Currently browsing posts about: Food-safety

Two items about pet food this week.  Today: safety.  Tomorrow: environmental sustainability.

I have a long-standing interest in pet food, which I view as an integral—essential—component of our overall food system , not least because pet food uses food components that would otherwise be wasted.  I co-authored a book about pet food issues: Feed Your Pet Right.

If there are problems with the safety of pet food, you can bet those problems will occur in the food supply for humans.  I wrote a book about that too: Pet Food Politics: The Canary in the Coal Mine.

I am not the only one interested in such topics.  Phyllis Entis has written two books crticizing the safety hazards of pet foods.

• TAINTED. From Farm Gate to Dinner Plate, Fifty Years of Food Safety Failures 
• TOXIC. From Factory to Food Bowl, Pet Food Is a Risky Business

She keeps me up-to-date on the latest problems that arise.

I don’t know how closely you’re watching the pet food industry these days, but I thought this piece I just posted might interest you: When ‘truths’ collide: Darwin’s, ANSWERS, and the FDA

This was an account of an FDA Advisory and its non-consequences: Do Not Feed Certain Lots of Darwin’s Natural Selections Pet Food Due to Salmonella and Listeria monocytogenes.

The U.S. Food and Drug Administration is cautioning pet owners that FDA samples of five Darwin’s Natural Pet Products raw cat and dog food made by Arrow Reliance, Inc. tested positive for Salmonella and a sixth FDA sample tested positive for Salmonella and Listeria monocytogenes (L. mono)…If you have any of the Darwin’s Natural Selections pet food product listed above, stop feeding the product to your pets and throw it away in a secure container where other animals, including wildlife, cannot access it. Do not donate the food.

The bigger story here, as Phillis Entis explains, is that the FDA did not force the company to recall the products; it asked Darwin to rissue a recall volunarily.

But in this case, the company resisted.  It voluntarily decided not to do the recall.  Pet Food Industry (an essential source of information) tells this story.

In a September 20, 2024, memo from the company to consumers which was sent to Petfood Industry, Darwin’s Natural Pet Products had this to say given the FDA’s public notice regarding the affected lots of cat and dog food.

The memo is worth a look.  It says things like this:

• At Darwin’s, the health and safety of your pets is our absolute top priority, and we take rigorous steps to support their well-being and to foster strong lines of communication with you and our fellow community members.
• It is also very important to know that the FDA has received no consumer complaints regarding any of these lots.
• We find the FDA’s public notice to be wholly unnecessary, and ultimately, based on flawed regulatory decision-making, and we have taken steps to make this position clear to the agency.

Oh.

Food safety lawyer Bill Marler asks: Will the FDA use its Recall Authority to Mandate a Pet Food Recall due to Salmonella and Listeria?   .The FDA has that authority.  It did not use it.

That leaves you on your own to make sure you do not buy Darwin products for your pet.

The FDA provides plenty of information as a basis for you taking responsibility for such things.

Its advisory asks this question: Why is the FDA concerned about Salmonella and L. mono in pet food?

Pet foods contaminated with Salmonella and L. mono are of particular public health importance because they can affect both human and animal health. Pets can get sick from Salmonella and may also be carriers of the bacteria and pass it on to their human companions without appearing to be ill…The Federal Food, Drug, and Cosmetic Act requires that all animal foods, like human foods, be safe to eat, produced under sanitary conditions, contain no harmful substances, and be truthfully labeled. Refrigeration or freezing does not kill Salmonella or L. mono.

It provides  these resources:

• Get the Facts about Salmonella
• Salmonella (Salmonellosis)
• Get the Facts about Listeria
• Listeria (Listeriosis)

Do we need more forceful regulation of pet food?  Of course we do.

A reader writes:

Can you address the current food crisis outlining the many foods, long time frame, economic impact, and personal effort involved in this event?

I did not realize until I read the NPR email news brief this morning that one factory is the source of nine  deaths,  that multiple meat products are suspect, that many stores are involved, that sell-by dates extend into October, that products may be in appliances at home, and that all food in the appliance must be disposed of and that the empty appliance must be thoroughly cleaned.

