Do food producers have any idea what goes in their products? Traceability, another fairytale

For all the food companies that brag about traceability, why does it take so long to figure out that your suppliers are in a recall and maybe you should be too?

HT_betty_crocker_recall_as_160712_12x5_1600The lingering, lasting recalls involving products that contain E. coli O121- tainted wheat from General Mills, Listeria-tainted frozen produce from CRF Frozen Foods in Pasco, Wash, and Listeria-tainted sunflower kernels from SunOpta, pile up daily.

Yesterday, the girlfriend of my much younger youth, Betty Crocker, recalled cake mix in Canada because it possibly contained E. coli flour from General Mills.

But how could I not lick her spoon, or sample her beater, as a child or an adult?

Randy Shore of the Vancouver Sun asked me those questions the other night during a conversation about risk, cookie dough and preaching.

I said I don’t preach, I provide information, people can do what they like, but it really sucks if your kid gets a Shiga-toxin producing E. coli like O121 because it’s a serious illness, often with lifelong consequences.

And it’s a scam that for all the prowess and profits of these companies, from Betty, to Golden Dipt brand Jalapeño Breader, to Planters Sunflower Kernels, they can’t figure out who is supplying their shit ingredients.

Markets/local/sustainable/whatever adjective are no better.

It’s food fraud.

Rick Holley, a professor emeritus of food safety at the University of Manitoba in Winnipeg (that’s in Canada) told CBC News that eating foods that aren’t well cooked is sorta like the risks people take when they jaywalk and don’t cross the street at a traffic light or stop sign.

“We know only too well that there are folks who like to eat food that’s not well cooked or isn’t cooked and against the best advice, because the food we eat is not sterile — there are risks associated with it. Having said that, I enjoy my salad in the summer time. Uncooked.

“Where we need also to do some work is on maintaining and improving the levels of sanitation in all parts of the food system, food processing plants. We know from investigations that have been done both in Canada and the United States that when there are lapses in sanitation, problems occur in food processing plants. We can see it now happening in mills.”

UCM511108According to Shore at the Vancouver Sun, the U.S. Food and Drug Administration has warned people not to eat raw cookie dough, effectively killing the fun of making cookies.

1.) How serious is the cookie dough threat?

In 2009, at least 71 people in 31 states were sickened by Nestle Tollhouse cookie dough contaminated with E. coli O157: H7. While nobody died, 11 people suffered serious complications. Nestle now uses heat-treated flour.

2.) What about homemade cookie dough?

The flour you use at home to make cookies has likely not been treated to kill salmonella and E.coli, so it should not be eaten raw. Irradiation is used to control insects in flour, not bacteria, so don’t depend on it for food safety.

3.) What about cookie dough ice cream?

Cookie dough ice cream is a guilty pleasure, but you can eat it without risk. Ben & Jerry’s cookie dough is made with pasteurized eggs and heat-treated flour. Most manufacturers, including Dreyer’s and Haagen-Dazs, use similar methods. 

4.) What will happen to me?

According to the Canadian Food Inspection Agency, rainbow bits contaminated with E. coli O121 may not look or smell spoiled but can still make you sick. Symptoms can include nausea, vomiting, mild to severe abdominal cramps and watery to bloody diarrhea. In severe cases of illness, people may die.

5.) Should I panic?

While the CFIA is so far silent on the issue, the FDA warns that you should not eat or allow your children to play with raw flour products, including homemade PlayDoh. If you make cake, cookies or pancakes, don’t lick the beaters.

Julia Calderone of Consumer Reports lists her own five ways you could get an E. coli infection from flour.

They’re not that surprising to microbiology-types.

Be the bug. Follow the bug (especially animal poop).

Since December 2015, 42 people across 21 states have developed an E. coli infection after eating uncooked flour. The outbreak is caused by a potentially dangerous strain of E. coli called O121.

Like E. coli O157, which has been responsible for food poisoning outbreaks from undercooked ground beef, O121 is a toxin-producing bacteria that may cause abdominal cramps, bloody diarrhea, and possibly life-threatening kidney damage. Fortunately, so far no one who has become ill from flour or flour-based products has developed kidney damage or died, but 11 people have been hospitalized. 

Products produced at a General Mills plant in Kansas City, Missouri, in November 2015 are the culprits behind these cases of E. coli infection. The company voluntarily recalled 10 million pounds of possibly contaminated flour, including their Gold Medal, Signature Kitchens, and Gold Medal Wondra flour brands. Several cake and pancake mixes that may have used General Mills flour have also been recalled.

The U.S. Food and Drug Administration and the Centers for Disease Control and Prevention are currently investigating these cases of E. coli infection, and are advising consumers not to eat flour and flour-containing foods that have not been cooked or baked. Consuming raw flour is a potential hazard, says the FDA, since it isn’t meant to be a ready-to-eat product.

Some of the ways you could ingest uncooked flour may not be so obvious. Here are five sources of potentially tainted flour that you should watch out for if you want to prevent a possible associated E. coli infection. 

  1. Raw doughs and batters.Of course, cookie doughs, pizza doughs, and cake and pancake batters are risky, so you should be careful not to accidentally or intentionally eat them before they’re cooked.

