Opinion

Yesterday the CDC and FDA announced that Jensen Tuna of Louisiana was recalling frozen ground raw tuna sourced from JK Fish of Vietnam due to possible Salmonella Newport contamination. The recalled tuna was individually packaged in one-pound bags and sold in 20-pound boxes under lot numbers z266, z271, and z272.

The product was sold to wholesalers in Connecticut, Iowa, Illinois, Minnesota, North Dakota, New York, and Washington.

These wholesalers further distribute the product to restaurants and retail locations. The product was distributed from November 30, 2018 to March 15, 2019.

The voluntary recall is in response to the CDC and FDA’s investigation of 13 illnesses caused by Salmonella, confirmed to date after eating ground tuna at various restaurants and retailers.

As of today (April 17), the ground tuna samples were found negative for Salmonella.  The illnesses are reported in Connecticut, Iowa, Illinois, Minnesota, New York, North Dakota and Washington.

Today, our global food supply is a long one.  The lengthening of the supply chain allows more opportunities for problems to occur.

In 2012 Chris Fronzak, my client and lead singer for the heavy metal band Attila, consumed a spicy tuna roll containing Nakaochi Scrape at a Metairie, Louisiana restaurant while his band was on tour – the “Sick Tour.” I kid you not.

Here is the story of the 2012 Salmonella outbreak investigation.

Local, state, the CDC and the U.S. Food and Drug Administration (FDA) collaborated in an investigation of a multistate outbreak of Salmonella Bareilly and Salmonella Nchanga infections, which was ultimately shown to be associated with consumption of an imported frozen raw yellowfin tuna product, known as Nakaochi Scrape[1], from Moon Marine USA Corporation. Nakaochi Scrape is tuna backmeat that is scraped from the bones of tuna and may be used in sushi, sashimi, ceviche, and similar dishes.

Salmonella Bareilly and Salmonella Nchanga are unusual serotypes of Salmonellain the United States. Public health investigators used DNA “fingerprints” of Salmonella bacteria obtained through diagnostic testing with pulsed-field gel electrophoresis, or PFGE, to identify cases of illness that were counted as outbreak associated cases. They used data from PulseNet, the national subtyping network made up of state and local public health laboratories and federal food regulatory laboratories that performs molecular surveillance of foodborne infections.

A total of 425 individuals infected with the outbreak strains of Salmonella Bareilly or Salmonella Nchanga. There were 410 people infected with the outbreak strain of Salmonella Bareilly were reported from 28 states and the District of Columbia. The number of ill persons infected with the outbreak strain of Salmonella Bareilly identified in each state was as follows: Alabama (5), Arkansas (1), California (8), Colorado (1), Connecticut (11), District of Columbia (3), Florida (1), Georgia (20), Illinois (30) Indiana (1), Kansas (1), Louisiana (6), Massachusetts (36), Maryland (39), Missouri (4), Mississippi (2), Nebraska (2), New Hampshire (2), New Jersey (39), New York (62), North Carolina (12), Pennsylvania (37), Rhode Island (6), South Carolina (5), Tennessee (4), Texas (14), Virginia (33), Vermont (1), and Wisconsin (24).

Fifteen persons infected with the outbreak strain of Salmonella Nchanga were reported from 7 states. The number of ill persons infected with the outbreak strain of Salmonella Nchanga identified in each state was as follows: Georgia (2), Maryland (1), New Jersey (3), New York (6), Texas (1), Virginia (1), and Wisconsin (1).

State and local public health and regulatory officials worked with the U.S. Food and Drug Administration (FDA) to conduct a traceback investigation of tuna. Investigators visited restaurants and grocery stores associated with ill persons and collected information about the ingredients used in “spicy tuna” recipes. Raw tuna was found to be a common ingredient used to make “spicy tuna” among all five restaurant or grocery store clusters for which ingredient information was available. FDA selected four of the clusters, which were located in Connecticut, Rhode Island, Texas, and Wisconsin, as the focus of the initial traceback investigation. All 4 establishments received the same imported frozen raw Nakaochi Scrape tuna product from a single tuna processing facility in India, Moon Fishery Pvt Ltd.

On April 13, 2012, Moon Marine USA Corp., also known as MMI, of Cupertino, CA, voluntarily recalled 58,828 pounds of a frozen raw yellowfin tuna product, labeled as Nakaochi Scrape AA or AAA. A Seafood HACCP (Hazard Analysis and Critical Control Point) inspection was conducted by FDA April 19-24, 2012, at the Moon Fishery Pvt. Ltd. processing facility in Aroor, India. Based on the initial tour of the facility, inspectors identified several seafood HACCP deficiencies, such as lack of controls for histamine at receipt of product, lack of controls for Clostridium botulinum at storage, and several significant sanitation observations of concern.

During the investigation, samples of the implicated product were collected for laboratory testing. On April 24, 2012, the Wisconsin Department of Health Services announced that the Department of Agriculture Trade and Consumer Protection laboratory had found Salmonella Bareilly contamination in recalled yellowfin tuna and in a spicy tuna roll made with the recalled tuna.

On April 26, 2012, FDA announced finding the outbreak strain of Salmonella Bareilly from two samples taken from unopened packages of recalled Nakaochi Scrape tuna from Moon Marine USA Corporation. One of the samples also yielded another type of Salmonella with a PFGE pattern indistinguishable from a cluster of Salmonella Nchanga infections. Based on an epidemiological link and results of laboratory testing, CDC combined the Salmonella Bareilly investigation with an ongoing Salmonella Nchanga investigation, and the 2 associated PFGE patterns were grouped together as the “outbreak strains.”

By May 17, 2012, laboratory testing conducted by state public health laboratories in Connecticut, Maryland, Massachusetts, Pennsylvania, South Carolina, and Wisconsin isolated Salmonella from 53 (96 percent) of 55 samples taken from intact packages of frozen yellowfin tuna scrape from Moon Marine USA Corp. or from sushi prepared with the implicated scrape tuna product. Of the 41 Salmonella isolates for which PFGE results are available, 36 samples yielded the outbreak strain of Salmonella Bareilly, and 12 samples yielded the outbreak strain of Salmonella Nchanga. Seven samples yielded the outbreak strains of both Salmonella Bareilly and Salmonella Nchanga.

On May 10, 2012, Moon Fishery (India) Pvt. Ltd., the manufacturer of the frozen yellowfin tuna Nakaochi Scrape, expanded the voluntary to include its 22-pound boxes of “Tuna Strips”, Product of India, marked as “AA” or “AAA Grade” because the product has the potential to be contaminated with Salmonella. The recall was announced after FDA laboratories isolated the outbreak strain of Salmonella Bareilly from a sample of tuna strips from Moon Fishery (India) Pvt Ltd collected as part of increased surveillance efforts. The shipment in question did not enter into U.S. commerce and no human illnesses were associated with this product. [2]


[1] Tuna scrape is the part of the fish that remains after the filets have been removed as whole cuts. Once a knife has been run down both sides of the spine to cut off the filets, meat close to the bone missed by the blade is then scraped out with a spoon-like device. After being collected in this way, it is sometimes chopped into smaller bits, but no more processing is done.

[2] See CDC Final Update dated July 26, 2012, http://www.cdc.gov/salmonella/bareilly-04-12/index.html

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