My immediate response was to say that this is yet another recall due to foodborne illness and I’ve written previously about lots of these.  But this one is especially tragic.

• The products—meat contaminated with Listeria—killed people who ate them.
• The plant in which they were produced is inspected daily by an on-site USDA inspector.
• Even so, the plant was especially dirty and unsafe.

The CDC reports: “Epidemiologic, laboratory, and traceback data show that meats sliced at delis, including Boar’s Head brand liverwurst, are contaminated with Listeria and are making people sick.”

This particular outbreak began in June.

The USDA issued a recall notice at the end of July.

FSIS [USDA’s Food Safety and Inspection Service] is concerned that some product may be in consumers’ refrigerators and in retail deli cases. Consumers who have purchased these products are urged not to consume them and retailers are urged not to sell these products with the referenced sell by dates. These products should be thrown away or returned to the place of purchase. Consumers who have purchased these products are also urged to clean refrigerators thoroughly to prevent the risk of cross-contamination.

Boar’s Head published a list of the recalled products.  These include several brands and product types.

CBS used FOIA to request USDA’s records of Boar’s Head inspection results.  These take up 44 pages.

Food Safety News did a summary: “Inspection report reveals history of sanitation issues at Boar’s Head plant linked to deadly Listeria outbreak.”

Over a year of repeated sanitation failures — totaling 69 violations — at Boar’s Head’s Virginia plant, appears to have fueled the ongoing Listeria outbreak that has sickened 57 people across 18 states and claimed nine lives…The violations documented in the report include the presence of mold and mildew on surfaces that employees use to wash their hands, on the outside of steel vats and in holding coolers between smokehouses. These conditions are particularly concerning given the ability of Listeria monocytogenes to thrive in cold, moist environments.

CBS did a news video on the inspection results: “Mold, mildew and bugs linked to listeria outbreak, records show.”

Food safety lawyer Bill Marler is calling for a Congressional Investigation.

…years of inspection reports leave little doubt that the Boar’s Head plant’s HACCP [required safety plan] must have been either non-existent or used for toilet paper. It is hard to wrap your head around how food could be produced in these conditions by this company and under the un watchful gaze of FSIS inspectors.

Today’s New York Times points out that food safety recalls have additional consequences.  The economic viability of the town that houses this Boar’s Head plant depends on it for employment and purchases of local services.

Comment

Few of the food safety issues I’ve written about recently involve meat.  This is because of a major overhaul of USDA requirements for meat safety in the 1990s.  Once the USDA required meat producers to develop and use HACCP [Hazard Analysis and Critical Control Point] safety plans, outbreaks due to contaminated meat declined.  When done right, these plans are highly effective.  They require producers to identify places in production where contamination could occur, take steps to prevent contamination at those critical control points, and monitor to make sure those steps were taken.  USDA inspectors are supposed to make sure all that happens.

But the inspection system has a built-in conflict of interest.  The system is voluntary.  The USDA cannot force compliance or order recalls.  All it can do is to withdraw its inspectors, thereby forcing the plant to close.  Nobody ever wants to do that.

The food safety system, divided between two agencies as it is (with different legislative mandates and different powers), needs an overhaul.  Lives are at risk.

If you have any Boar’s Head products in your freezer, better take a look at what they are and get rid of any on the recall list.

And let your congressional representatives know that you want better food safety oversight.

Additions

Thanks to Michael Jacobson for sending a link to the Boar’s Head website and the company’s promotional video.  After seeing it, this feels like even more of a tragedy.

Here’s Bill Marler’s legal complaint, just filed.

7-31-24: USDA withdraws inspectors

9-13-24: Boar’s Head announces plant closure

By the time the FDA posted this outbreak alert, the cucumbers had all been picked, shipped, and done their damage.

