Darwin’s QA program evolves in response to FDA enforcement measures

The following story by Phyllis Entis first appeared in Food Safety News and is reposted here with permission.

Arrow Reliance Inc., dba Darwin’s Natural Pet Products, is taking steps to correct multiple violations of the Federal Food, Drug, and Cosmetic Act discovered during an investigation of Darwin’s raw pet food manufacturing facility in December 2017 and January 2018.

The Food and Drug Administration detailed the problems in a warning letter April 2.

A redacted copy of Darwin’s response letter was obtained by Food Safety News in response to a Freedom of Information Act request.

The investigation was triggered by a series of product recalls announced by the company in late 2017 due to Salmonella contamination in samples of Darwin’s raw frozen pet foods, following customers’ complaints of a kitten death and other ill pets. The joint investigation was carried out by the FDA and the Washington State Department of Agriculture (WSDA).

The FDA warning letter, and the Establishment Inspection Report that preceded it, highlighted several issues, including:

  • Bacterial pathogens (Salmonella, Listeria monocytogenes and/or E. coli O128) present in samples of various Darwin’s Natural Selections and ZooLogics brands of raw pet food;
  • The identical strain of Salmonella was recovered from both the dead kitten and a sample of food that had been fed to the kitten;
  • The protocol used by Darwin to reduce pathogen contamination through the application of bacteriophages had not been validated;
  • Failure to conduct operations under cGMPs (current Good Manufacturing Practices)
  • Raw materials not thawed under conditions that would minimize potential for growth of undesirable pathogens;
  • Animal food contact surfaces not made of appropriate materials or maintained to protect animal food from becoming contaminated; and
  • Equipment and utensils not used appropriately to avoid adulteration of animal food with contaminants.

In its response to the FDA warning letter, Darwin officials reported conducting a risk assessment to identify the root cause or causes of contamination. Based on the results of their assessment, the company concluded that the primary source of their contamination problem was pathogens present in some raw materials. 

To address that issue, Darwin has adopted new approaches to reducing or eliminating pathogens in those raw materials, including:

  • Requiring all meat suppliers and produce suppliers to use a pathogen-reducing treatment (details redacted) prior to shipping raw materials;
  • On-site audits of meat suppliers and primary produce supplier;
  • Pathogen testing conducted by an independent testing lab of a number of inbound raw materials;
  • Additional “interventions” that are being evaluated (details redacted) for possible inclusion in the company’s processes to further reduce pathogen levels;
  • Increasing the dosage of bacteriophages to match the manufacturer’s “standard” recommended dosage and tested a revised method of application; and
  • Conducting validation tests, which were carried out by an independent testing lab, to confirm the effectiveness of the higher bacteriophage dosage and revised application method.

According to Darwin’s response letter, in 2016, the company hired a Quality Assurance (QA) manager who developed the company’s first formal Standard Operating Procedures (SOPs) and Sanitation Standard Operating Procedures (SSOPs) and expanded the company’s sanitation and environmental testing programs. Prior to 2016, the sanitation and quality assurance functions were handled by the production department.

In response to the violations detailed in the FDA warning letter, the company expanded its QA team, adding an assistant manager and technicians. It also conducted a comprehensive review and update of its Good Manufacturing Practices (GMPs) conducted training sessions for employees, and corrected other issues raised by FDA and WSDA inspectors during the inspections initiated in December 2017 and completed in January 2018.

When asked to comment on the remedies outlined in Darwin’s response letter, a spokesperson for FDA said “… we aren’t able to share … any information about discussions with firms regarding their responses to warning letters.”

FDA’s investigation remains open, according to the agency spokesperson.

Did FDA just reveal manufacturer of contaminated Kellogg’s Honey Smacks cereal?

When CDC alerted the public on June 14th to an outbreak of Salmonella illnesses linked to Kellogg’s Honey Smacks breakfast cereal, the agency was coy as to who was the actual manufacturer of the contaminated product.

Today, with its weekly release of Warning Letters, FDA may have answered the question.

On July 26, 2018, FDA issued a formal Warning Letter to Kerry Inc., headquartered in Beloit, Wisconsin after an inspection of the company’s cereal-production facility in Gridley, IL revealed a manufacturing environment in which Salmonella had made itself at home.

The Warning Letter listed several serious violations of the Federal Food, Drug and Cosmetics Act, including:

  1. The Gridley facility’s hazard analysis did not include contamination of ready-to-eat cereal with environmental pathogens such as Salmonella, even though this type of contamination has occurred in the past
  2. Gridley repeated found Salmonella in its production environment, but took no corrective action
  3. Gridley recorded 81 positive Salmonella environmental samples and 32 positive Salmonella vector samples between September 29, 2016 and May 16, 2018
  4. Gridley did not implement sanitation or preventive control procedures upon finding Salmonella in its manufacturing environment
  5. Gridley did not implement the company’s own written environmental monitoring program procedures.

