In response to my post on tuna scrape, Professor Alan Reilly, Chief Executive, Food Safety Authority of Ireland (the equivalent of our FDA) sent this photograph of an actual tuna scrape label.

After I forwarded it to Bill Marler, he noticed that it is one of several photographs posted on the FDA’s tuna scrape recall web page).

The type is too small to read so I’ve done some cropping:

Professor Reilly asks:

What is puzzling me is why this product “minced tuna” was used in sushi products. The label (copy attached) clearly states that the product must be cooked before consumption and it is for industrial uses only (labelled not for retail).

Those are good questions, but here’s another, equally alarming.  What’s that strangely formatted Nutrition Facts label? It does not precisely follow FDA design or content requirements.

This is a red flag.  If the company is not following labeling rules, it might not be  following other rules either—safety, for example.

Safety?  Uh oh.

Bill Marler reports that the FDA “483 Inspection Report” on the Indian tuna processing facility is now available.  Read these quotes and shudder:

• Tanks used for storage of process waters have apparent visible debris, filth and microbiological contamination.
• There is no laboratory analysis for water used in ice manufacturing at the [redacted] facility to show the water used to make ice is potable.
• Apparent bird feces were observed on the ice manufacturing equipment at Moon Fishery; insects and filth were observed in and on the equipment.
• Tuna processed at your facility, which is consumed raw or cooked, comes in direct contact with water and ice.

I draw several lessons from this episode:

• Food is safer when cooked.
• Labels need to be read—and followed—carefully.
• Raw sushi is a high risk product, especially if it doesn’t cost much.
• The FDA needs to be doing a lot more inspecting of overseas facilities, and before they cause problems.

All of this means that we need a better food safety system, one that can address the enormous proportion of our food supply that comes to us from countries with weaker food safety standards.

Addition, May 17: Ben Embarek, a food safety scientist at the World Health Organization notes that the 483 report reveals that Moon’s HACCP plan did not list appropriate critical control points.  Anyone auditing the plan should have picked up the problems on paper, which is easier and less expensive to do than an on-site inspection.  But the FDA does not pre-audit international HACCP plans.  They are supposed to be cleared by exporting companies registered by FDA.  Comment: it’s hard to imagine that the current system can work, and it clearly does not.

While Weight of the Nation is airing on HBO this week (I’ll comment on it after it’s fully aired), here’s what happens when public health officials try to do something to make it easier for kids to eat more healthfully.

The Massachusetts public health department came up with a proposal to ban bake sales in public schools 30 minutes before, during and after classes.

The reaction?  An uproar.  The ban, according to critics, would

• Make it harder to raise money for class trips and athletic equipment
• Undermine the fundraising efforts of parent and student groups
• Not help prevent obesity
• Take away choice from school districts (“government gone awry”)

Under this kind of pressure, “the governor spoke, emergency orders were issued, and the Legislature voted.”

End of ban.

Massachusetts public health commissioner John Auerbach pointed out:

The school nutrition standards have always been about reducing childhood obesity in Massachusetts and protecting our kids from the serious long-term health impacts that obesity can cause…At the direction of Governor Patrick, the department will seek to remove these provisions.

We hope to return the focus to how we can work together to make our schools healthy environments in which our children can thrive.

Best of luck.

This reminds me of what happened in Texas, when Susan Combs, then state agriculture director, attempted to ban cupcakes from public schools.

As Dr. Cathy Isoldi described in her study of school celebrations earlier this year (on which I am a co-author),

Such bans have prompted intense opposition in many areas of the country. In Texas in 2005, a ban on food service during classroom celebrations elicited parent outrage and resulted in the addition of a Safe Cupcake Amendment to the state’s nutrition policy. The amendment, known as Lauren’s Law, ensures that parents and grandparents of schoolchildren celebrating a birthday can bring in whatever food items they choose for classroom celebrations.

Cathy’s work makes it clear that school celebrations alone can account for a whopping 20% to 35% of a child’s daily calorie needs.  This percentage does not account for additional treats sent home with children,  given to them by teachers as rewards, or purchased in school at bake sales.

