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Special Edition: Food Safety

Food safety is an issue every meat business takes considerable careover as the financial costs of a recall, not to mention the reputational risk, can be devastating. In this special newsletter, GlobalMeatNews takes a look at the latest recalls, changes to food safety regulation and other key developments across the supply chain.

• Food safety tips for storm-battered businesses: Donald Trump’s government has shared food safety tips after New York, New Jersey, Pennsylvania and Virginia declared states of emergency as the deadly storm Stella swept across the north-eastern US… Read
• Subway hits back at fake chicken allegation: Subway has strongly denied media claims that its chicken is roughly half soy, calling the analysis “baseless” and “factually incorrect”… Read
• Canada green-lights irradiation for ground beef: Irradiated ground beef looks set to hit the shelves of supermarket stores after the Canadian government approved its sale… Read
• New food safety rules for butchers: New rules simplifying food safety management in small retail businesses, including butcheries, have been proposed by the European Food Safety Authority (EFSA). .. Read
• California food firm hit by 26t recall: US, California-based Ready Pac Foods Inc has recalled 26 tonnes (59,225 pounds) of chicken salad products that may be contaminated with listeria… Read
• Online forum explores packaging advances for meat safety: Suppliers seeking an edge in the fight to kill germs and boost shelf-life through packaging innovations can access a free online forum held on 23 March, featuring EU and US experts. .. Read

The congressional watchdog Government Accountability Office (GAO) has just published its latest plea for coordinating federal food safety programs: A National Strategy Is Needed to Address Fragmentation in Federal Oversight.

GAO persists in pointing out that 16 federal agencies administer 30 laws government food safety and quality, although USDA (meat and poultry) and FDA (everything else) have the greatest responsibility.

Despite some progress, GAO’s long-standing recommendation for a single, unified food safety agency continues to be ignored.

HHS’s and USDA’s efforts since 2014 are positive steps toward government-wide planning, but OMB has not addressed our recommendation for a government-wide plan for the federal food safety oversight system. Without an annually updated government-wide performance plan for food safety that includes results-oriented goals, performance measures, and a discussion of strategies and resources…Congress, program managers, and other decision makers are hampered in their ability to identify agencies and programs addressing similar missions and to set priorities, allocate resources, and restructure federal efforts, as needed, to achieve long-term goals. Also, without such a plan, federal food safety efforts are not clear and transparent to the public.  OMB staff told us that they were not aware of any current plans to develop a government-wide performance plan for food safety.

The footnotes list previous GAO reports aimed at rationalizing our food safety system, among them:

• GAO, High-Risk Series: An Update, GAO-15-290 (Washington, D.C.: Feb. 11, 2015), GAO-15-180.
• GAO, Federal Food Safety Oversight: Food Safety Working Group Is a Positive First Step but Government-wide Planning Is Needed to Address Fragmentation, GAO-11-289 (Washington, D.C.: Mar. 18, 2011)
• GAO, High-Risk Series: An Update, GAO-07-310 (Washington, D.C.: January 2007)
• GAO, Food Safety: U.S. Needs a Single Agency to Administer a Unified, Risk-Based Inspection System, T-RCED-99-256 (Washington, D.C.: Aug. 4, 1999).
• GAO, Food Safety: A Unified, Risk-Based System Needed to Enhance Food Safety, T-RCED-94-71 (Washington, D.C.: Nov. 4, 1993)
• GAO, Food Safety and Quality: Uniform, Risk-based Inspection System Needed to Ensure Safe Food Supply, RCED-92-152 (Washington, D.C.: June 26, 1992)
• GAO, Need to Reassess Food Inspection Roles of Federal Organizations, B-168966 (Washington, D.C.: June 30, 1970).

One of these years, maybe?

Ellen K. Silbergeld. : How Industrial Meat Production Endangers Workers, Animals, and Consumers.  Johns Hopkins Press, 2016.

Ellen Silbergeld, a professor of environmental health sciences, epidemiology, and health policy at Hopkins, has long been a strong advocate for getting toxic substances out of our food supply.  Here, she takes on our system of industrial farm animal production in a plea for better treatment of everyone and everything involved in it.

Big issue #1: the use of antibiotics as growth promoters.  This not only induces bacteria to become resistant to those drugs, but also is unnecessary.

Big issue #2: the failure of HACCP (Hazard Analysis and Critical Control Point—the method for preventing food safety problems) to prevent harmful, antibiotic-resistant bacteria from reaching the public.

