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Lessons From Carrot Recall: Los Angeles Salad Company Execs Share Their Experience

Jim Prevor’s Perishable Pundit, August 31, 2007

Our piece, Costco Recalls Mexican Grown, U.S. Packed Baby Carrots From Canadian Stores, was written as the Shigella outbreak was just being reported. In the confusion, we incorrectly stated that the carrots were grown in Mexico and packed in the U.S.

In fact, they were both grown and packed in Mexico.

To understand what happened and to see if there are broader industry lessons to be learned, we asked Pundit Investigator and Special Projects Editor Mira Slott to find out more:

Bob Hana
CEO
Los Angeles Salad Company
John Shaughnessy
Quality Assurance and
Food Safety Manager

Q: I’m so glad to finally be able to speak with you. I imagine you’ve been working overtime managing the initial and expanded recall and fielding hundreds of inquiries, as exemplified by you now taking the time to personally conduct this interview on a Saturday (Editor’s note, the first interview was conducted on Saturday, Aug. 25, 2007 and the last question was answered on August 30, 2007).

BOB: It is our pleasure. We appreciate you taking the time to dig into the story and give accurate information; to give us the opportunity to tell our side and not sensationalize the news.

What’s happened to date is that every local news channel, T.V. and radio station in southern California is basically telling a scare story, setting the stage for questions.

A news channel T.V. crew came to our company during this challenging time, demanding an interview and entrance to our facilities. They started opening bags of carrots and stepping on them, trying to incite a reaction, the whole time video taping. We wanted to put our focus on food safety, our customers, managing the recall, talking with the people on our hot line, and getting to the source of the problem.

Q: How and why did this recall happen?

BOB: I’d like to take you back to the beginning, Friday, August 17. In mid-afternoon we received a call from the Canadian Food Inspection Agency [CFIA]. They reported to us they believed that the carrots we sold in that marketplace had been linked to stomach illness. It got to their attention through the health authorities. Four people reported getting sick. All tested positive for Shigella, and all four had completely recovered. There were no hospitalizations, and the one thing they all had in common was they all purchased baby carrots distributed by our company at Costco.

It may be of interest that the people in Canada who reported some kind of incident said they did not microwave the product. (There are instructions on the package for microwaving, but consumers can also eat the product raw). In addition, there have been no reported illnesses in the U.S. and no additional illnesses in Canada.

JOHN: We then asked CFIA if they had any samples of products they had tested, and they said they had received for sure one sample from one consumer who was sick. They sent four samples to a lab, and three came back negative. One came back presumptive positive. The one that came back presumptive positive was sent for DNA testing.

We asked CFIA when that information would be available from the PRC testing. They told us the results of lab tests would probably be available mid-week or possibly earlier. Then we had more in-depth discussions on protocol, methodology, etc., and learned that the recall was based on a statistical profile.

BOB: The recall issued on that Friday did not come from our company. CFIA contacted Costco and urged them to perform a voluntary recall. We were informed during that time frame of all that was going down. We asked CFIA to please stay in touch with us. We wanted to be right there in the loop so we could properly address anything that might come up.

Our focus then shifted to how we identify the source of that contamination. What steps could be taken immediately. We wanted to understand as much as we could about where it came from, how and why the problem occurred and to guarantee it never happens again.

We’ve had a management crisis team in place for a good number of years made up of six members. There were only three of us there when this came to our attention. The other three were out of town or away on vacation. All the burden of dealing with this entire issue fell on basically three people.

Q: Did all product in question come from Mexico?

JOHN: Yes. Everything was grown and packed in Mexico. This facility [in Los Angeles] just played as box-in, box-out.

Q: Were you able to narrow the potential sources of the problem based on your procurement operations there?

BOB: We knew exactly where it came from, where it was grown, processed and packed. We’ve had for quite a number of years a full recall food safety program. We do mock recalls at least three times a year, and have a very solid traceback procedure in place.