The outbreak

Total Illnesses: 449
Hospitalizations: 125
Deaths: 0
Last Illness Onset: June 4, 2024
States with Cases: AL, AR, CT, DE, DC, FL, GA, IL, IN, IA, KY, ME, MD, MA, MI, MN, MO, NV, NJ, NY, NC, OH, OK, PA, RI, SC, TN, TX, VA, VT, WA, WI [31 states]

The CDC investigation:  Of 188 people interviewed (69%) reported eating cucumbers.

The product

cucumbers distributed by Fresh Start Produce Sales, Inc. and grown by Bedner Growers, Inc., of Boynton Beach, FL. Recalled cucumbers are beyond shelf life and should no longer be available for sale to consumers in stores.  Bedner Growers, Inc.’s growing and harvesting seasons are over. There is no product from this farm on the market and likely no ongoing risk to the public.

The self-protective reaction

According to Food Safety News,

the Florida Department of Agriculture (FDOA) called the U.S. Food and Drug Administration’s (FDA) tracing of a Salmonella outbreak to a local cucumber grower “at best inaccurate, and at worst misleading.” Apparently, the head of food safety at the FDOA, who told the FDA in an email “We find the science inaccurate, unsubstantiated and unnecessarily damaging to the firm implicated.”

Comment

This outbreak is worth special attention, not least because so many people were affected in so many states, and the cucumbers were gone by the time investigators knew they were the most likely cause.

• Half the cases were due to a new kind of Salmonella, S. Braenderup.
• The FDA idenified S. Braenderup in untreated canal water used for irrigation.

Salmonella in the water?  This means there must be some kind of enormous CAFO (Confined Animal Feeding Operation) nearby, spilling its cattle, dairy, or poutry waste into local streams.

The regulatory issues

This brings me to law professor Timothy Lytton’s latest paper on precisely this issue:  Lytton, Timothy D., Known Unknowns: Unmeasurable Hazards and the Limits of Risk Regulation (July 02, 2024). Oklahoma Law Review, Vol. 76, No. 4, p. 857, 2024.

This Article develops general principles for addressing known unknowns using a case study of efforts to regulate agricultural water quality. Contaminated water used to cultivate fresh produce is a well-known cause of recurrent foodborne illness outbreaks. Unfortunately, it has, so far, proven impossible to reliably quantify the risk of human illness from any given source of agricultural water.

At least one problem here is the split in regulatory authority between FDA (cucumbers) and USDA (animals).  FDA has no authority over CAFOs.  Its authority stops at the farm.  How is the cucumber farmer supposed to stop toxic forms of Salmonella from getting onto cucumber fields?

That is the insoluble regulatory problem Lytton’s piece addresses.

The FDA has issued its boringly titled Southwest Agricultural Region Environmental Microbiology Study (2019 – 2024).

The report seems designed to be boring.  Its subject, however, is anything but.

Let me do some translating (in Italics).

• “The study was designed to improve understanding of the environmental factors that may impact the presence of foodborne pathogens in the Southwest agricultural region.”  [Leafy greens contaminated with pathogenic bacteria make lots of people really sick, undoubtedly because they come in contact with CAFOs, confined animal feeding operations].
• “Samples were collected from irrigation waters, soil, sediments, air/dust, animal fecal material, wildlife scat, and other sources across approximately a 54 mile (7,000 acres) area of the southwest growing region.” [It’s about time the FDA did this].
• “Special attention was given to the geography of the study region and the types and locations of agricultural and other adjacent and nearby land use activities relative to produce production areas.  For example, there is a Concentrated Animal Feeding Operation (CAFO) with more than 80,000 head of cattle and an associated compost operation in proximity to some of the produce production areas studied. [Oh.  What a surprise].

The investigation’s findings

• “STEC [Shiga toxin-producing E. coli] can survive in the air and that dust can act as a transfer mechanism for both pathogens and indicator organisms (e.g. generic E. coli) from adjacent and nearby land to water, soil, and plant tissue “[toxic bacteria spread from CAFOs by air and dust].
• “The research team repeatedly observed that generic E. coli concentrations and STEC prevalence and isolation frequency increased as irrigation canal water flowed past an adjacent livestock and compost operation” [toxic bacteria spread from CAFOs by water].
• “…birds and other wildlife do not appear to be significant sources of STEC or E. coli O157:H7 ” [blaming wild birds for contaminating leafy greens is not going to work].
• “STEC strains detected in water, sediment, and plant tissue harvested from our research plots genetically matched strains isolated in air samples providing evidence that bacteria in air can transfer to other locations and surfaces.”  [Toxic bacteria get around easily].