You don’t see an occasional cupcake as a problem?  Read Bettina Siegel’s post on what goes on in her kids’ school and how often schoolkids are exposed to junk foods during the school day.

Of course kids will eat treats rather than healthier foods if given half a chance.  Isn’t it an adult responsibility—at home and at school—to make sure that kids eat healthfully?

The environment of many schools is anything but conducive to good health practices.  While outright bans may be seen as going too far, some kind of restriction on junk food in schools seems like a sensible adult decision, given the impact of obesity on children, families, and the health care system so well documented in Weight of the Nation.

State legislatures should be promoting such efforts, not overturning them.

I was a member of the FDA Food Advisory Committee when the agency approved production of genetically modified foods in the early 1990s.

At the time, critics repeatedly warned that widespread planting of GM crops modified to resist Monsanto’s weed-killer, Roundup, were highly likely to select for “superweeds” that could withstand treatment with Roundup.

I wrote about this problem in Safe Food: The Politics of Food Safety.  I added this update to the 2010 edition:

Late in 2004, weeds resistant to Monsanto’s herbicide Roundup began appearing in GM plantings in Georgia and soon spread to other Southern states.  By 2009, more than one hundred thousand acres in Georgia were infested with Roundup-resistant pigweed.  Planters were advised to apply multiple herbicides, thereby defeating the point of Roundup: to reduce chemical applications.

Today, the idea that planting of GM crops is “widespread” is an understatement.

So, according to Reuters, is Roundup resistance.

Weed resistance has spread to more than 12 million U.S. acres and primarily afflicts key agricultural areas in the U.S. Southeast and the corn and soybean growing areas of the Midwest.

Many of the worst weeds, some of which grow more than six feet and can sharply reduce crop yields, have become resistant to the popular glyphosate-based weed-killer Roundup, as well as other common herbicides.

This is not a trivial problem.  As the Ottawa Citizen explains,

The resilience of nature is evident across almost five million hectares of superweed-infested U.S. farmland. Some runaway weeds in the southern U.S. are said to be big enough to stop combines dead in their tracks.

How is the chemical industry responding to this threat?  Zap it harder!

The industry is pressing the U.S. and Canadian governments to approve GM corn engineered to resist 2,4-D.

Remember 2,4-D?   It was the principal ingredient in Agent Orange, the defoliant used during the Vietnam War.  Although the health problems it caused have been attributed to contamination with dioxin, the uncontaminated chemical has also been associated with illness in some studies (the Wikipedia entry has references).

The chemical industry maintains that 2,4-D is safe at current usage levels.  Maybe, but Ontario bans its use on lawns, gardens, and in school yards and parks.  Weeds resistant to 2,4-D have been identified since the 1950s.

Is pouring more toxic herbicides on food crops a good idea?  These chemicals cannot be healthy for farmworkers or for soil or groundwater.

Organic agriculture anyone?

Addition: Fred Kirschenmann, Distinguished Fellow at the Leopold Center at Iowa State and organic farmer says in an e-mail:

The other issue that has weed scientists concerned is the fact that 2-4-D is known to be much more invasive than many other herbicides—it can drift in the air for long periods of time and land on many unintended crops.

2-4-D has been identified as the main cause for destroying the grape industry in Iowa—in the 1940’s Iowa was the 4th largest grape producing state in the nation, and then was virtually reduced to zero.

Clearly if 2-4-D is going to be the “answer” to Roundup Ready resistance it will now be used in much larger quantities than in the 1950’s and is not only likely to destroy the rebounding grape production (I think some 200 acres now) and the 8 wineries in Iowa, but will make it extremely difficult to grow vegetables, which will not be good news for the burgeoning CSA/farmers Market industry that has emerged in recent years.

I was riveted by an article in today’s New York Times about the latest decision of an FDA drug advisory panel.

The panel voted to approve a new weight-loss drug, lorcaserin.  The vote was mixed: 18 for approval, 4 against, and 1 abstention. The majority felt that the benefits outweighed the risks and that even if there were risks, “new tools are needed to treat a major health problem.”

