Some Tips For The Tea Party

I’ve been challenged to find some policy planks for the Tea Party that would reduce the cost of federal food safety enforcement without putting the public at (greater) risk.

Here are a few thoughts, drawn from more than three decades of working in food safety.

Consolidate the food safety enforcement arms of FDA and USDA (Food Safety and Inspection Service). This would eliminate duplication of overlapping lab facilities and inspection programs. As a bonus, food companies now dealing with two separate federal agencies would only need to deal with one.

Require every shipment of imported ingredient, raw food or processed food to be accompanied by a Certificate of Analysis from an accredited laboratory. The cost would be paid for in toto by the off-shore producer and/or the importer – NOT by the US government. Domestic food processors must pay for their own lab tests. So should importers.

Eliminate the 100% inspection of federal meat plants. These resources can be spread more evenly throughout the newly consolidated agency, and increase overall food safety enforcement without increasing costs.

Eliminate HACCP mandates for the food industry. Motorists are told what speed limit they must observe – NOT how to observe it. Likewise, food producers and processors should be told what food safety standards they are expected to achieve. How they achieve these standards should be left to each individual company. As long as the standards are met, the way in which they are achieved should be irrelevant.

Privatize non-safety activities, such as USDA’s egg grading service. Last year’s shell egg-related outbreak of Salmonella Enteritidis demonstrated all too clearly that this is not looked upon by USDA as a safety function. Producers should be responsible for arranging – and paying for – activities such as shell egg grading.

I’m sure that there are more good ideas floating around in the blogosphere. I welcome your comments and rebuttals, and will be happy to post alternative suggestions.

Doing Away With Food Safety Enforcement – A Modest Proposal

I’ve just figured out how to cut nearly 1.3 BILLION DOLLARS A YEAR from the US budget deficit.

All we have to do is to close down USDA’s Food Safety and Inspection Service and FDA’s Food Safety activities (including the Center for Food Safety and Applied Nutrition) and let the food industry take care of itself.

Just think. No more on-site inspectors in meat and poultry plants. No expensive government lab facilities with their high-priced staff. No mandatory HACCP. No mandated recalls. No bureaucratic nonsense about registering food facilities.

And no penny-ante fines and penalties for transgressions of food safety laws. Let the courts and the personal injury lawyers have their fun.

What’s the worst that could happen? After all, aren’t most companies ethical, and wouldn’t they bend over backwards to maintain their reputations?

So, there’d be an occasional lethal outbreak of Salmonella due to contaminated meat or poultry.

So, there’d be the odd outbreak of E. coli O157:H7 because of contaminated lettuce or melons.

So, every now and then, a company would knowingly ship Salmonella-contaminated food to its customers.

So, our raw poultry would have a 1:5 chance of being contaminated with Salmonella and would be guaranteed to contain Campylobacter.

So, a consumer couldn’t tell where a raw shell egg was produced or packaged simply by looking at the egg.

So, what’s the big deal?

Would we be any worse off than we are under the present system?

Kellogg Struggles With Listeria

The Kellogg Company is struggling with the “…presence of a persistent strain of L. monocytogenes…” in its Augusta, Georgia manufacturing facility, according to a warning letter released today by FDA.

Kellogg inherited the cookie manufacturing facility when it acquired Keebler in 2001. The company manufactures several brands and varieties of cookies at the facility, including Pecan Sandies, Chips Deluxe, Famous Amos, Pecan Swirls, Cinnamon Swirls, and Lemon and Raspberry Sandies. In 2009, Kellogg expanded the facility, adding Girl Scout cookies, Kashi, and a new Keebler cookie to the product mix.

In January 2010, FDA inspected the Augusta production facility and found Listeria monocytogenes in environmental swab samples collected during the inspection. More than one year later – in February 2011 – the identical strain of Listeria monocytogenes was still present in the manufacturing plant.

FDA found L. monocytogenes in fifteen environmental samples taken during the 2011 inspection. Seven of the positive samples were from direct food contact surfaces. While FDA acknowledges that the finished products may not support growth of L. monocytogenes, the presence of this persistent pathogen is a clear signal that the company’s cleaning and sanitation program is inadequate. According to the warning letter,

“The presence of a persistent strain of L. monocytogenes in your facility between January 2010 and February 2011 is significant in that it demonstrates that your cleaning and sanitation efforts were inadequate to remove this organism. We note that although your finished product cookies may not support the growth of L. monocytogenes, the positive environmental swabs are indicators of insanitary conditions in your facility and demonstrate a failure of cleaning and sanitation operations that may allow for contamination of foods with filth or pathogens.

Bacteria may enter and/or be transported through a food plant by a variety of routes that include, but are not limited to: roof leaks; the shoes of employees, contractors, and visitors; the wheels of fork lifts, pallet movers, and moveable equipment; soiled pallets; soiled raw material packaging; raw ingredients; and by various pest vectors. Once established on production area floors the organism can contaminate food and food-contact surfaces through either human or mechanical means.”

In addition to the persistent presence of L. monocytogenes in the production plant, FDA inspectors noted several other sanitary concerns during their inspection. These included:

Multiple pipes were wrapped with material/insulation that appeared to be saturated with condensation.

Pooling water due to drips from condensate was observed above mixers…, behind an unwelded splash guard; the pooled condensate was observed dripping directly into an open upright mixer bowl.

Pooling water was observed below the in-feed of spiral cooler…

Pooling water was observed at the in-feed of spiral cooler…; the pool had a build-up of product debris and a black substance.

Pooling water was observed in spiral cooler … on the southwest corner below the mesh conveyor.

Approximately twenty flies were observed exiting a drain located near spiral cooler … and making contact with food contact surfaces.

Approximately thirty flies were observed swarming in proximity of the flour sock of mixer …

Approximately eighty flies were observed after the back panel of mixer … was removed.

This is not Kellogg’s first brush with a Listeria monocytogenes contamination problem. An October 2009 inspection of the company’s Eggo Waffle production facility in Atlanta, GA found L. monocytogenes in the plant environment. The 2009 inspection was initiated after the Georgia Department of Agriculture found L. monocytogenes in an Eggo Buttermilk Waffle finished product sample during a routine inspection. The contamination was detected before the Eggo’s were shipped; however, as a precaution, Kellogg recalled two other products that were manufactured at the same facility as the Eggo’s.

The Eggo contamination is unrelated to the problems reported in the Augusta facility.

The most significant health risk at the Augusta plant is not the presence of Listeria monocytogenes – although that is bad enough. The real concern – as the FDA warning letter points out – is that the plant’s cleaning, sanitation and pest control programs are ineffective, and might allow other pathogens, such as Salmonella, to gain a foothold.

It’s easy for a company to become complacent, especially when its products are “shelf-stable.” Other companies, such as McNeil Consumer Healthcare (part of Johnson & Johnson), have paid dearly for their complacency.

Kellogg! Put your Keebler elves to work, and clean up your production environment.