The conclusions

Having proven that CAFOs contaminate air, soil, and water with toxic bacteria, the report concludes:

The preliminary results of this study stress the interconnectedness between people, animals and the environment and serve as an important model for how to foster productive dialogue among diverse stakeholders to improve food safety.

Comment

Foster dialogue?  They have to be kidding.  CAFOs need to be held responsible for the waste produced by their animals.  Human wastes are not allowed to be released untreated into the environment; neither should animal wastes.

Here is food safety lawyer Bill Marler’s comment.

Last week, the FDA essentially took tara flour out of the food supply.

Today, the U.S. Food and Drug Administration (FDA) posted on its website its determination that tara flour in human food does not meet the Generally Recognized As Safe (or GRAS) standard and is an unapproved food additive. The FDA’s assessment of the ingredient is detailed in a memo added to the agency’s public inventory.

The FDA explained what this is about.

In 2022, Daily Harvest used tara flour in a leek and lentil crumble product which was associated with roughly 400 adverse event reports. The firm took prompt action to voluntarily recall the product and conduct their own root cause analysis, during which they identified tara flour as a possible contributor to the illnesses. To date, the FDA has found no evidence that tara flour caused the outbreak; however, it did prompt the agency to evaluate the regulatory status of this food ingredient.

Daily Harvest makes frozen vegan meals for home delivery.  One of these meals contained tara flour.  Of 26,000 such meals sent out, 400 caused eaters to become desperately sick, some needing hospitalization, some needing surgery (I’ve met some of them).

In my posts, I speculated about why tara flour could cause such severe reactions.

Bill Marler, the food safety lawyer representing a great many of the victims, pushed the FDA to get tara flour out of the food supply before anyone else got sick.  His December 2023 letter reviews what is known about this situation to date.  The FDA paid attention!

Now, two years later, the FDA is doing what it can to prevent tara flour from getting into the food supply.  Good.

Here’s what I’ve had to say about this:

• The Daily Harvest mystery—a cause at last?
• The Daily Harvest recall mystery: update
• Tara flour: a quick review of the research
• What’s up with the Daily Harvest recall?

Here’s what Food Safety News has to say.  It notes more cases than are reported by the FDA, many of them represented by food-safety attorney Bill Marler.

Daily Harvest seems to have survived this tragedy, is still in business, and right on top of currents trends.  Its latest:

Daily Harvest’s January Jumpstart program features GLP-1-focused meal plans:  Daily Harvest’s debut of its GLP-1 Companion Food Collection as part of its quick-to-prep January Jumpstart plan includes “meals made with only real foods that are calorie-conscious while delivering ample vitamins and minerals,” Carolina Schneider, MS, RD, Daily Harvest’s nutrition advisor, told FoodNavigator-USA…. Read more

I learned about this one from Bill Marler’s blog: This is Nuts – California and Washington E. coli Outbreak linked to Gibson Farms Walnuts 

This refers to the CDC announcement: E. coli outbreak linked to organic walnuts

The CDC issued a warning: CDC warns of E. coli outbreak linked to organic walnuts sold in bulk

The FDA has its own investigation: Outbreak Investigation of E. coli O157:H7: Bulk Organic Walnuts (April 2024): Do not eat, sell, or serve recalled organic walnuts sold in bulk bins at natural food and co-op retailers in multiple states. FDA’s investigation is ongoing.

The CDC points out:

• Almost all sick people purchased organic walnuts from bulk bins in food co-ops or natural food stores in California and Washington.
• FDA determined that Gibson Farms, Inc supplied these walnuts and Gibson Farms, Inc has recalled these products.: These walnuts have expiration dates between May 21, 2025, and June 7, 2025.
• FDA has a list of stores that may have received these walnuts.

