A Traceability Challenge: “Whatever it Takes”

When there is a recall of a food which you do not produce or use in your product, do you pay attention? Do you keep an eye on CDC and FDA notifications? Do you follow the traceback efforts of outbreaks?

With the number of recalls occurring on a nearly daily basis, it can be extremely difficult: According to the FDA and USDA recall alert pages (https://www.fda.gov/Safety/Recalls and https://bit.ly/2g0aJbA), in April alone, there were 34 food recalls. That is more than one per day on average. So it can be tempting for food facility management teams to focus only on recalls of foods that directly impact their businesses.

But I would recommend you take the time to read — and read into — every food recall that occurs. Or at the very least, to do so when a recall is enacted because of a foodborne-illness outbreak, or a foodborne outbreak occurs and no recall, or only a limited recall, is able to be made.

What do I mean by this?

Reading Recalls. Let’s take, for example, the multi-state outbreak of  E. coli  O157:H7 infections linked to romaine lettuce. I discussed the outbreak and improvements the produce industry has made because of similar previous outbreaks, in my May 17 e-newsletter, What Are We Learning from Produce Outbreaks? So I won’t repeat those thoughts here, but I would encourage you to read the article.

What I would like to reiterate, and discuss in more depth, are the lessons to be learned and the responses to be made.

A quick overview: At the time of this writing, the outbreak had reached a case count of 172 infections in 32 states, resulting in 75 hospitalizations and one death … and no recalls. At best, the contamination was linked to the Yuma, Ariz., growing region. But with 90% of the nation’s winter leafy vegetables grown there, that involves a whole lot of romaine lettuce. And because no single source had yet been found, CDC’s advice to consumers and retailers was to not eat, sell, or serve any romaine lettuce unless it could be confirmed that it was not from the Yuma region.

Now, if you don’t produce a salad product, you may be keeping just a cursory eye on all this — or not even taking the time to follow it at all. But you should.

Whether or not you use or have romaine lettuce in your facility, the outbreak impacts you as it does the entire food industry. It impacts the way consumers view food production and the way the government regulates it.

Of course, it is even more impactful if you are in the segment of the industry in which the situation occurred. For example, I know of an ice cream manufacturer that has had two FSMA inspections — including full-fledged environmental sampling swab-a-thons. Interestingly, those inspections were almost exactly a year apart. Why? Ever since the Blue Bell incident of 2015, ice cream has been subject to increased scrutiny.

As to the two inspections a year apart — with FDA’s recent focus on whole genome sequencing (WGS) testing that can link pathogens across time and distance, they were likely looking for resident strains as occurred in Blue Bell.

Learning Lessons. But whether a recall or outbreak is in your industry segment or not, there are lessons that can be learned and improvements that can be made. To jump back to produce, my hope is that this most recent outbreak follows the example of two previous major outbreaks which led to major industry improvements:

• The Leafy Greens Marketing Agreement (LGMA): In 2007, in response to the infamous spinach E. coli outbreak, California farmers made an unprecedented commitment to protecting public health through the creation of the LGMA. With a goal to assure safe leafy greens and confidence in our food safety programs, the program involves a set of food safety practices for leafy greens. Participation is voluntary, but once committed, a company is subject to mandatory USDA audits.
• The Produce Traceability Initiative (PTI) is an industry-led effort to drive whole-chain traceability through common data standards. The initiative includes seven milestones  for implementing case-level electronic traceability in the produce industry. 

While pro-action is better than reaction, sometimes it’s a matter of “whatever it takes.” There are some things we will likely never know about the source of the romaine lettuce contamination, but I’m hoping that a reaction to it is an increased focus on traceability, on more quickly and completely tracing the product — no matter what food it is — to reduce the public health impacts and more quickly and completely alleviate consumer fears. Which also positively impacts the industry as consumers become more willing to again purchase the product.

A Traceability Challenge. Our current tracking systems don’t work. They take too long, and they are too imprecise. The requirement initiated under the Bioterrorism Act of 2002 to trace one forward/one back is good, but it doesn’t require a lot of detail, nor do the FSMA requirements for one forward/one back add much to that. We need more detail from FDA on traceback — and we need the agency to develop the high-risk food lists and requirements that were Congressionally mandated.

And no matter what system is implemented for traceback — be it federally mandated or not — we need to ensure that the data put into the system is accurate and complete. Any system is only as good as the data put into it.

So I’d like to challenge both the industry and its regulating agencies to take a good, hard look at all recalls and outbreaks and how we are tracing those incidents back to the source — when we are able to do so. What can we do to improve our systems? How can we make them faster and more accurate?

What can we learn from all these incidents, be they in our supply chain or industry segment — or not.