But raw dough can also make you sick even if you don’t intend to eat it. For example, kneading bread dough often leaves you with floury hands. Some restaurants give children balls of uncooked dough to play with, and they could stick either the tainted ball or their contaminated fingers into their mouth. Even storing uncooked dough next to other foods could cause a problem, so be sure to handle and stash it carefully.

  1. Arts and crafts materials.Websites devoted to pantry-based projects offer recipes for modeling clays, play doughs, spray glue, paper mache, and ornaments with flour as the main ingredient. For now, avoid making these mixtures with kids, and be sure to wash your hands and work surfaces thoroughly afterward if you decide to work with them.
  2. No-cook dishes.Some flour-containing recipes for truffles, icing, and even cookies don’t involve heating or baking. So if the recipe doesn’t call for the dish to be thoroughly cooked, skip it.
  3. Contaminated cooking and eating surfaces.Flour is light and powdery, and can easily fly everywhere in your kitchen if you aren’t careful. Even miniscule amounts of tainted flour can make you sick, so be sure that foods that will be eaten raw don’t come into contact with flour-dusted counters, cutting boards, plates, and the like. Wash these—as well as your hands—in hot soapy water after using them. Be careful if you’re dredging meat or chickenin flour before cooking, so the flour doesn’t go all over the place.
  4. Containers you use to store flour.When you purchase a new bag of flour, you might dump the new flourinto a flour bin or canister that has some old, recalled flour already in it, unwittingly contaminating your new stash. If you’re not sure if the flour you currently have has been recalled, throw it out. Make sure that you thoroughly clean your storage container before using it again.

An approach to evaluate and manage supply chain risk

Friends of ours were over for dinner last night and the matron is doing some sort of business education upgrade to prepare for the future.

Her research topic is supply-chain management within her firm, so I sent her this from David Acheson and Jennifer McEntire of The Acheson Group (TAG):

supply.chain.risks.oct.14In today’s food and beverage industry, everyone has a supply chain that they rely on. And with that comes risk.  You may be staking your brand reputation on the quality and safety of products or ingredients you are sourcing from somewhere that is not under your direct control. In short, you are relying on someone else to do things right, and inheriting risk if they don’t. Congress recognized that sometimes you rely on suppliers to control risk, which puts supplier management into the bucket of a “preventive control” and thus part of the Food Safety Modernization Act

But the road doesn’t end at regulatory compliance. Food professionals often worry about their supply chain, so much that it provokes many sleepless nights for executive leaders.  Why? Because no matter how many suppliers you have, their operations are not under your direct control. Again, you rely on a third party to make regulatory and ethical decisions in relation to your product, and ultimately, your brand. You rely on them to do the right thing.  And let’s face it—sometimes people just don’t. That’s why The Acheson Group (TAG) has developed an approach that goes beyond a “one size fits all” practice of asking for a certificate of analysis (COA) and an audit report.  With those two boxes checked we feel good about our suppliers and can relax – right?  Wrong!

Clearly the extent of the risk to you from your supply chain is dependent on many factors, some of which directly relate to what you do with the ingredients or products once received.  For example, if you are making a cooked product, then you worry less about microbiological contaminants in your externally sourced ingredients being used in your cooked product.  However, depending upon the region from which they are sourced, you may need to be concerned about heavy metals in those same ingredients since the cooking step will do nothing to mitigate the risks from heavy metals or other chemical contaminants.

One is often faced with the question of how to manage complex supply chains in a way that does not break the bank.  Like most things related to food safety, the logical approach to controlling the supply chain is a risk-based approach.  In simple terms, this means asking yourself, “Which of my suppliers are ones that I consider to be high risk?”  Many in the food world do this type of mental exercise on a regular basis, but typically it is somewhat ad hoc, based on instinct, the result of a group brainstorm, and not fact-based, objective or consistent.  The reliance on “gut feel” doesn’t generally cut it when trying to secure the resources to manage that risk. And it’s not going to satisfy FDA either, which proposes that the evaluation of supplier risk (assessed through regulatory compliance, your history with them, and other factors) be documented when suppliers are controlling hazards – whether through the Preventive Controls rule or as part of Foreign Supplier Verification.

As you think about how to balance your resources with your risk, it becomes evident that the need for metrics to quantify supply chain risk is an effective approach.  One of the tactics we have taken at TAG is to incorporate this mindset through a logical extension of these challenges and develop an approach that analyzes supply chain risk from two dimensions. The first dimension is to determine the inherent risk of the product or the ingredient.  Clearly some products have more inherent risk than others. For example, leafy greens are generally considered to be a higher risk than a dry powder.  As a result, our approach has been to develop a series of questions, the answers to which each carry a score that then allows you to quantify the inherent risk of a given product or ingredient.  By going through this process with all the products you use, it is possible to then rank the products numerically by risk.

