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SPECIAL EDITION — PISTACHIO RECALL HAS MORE QUESTIONS THAN ANSWERS

Kraft At Crux Of Pistachio Recall;
Hasn’t Fully Audited Supplier
In Almost Four Years

Jim Prevor’s Perishable Pundit, April 3, 2009

Kraft occupies an odd position in this pistachio matter. It didn’t grow or process the pistachios; it didn’t even receive them or, initially, test them. Yet its policies on food safety and contacting government agencies have really been the catalyst for the whole matter.

We asked Pundit Investigator and Special Projects Editor Mira Slott to find out more:

Adrienne Dimopoulos
Senior Manager, Corporate Affairs Operations,
Kraft Foods
Northfield, Illinois

Q: How did Kraft identify the source of the contamination to be pistachios from Setton Pistachio?

A: During the testing of ingredients, the external manufacturer, Georgia Nut Company, discovered there was a small potential for Salmonella in a batch of pistachios supplied by Setton. Georgia Nut informed us that a spot test revealed Salmonella. They notified Kraft and together we contacted FDA.

We’re proud of the comprehensive programs we have in place. Our quality control systems were effective in this instance.

Q: Did Kraft conduct its own independent testing to confirm these results?

A: We dispatched our own auditors out to Setton Pistachio. They were there for several days.

Q: What did Kraft learn during the audit?

A: We did our own observations and testing at Setton facilities… lots of environmental testing, ingredient and product testing. Auditors went over the entire facility to be sure food safety systems were in place. Kraft did a comprehensive audit.

Q: Did Kraft find Salmonella contamination in its testing at the Setton plant? Were you able to link the four Salmonella serotypes found during the Georgia Nut testing to the Setton facilities?

A: Georgia Nut Company discovered the Salmonella. I’m not sure what Kraft’s test results revealed. In their testing, Georgia Nut found Salmonella, called Kraft and then reached out to Setton, the supplier.

In my understanding of how product testing for pathogens works, you could have a whole batch of nuts and one little spot test comes back positive for Salmonella and the rest of the batch could be fine.

Q: How does Kraft know definitively that the contamination occurred at the Setton plant and not some time after it left the facility?

A: At Setton Pistachio, our auditors observed situations where raw and roasted pistachios were not properly segregated. This could explain the sporadic contamination. We saw raw and roasted product processed on the same line without proper sanitation in between the raw and the roasted products. It wasn’t up to what we would want them to do.

Then the FDA did their own investigation and also determined potential risk for contamination.

Q: If March was the first time samples from Setton product came back positive for Salmonella, why are products from months earlier being recalled? And why is FDA telling consumers not to eat any pistachios period?

A: Setton Pistachio is not the only supplier out there, and not every code date is affected. We wanted to move as quickly as possible to remove any potentially contaminated product from store shelves. We didn’t want to take any risks.

Q: Does Kraft conduct routine audits of its suppliers? Why wasn’t Setton Pistachio operating up to Kraft’s food safety standards?

A: We regularly do audits and conduct testing. We do audit our manufacturers and their suppliers. We share with them what processes we would like them to implement in their plants.

Q: So to clarify, Kraft did do audits of the Setton plant before this most recent visit?

A: We conducted a full audit of the Setton plant in December 2005, and visited the plant in December 2008 for a technical audit.

It’s important to know an inspection is a one-point-in-time event. What becomes critical is consistent food safety processes in place during the manufacturing at all times.

Audits do not guarantee food safety. What makes it safer is larger protocols in place and comprehensive checks to insure the food safety system is working. We’ll be evaluating frequency of audits.

We have an audit program to verify compliance. We require an external manufacturer to have a food safety plan in place; none is perfect, but when we have a situation like this we review it and learn how we can do it better.

Q: Did Setton Pistachio supply raw or roasted product to Georgia Nut Company? In what form did it arrive?

A: Setton supplied bulk roasted shelled pistachios processed and ready to go into products Georgia Nut Company manufactures.

