Raw Milk Consumption A Risky Proposition – CDC

“Consumption of nonpasteurized dairy products cannot be considered safe under any circumstances.”

– US Centers for Disease Control and Prevention

Less than 1% of dairy products consumed in the USA is unpasteurized. Yet consumption of unpasteurized dairy products – mainly milk and cheese – accounted for 60% of dairy-associated disease outbreaks between 1993 and 2006, according to a report released today by the CDC.

The risk of illness linked specifically to drinking raw milk was even more glaring; 80% of fluid milk-related disease outbreaks were associated with unpasteurized milk.

Disease outbreaks traced to unpasteurized dairy products also were more likely to result in hospitalization (13% of victims hospitalized) versus those associated with pasteurized dairy products (1% hospitalization rate).

Campylobacter, one of the two most common causes of bacterial foodborne disease, was responsible for more than 54% of the outbreaks involving unpasteurized milk and cheese. Only 13% of the outbreaks associated with pasteurized dairy products involved Campylobacter.

Of the 4,413 confirmed dairy-product associated illnesses reported during the 1993-2006 period, 1,571 (~36%) were linked to unpasteurized milk and cheese consumption, even though less than 1% of milk drinkers who responded to a 2005-2006 survey reported that they usually consumed raw milk.

And legalizing the sale or distribution of raw milk is not the answer to improving its safety. States in which the sale and distribution of raw milk was permitted experienced higher rates of unpasteurized dairy product-associated disease than states where its distribution was illegal.

The risk of illness that is assumed – often unwittingly – by those who choose to drink unpasteurized milk is underscored by the recent 4-state outbreak of Campylobacter illnesses that were traced unequivocally to raw milk produced and supplied by The Family Cow dairy farm in Pennsylvania. Seventy-seven people were sickened in that outbreak at last report.

The final paragraph of the CDC report says it all:

“Our analysis shows that legal intrastate sale of nonpasteurized dairy products is associated with a higher risk for dairy-related outbreaks and implies that restricting sale of nonpasteurized dairy products reduces the risk for dairy-related outbreaks within that state. Pasteurization is the most reliable and feasible way to render dairy products safe for consumption. Although warning labels and signs or government-issued permits are prudent where the sale of nonpasteurized dairy products is legal, they have not been shown to be effective and, given the results of this analysis, do not seem to reduce the incidence of outbreaks involving nonpasteurized dairy products to the degree that pasteurization does. Whether certain types of warnings or more explicit health advisories might be more effective than others is unknown. Public health officials at all levels should continue to develop innovative methods to educate consumers and caregivers about the dangers associated with nonpasteurized dairy products. State officials should consider further restricting or prohibiting the sale or distribution of nonpasteurized dairy products within their states. Federal and state regulators should continue to enforce existing regulations to prevent distribution of nonpasteurized dairy products to consumers. Consumption of nonpasteurized dairy products cannot be considered safe under any circumstances.”

FDA and Stealth Recalls

Stealth – the act or characteristic of moving with extreme care and quietness, especially so as to avoid detection

– Collins English Dictionary – Complete and Unabridged © HarperCollins Publishers 1991, 1994, 1998, 2000, 2003

About 10 days ago, I complained about an unpublicized Class I recall, which was described in FDA’s Weekly Enforcement Report dated February 8, 2012. The recall involved 114 tons of cut leaf “curly” spinach from Tiro Tres Farms, Eagle Pass, TX. The offending spinach was recalled by the manufacturer after the product was found to be contaminated with E. coli O157:H7.

I received some comments – and some flak – about my article, so I decided to see whether this was a one-time incident or whether there have been other Class I recalls about which we consumers were never informed. The following recalls were gleaned from FDA Weekly Enforcement Reports dated on or after November 2, 2011.

Nicho Produce Co., Inc. (Edinburg, TX): A CUT ABOVE produce items. Thirty-three (33) different items, including shredded, cut, sliced, diced or cubed salad greens, vegetables and fruits, most of them packed in 5-lb bags. Products were recalled due to potential contamination with Listeria monocytogenes. This was an FDA-initiated Class I recall, announced by letters dated December 9th and 19th, 2011, and involved 9,829.5 “pieces” distributed in Texas.
River Ranch Fresh Foods LLC, (Salinas, CA): River Ranch and Hy-Vee bagged salads and coleslaw with Best if Used by date of 4 NOV 2011. Product was recalled after FDA found two environmental sub samples positive for Listeria monocytogenes. This was an FDA-initiated Class I recall that was subsequent to an earlier public recall of Farmers Market and Hy-Vee brands of bagged salads, also produced by River Ranch. This stealth recall involved 588 cases of bagged salads, which were distributed to Indiana, Iowa and Canada.
Rio Queen Citrus, Inc. (Mission, TX): TexRio Tomatoes, packed in 20-lb bulk boxes, imported from Mexico. Notification of the company-initiated Class I recall was by telephone on November 25, 2011. Two hundred forty-three (243) boxes were recalled because the tomatoes were potentially contaminated with Salmonella. Distributed to Texas and Missouri.
Four Seasons Produce, Inc. (Ephrata, PA): Farm Wey labeled cantaloupes, Lot #32773301 & 32773302, manufactured by Farm-Wey Produce, Inc. (Lakeland, FL). Four Seasons recalled 1,064 cases (15/case) on November 19th by email, telephone and fax after being informed by New York State that the melons were potentially contaminated with Salmonella. The recalled cantaloupes were distributed to New York, Pennsylvania, Puerto Rico and Bermuda.
Combs Produce, LP (Dallas, TX): Natures Harvest Grape Tomatoes, recalled by email on November 25, 2011 due to potential contamination with Salmonella. Approximately 400 cases were distributed to Oklahoma and Texas.
Supreme Protein (Manasquan, NJ): Supreme Protein Chocolate Caramel Cookie Crunch (0.71 oz/20g bars; Lot B11272A October 2012), manufactured by Belmont Confections Inc. (Youngstown, OH). The firm initiated a recall by email, letter and telephone on October 11, 2012 of 473 bars, because the product was potentially contaminated with Salmonella. The recalled bars were distributed nationwide.

