public that there was “little likelihood of illness.” The USDA had video evidence that
occasionally a postinspection cow would become nonambulatory and lie down (called
“downer cattle”) before entering the slaughterhouse of meat processor Hallmark/West-land. In these situations, the cow is supposed to receive another inspection before
being slaughtered. Instead, Hallmark workers used forklifts and prods to force downer
cattle into the slaughterhouse. Even though there were no reported illnesses as a result,
the federal agencies became concerned that downer cattle could have a brain disease
called bovine spongiform encephalitis (BSE), or “mad cow disease.” An outbreak of
BSE in the United Kingdom a few years ago led to a massive herd culling and several
human deaths.
Although there has never been an outbreak of BSE in America, the USDA demanded that Hallmark recall all meat products produced from 2006 to 2008. While
the 143 million pounds recalled is a massive quantity of beef, that number didn’t include hundreds of products, such as pizza or tacos, that contained beef from Hallmark. The recall forced Hallmark out of business almost immediately, and many of
the company’s customers suffered millions
of dollars in losses. This raises questions
about the necessity and scope of this recall.
If the recall was indeed justified, the federal
agencies involved shared almost no information with the industry to support their
actions.
“The current system
has established
three classes of recalls
Food Allergens and Other
“Special” Circumstances
Scientists estimate that approximately
12 million, or about 4 percent, of Americans suffer from food allergies, mostly to
the “big eight” allergens: milk, eggs, wheat,
soy, nuts, peanuts, fish and shellfish. Allergic reactions range from short-term, mild discomfort to life-threatening anaphylactic
shock. Failure to list a “big eight” allergen on a food label requires a recall of the
product. Obviously, mistakes in listing allergens should be corrected, but is an all-encompassing food recall of every product the best approach? Rather than this one-size-fits-all approach, each situation should be evaluated independently to determine
next steps.
A total recall is also mandated for products with unlabeled, nonallergenic ingredients. Recently, a supplier inadvertently added an ingredient to their products that contained monosodium glutamate (MSG). The USDA learned about the MSG several
months later and forced the company to recall all products in the marketplace, resulting in millions of dollars in losses.
Administrative recalls, which involve a failure to obey a rule that does not pertain
to food safety, can also be costly and challenging for companies. One administrative
recall last year was mandated after the company was found to have “failed to comply
with its Hazard Analysis and Critical Control Points (HACCP) plan.” In this case, that
meant the company failed to sign a form listing steps being taken to control Listeria.
There was no Listeria in the product and there were no illnesses, but all product was
recalled because of a missing signature. Clearly, HACCP planning and compliance is
necessary, but should an administrative error require the expense of a recall in every
instance?
that define
three levels of risk.”
additional reports to recall products that
contained the contaminated ingredient.
As many in the food industry know,
more than half of product recalls are
market withdrawals because of quality is-
sues unrelated to food safety. Unfortu-
nately, most of the remaining are Class I
recalls, although many are not always
found to fit the definition of “reasonably
likely to cause illness.”
This blurring of distinctions between
Class I, II and III recalls often creates
fear among the public, which increas-
ingly believes every recall is life-threaten-
ing and may unjustly conclude that the
nation’s food supply is unsafe.
Recall notices posted on government
and supplier websites often contain a
statement similar to the following:
“While no one has reported illness, and
we believe the food is safe, we are recalling this product in an abundance of caution.” This “abundance of caution” often
ignores the Class I, II and III FDA standards for recalls and can cost American
companies and consumers hundreds of
millions of dollars annually. 2 The growing number of product recalls, and subsequent media coverage, has also had a
numbing, “boy who cried wolf” effect on
the public, making it difficult for individuals to know when to take a recall
seriously.
The industry and public would benefit from a set of science-based rules to
guide the food industry in better determining and defining the circumstances
that should lead to product recalls. Fortunately, the industry is taking steps in
this direction.
Growing Number of Recalls
The first annual FDA report on the Reportable Food Registry cites at least 200
Class I recalls from September 8, 2009, to September 7, 2010. That number grows significantly when including secondary or ingredient-related recalls. For example, the report lists an account of Salmonella in hydrolyzed vegetable protein that led to 1,001
Conference for Food
Protection (CFP)
In 2010, I submitted a proposal to the
CFP, an organization of federal, state
and local regulators, academia and food
industry representatives, to form a Recall
Evaluation Committee to evaluate the
current recall definitions and system.
That proposal was accepted and more
than 50 CFP members have volunteered
for the committee to achieve the follow-
ing goals:
• Develop a classification system for
food recalls that can be adopted by