The benefits are worth a look.

• People taking the drug lost an average of  5.8% of their body weight in a year, compared to 2.5% for people taking a placebo.  This difference is below the FDA’s standard for approval which requires a 5% difference.
• Among those taking the drug, 47% lost at least 5 percent of their weight after a year, whereas only 23% of those taking the placebo did so.  This meets a second FDA standard for approval.

What about the risks?  The drug:

• Causes tumors in rats (although perhaps at higher doses than might be taken by people).
• Damages heart valves (in the same way the withdrawn drug, Fen-Phen, did).

Also in the Times is a piece by Dr. Danielle Ofri on her experience with patients who want weight-loss drugs.

She quotes from an essay called “Lemons for Obesity” by Dr. Michael S. Lauer, who was a minority voter on the FDA panel that approved the weight-loss drug Qnexa earlier this year.

The weight-loss field is strewn with lemons, more so than other areas of medicine, Dr. Lauer argues. Because of the enormous potential market for these drugs — two-thirds of American adults are overweight or obese — pharmaceutical companies rush new drugs to market after conducting only small clinical trials. The F.D.A. and doctors are complicit in the process, Dr. Lauer says, leaving the population at large to act essentially as guinea pigs.

Shares of the maker of the drug nearly doubled after the decision.  The Times reported that “Arguments by investors have been passionate.”

People who cannot easily lose weight are desperate for help.

But is it ethical to put them at this kind of risk?

The Government Accountability Office is complaining again about the inadequacies of the American food safety system, and with good reason.

Its 2012 Annual Report, Opportunities to Reduce Duplication, Overlap and Fragmentation, Achieve Savings, and Enhance Revenue, says that the food safety system is:

fragmented and results in inconsistent oversight, ineffective coordination, and inefficient use of resources.

In 2007, GAO added food safety to its list of high-risk areas that warrant attention by Congress and the executive branch.

More recently GAO found that this fragmentation extends to the responsibilities across multiple agencies to defend food and agricultural systems against terrorist attacks and natural disasters…Many of these activities are everyday functions or part of the broader food and agriculture defense initiative and would be difficult for the agencies to separately quantify.

This report repeats what the GAO has been saying since the early 1990s:

there is no centralized coordination to oversee the federal government’s overall progress in implementing the nation’s food and agriculture defense policy.

Because the responsibilities outlined in this policy (HSPD-9) are fragmented and cut across at least nine different agencies, centralized oversight is important to ensure that efforts are coordinated to overcome this fragmentation, efficiently use scarce funds, and promote the overall effectiveness of the federal government.

Reminder: the present food safety system is mainly divided between two agencies: USDA (meat and poultry) and FDA (everything else).

Centralized oversight of food safety?  What a concept.

The FDA has just released a classy new report on Global Engagement, summarizing its efforts to deal with issues raised by the globalization of drugs, medical devices, and foods.

This is a big deal.  In 2009, 300,000 foreign facilities in more than 150 countries exported $2 trillion worth of FDA-regulated products to the United States.

Given these numbers alone, the FDA has some challenges.

In 2011, one out of every six FDA-regulated food products in the U.S. came from abroad.  Imports of fresh fruits, vegeta­bles, coffee, tea, and cocoa have more than doubled since 2000.

We import:

• 80 percent of seafood
• ~50 percent of fresh fruit
• ~20 percent of fresh vegetables

As the report explains,

• Many products entering the United States are made or grown in countries that lack the necessary regulatory over­sight to ensure their quality and safety.
• Greater numbers of suppliers, more complex products, and intricate multinational supply chains introduce risks to product safety and quality, including more oppor­tunities for economic adulteration and the spread of contaminated products.
• FDA can only realistically inspect a small percent­age (less than 3 percent) of the enormous volume of food products arriving at U.S. ports of entry, making it crucial that the Agency focus on ensuring that food products meet U.S. standards before they reach the United States.

