Currently browsing posts about: Food-safety

The CDC reports that more than 1000 people have been infected with a toxic form of Salmonella, almost certainly from contact with backyard poultry.

Among these cases of illness, 23% are among children under the age of 5 years.

The link to backyard poultry comes from epidemiologic and laboratory evidence.

The CDC warns owners of backyard poultry to take steps to avoid acquiring Salmonella from their poultry

This problem has become so serious that the CDC has a webpage devoted to the safety of backyard poultry.

Best to follow its advice.

Since writing two books about pet food in 2008 (Pet Food Politics) and 2010 (Feed Your Pet Right), I haven’t said much about this topic but am inspired to comment by this article in Food Safety News.

If you are a pet food maker, and the FDA finds Salmonella in your products and insists you recall them, what should you do?

A.  Recall the products immediately

B.  Apologize to your customers and promise this will never happen again

C.  Hire a food safety expert to review and revise your food safety procedures

D.  Train all employees to follow food safety procedures diligently

E.  Sue the FDA to allow you to continue selling Salmonella-contaminated pet food

The correct answer?  E, apparently.

Incredible as it may seem, Lystin LLC, the parent of Answers Pet Foods which sells raw meat and poultry, is suing the FDA on Constitutional grounds to allow it to sell foods contaminated with Salmonella. Why?

According to this company, people should be able to feed their pets whatever they like, especially because its brands already carry this warning:

WARNING: NOT FOR HUMAN CONSUMPTION. THIS PRODUCT HAS NOT BEEN PASTEURIZED AND MAY CONTAIN HARMFUL BACTERIA.

You want to continue buying this pet food?  OK.  You were warned.

Personally, I’d find another brand more committed to the safety of dogs and their owners.

I can’t wait to see who wins this one.

I’m always interested to see what food safety lawyer Bill Marler has to say about the latest lapses.  He often represents the innocent-but-unlucky victims of food poisonings.  All they were doing was getting something to eat or feed their kids.  They had no idea the food was contaminated with a deadly form of E. coli or Salmonella.

In a recent post, Marler reflected on the enormous progress made by meat producers in reducing pathogens in their products.  Marler explains:

From the Jack in the Box E. coli outbreak of 1993 until the 2002 ConAgra E. coli outbreak, at least 95% of Marler Clark revenue was E. coli cases linked to hamburger.  Today, it is nearly zero.  That is success.  To the beef industry – thank you for meeting the challenge…for now, hats off to you.

But, he points out, the meat industry must continue to act with vigilance, as demonstrated by the CDC’s recent safety warning about ground beef contaminated with toxic E. coli O103.

The CDC lists the statistics of this recent outbreak to date.

• Reported Cases: 177
• States: 10
• Hospitalizations: 21
• Deaths: 0

The recalls of ground beef have started.

• Grant Park Packing in Franklin Park, Ill., recalled approximately 53,200 pounds of raw ground beef products on April 24, 2019.
• K2D Foods, doing business as Colorado Premium Foods, in Carrollton, Ga., recalledapproximately 113,424 pounds of raw ground beef products on April 23, 2019.

Others may follow.

Meat producers: eternal vigilance, please.  Lives are at stake.

As for food safety in general: The CDC says foodborne illness cases are increasing.

During 2018, FoodNet identified

• 25,606 infections
• 5,893 hospitalizations
• 120 deaths

Note: these are fully preventable.

And food producers must make sure that they are fully prevented.

Timothy D.  Lytton.  Outbreak: Foodborne Illness and the Evolving Food Safety System.  University of Chicago Press, 2019.

I did a blurb for this one:

In Outbreak, Lytton gives us a legal scholar’s superb analysis of how government, lawyers, and civil society are struggling to prevent the tragic and unnecessary illnesses, hospitalizations, and deaths caused by microbial food contaminants.   Foodborne illness may seem like an intractable problem, but Lytton’s suggestions for dealing with it are well worth attention, as is everything else in this beautifully written, thoughtful, and readable account.  I couldn’t put it down.

Food safety attorney Bill Marler reviewed it for Food Safety News.

Lytton said his goal was to help readers understand the science, practicality, liability, enforcement and self-monitoring measures necessary to achieve higher levels of food safety. Meeting that goal includes helping readers understand the following:

• Why government spends so much more money justifying food safety regulations than evaluating whether they actually work.
• The need for greater experimentation in food safety regulation.
• Improving private third-party food safety auditing through greater liability exposure for negligent auditing.
• The potential for liability and recall insurance to improve food safety.
• The history of third-party food safety auditing (which goes back much earlier than AIB in the 1920s).
• The litigation dynamics of food safety lawsuits.

