Black Sand in Bread. How did that happen?

A customer called to complain about a wheat flour delivery. The QA lab reported a black granular substance in a morning production of bread with a black sand-like substance found in one of the flour silos. The customer stated: "Changing the flour silo corrected the problem and we are recalling the contaminated bread." The response: "We will have someone there today to investigate."

Black sand in bread and in the flour. How did that happen?

Although this incident may be fictitious with any similarity to real events purely coincidental, there are lessons to be learned: How did it happen? Who will pay for damages? Where is the food safety gap? What are practical solutions to prevent an incident happening to you?
 

The Investigation. A company sanitarian was on site in a few hours. The problem was validated and plans were made to empty and clean the flour silo. Samples were obtained along with other important information such as receiving information, driver, and trucking company contact. The customer was informed and asked to have its problem-related costs prepared for a meeting scheduled for the following day.

The investigation started at the nearby flour mill with truck load-out samples. These samples showed no evidence of any black sand, although the lab verified the contamination to be black sand. (Note: This company's policy for flour trailers is that all trailers are exclusively dedicated to flour use; they are not to be used even for other human food.)

The sanitarian found the trailer pre-loading inspection reports to be in order but also found that the truck shipment did not originate from this mill. The shipping manager traced the suspect truck shipment while the sanitarian went to the trucking company.

Records showed that the suspect trailer was loaded at the trucking company's railcar transfer yard from a railcar originating at an out-of-state flour mill (of the same company), because the customer had requested a different flour that was not produced locally. The sanitarian requested the originating flour mill's railcar load-out samples, pre-loading cleaning/inspection report, and security lock IDs, along with any other shipment-related information. The sanitarian examined the trucking company records of trailer delivery history, pre-loading inspection reports, sifter tailings, loading samples, railcar shipment receiving information, security lock IDs, and railcar flour samples, along with the trailer cleaning records.

The Cause. During his review, the sanitarian found there was a lack of recordkeeping with basic quality assurance and food safety management of this railcar-to-trailer transfer activity. Tracing the suspect trailer's recent history showed a backhaul shipment of black sand. The review did find, however, that the originating flour mill's records, samples, and security were in order.
 

The Solution. A morning meeting was scheduled at the trucking office with executives of both the flour and trucking companies. The sanitarian presented investigation results, after which the truck driver confessed to a policy violation. The driver was immediately disciplined and a regional manager was assigned to correct systematic deficiencies. The trucking company provided compensation to the supplier and customer of all related damages during the morning meetings.
 

Lessons Learned. What are lessons learned from this incident? One lesson is to recognize QA gaps. Out of sight/out of mind can be trouble. Some questions you should ask or investigate include:

• Are there gaps anywhere within your entire QA system?
• Do you have any railcar-to-truck transfer operations similar to this incident?
• Are assumptions being made with key suppliers and not being verified?
• Are there gaps in contract co-packing of your products or in distribution warehouses repairing damaged products?
• Are there gaps at retail stores, with damaged products being sold at a discount, and/or in customer returns with damaged products?

Another lesson learned is how the responsible party provided a timely solution to its customers, in addition to correcting internal issues. Some companies might turn this incident over to attorneys. Can attorneys correct QA systematic issues in a timely manner? FIFRA does not stand for Future Income For Regulatory Attorneys.

QA solutions are abundant and available to correct systematic flaws with farm-to-fork products. There are times that systematic flaws occur beyond day-to-day routines. To prevent these, periodically examine your process all the way to consumption looking for possible systematic gaps in your entire QA and food safety system. As the old but true saying goes: an ounce of prevention is worth a pound of cure.