We knew exactly what ranch, packaging facility, the date and time of harvest, the date it was shipped, when it arrived, a description of product temperatures, plus retention samples. We take retention samples at each step along the supply chain for every farm and every packing house, as well as in the distribution system.

Q: What do you do with these retention samples?

JOHN: A retention sample is a snapshot or reflection of all product produced on a particular day, a random sample of that lot indicative of the quality of that lot. We do random physical and analytical chemical testing based on statistics as a matter of course. We are doing precursor testing, and if the sample doesn’t pass one area, it goes on to another test, etc.

Q: What kinds of testing? At what point do you screen for pathogens such as E. coli, Salmonella and Shigella?

JOHN: We do TPC (Total Plate Count), coliform, E. coli… and we have the capability to test for Lysteria, Salmonella and further testing externally at a third-party lab. We also can do internal testing on E. coli H: 0157.

Q: When do you determine that’s necessary?

JOHN: We do that if there is a potential problem in our initial testing, for example, if TPC comes out of compliance. We do an initial screen, and if the product doesn’t pass, we test further. We’ve been doing this for many years.

Q: Have you considered the 12-hour rapid test as Costco is requiring on spinach and leafy greens and as Natural Selection Food is doing? Have you looked into a test-and-hold plan?

JOHN: We made a lot of changes after the California Leafy Greens Agreement, and even before that changed the scope of our food safety plan significantly. Currently we are using a 24-hour test, but we are definitely looking into more rapid test methods and considering a test-and-hold program.

BOB: We have an in-house, fully-staffed lab. We have eight technologists with a quality assurance manager, a sanitation manager and other food safety experts. John [Shaughnessy] is Vice President and Acting Board Member for the California Environmental Health Association (CEHA). He has a credential from the National Environmental Health Association (NEHA) and Certified Food Safety Professional (CFSP). An article in the Orange County Register a few months ago spoke of our strong food safety program. (Editor’s Note: See the article here.)

Q: In this case, your retention sample testing didn’t help you to catch the Shigella and pre-empt the problem. Why?

BOB: You must remember, from a statistical standpoint, this testing is like finding a needle in a haystack. We began on Friday preparing information. We contacted the ranch and asked them to begin a thorough investigation in the packing house. We immediately took the retention samples we had on the west coast and in our Miami distribution facility, and the retention samples in the packing house in Mexico.

We did testing on these similar lots and delivery dates in questions. This happened on the weekend. We checked on Monday but didn’t have results yet.

We continued to have discussions with CFIA. These were all verbal. There was no written communication. Also, it is extremely important to tell you we had contact with FDA. John can walk you through that conversation.

JOHN: I heard from Larry Howell at the FDA on Tuesday late afternoon. He informed me that the CFIA contacted them and said they had a positive result on their PCR test for Shigella. That was concurrent with the information being relayed by the California Department of Health.

BOB: FDA was asking us what our recourse would be at this time. We said we’ve been gathering all the information and people in our organization to determine the course of action we were going to take. We caucused and a decision was made to do a recall system-wide.

All reported illnesses came from two store warehouses in Calgary we were shipping. There were 14,652 units of 1.5 pound bags, in 50 to 60 stores. Costco, because of its membership card program, was able to isolate and inform those who purchased product very promptly.

On a positive note the people at Costco are the best. They were all over it. They were able to guarantee the safety of the food supply, and because of the systems in place, and the quality of the organization, they were very supportive and helpful to us in determining the scope of this.

We stayed in contact with all our customers. When we decided to issue the recall nationwide, that’s when we extended communication.

Another thing; up until now, I hadn’t had much dealing with the FDA, but I don’t know how they could have done a better job.

Q: Why and how did you decide to extend the recall? How do you trace forward and determine the recall’s limitations… Every customer who bought that item produced when? How did you divide the time on the production line? Just on one shift, one day, two days, a week… by when the plant was sanitized…?