Food safety seems very much on the agenda this week.

The Government Accountability Office (GAO) has released its latest biennial High Risk list of programs “vulnerable to fraud, waste, abuse, and mismanagement, or that need transformation.”

Of interest is this listing: Improving Federal Oversight of Food Safety. The report finds not much change from goals set two years ago; the goal for an action plan is still not met:

Without a government-wide performance plan for food safety, 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. Moreover, without a centralized collaborative mechanism—like the FSWG [Food Safety Working Group]—to address food safety, there is no forum for agencies to reach agreement on a set of broad-based food safety goals and objectives that could be articulated in a government-wide performance plan on food safety.

The GAO explains why inadequate federal oversight of food safety poses a high risk.  Safety issues, it says,

are governed by a highly complex system stemming from at least 30 federal laws that are collectively administered by 15 federal agencies. For more than four decades, we have reported on the fragmented federal food safety oversight system, which has caused inconsistent oversight, ineffective coordination, and inefficient use of resources. We added federal oversight of food safety to the High-Risk List in 2007. In recent years, moreover, we have made recommendations aimed at helping to reduce fragmentation in federal food safety oversight. As of November 2018, two of three recommendations related to this high-risk area had not been implemented.

In 2017, I wrote about how the GAO has been calling for decades—more than 40 years—for better coordination of food-safety oversight, and my post lists a selection of GAO reports dating back to 1970.

The GAO is still at it.

We should not give up either.

I occasionally write about disease outbreaks caused by food and am especially interested in those caused by romaine lettuce, because it’s so hard to trace back where it came from and how it got contaminated.

This post is about two outbreaks of toxic E. coli O157:H7 from Romaine lettuce.

Outbreak #1: This one pretty much ended in November 2018.  My post on it is here.  The CDC’s page on it  is here.

It was especially serious:

• 210 reported illnesses from 36 states
• 96 hospitalizations
• 27 cases of hemolytic uremic syndrome (HUS)
• 5 deaths

Food safety lawyer Bill Marler posted a slide show analyzing this outbreak on his website: “Thanks to FOIA, the CDC and FDA, the 2018 E. coli Romaine Outbreak becoming more Transparent.”  At least that.

Outbreak #2.  In February, the FDA published its “Investigation Summary: Factors Potentially Contributing to the Contamination of Romaine Lettuce Implicated in the Fall 2018 Multi-State Outbreak of E. coli O157:H7.”

The FDA’s web page on this outbreak is here, and the CDC’s is here.

Bill Marler, whose firm represents victims of these outbreaks, posted annotated comments on the announcement.  He titled his post: “The FDA to Leafy Green Growers – “Please voluntarily stop poisoning your customers.”

Despite finding that E. coli outbreaks spanning years likely came from the same are or farm and was most likely caused by the same factors enumerated above, the FDA only sets forth “recommendations” that growers of leafy greens assess their growing operations for compliance with applicable requirements of the FSMA Produce Safety Rule and GAPs, including (see my snide comments in bold).

I will just give one example of his comments:

FDA continues to recommend (suggest, plead, beg, whine) that leafy green growers, buyer/shippers, and retailers be able to trace product back to the specific source in real time and make information about the source, such as harvest date and standardized growing regions, readily available for consumers on either packaging, point of sale signs, or by other means.

Voluntary, alas, isn’t good enough.  The FDA needs authority to require, demand, insist on.  Now.

If you want to see what this is about, take a look at the documents:

• FDA’s final guidance for leafy green growers is here.
• FDA guidance documents for leafy green growers are posted here. There are lots of them.
• FDA guidance documents for retailers selling leafy greens are posted here.

I maintain an active interest in pet food, even though my books on the topic came out a few years ago

• Pet Food Politics: The Chihuahua in the Coal Mine (2008): a contemporary history of the 2007 recalls resulting from pets dying from melamine poisoning.
• Feed Your Pet Right (2010): an analysis of the pet food industry co-authored with Mal Nesheim.