These are just a few examples from less than 4 months’ worth of FDA Enforcement Reports. For brevity and simplicity, I limited myself to Class I microbiological hazards, and did not include undeclared allergens, foreign material contamination (i.e., metal, glass, etc) or undeclared/unapproved additives.

I was taken to task for my February 9th stealth recall ‘rant’ by Jim Prevor of the Perishable Pundit in his February 15th item “Food Safety, Recalls And Why Consumers Don’t Always Need Notification.” What were his gripes, and how do they stack up in light of what I have found?

Prevor theorized that the E. coli O157:H7-contaminated spinach was not destined for direct retail sale; therefore, he concluded, there was “…no need to notify consumers.”

But, USDA’s Food Safety and Inspection Service routinely publicizes recalls of products that are destined strictly for the institutional market. Why should FDA not do likewise?

Prevor also suggests that the recall was not publicized to avoid worrying or confusing consumers, who would not differentiate between the recalled (curly) spinach from Texas and the unaffected (flat leaf) baby spinach from California and Arizona. He concludes that avoiding a public announcement was the responsible path, to prevent crushing “countless farmers and processors”.

Sorry, Jim, but how does that justification extrapolate to the “Branded” products I’ve cited above – especially those that were sold in retail-sized packaging bearing lot number identification and/or expiration dates?

Finally, Prevor ends his article with the following statement:

One suspects that the decision to not announce recalls when the announcement would not enhance public health is motivated by the desire to protect another value: Maintaining viable farms, industries, jobs, etc.

Interesting. I always thought that the primary responsibility of FDA was to protect public health.

FDA relies on consumers and consumer advocates to help it carry out its broad mandate. The agency has no choice – it cannot afford to inspect more than a tiny fraction of food producers and processors in the USA. But, like it or not, the flip side of this dependency is the need to keep consumers informed. Naive consumers, or those who are ignorant of existing recalls, are more likely to become casualties than collaborators.

When President Obama took office, he promised “transparency” in his administration. I grant that the workings of FDA, USDA and other US agencies are more open than those in many – perhaps most – other countries. Nevertheless, the President’s promise raised the bar for FDA. At the very least, there should be a consistent – and transparent – policy guiding the agency’s decisions on when and how to release information about recalls. This is especially true for FDA-initiated recalls.

Speaking as a consumer, and as a food safety microbiologist with more than 30 years of experience – several of them with Canada’s food safety regulatory agency – I strongly believe that all Class I recalls should be posted promptly on the government’s food safety website.

Consumers deserve – and should demand – no less.

One Rotten Egg Spoils The Salads

On January 26th, Michael Foods alerted its customers in the food service sector to a Class I recall of three lot codes of Papetti’s Brand hard-cooked eggs (sold in 25-lb tubs; Lot codes 1362W, 1363W, and 1364W; Use by dates of February 11th, 12th and 13th), after product testing revealed possible contamination with Listeria monocytogenes.

The recalled eggs were supplied to foodservice distributors such as US Foods and Sysco. Even though the recall bore the highest risk classification (Class I) – and even though Michael Foods’ facility is under FDA jurisdiction – notice of the recall did not appear on the FDA Recalls, Market Withdrawals, & Safety Alerts web page. The public became aware of this recall on January 27th, when 18th Street Deli Inc recalled 118 pounds of Julienne salad products containing eggs that were included in the Michael Foods recall.

As has happened so often in recent years, the initial recall soon was expanded to include additional lot codes. On February 1st, Michael Foods announced the recall of hard-cooked eggs sold under six brand names (Columbia Valley Farms, GFS, Glenview Farms, Papetti’s, Silverbrook, and Wholesome Farms). The recall covered all 10- and 25-pound pails of hard-cooked eggs packed in brine bearing lot codes 1 LOT 1350W through 1 LOT 2025W (“1” refers to the production line impacted by the recall; “W” identifies the eggs as coming from the Wakefield, NE production plant), and expiration dates ranging from 1/30/201 to 3/10/2012.

The eggs covered in the expanded recall, according to Michael Foods, were supplied to food distributors and manufacturers located in 34 states (AL, AR, AZ, CA, CO, FL, GA, IA, IL, IN, KS, KY, LA, MI, MN, MO, MS, MT, NC, ND, NE, NJ, NV, OH, OK, OR, PA, SC, TN, TX, UT, WA, WI, and WV); none of the eggs were sold directly to retailers or consumers.

The company explained that the recall was expanded after “…a thorough investigation which indicated a specific repair project that took place in the packaging room as the likely source of the contamination.” In other words, once again, a company manufactured and has shipped a ready-to-eat product before ensuring that the production environment was microbiologically secure.

As a result of this “wing and a prayer” approach to food safety, several companies have been faced with initiating precautionary recalls. I certainly hope that Michael Foods’ liability insurer has deep enough pockets to cover the cost of all of these secondary recalls.

Most of the retail-level recalls triggered by the distribution of contaminated hard-cooked eggs affect ready-to-eat salads and sandwiches. I have posted a separate page listing the recalled items announced so far, including information on their retail distribution. I shall be updating the recall list as I learn of additional items.

If you have purchased a salad or sandwich mentioned in any of these recalls, please discard it or return it to the place of purchase for a refund. Listeria monocytogenes can be a deadly illness, especially for the elderly, the very young, people with reduced immunity and pregnant women. Do not take a chance with your health or with the health of your family members.