A June 2023 FDA inspection of ReConserve of Maryland, Inc. found multiple food safety and sanitation issues at the facility.

The inspection outcome was classified as “Official Action Indicated,” and a summary of the observations was posted on the FDA’s searchable inspections dashboard.

“Official Action Indicated” means that regulatory and/or administrative actions are recommended, according to the FDA’s definition of inspection classifications.

The actual actions taken by the agency will depend, at least in part, on the willingness of the company to correct each of the issues identified during the inspection in a timely manner.

ReConserve Inc. is a recycler of edible food waste, with multiple locations across the United States.

According to its website, the company recycles bakery, cereal grain, snack foods, and related food by-products into ground meal that can be incorporated into feed for poultry, swine, dairy cattle, and beef cattle.

During the course of the inspection, the FDA noted the following infractions:

• You did not keep the grounds around your animal food plant in a condition that would protect against the contamination of animal food.
• You did not effectively protect the animal food stored outdoors in bulk from contamination.
• You did not inspect, segregate, or otherwise handle raw materials and ingredients used in manufacturing under conditions that will protect the animal food against contamination and minimize deterioration.
• You did not identify and evaluate each known or reasonably foreseeable hazard for each type of animal food you manufacture, process, pack or hold in your facility.
• You did not identify and implement preventive controls to ensure that any hazards requiring a preventive control are significantly minimized or prevented.
• You did not conduct a reanalysis of your food safety plan as appropriate.

Why this matters

ReConserve describes its finished product as a “high-energy, nutrient dense, highly palatable” substitute for “more expensive feed grains and fat,” which can be incorporated into animal food rations at levels as high as 25% for poultry and 30% for swine.

Improper storage and handling of bakery and other cereal grain by-products can easily lead to mold growth in the material, with the potential for development of aflatoxins and other mycotoxins.

Improper or inadequate controls during and after processing could result in contamination with harmful bacteria, such as Salmonella, as a result of cross-contamination or exposure to rodent or bird infestation.

Either of these outcomes put livestock at risk.

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The Council of State and Territorial Epidemiologists (CSTE) has approved a position statement recommending that invasive Cronobacter infection in infants be added to the list of approximately 120 notifiable diseases in the United States.

The position statement was developed by the CSTE in conjunction with the US Centers for Disease Control and Prevention (CDC), the Food and Drug Administration (FDA) and the Association of Public Health Laboratories (APHL).

The CSTE is a voting body comprised of State Epidemiologists from all U.S. states, territories, and the District of Columbia. 

The text of the statement will be released in coming weeks.

STOP Foodborne Illness, a national public health non-profit organization, hailed the announcement, predicting that the CSTE decision would have a “…meaningful impact on infant mortality.”

A look back

In February 2022, consumers were shocked to learn of four infant illnesses due to Cronobacter infections linked to consumption of powdered infant formula manufactured by Abbott Nutrition.

As the months passed and more was learned about the evolution of the contamination problem, food safety experts and members of the public began to advocate for adding Cronobacter to the list of infectious diseases reported as a matter of course to the CDC’s national surveillance database.

Notifiable versus reportable

What is a notifiable disease, and how does it differ from a reportable disease?

Although these two terms are often used interchangeably in the context of disease surveillance, they actually have quite different meanings as far as the CDC is concerned.

This screenshot from the CDC website explains the differences between notifiable and reportable diseases.

Reporting of notifiable disases is voluntary, and personal information is redacted from the reports that reach the CDC. The data from notifiable disease reports is useful for statistical surveillance, but cannot easily be used to locate the source of an outbreak.

On the other hand, reportable diseases (which are specified individually by each state or territory) MUST be reported to public health authorities by healthcare professionals, hospitals and laboratories. Reports supplied to the CDC in these instances contain information on the individual patients, and can be used to track the source and scope of disease outbreaks.

A notifiable disease may also be reportable by one or more states and territories, if those local authorities decide to make it so.

Under no circumstances does the CDC have the authority to MANDATE reporting of either notifiable or reportable diseases.

The bottom line

Adding invasive Cronobacter infection in infants to the list of national notifiable diseases is a long overdue action, which will improve the CDC’s ability to track trends in the frequency of this disease condition.

Let us hope that it will also spur additional states and territories to mandate reporting of Cronobacter infections to local public health authorities in their jurisdictions.

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