To deal with this problem, the FDA has opened offices in:

• China: Beijing, Shanghai, and Guangzhou
• India: New Delhi and Mumbai
• Latin America: San Jose, Costa Rica; Santiago, Chile; and Mexico City, Mexico
• Europe: Brussels, Belgium; London, United Kingdom; and Parma, Italy
• Asia-Pacific: FDA headquarters
• Sub-Saharan Africa: Pretoria, South Africa
• Middle East and North Africa: Amman, Jordan

The FDA seems seriously concerned about its global initiatives and the safety problems posed by our globalized food supply.

The volume seems impossible to manage.  Let’s hope the FDA’s efforts do some good.

A reader writes:

Here’s what I don’t understand.

Everyone who is scared of raw says they want their dog’s food to be cooked, to kill salmonella.

But here is kibble, which by definition is cooked to the point of losing most of its original nutrients, but STILL has salmonella.

I don’t see how this is possible.  If it’s cooked enough to be “kibbled,” how can it possibly still have salmonella? It just seems like the worst of all possible worlds.

This question refers to the recent recall of dry dog food manufactured by Diamond Pet Foods.

As the CDC explains, Michigan public health officials found Salmonella in an unopened bag of a Diamond kibble product during routine testing.  This particular Salmonella strain had been found to infect at least 14 people.

CDC investigators connected the dots between the illnesses and dog food through interviews:

Seven of 10 (70%) ill persons interviewed reported contact with a dog in the week before becoming ill.

Of 5 ill persons who could recall the type of dog food with which they had contact, 4 (80%) identified dry dog food produced by Diamond Pet Foods that may have been produced at a single facility in South Carolina.

In my book, Pet Food Politics: The Chihuahua in the Coal Mine, I tell the story of the massive pet food recalls of 2007 due to contamination with the industrial chemical, melamine.  And in Feed Your Pet Right, my co-authored book about the pet food industry, I explain how pet foods are manufactured and why they are so subject to contamination and recall.

Canned pet foods are sterile.  Dry kibble is not.  It may be sterile at the point of extrusion, but it is a perfect growth medium for bacteria.  It is nutritionally complete.  Although some nutrients are lost during processing, the product formulas compensate for such losses.  That is why dogs can survive on “complete and balanced” dry foods.

If the factory is contaminated with Salmonella, the bacteria can fall into the production lines and get packaged into the kibble bags.

Dogs are relatively resistant to Salmonella and usually do not show signs of illness from eating contaminated kibble.

But humans who handle the food or the dog can acquire the bacteria and get sick.

This makes dry dog food a potentially hazardous product, one best kept away from people with weak immune systems such as young children and the elderly.

People like feeding dry food to pets because it is convenient and cheap.

My point in Pet Food Politics was that pet food is an indicator of problems in food safety regulation.  If pet foods are not forced to be produced under strict food safety measures, humans and the human food supply are also at risk.

Resources

• Products recalled by Diamond Pet Foods
• FDA’s main Diamond recall page
• FDA’s recall announcement, puppy food
• FDA’s recall of Chicken Soup for Pet Lover’s Soul
• Food Safety News account of the recalls
• Food Safety News post on what dog owners should do 
• AmericanVeterinary Medicine Association’s list of previous pet food recalls 

My Q and A column in the San Francisco Chronicle appears on the first Sunday of every month.  This one is about safety problems with tuna scrape.

Q: I had no idea that the tuna in my sushi roll was scraped off the bones in India, ground up, frozen, and shipped to California. Is this another “slime” product? Can I eat it raw?

A: No sooner did the furor over lean, finely textured beef (a.k.a. “pink slime”) die down than we have another one over sushi tuna. On April 13, the Food and Drug Administration said Moon Marine USA, an importing company based in Cupertino, was voluntarily recalling 30 tons of frozen raw ground yellowfin tuna, packaged as Nakaochi scrape.

Centers for Disease Control and Prevention investigations linked consumption of Nakaochi scrape sushi to about 250 diagnosed cases and an estimated 6,000 or so undiagnosed cases of illness caused by two rare strains of salmonella. Among the victims who were interviewed, more than 80 percent said they ate spicy tuna sushi rolls purchased in grocery stores or restaurants.