Overall, she says:

The inextricable relationship between industrial food animal production and the environment challenges us in two ways.  First, we are all at risk–not just those of us who consume the products of industrially raised animals–and second, decontaminating food products will not contain the public health problems of this industry.  It is time to think about industrial food animal production as an industry in terms of environmental pollution, and it is long overdue to recognize that its pollution footprint, like its production, is industrial in scale (p. 127).

As for the remedy, “agriculture is an industry, and as such it carries certain obligations.”  These include, among others:

• Industries must abide by laws that prevent monopolization, price fixing, and overconcentration.
• Industries must bear full liability for unsafe products.
• Industries must obey the labor laws of the country.

She has plenty more to say about government’s role in all this.

Our role is to insist that industry and government follow and apply laws.  We had best get busy.

Presidential candidate Donald Trump gave a speech to the Economic Club of New York about his tax reform plan to “make America great again.”

The plan would eliminate some programs he finds annoying, the FDA’s food safety regulations among them.

The tax plan, including the FDA provisions, was posted on Trump’s website, but it is no longer there.

Fortunately, @nycsouthpaw did a screen capture and posted it on Twitter.  Among other things, Trump would like to eliminate:

Food safety lawyer Bill Marler, who begs producers of unsafe food to “put me out of business” is getting his wish and notes how well the new food safety rules are working.  He says Trump must love him: Killing the FDA is good for business:

How did “The Donald” know that my business has dropped over the last few years as the regulatory work of our governmental agencies have kicked into gear.

Who knew that food safety would be an issue in this year’s election, let alone Skittles.

Chase Purdy writing in Quartz says “The system for catching dangerous pathogens in America’s food supply is finally working.”

Here’s the best evidence: the remarkable decline in cases of STEC (Shigella Toxin E. Coli).

Quartz quotes food safety lawyer Bill Marler: “You look back over time and, from 1993-2003, about 90% of my firm’s revenue was from E. coli cases connected to hamburger.”

What changed?  Regulation.

The USDA now considers STEC to be an adulterant and does not permit meat and poultry contaminated with it to be sold.

But then there’s Salmonella.  It is not considered an adulterant.  Why not?  Because it occurs so frequently that USDA considers it normal.  Cases of Salmonella have not declined as much as they should.

In the meantime, the FDA is diligently following through on its food safety rulemaking.  On August 24, it opened three more sets of draft guidance documents for public comment.

• Draft Guidance for Industry #235 – Current Good Manufacturing Practice Requirements for Food for Animals: helps producers of animal feed comply with Good Manufacturing Practice requirements.  And see .  Federal Register Notice for the Draft Guidance for Industry on Current Good Manufacturing Practice Requirements for Food for Animals
• Draft Guidance for Industry #239 – Human Food By-Products for Use as Animal Food: helps providers of byproducts of human food production with how to use them safely in animal feed.  And see Federal Register Notice for the Draft Guidance for Industry on Human Food By-Products for Use as Animal Food
• Draft Guidance for Industry for Classification of Activities as Harvesting, Packing, Holding, or Manufacturing/Processing for Farms and Facilities: helps food companies decide if and how FSMA rules apply to their operations.  And see Federal Register Notice for the Draft Guidance for Industry for Classification of Activities as Harvesting, Packing, Holding, or Manufacturing/Processing for Farms and Facilities

FDA officials explain:

When we were drafting and seeking public comment on the rules that will implement theFDA Food Safety Modernization Act (FSMA), we promised that we would do whatever we could to help the regulated industry understand and meet the new requirements….Meeting the FSMA mandate involves cooperation between the FDA and the food industry. From the smallest food operation to the largest company, we want to be sure that we’re all on the same page and these draft guidances will help get us there.

Onward and upward.  This is progress.  It would be nice if it went faster but it’s real progress—even if Bill Marler still has plenty of work to stay busy.

The Senate just voted to reverse a decision of Congress last year to remove catfish inspection from the FDA (which is usually in charge of regulating seafood) and give it to the USDA (which usually regulates meat and poultry).

Why did the 2008 and 2012 farm bills say that catfish inspection should be given to USDA?

It depends on whom you ask.

• Defenders say it’s because USDA has the resources to protect us against unsafe Vietnamese catfish.
• Critics said it’s to protect the Mississippi catfish industry against the food safety hazards of cheap imported catfish from Vietnam.

Indeed, the USDA inspection program is finding antibiotics and other unapproved carcinogens in catfish imported from Vietnam.

This issue, however, is a sticking point in US negotiations with Vietnam over the Trans Pacific Partnership trade agreement.

Vietnam wants the USDA catfish inspection removed as an unfair barrier to trade.

As I wrote about this issue in 2013,

What is this about?  Not fish safety, really.  It’s about protecting catfish farmers in the South and setting up “more rigorous” safety criteria that will exclude competitive foreign catfish imports, especially from Vietnam.

