, a 16 percent chance that it was due to Listeria, a 14 percent chance it was due to Salmonella, and a 3 percent chance it was due to E. coli.
For the industry this paints a rather interesting picture.
Going forward, do processors put available resources into controlling allergens and labeling? Do they follow the industry trend of sampling for pathogens? Or do they take a combination of approaches?
This year has turned out to be the “Year of the Micro Test.” It seems everyone is clamoring for more micro testing from the food industry, from produce to ground meat and everything in between. Testing methods themselves are getting better, yet as many are aware, there have been multiple cases of product later being recalled or implicated in foodborne outbreaks, and enforcement actions taken when the source product had been tested and found negative.
The fact that the source material was tested and yet turned up positive later on, without any evidence of additional contamination, has a lot of people worried about all the testing they are doing. While the actual testing methods are getting better, the sample collection procedures often leave a lot to be desired.
For the beef industry, there are a lot of people who have a very false sense of security because they are doing N60 testing. Microbial sampling for safety has huge flaws. There are viable but non-culturable cells present, and even if you get them in the sample they won’t grow — but expose the product to conditions they like and they will start to multiply.
You tested, it was negative, but only when the customer downstream temperature-abused the product did the product develop positives.
Additionally, there is the actual sensitivity of the testing methods. No sampling protocol/testing method can detect a single viable cell 100 percent of the time, or in most cases even 50 viable cells. So your result was negative, you feel great and ship the product. But again, a customer downstream temperature-abused the product, a state lab tested it, and the product now has positives.
On top of that, you have the issue of actual sample size. In most cases, the actual sample is very small compared with the product it represents, and while you are told that the testing method has an xprobability of finding the bacteria you are looking for, does it really? If you use sqconline.com to determine a statistically valid sample size (sampling plans that have been validated by court cases), you might be shocked at how many strips of meat you should be collecting for N60!
Think of it this way: N60 is looking for surface contamination, and each sample collected is supposed to be 1 by 3 inches. How many inches of surface are on the average animal slaughtered? How many animals are represented in the 10,000-pound lot? Take five combos at 2,000 pounds each, and you are relying on a dozen 1-by-3-inch strips per combo to prove your product is safe? And remember, “safe” means that there are less than 10 viable cells
(E. coli O157:H7), because that is what it takes to make someone sick (literature says as few as 10).
My recommendation is to put your valuable resources into prevention: Stop it from happening in the first place. So you ask, ‘Why test, or better yet, should I test?’ The answer is yes, testing is an important tool industry can and should use. The key, though, is to use micro testing appropriately.
To put it another way, testing should be used to validate that the preventive measures you have taken actually work.
Testing is a very useful tool when used correctly; sometimes you need a wrench and other times a hammer. Sampling is the same. Rapid tests are good indicators and early warnings that something isn’t working; however, you need to do more in-depth testing to validate your program. You actually have to go looking for the bug in a way that you can find it, if it is there.
After that, the real key with testing is what you do with the results. If you are constantly diverting product to cooking because you are getting positives, you need to make a change to a process to stop the contamination, it is as simple as that. It isn’t just good food safety; it’s good business sense.
Another trend that shows up more and more is chemical residues, and what the public perceives to be residues. The big blowup about “what is GRAS?” is a good example.
The produce industry has been on the frontlines of this trend, but more and more “grassroots” organizations are pointing at meat and poultry and accusing pretty much everyone of contaminating product with antibiotic residue and other chemicals.
As is typical of these types of attacks on the mainstream part of the industry, there is always a grain of truth but typically very little scientific support. The danger is that when enough people cry “the sky is falling,” our regulatory agencies typically have knee-jerk reactions that make little sense when looking at the true risk. How much money is spent on regulating BSE in the slaughter and processing environment? How many animals have tested positive?
Toward the future
Trace backward and forward. While the FDA is still working all the bugs out of FSMA, FSIS has issued two Federal Register Notices that should have put everyone who grinds beef on notice. While FSIS compliance officers have always gone into grocery stores and meat markets, FSIS is proposing to require specific records so they can trace product more effectively. They are also changing the way they perform trace-back — they are going to start before they receive a confirmed positive.
For everyone who grinds or supplies grinders, the new recordkeeping requirements need to be implemented, and then I strongly recommend that you extensively test them. The last thing you want is for a compliance officer to stop by and ask for them and not have them available.
I also expect third-party auditors to pay a lot closer attention to actual food safety and for them to spend less time on the “checkbox” type of auditing done in the past. Several of the larger law firms that specialize in food-safety litigation have made it clear they are looking at the third-party auditor as well as the establishment.
Any consultant or auditor should be able to provide you with proof of professional liability insurance. My recommendation is to ask for it and require it in any contract you have with consulting or auditing firms.
Another trend that is starting to pick up steam is that equipment manufacturers are redesigning equipment to not just make cleaning and sanitizing easier and more effective, but to make environmental sampling easier to accomplish as well as product sample collection.
The ultimate task
I said it last year in this space, and I am repeating it this year: Getting the consumer to trust their food while simultaneously getting them to cook their hamburgers is probably the hardest task anyone has for the future. As an industry we need to get the message out there that yes, we produce safe products. Whenever I see a Facebook post accusing a food producer of some heinous crime, I cringe. Inevitably you see it go viral.
Getting the word out about how we ensure food safety and how we are continually improving is something that is a responsibility that we all share.
After all, when there is bad press for one, it ends up being bad press for all.
Now, finally, time for dinner — and yes, we use a calibrated thermometer!