Scrape refers to the meat left on fish skeletons after the filets are cut off. This is perfectly good fish, but difficult to get at. I once visited an Alaskan salmon packing plant and asked what happened to the delicious looking meat between the bones. The answer: pet food. (Lucky cats.)

A hot commodity

But tuna is too valuable to leave behind, and companies in India use special devices to scoop out the meat, combine it with scrapings from many other fish, chop the mixture, freeze it in blocks, and ship it to importers in the United States. Unlike “pink slime,” tuna scrape is not treated with ammonia or anything else to kill harmful bacteria.

Nevertheless, it is supposed to be safe. The FDA requires producers of imported foods to follow established safety plans. Although the United States imports about 80 percent of seafood sold domestically, the FDA only inspects 1 or 2 percent.

This means we have to rely on the diligence of international food producers in following safe-handling procedures, and of U.S. importers in verifying safety through pathogen testing. But even well-intentioned producers can make safety errors, especially when dealing with high-risk foods.

Tuna scrape is very high risk. Its supply chain is long, complicated and international, leaving many opportunities for contamination. And it is eaten raw.

This tuna scrape came from a single processing plant in India owned by Moon Marine International of Taiwan. Tuna are plentiful off the Indian coast, and the tuna processing industry is expanding rapidly. India has dozens, perhaps hundreds, of fish processing facilities, but most are relatively small and their number, size and geographical dispersion make monitoring difficult.

Safe handling issues

The frozen scrape blocks are supposed to be held at subzero temperatures throughout shipping. Even so, they pose a safety risk. They combine the scrapings from many fish. One contaminated scraping can contaminate the entire lot.

And subzero freezing may kill some salmonella, but large fractions can survive, remain viable, and multiply when the blocks are thawed.

Once the tuna scrape arrived in America, I’m guessing it was trucked to Cupertino and from there to retailers and distributors who further trucked them to restaurants and grocery stores. There, sushi chefs thawed the scrape and used it to make spicy tuna rolls.

Tuna scrape is used in supermarket-grade sushi, not the fancy stuff. Sushi used to be – and still is, in places – an art form requiring exceptional skills. In Japan, sushi chefs can train for as many as 10 years to learn how to recognize the freshest, safest and most delicious fish. Sushi served by such chefs is made to order. It is never pre-prepared. It can be breathtakingly expensive.

But in America, sushi has gone mainstream. You can find prepackaged sushi rolls at practically any supermarket or convenience store, at a cost equivalent to hamburger.

Cheap sushi is made with cheap ingredients – hence, Nakaochi scrape – by chefs with far less training. A typical certification program for sushi chefs in this country can be completed in two or three months. Some offer certification online. Although these programs address safe food-handling procedures, the training is necessarily superficial.

What are the odds?

Sushi aficionados argue that while raw fish is never perfectly safe, the safety odds are much better when the chef is well trained, and the fish are freshly caught and cut to order in front of you. By their standards, tuna scrape is suitable only for pet food, which is at least cooked to kill pathogens.

If anything, the tuna scrape outbreak teaches why it is so important to know where food comes from and how it is made. Caveat emptor.

Nutrition and public policy expert Marion Nestle answers readers’ questions in this monthly column written exclusively for The Chronicle. E-mail your questions to food@sfchronicle.com, with “Marion Nestle” in the subject line.

Addition, May 14:  Bill Marler reports that the FDA “483 Inspection Report” on the Indian tuna processing facility is now available.  Here are excerpts from the most revealing section:

Tanks used for storage of process waters have apparent visible debris, filth and microbiological contamination…There is no laboratory analysis for water used in ice manufacturing at the [redacted] facility to show the water used to make ice is potable…Apparent bird feces were observed on the ice manufacturing equipment at Moon Fishery; insects and filth were observed in and on the equipment…Tuna processed at your facility, which is consumed raw or cooked, comes in direct contact with water and ice.