Food retailers and retail trade associations are for reverting inspection to FDA. They say USDA’s catfish inspection program will take years to allow imports from Vietnam, thereby causing the cost of domestic catfish to rise.

But today, Politico Morning Agriculture reports that more than 100 House Republicans are urging repeal of the USDA’s catfish inspection program, pointing out that

The Government Accountability Office (GAO) has 10 times stated that this program is “duplicative” and at “high risk” for fraud, waste, abuse, and mismanagement…This is not a food safety issue.  USDA acknowledges that catfish, regardless of where it comes from, is considered a “low risk food.”

When I wrote this issue previously, I got comments that I needed to better appreciate the superiority of USDA’s import safety program.  As I said in response:

It’s not surprising if USDA’s import safety system is better than the FDA’s.  USDA gets $14 million a year to run its currently non-operating catfish inspection system.  The FDA gets $700,000 and, according to the Government Accountability Office, has managed pretty well with it.

My conclusion then and now:

If the political fuss over catfish inspection reveals anything, it is why we so badly need a single food safety agency—one that combines and integrates the food safety functions of USDA and FDA—to ensure the safety of the American food supply.

Documents

• The Senate resolution
• USDA’s catfish inspection program

The CDC has started a page on the E. coli O121 (STEC O121) outbreak linked to General Mills flour:

In interviews, ill people answered questions about the foods they ate and other exposures in the week before they became ill. Sixteen (76%) of 21 people reported that they or someone in their household used flour in the week before they became ill. Nine (41%) of 22 people reported eating or tasting raw homemade dough or batter. Twelve (55%) of 22 people reported using Gold Medal brand flour. Three ill people reported eating or playing with raw dough at restaurants.

The CDC’s “At A Glance”

• Case Count: 38
• States: 20
• Deaths: 0
• Hospitalizations: 10
• Recall: Yes

It looks like cases are—or were—popping up one at a time.  There is always a reporting lag.

While waiting for more information, the CDC recommends:

• Do not use, serve, or sell the recalled flours.
• Do not eat raw dough or batter, whether made from recalled flour or any other flour.
• Bake items made with raw dough or batter before eating them.
• Do not taste raw dough or batter.
• Do not serve raw dough to customers or allow children and other guests to play with raw dough.

But really. Gold Medal flour?  If flour is used for cooking or baking, the bacteria would be killed.

OK.  I totally get eating raw cookie dough.  I did plenty of that back in the day when I baked cookies for my kids, and they helped clean the bowl.  Eating raw cookie dough may sound disgusting, but the mix is truly delicious.

If you’ve never tried it, now is not a good time to start.  In 2009, there was a really nasty E. coli outbreak from eating pre-packaged raw cookie dough.

But eating or playing with raw dough in restaurants?   Is this common practice?  News to me.

Documents

• Recall list and advice to Consumers, Restaurants, and Retailers
• FDA announcement and investigation
• Shiga toxin-producing Escherichia coli O121 (STEC O121) infection
• Signs & Symptoms
• Key Resources

Food Chemical News reports that the Senate Appropriations bill comes with report language instructing the FDA to:

• Conduct a risk assessment to see how harmful it really is to eat Listeria-tainted frozen vegetables [these, presumably, would be cooked before eating].  CRF Frozen Foods had to recall of 358 organic products after 7 people became ill.
• Release no sodium guidelines before the National Academies of Science has a chance to update the Daily Reference Intake (DRI) for sodium [which will take years].  The report says “it is “imperative that any guidance be issued using the latest sound science…based upon an updated DRI report.”  House directives said the same thing.  [The FDA has just released voluntary sodium guidelines for public comment].
• Release its overdue report on food traceability systems: “The Committee directs the FDA to collaborate with science-based international and industry-led food traceability initiatives of the type recommended by the pilot projects…[and] to make publicly available information on FDA’s efforts to encourage…traceability initiatives.”
• Reconsider its E. coli standard.  The Senate views this standard as too stringent and disruptive of raw milk cheese businesses.
• Actively engage stakeholders in best practice standards for medical foods. “They should work together on “forming a framework for a distinct regulatory pathway for medical foods that does not encumber its progress towards approval for patient use.”
• Better enforce standards for antibiotics in shrimp imports.
• Sample olive oil bottles at retail to determine if they are adulterated, and report findings to Congress.
• Report on efforts to implement regulations for the growing commercial human milk industry.

Some of these directives would improve food safety, but some would not.

All make more work for the FDA.

Does the Senate also plan to appropriate sufficient funds for the FDA to do all this in addition to what it is already doing?  Want to take bets?