November, 2006

Fruits of Thought

Food Safety Action Plans

As it is said that generals are always preparing to fight the last war, we need to be careful about an overemphasis on the specifics of the spinach/E. coli situation. The next food safety crisis might involve scallions, melons, tomatoes or some other product. It might have nothing to do with California. It might be foodservice product or retail. It might be caused by a growing operation, or a packing operation, or a processor or mishandling later in the chain. It might not involve food safety as much as bio-security. It is unpredictable.

There will be more outbreaks. The technology of matching sick people to what they ate and then matching a specific strain across the whole country is advancing so quickly that even as the food supply gets safer, we will probably still have more outbreaks.

We need to look for lessons learned from this crisis that can help individual companies and the industry as a whole avoid future crises and, just as important, minimize their impact when they do occur. Here are some suggestions:

1. Know primary and secondary suppliers

The long list of brands packed at Natural Selection Foods points out that the corporate vendor is not always the point. The key is knowing the actual source of the product you are buying. You want primary and secondary vendors that actually process and pack in different places. Otherwise, you are not getting the diversification of risk a buyer is looking for. You also need to maintain this status during the business relationship. This means vendors have to be on notice that they must inform buyers if they switch processing facilities.

2. Segregate product categories

The FDA knew that the problem was confined to bagged spinach. Yet, the FDA advised not to eat any spinach based on its understanding that retailers were opening bags of spinach to sell as loose.

We now know product usage channels need to be as narrow as possible. A foodservice pack of spinach can be ordered specifically for the salad bar. Vendors should sell bagged products with lines on the packaging prohibiting its sale as a bulk item, and retailers should adopt a policy of not using retail product for salad bars and foodservice operations.

3. Labels must be accurate

It is common practice to print broad labels that say things such as “May contain spinach, arugula, etc.” or “May contain products from France, Canada, Germany, etc.” As a result, many bags of spring mix and other blends that didn’t even contain spinach were destroyed.

Now that we see the price that can be paid on the occasion of a food safety outbreak for such a practice, we need to stop it. Labels should be accurate, not overly broad.

4. Trace-back needs improvement

The fact that the FDA was looking at nine ranches and then narrowed it to four is unacceptable. They should be able to pick up a bag and with only the bar code, a processor should know the exact field the product came from. If it is a blend, the processor should know which field each constituent of the blend came from.

5. We need a track-forward mechanism

We have thought of trace-back in terms of having some bad product in hand and then tracking back to processor and farmer.

This outbreak taught us of the need for a track-forward system. If we know a farm or processor had problems on a certain day or week, we need to know, instantly, where that product is now.

If dealing with processed product, we need to know the brands this might have been packed into.

In this spinach crisis, we had recalls dribbling in since processors as far away from Salinas as New Jersey had purchased bulk product from Natural Selection Foods and then repacked it in their own labels.

Processors around the country were waiting for the FDA to show up with a report that someone ate their brand of spinach, and then they recalled. If we knew a terrorist had poisoned every leaf shipped by a processor on one particular day, we would need to know every label and brand that product is under and we would need that information within five minutes.

6. We have to stop the consumption of products past best-if-used-by dates

If all the people who the CDC says got sick from eating spinach actually did so, then a number of people were eating spinach past its “Best-If-Used-By” dates. We have had the technology for years to turn a label a different color if the cumulative exposure to temperature exceeds a pre-established limit. We also can put Best-If-Sold-By in addition to Best-If-Used-By dates on products. Retailers have resisted these methods because they don’t want to eat the shrink. High time those objections get overridden.

7. Store-level communication must be improved

Retail produce departments and restaurants both had incorrect signage and incorrectly informed employees saying all kinds of wrong things during the crisis and to the present day. We need a better action plan to make sure in-store signage, employee training and reference sources are always up to snuff.

8. HACCP plans must be certified

The core of industry food safety efforts are HACCP plans. In many cases, these are just photocopies of other people’s documents. It is not sufficient just to have a HACCP plan. These need to be certified by people of proper education and training.

9. The produce industry needs to look at its institutions

Does the dual PMA/United representation best serve the industry during such a crisis or would be better served to have only one national association?  pb