JOHN: Based upon information CFIA generated, and by Costco, analyzing product code dates and roughly the times when consumers ingested product, we were able to conduct an investigation to determine the scope of the recall. There are many issues involved in the analysis. Sanitation in our plants is continually going on. For example, every time we run a certain commodity, our plant is washed down, or if an item runs for a specific period of time, the production line is re-sanitized.

BOB: Back to Tuesday and our decision to do that expanded recall… We contacted every customer that bought that item and gave specific information on the product in question. They knew before the press release came out that it was coming.

JOHN: We gave the press release to the AP as suggested by FDA. There was some miscommunication in the initial expanded recall release published Wednesday morning, and the FDA worked very closely with us to fix the errors, involving corrections in some of the regions affected.

BOB: When we made the decision to do the recall, we saw nothing in writing to confirm the problem. Everything was verbal with CFIA and FDA, which have a close relationship. It was based on the evidence at hand. Through FDA and CFIA, we followed the lines of the recall; what products would have been produced during that time through that facility. In our statement to our customers, we shared details.

BOB: We have over 12,000 people involved in our business endeavor between South America, Mexico and U.S. farming, harvesting, packing, and distribution. Our suspicion is that this Shigella problem is going to be traced back to one person. It’s incumbent upon us to find that source.

This is a responsibility we take very seriously with all our operations in constantly sharing information, managing and updating quality assurance and food safety programs. Every time we see an incident in our industry, our heart goes out to those who are hurt.

Food safety is the cornerstone of our business. I’ve been at Los Angeles Salad Company since 1992, when it was owned by a public company. I bought the business in 1999. I’ve always preached that the most important thing is the safety of our product and people. That’s our philosophy whenever we are packing or shipping products. We are committed to have quality and safety practices in place to prevent food safety problems.

We have to be vigilant to protect the food supply. It’s not just about being in compliance. That’s the smallest part. Food safety programs must continue to evolve. There has to be a heartfelt commitment.

I have every confidence in the food safety throughout most of Mexico, and in particular the companies we deal with. Right now we have no reports of any illnesses with the expanded voluntary recalls. We’ve received 300 to 400 calls from concerned consumers, but none of these people have been sick. Fortunately, no one has been seriously injured.

This has been an intense and trying week. We couldn’t be more proud of our food safety team, and the countless others who came through in this crunch time.

Q: What have you learned? Are you implementing any additional food safety steps and, if so, what are they?

BOB: We are increasing environmental testing in all our plants, the frequency and intensity. On the processing and packing side, we are putting people on full alert and stepping up food safety measures. Our presence in all our various packing houses has increased. We’re routinely in those, more than once a week, but we’re going to have even more inspections.

Q: Do you have third-party certification such as ISO 9000 or EurepGAP? Do you work with third-party auditors to verify food safety programs?

JOHN: I’m not a big fan of some of these certifications. A certification on the wall doesn’t mean a lot if it is not that thorough. Our customers do not require us to have certificates. We do high level food safety audits, based on rigorous HACCP standards and curriculum on critical control points, prerequisite programs that support the core food safety principles of the produce industry.

BOB: Los Angeles Salad Company schedules three third-party food safety and quality systems audits per year. These audits are conducted by NSF Cook & Thurber and Primus Labs. The most recent audit was conducted on July 30, 2007, by NSF Cook & Thurber. The audit resulted in a score of 96 percent.

Baja Mexico also schedules third-party food safety and quality systems audits. These audits are conducted by Primus Labs on an annual basis. The most recent audit was conducted on August 22 and August 23, 2007 by Primus Labs. The audit resulted in a score of 92 percent.

In addition, there are numerous second-party audits conducted by our customers at our facility in City of Industry and in Baja Mexico.

Q: If the Los Angeles facility requires three audits a year, what is it about the Mexico facility that makes it only require one?

JOHN: I know that is definitely going to change. We will be increasing the frequency of our required audits in Mexico. They also have vendor audits.

Q: Why are you sourcing carrots from Mexico at this time of year?

BOB: These carrots are a special variety that we have been getting from our suppliers for a number of years. They are grown in a great spot, which allows for the carrots to grow year round.