The second dimension to this process is to follow the same steps for each supplier.  Referring to the earlier example, a leafy green supplier may have implemented robust good agricultural practices and be ahead of the game in relation to on-farm risk control.  Another supplier of leafy greens may be adequate, but have a few areas in which there is opportunity for improvement. In this situation, while the inherent product risk is the same for the leafy greens product itself, the actions and controls put in place by different suppliers will lead to differing risks and consequences for the same product.  By again asking a series of customizable questions and placing scores on each answer, you can then rank supplier risk over a wide range of variables.  Much like the product-risk scoring explained earlier, you can then rank the suppliers numerically by risk.

The next part of this process is to match the product with the supplier by comparing the two ranked lists (product ranking and supplier ranking). By going through this process, it is possible to identify the high-risk products with the high-risk suppliers, thus identifying your greatest supply chain vulnerabilities.

This process will allow the application of objective, standardized, and consistent metrics to supply chain risk and rank product-supplier combinations in terms of high to low risk.  But, that is only the first step! Because critical questions have been assigned to both the product and the supplier, it is then appropriate to look at which questions drove the score high and thus develop a risk management strategy that is focused on fixing and mitigating the problem.   For example, if a supplier is scoring high due to the lack of a robust environmental control program or allergen control program, you can address that deficiency specifically with the supplier and thus reduce your risks. This tool allows you to capture not only the identity of the risk, but how to apply resources to eliminate the risk.

Despite all the benefits listed above, the overall value of this approach is to allow your firm to have a tangible, objective method to leverage metrics in driving the decision-making process. It will allow your company to defend why resources need to be directed to certain areas of supply chain risk control.   Another advantage of this approach is that it is possible over time to monitor improvement in risks through the overall reduction in scores.   However, even as overall risk scores drop, product-supplier combinations that reveal the highest risk when compared to the other groupings are still visible, allowing the firm to concentrate new efforts upon driving down risk even further.

In today’s cost-conscious environment, the more we can use technology to drive risk-based decisions, the better we will be able to manage those risks, and successfully!  It has been TAG’s experience that some of the most sophisticated, global food companies struggle more with supply chain risk uncertainties than any other challenge. Perhaps the driver of this worry is the fact that the supply chain is viewed as an “accepted” risk, or maybe because the system itself is so large and cumbersome it seems too difficult to control.  Our philosophy is to help companies understand how to get their arms around the challenge of supply chain risk and to make wise use of limited resources, and thus, we have developed this tool to achieve just that.

Irrespective of whether or not your brand is a household name, you have customers who rely on the safety of your product and expect good quality.  In real terms, when your suppliers let you down and you don’t catch the problem — or you do, but you don’t intervene — you may then be, in reality, not just letting your customers down but your company as well. Thus, managing supply chain risk is not only a forthcoming regulatory requirement, it’s what you need to do to protect your brand.


Cargill wins suit v. Greater Omaha Packing

A U.S. District Court jury in Omaha found for Cargill Meat Solutions Corp. in its lawsuit against Greater Omaha Packing Co. for supplying E. coli O157:H7-tainted beef, and awarded Cargill a $9 million judgment plus court costs, according to meat industry publications, quoting court documents.

e.coli.vaccine.beefCargill sued Greater Omaha in 2011, for supplying beef contaminated with E. coli O157:H7 that sickened dozens of people in 2007. 

After horse meat scandal, food producers test for kangaroo and dog

The horse meat crisis has led the world’s largest food manufacturer Nestle to test for the presence of meat such as kangaroo and dog, according to the head of food safety at the firm’s research centre Dr horse.meat.09John O’Brien.

As reported in the Irish Times, Dr O’Brien, a former head of the Food Safety Authority of Ireland, people working in food safety had now become molecular detectives. “Not only are we concerned with horse, we are also keeping an eye on kangaroo, dogs, goats and a few other species and asking questions. Could any of these find their way into the food chain? So we have probes for all of those.”

Starbucks didn’t know who supplied ham

Having pulled thousands of unsafe, spoiled ham sandwiches from its shelves on three occasions, Starbucks now claims its meat vendor owes nearly $5 million.

Levi Pulkkinen of Seattlepi.Com  writes that according to a recent lawsuit, Starbucks didn’t even know who was producing the offending ham until starbucks.ham.listeria.jul.13months after complaints began coming in from customers. As it turned out, the primary vendor had subcontracted out the coffee giant’s ham order.

At issue in the lawsuit filed earlier this month in U.S. District Court for Western Washington are ham sandwiches filled with spoiled meat bought from a vendor.

The lawsuit indicates Starbucks trashed only some of the sandwiches containing ham bought from the vendor. Sandwiches containing meat from the supplier continued to be sold at Starbucks stores for nearly two weeks after the company learned at least some of the ham purchased from Wellshire Farms Inc. was tainted.

A Starbucks spokesman declined to say when the company stopped selling all the sandwiches using the ham provided by Wellshire Farms.

Speaking Friday, spokesman Zak Hutson said that the ham used in the hot breakfast sandwiches – which were pulled from Starbucks shelves three times before Starbucks changed ham suppliers – was a different from the Wellshire-provided meat used chain’s cold sandwiches. The lawsuit indicates cold sandwiches using the Wellshire-sourced ham remained for sale for 11 days after Starbucks found “potentially harmful bacteria” on ham bought from the New Jersey pork products supplier.