Here are some recent items:

1. Pet food is big business ($63 billion last year).  It brings people into supermarkets and boosts sales.  [OK.  You already knew this, no?]
2. Evangers, a pet food maker occasionally in trouble over ingredient and food safety problems has been caught with horse meat in its products. It says it doesn’t use horse meat, even though it has a license to use it.  It blames its beef supplier.Private label pet food brands are selling well.   They are cheaper.  For the record: all complete-and-balanced pet foods are required to meet the same nutritional standards and to support dog and cat reproduction, growth, and development (they are like infant formula in that regard).
3. Food safety issues for humans also mean food safety issues for pets. The CDC is warning people not to consume certain turkey products because of illnesses caused by Salmonella. “Evidence collected by federal officials investigating the illnesses has revealed the outbreak strain in samples from live turkeys and many kinds of raw turkey products, including pet food.”
4. Raw pet food  continues to raise food safety risks: Rad Cat Raw Diet has been recalled due to Listeria contamination.   A case of human Salmonella illness has been linked to a Darwin’s raw pet food.
5. And the FDA announces the recall of Nutrisca dry dog food with levels of vitamin D so excessive that they made dogs sick.
6. Mars Veterinary, the biggest manufacturer of pet foods, is working on some new products made from—get this—lab-grown mouse meat.  No, I did not make this up; I got it from Business Insider.
7. Wild Earth, Inc., a biotech pet food startup, sells treats made with lab-cultured protein from the koji fungus, Aspergillus oryzae.
8. The humanification of pet food, says The Atlantic, is nearly complete.
9. Whole Dog Journal asks this burning question: Should you feed ice cream to your dog? (The short answer is no, but this gives me a chance to praise Nancy Kerns’ admirably sensible advice about dog feeding, care, and training).

You can see why I love writing about pet food.

The outbreak caused by romaine lettuce contaminated with a toxic strain of E. coli (which I wrote about earlier), was especially serious:

• 210 reported illnesses from 36 states
• 96 hospitalizations
• 27 cases of hemolytic uremic syndrome (HUS)
• 5 deaths

The FDA is continuing to produce comprehensive, thoughtful reports on such outbreaks and recently issued a report of its environmental investigations.

I’ve pulled out some key points from this report about how this outbreak happened and why such outbreaks are so difficult to investigate:

• The traceback identified a total of 36 fields on 23 farms in the Yuma growing region as supplying romaine lettuce that was potentially contaminated and consumed during the outbreak.
• Three of these samples were found to contain E. coli O157:H7 with the same rare genetic fingerprint (by whole genome sequencing) as that which made people sick. These three samples were collected in early June from a 3.5 mile stretch of an irrigation canal near Wellton in Yuma County that delivers water to farms in the local area.
• FDA considers that the most likely way romaine lettuce became contaminated was from the use of water from this irrigation canal, since the outbreak strain of E. coli O157:H7 was found in the irrigation canal and in no other sampled locations.
• A large concentrated animal feeding operation (CAFO) is located adjacent to this stretch of the irrigation canal.

Among the FDA’s conclusions were these:

• There are several ways that irrigation canal water may have come in contact with the implicated romaine lettuce including direct application to the crop and/or use of irrigation canal water to dilute crop protection chemicals applied to the lettuce crop, either through aerial or ground-based spray applications.
• How and when the irrigation canal became contaminated with the outbreak strain is unknown. A large animal feeding operation is nearby but no obvious route for contamination from this facility to the irrigation canal was identified. Other explanations are possible although the EA team found no evidence to support them.

Among its recommendations were these:

• assure that all agricultural water (water that directly contacts the harvestable portion of the crop) used by growers is safe and adequate for its intended use (including agricultural water used for application of crop protection chemicals);
• assess and mitigate risks related to land uses near or adjacent to growing fields that may contaminate agricultural water or leafy greens crops directly (e.g. nearby cattle operations or dairy farms, manure or composting facility).

Contamination of leafy greens with toxic bacteria from animal waste has been a problem for years.

Growing vegetables near CAFO’s seems like a particularly bad idea.  CAFOs, which produce vast amounts of untreated animal waste should not be located near water sources.

Requiring CAFOs to treat animal waste, as human waste is required to be treated, is a necessary first step in producing safe food.

Commissioner Scott Gottlieb’s statement

Because leafy greens are a highly perishable commodity, the ability to traceback the route of a food product as it moves through the entire supply chain, or traceability, is critical to removing the product from commerce as quickly as possible, preventing additional consumer exposures, and properly focusing any recall actions. During the romaine investigation we found the typical traceback process to be particularly challenging because much of the finished lettuce product contained romaine that was sourced from multiple ranches As a result, our investigation involved collecting documentation from each point in the supply chain to verify the movement of product back to the Yuma area. Complicating this already large-scale investigation, the majority of the records collected in this investigation were either paper or handwritten.