Lots To Think About When It Comes To Recalling Lots
Jim Prevor’s Perishable Pundit, April 24, 2012
We often receive requests to think about issues in the news. This letter is an example:
Indeed, this is a pattern that we often see when there are test results positive for a pathogen — recall the whole lot to reassure the industry, regulators and consumers that steps have been taken to address any problem.
Alan is shrewdly drawing attention to the Achilles heel of this issue — do the lot numbers mean anything and, if so, what do they mean as far as food safety goes?
It is not a new issue. As far back as June, 17, 2008, we urged in this piece that lot sizes needed to be defined in such a way that they would be meaningful in terms of food safety — that is to say that there needed to be some action — a firewall, so to speak — such as sanitation by which a recall of just one lot would be meaningful.
Now most top processors are doing this, but there has not been success at getting industry consensus on this issue. We would consider it a significant hole yet to be plugged in the various food safety metrics and auditing standards.
One academic very involved in developing standards put the issue this way:
The absence of a consensus, of course, means that no standard is incorporated into popular industry audit programs. So only buyers who explore this issue really can be certain what their processor is doing. It is worth noting, of course, that although the issue typically arises in the context of processed product, the same question would bedevil any recall of bulk product run on any packing line or even cut in the field. What is the assurance that one lot is a meaningful dividing point in terms of food safety?
Industry leadership has been aware of the problem and United Fresh has long been working to find consensus. The initiative has been stewarded on staff by David Gombas, Ph.D., Senior Vice President Food Safety and Technology,and Barry Eisenberg, Ph.D., Vice President Food Safety Services at United Fresh, and they were kind enough to give us an update on the issue:
David’s search for what makes sense is completely appropriate. The problem here, though, is that the trade’s failure to come to a consensus is leaving the industry vulnerable to an accusation of doing PR stunts rather than meaningful food safety recalls.
Just imagine the outcry that would ensue if, one day, a company tries to do the “right thing,” recalls a complete lot and someone gets sick from the lot before or after the recalled lot and it turns out that the lot was defined for business purposes — not food safety purposes? Imagine how you would feel if you were the shipper or processor on that product and you had made the call to recall just the lot as a way of assuring consumers that the problem had been contained.
The truth is that even when a pathogen is found on a test, very often tests of other leaves in the SAME BAG come back negative.
Once in a while, of course, we have had serious and substantial food safety recalls that are motivated by many people getting sick. If, however, one removes those few incidents from the database, we are not aware of any research that indicates the product in the bag produced right before or right after the bag that is found to test positive is any more likely to test positive than any other bag ten lots away.
This means, of course, that no recall at all is actually justified by science. The recall is really, in the spirit of the famous Tylenol recall, a confidence-building measure. The size of the recall is a kind of split-the-difference number to avoid extraordinary expense and yet still be seen as doing something.
Of course, it is not clear that all this specificity actually means much anyway. As David Gombas points out, most of the product is typically long gone by the time such recalls are announced. Beyond this, though, many retailers ignore such detailed recalls and remove all of that product from the shelves, everything from that shipper, etc.
Partly they do this because most retail executives don’t trust their own systems and employees to get rid of specific lot numbers, partly because it is expensive to check each bag individually and, partly, because they have the luxury of billing back suppliers for the product the retailer removes from distribution.
When one is not paying for the recall, it is easier to opt for a more expansive recall.
Alan Siger’s comments about the other uses to which product from growers may have been put is less discussed but no less important. Maintaining these types of records is as much a part of traceability as anything else and, once again, the industry leaves itself vulnerable if we recall a lot of salad that includes Romaine but we don’t do anything regarding the rest of that farmer’s Romaine that was probably used in ten different products.
We discussed this issue in an interview with Michael McCartney, which you can read here.
Because the science here is so limited and so our ability to say that we have significantly reduced food safety risk through any of these actions is so weak, we have to view these lot-based recalls as sort of common-sense expression of reasonable action.
This means that if the trade’s policy toward this was on the front page of The New York Times — and it is reasonable to think that one day it will be — we want a policy that would be perceived as intellectually coherent.
Consumers have an interest in economical food, so simply taking a maximal position and saying that everything that can be recalled should be — damn the expense, full speed ahead — is probably not prudent. But if the question Alan Siger asked the Pundit was instead put to the California Leafy Greens Marketing Agreement or WGA or United or PMA — all of them should be able to offer a definition of what a lot means, be able to articulate standards by which the trade goes back to the grower lot and, in general, be upstanding, logical and straight-forward.
That probably means that United ought to get that White Paper done, which means the trade needs to make it a priority.
All these things are easy to set aside, but the whole point is to settle the issue before a crisis hits and before we have to explain things before Congress or the public.
Many thanks to Alan Siger of Consumers Produce in Pittsburgh for leading us to think through this important topic.