Comment:  All toxic E. coli outbreaks are troubling because the illnesses are so serious and all are preventable if producers were doing what they were supposed to be doing.  But walnuts?  My first question is how could walnuts, firmly encased in shells, get contaminated with animal fecal wastes, the usual source of this strain of E. coli.  This reminds me of the Odwalla juice E. coli problems; the company had harvested apples that had fallen on the ground. Did Gibson harvest walnuts off the ground?  Whatever it did, the company should have been following a food safety plan mandated by the Food Safety Modernization Act, which requires prevention controls and testing to make sure things like this donn’t happen.

Are non-organic walnuts harvested any differently from organic walnuts.   Here’s what one producer says.

The nuts are removed from the tree using a mechanical shaker, a machine that grasps the trunk and shakes the whole tree. The nuts drop to the ground, are then swept into windrows and picked up with harvest machinery. This operation is completed quickly to reduce the time nuts remain on the ground.

Uh oh indeed.  I hope this incident causes some changes in this procedure.

In the meantime, Marler has more to do.

As I’ve said before, USDA is at long last taking a first step toward declaring Salmonella an adulterant on poultry products.

Here’s the headline: USDA Finalizes Policy to Protect Consumers from Salmonella in Raw Breaded Stuffed Chicken Products:  an adulterant in raw breaded stuffed chicken products when they exceed a specific threshold (1 colony forming unit (CFU) per gram or higher) for Salmonella.

And here’s the Advance Copy of Final Rule: Salmonella in Not-Ready-To-Eat Breaded Stuffed Chicken Products.  

What this rule means: raw breaded stuffed chicken shown to have more than one colony forming unit of Salmonella (basically none) cannot be sold.  Period.

I have long argued:

• Chicken should be free of pathogenic bacteria when we buy it.
• We should not have to run our kitchens like biohazard laboratories.
• Poultry producers should be responsible for eliminating pathogens in their flocks.

Finally, the USDA is taking some action on this.  It promises to start rulemaking on other chicken products.  This can’t come too soon.

As for the chicken industry, alas: NCC [National Chicken Council] Expresses Grave Concerns with New FSIS Salmonella Regulation

NCC is gravely concerned that the precedent set by this abrupt shift in longstanding policy has the potential to shutter processing plants, cost jobs, and take safe food and convenient products off shelves, without moving the needle on public health….“NCC estimates that on an annual basis, over 200 million servings of this product will be lost, 500-1000 people will lose their jobs, and the annual cost to industry is significantly higher than USDA’s estimates. It is likely that this proposal would drive smaller producers of this product out of business entirely.

If you want to know why it’s taken the USDA so long to get this done, and only in one product, the NCC is your answer.

Additional resources

• Salmonella in Not Ready-To-Eat Breaded Stuffed Chicken Products: Final determination and response to comments
• The AP Story on the ruling

I thought this 2023 report was well worth a look.

Microbial diseases of animals can be transmitted to humans, and vice versa (witness COVID-19 in mink and zoo animals).  Some of these have led to serious epidemics.  Lots of people are worried that Confined Animal Feeding Operations could easily become the source of new and deadly forms of influenza.

But what interested me in this report is that industrial farm animal production is one of a great many sources of potential infectious disease transmission.

A few of the many examples, some well known to have caused Salmonella infections:

• Pets
• Hunted animals
• Production of bat guano and coyote urine (who knew?)
• Backyard chickens
• Crocodile farming
• Petting zoos
• Research animals

The report is cautious on the topic of the origin of COVID-19:

At the time of this writing, scientists continue to debate the precise origins of the virus but there is no question as to the impact it has had. Indeed, few aspects of daily life in the United States remain untouched.

The implication is clear.  We need much better monitoring of animal markets for pathogens.

The United States has no comprehensive strategy in place to address the threat of zoonotic disease. There are serious regulatory deficiencies across almost every animal industry. Large information gaps exist, and disease can seep between these cracks.

Lots to learn here and think about here.