Q: What were the results of your further testing, following the one CFIA sample that came back positive? Have there been any more positives?

JOHN: All our testing came back negative. There were no positives. Our investigation, however, is still ongoing.

Q: Has Los Angeles Salad Company been involved in other food safety recalls previously?

BOB: No. This is the first and only time. Our company has been in operation continuously since the late 1930’s, and there has never been a single incident or recall.

We appreciate that both Bob and John took the time to explain what happened to the industry. Going through a recall is always a trauma, and the temptation is always there to hunker down and hope it all goes away.

Yet the industry can only do better if we learn from what happened, which means we have to understand what happened. So Bob and John do a service by being willing to speak out.

It is all fine to run drills and simulations and have plans; if they are played out in real time few of us would perform perfectly. So analysis should not be construed as criticism. Let’s see what in this story holds some lessons for the broader industry:

  1. The industry is filled with crisis management plans. Yet, in this case the plan was designed with the expectation that six executives would take part, yet three were out of town or on vacation in what normally would be a slow summer week — so that left three to handle the crisis. There are a couple lessons here: First, staffing is part of a crisis management plan. Procedures for travel planning and vacation schedules need to be part of every plan. Second, the crisis management plan needs a fallback position. What if it was a real crisis, such as an earthquake and people couldn’t be located, who is the understudy? What happens? Answering these questions in calm times is what putting a crisis management plan together is all about.
  2. Costco’s membership card program allows it to quickly notify consumers of a food safety problem. How can any retailer offer its customers less? It could be a matter of life and death. At least offering a traceability card (membership, loyalty, etc.) and explaining to consumers its purpose should probably be mandatory.
  3. Although it is reassuring that the company’s executives have “…every confidence in the food safety throughout most of Mexico, and in particular the companies we deal with…” we wonder if buyers are giving imported food the careful consideration that consumers will probably expect after the China revelations. This product was recalled from Costco, several Kroger divisions and Publix. Plus Trader Joe’s. Did all of these organizations make the decision that the Mexican product was equal or better when it came to food safety than the product put out by Bolthouse or Grimmway? We don’t know, but it strikes us as the exact question that is worth asking because it gets to whether food safety is top-of-mind with procurement executives.
  4. The strongest argument for certifications such as British Retail Consortium, EurepGAP, ISO 9000 and whatnot is that they express publicly to what standard one is being inspected. Simply saying that our plant has a third-party auditor is not going to build public and regulatory confidence because it is not a public declaration of the standards to which one holds one’s organization.
  5. As if to prove the danger of not having a publicly proclaimed standard, we are told that while the Los Angeles facility has three third-party audits each year, the Mexican facility has only one. The good news is that Bob Hana says that this will change immediately. The bad news is that the industry has equally arbitrary auditing standards all over the country and around the world. Once again, we wonder what questions the buyers were asking? Although some do their own second-party audits, one would think they should set up to look for an anomaly such as this.

Los Angeles Salad is a serious company, with a serious food safety program. Nothing we mention may have had anything to do with the problem. Occasional Salmonella positives may just be a fact of life under the most rigorous food safety programs.

Yet, we can always do better. Although the promise to increase testing and other efforts are valued, we see a few key points:

  1. Uniform standards on US and foreign plants. If they audit three times a year here, it should be three times a year on foreign operations.
  2. Publicly recognized standards to build confidence. Those carrot growers should be required to get EurepGAP or other recognized certifications, and the plants should get BRC or other recognized certifications. One can always exceed these standards, but consumer and regulatory confidence depends on a recognized standard.
  3. Retailers need loyalty cards or other similar cards to help recall effectively on food.
  4. Crisis management plans need to include staffing plans.

These guys had a problem and it is easy to be critical. Our impression, though, is that very few companies are in a position to say it couldn’t happen to me. So we need to focus on learning, not blaming.

Many thanks to Bob Hana, John Shaughnessy and the Los Angeles Salad Company for helping us all to better understand the challenges of food safety.

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