Q: Is Kraft working with Setton Pistachio to address the problems?

A: Setton Pistachio is very committed to resolving this, and is a very solidly managed company. They’re not by any means trying to shirk any of their role in this. They want to get this right.

There is always a temptation to clam up at a time like this. So we appreciate very much that Adrienne Dimopoulos and Kraft Foods are trying to provide some needed transparency in this very murky subject. We note eight key points from the discussion:

1) “We’re proud of the comprehensive programs we have in place. Our quality control systems were effective in this instance.”

Actually we are not really sure about that. So a test found one little spot of
Salmonella — does that show a testing program is effective or that it just got “lucky” and hit a spot. Presumably if we tested every pistachio nut every day, we would find pathogens every now and then — maybe every hour. Is the testing program frequent enough to be statistically valid? If not, is “effective” the right word for such a chance discovery?

2) “I’m not sure what Kraft’s test results revealed.”

If Kraft’s tests had shown positive results, it would have told the FDA, which would have included that in its statement. It is a safe bet that, so far, at least, no other confirmations have been found.

3) “In my understanding of how product testing for pathogens works, you could have a whole batch of nuts and one little spot test comes back positive for Salmonella and the rest of the batch could be fine.”

We did a very thorough interview with Dr. Mansour Samadpour, an advocate for finished product testing. Much of it went to discussion of whether the testing was being done enough to be statistically meaningful. If, as Ms. Dimopoulos explains, one tiny spot on one pistachio could be positive while the thousands of pistachios surrounding that one are fine, how is it plausible that anyone is doing enough testing to get meaningful results? And if the results are not meaningful, isn’t shutting down an industry a ridiculous overreaction?

4) “At Setton Pistachio, our auditors observed situations where raw and roasted pistachios were not properly segregated. This could explain the sporadic contamination. We saw raw and roasted product processed on the same line without proper sanitation in between the raw and the roasted products. It wasn’t up to what we would want them to do.

Then the FDA did their own investigation and also determined potential risk for contamination.”

This is a little unfair. Finding a plausible route for contamination is neither proof nor evidence that the contamination occurred that way. Perhaps it “could explain” something but it doesn’t preclude alternative explanations.

5) “Setton Pistachio is not the only supplier out there, and not every code date is affected. We wanted to move as quickly as possible to remove any potentially contaminated product from store shelves. We didn’t want to take any risks.”

Kraft is not responsible for the decisions of the FDA. But the FDA did not simply choose to pressure this one supplier for a recall; it decided to issue a recommendation not to consume. It intentionally did not choose to exonerate states such as Arizona and New Mexico — as it did with tomatoes in the Salmonella Saintpaul outbreak this summer.

It also didn’t distinguish between processed products, where consumers might have trouble identifying the source of the pistachios, and jars or bags of pistachios that are easy to identify.

Finally it is treating a finding by one producer as statistically meaningful, when it is not.

We also question the FDA’s reliance on a private company in this matter. Who is to say that a private citizen with a grudge couldn’t one day implicate a person or company with the goal of ruining the company or a whole industry?

6) “We conducted a full audit of the Setton plant in December 2005, and visited the plant in December 2008 for a technical audit.”

Gadzooks! 2005 for the last full audit?? Even the companies that have great reputations for food safety, such as Kraft, really don’t do the job. Three-plus years is an eternity in the life of a factory.

7) “It’s important to know an inspection is a one-point-in-time event. What becomes critical is consistent food safety processes in place during the manufacturing at all times.

Audits do not guarantee food safety. What makes it safer is larger protocols in place and comprehensive checks to insure the food safety system is working. We’ll be evaluating frequency of audits.”

Bottom line: If one wants “consistent food safety processes in place during…all times” and “larger protocols in place and comprehensive checks,” one probably needs a comprehensive audit more frequently than every three years — and who knows when Kraft would have come back were it not for this situation.

We thank Adrienne Dimopoulos and Kraft Foods for helping the trade to understand better what really has happened in this pistachio situation.

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