Anyone who has been following news lately is aware of two epic recalls prompted by concerns that two firms may have produced and distributed foods contaminated Listeria monocytogenes: CRF frozen organic and traditional fruits and vegetables and SunOpta sunflower kernels. These recalls have been massive in scope because these foods were used as ingredients by other food manufacturers and in the case of CRF the firm recalling all products it produced since May 2014.
Food recall basics
FDA classifies food recalls into three distinct categories with Class I being the most severe and Class III the least severe.
- Class I: Dangerous or defective products that predictably could cause serious health problems or death. Examples include: food found to contain botulinum toxin or food with undeclared allergens.
- Class II: Products that might cause a temporary health problem, or pose only a slight threat of a serious nature.
- Class III: Products that are unlikely to cause any adverse health reaction, but that violate FDA labeling or manufacturing laws. Examples include: a minor container defect and lack of English labeling in a retail food.
It is important for food companies to contact FDA recall coordinators, whom are located throughout the country (contact information can be found here), when they decide to pull the trigger on a recall of food products they have produced, because FDA is responsible for classifying the recall based on relevant information provided by the firm.
Additionally, if it is determined that the firm is in a Class I recall situation, it is likely that a firm will be obliged to inform FDA via the Reportable Food Registry (RFR) that adulterated food products have left their control and has entered commerce.
Recently the FDA published “A five year overview of targeting inspection resources and identifying patterns of adulteration” which recaps FDA RFR reporting from September 8, 2009 – September 7, 2014. This report recaps RFR data by food group, and hazard on a yearly basis and is an instructional read if you are wondering where FDA will be placing increased regulatory scrutiny in the near future.
All things considered
So what are some things that public health officials and food companies may consider when with the possible need to recall a food produce occurs due to concerns based on epidemiological, sample positive and/or traceability investigation evidence.
1) Protect Public Health by Stopping Consumption of Potentially Contaminated Foods: The first and most obvious reason that FDA or other public health officials request that recall notices be sent out by a firm is to protect public health by alerting consumers to the fact that specific food products may be contaminated and may be capable of causing illness.
An interesting aspect to the aforementioned CRF foods frozen fruit and vegetable recall is the recall involved some not ready-to-eat foods, to which implicated CRF fruits and vegetables were added as an ingredient. The issue of how FDA should deal with not ready-to-eat foods contaminated with pathogens such as Listeria monocytogenes was recently discussed at the December 2015 FDA Food Advisory Committee meeting and was discussed in a previous blog post.
However for most fresh fruits and vegetables this argument is irrelevant as FDA considers most fresh fruits and vegetables ready-to-eat foods so this consideration does not apply. An addition reason that firms may wish to consider once they are informed that their products may be adulterated is product liability considerations as the firm now has been explicitly advised that their products may cause serious adverse consequences or death. Therefore, whenever presented with such evidence it is wise to consult with a food and drug law attorney whom can not only advise you on your rights and responsibilities from a regulatory perspectice but on your product liability vulnerabilities.
2) Inform Consumers That They May Have Consumed A Contaminated Food: Another reason that FDA or other public health officials request that recall notices be sent out by a firm is to inform consumers that they may have been exposed to a contaminated food. As an FDA Class I recall involves food products which may cause severe adverse health consequences or death, it is important to let consumer know that they may have been exposed to such an agent.
It is also important for consumers to understand what the symptoms are for a specific agent and that symptoms may not occur for days, weeks or months after consumption and to seek appropriate medical care if symptoms to appear. For example, in the case of Listeria monocytogenes the invasive form of the illness can have a very long incubation period that is estimated to vary from three days to three months.
3) Inform Food Handlers That They May Have Handled Contaminated Food: Yet another reason that FDA or other public health officials consider when requesting that recall notices be sent out by a firm is to inform food handlers whether they be at home or in food service operations that foods they handled may have been contaminated.
This information is important to food handlers who may wish to undertake extra cleaning and/or sanitizing of food contact surfaces that may have been used to prepare potentially contaminated food or ingredients. Special care and extra attention may be needed to prevent secondary contamination events from occurring via food contact surfaces on cutting boards, slicers or refrigerator surfaces.
4) Inform Food Preparers That They May Have Incorporated A Contaminated Food Ingredient Into Stored Foods: Finally, it is possible that potentially contaminated food ingredients may have been incorporated into complex foods which may have an extended shelf-life by for example freezing. As freezing alone does not kill most human pathogens it is important to let food preparers know that they may have a potentially contaminated prepared food in their freezer and to let them know to take appropriate action and discard such foods.
While these are all very good reasons to discard foods and prevent illnesses and even death, it still makes me sad from a sustainability perspective to see all this food going to waste, especially in cases when thorough cooking would almost certainly reduce, control or completely eliminate the risk of contracting a foodborne illness.
However, when in doubt throw it out and follow the Partnership for Food Safety Education dictum to cook, clean, chill and separate for safe food handling.
About the author: James Gorny, Ph.D., is the vice president for food safety and technology for the Produce Marketing Association (PMA) in Newark, DE. Prior to joining PMA Gorny was the senior advisor for produce safety at FDA’s Center for Food Safety and Applied Nutrition.
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