The Warning Letter does not refer to Kellogg’s Honey Smacks, or to any other brand or variety of ready-to-eat breakfast cereal by name, nor does it make reference to the Salmonella outbreak linked to Honey Smacks.

This Salmonella-laced production plant manufactures ready-to-eat cereals and “rice crisps intended for pet food“, according to the Warning Letter. One of the Salmonella-positive environmental samples found as a result of the FDA inspection was from the “…bottom of the roll-up door between [the] cereal coating room and [the] processing room for rice crisps intended for pet food.”

In its initial Outbreak Investigation release, CDC said, “Thirty (77%) of 39 people interviewed reported eating cold cereal. In interviews, 14 people specifically reported eating Kellogg’s Honey Smacks cereal.” 

The Salmonella problem at Gridley dates back almost two full years, to September 2016. It is very likely that other brands of ready-to-eat breakfast cereal manufactured in this facility during the last two years also harbor Salmonella. Some pet foods may be at risk as well.

Where are the other recalls?

Recalls and Alerts: July 24 – 28, 2018

Here is today’s list of food safety recalls, product withdrawals, allergy alerts and miscellaneous compliance issues. The live links will take you directly to the official recall notices and company news releases that contain detailed information for each recall and alert.

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United States

Allergy Alert: TeaSource recalls Roasted Chestnut loose leaf tea (1lb, 4oz, 2oz, or sample metal foil pouches) due to undeclared almonds.

Food Safety Recall: Lipari Foods, LLC recalls Premo brand Turkey & Swiss Club sandwiches (4/6 oz; Lot #17201807; Sell by 08/06/2018; UPC 612510001042) and Fresh Grab brand Turkey & Swiss Club sandwiches (18/6 oz; Lot #17201807; Sell by 08/06/2018; UPC 612510001042) due to potential Listeria monocytogenes contamination. The recalled products were distributed to food service and retail stores throughout Florida, Illinois, Indiana, Kentucky, Michigan, Minnesota, Ohio, Pennsylvania, Tennessee, Wisconsin and West Virginia.

Canada

Allergy Alert (Update): AJ International Trading recalls Wulama brand Fish Tofu and Want Want brand Shake Jelly products (see recall notice for complete product details) due to undeclared egg, sesame, and milk. The recalled products were distributed to retailers in Ontario.

Europe

Allergy Alert (Ireland): FSAI alerts consumers to undeclared sesame in Dee Durian Flavoured Thai Crispy Rolls (150g; Best before end  August 2019, December 2019 & March 2020).

Allergy Alert (Ireland): Lidl Ireland recalls McEnnedy Peanut Flavoured Super Size Flips (450g; Best before 12/11/2018; Batch code L35104) due to undeclared peanuts, other nuts, and cereal containing gluten.

Allergy Alert (Italy): Unigràs SRL recalls various flavours of Orasì Soia beverages due to undeclared milk. Please refer to the individual recall notices for complete details on the affected products.

Allergy Alert (UK): Quorn recalls Quorn brand 2 Gluten Free Burgers (2-pack/227g; Batch code 708049; Best before 30-Nov-19) due to undeclared gluten.

Allergy Alert Update (UK): Bradbury & Son (Buxton) Ltd recalls Lo-Col cheese alternative (195g; Best before 19 September 2018, 1 October 2018, 3 October 2018, 7 October 2018, 9 October 2018) because milk is not emphasized on the labelling.

Allergy Alert (UK): Asco Foods Ltd recalls Dee Thai Crispy Rolls – Durian Flavour (150g; Best before end of August 2019, December 2019, March 2020) due to undeclared sesame.

Allergy Alert (UK): Sainsbury’s recalls by Sainsbury’s Coconut & Yogurt filled Breakfast Biscuits and by Sainsbury’s Cocoa filled Breakfast Biscuits (186g; All batch codes; All date codes) due to undeclared sesame.

Allergy Alert (UK): Co-op recalls Hoisin Chicken Noodle Box (244g; Use by 31 Jul 2018) due to undeclared milk.

Food Safety Recall (Denmark): Løgismose recalls Løgismose brand håndskårne kyllingelår (370 – 500 grams; Lot #1921800921; Best by 26/07/18) and Løgismose brand kyllingebryst med vinge (310 – 425 grams; Lot #1921800921; Best by 26/07/18) due to Campylobacter contamination.

Food Safety Recall (France): Antoine Sabatier recalls Véritable jambon persillé de Bourgogne supérieur (350g; Lot #18198199; Best before 04/08/18) due to Salmonella contamination.

Food Safety Recall (France): Capitaine Houat recalls Crevettes entières cuites réfrigérées CAL 40/60 pièces/kg (500g; Best before 22/07/2018 – lot #38731191, Best before 23/07/2018 – lot #38776192, Best before 24/07/2018 – lot #38797193) due to Listeria contamination.

Food Safety Recall (France): GI-DOR-LAND recalls La CONSERVERIE DES BONNES CHOSES, LES GASTRONOMIES DU BERGERACOIS, LA PERLE DE RIGORD et ALAIN MARTIN preserves (cans and glass containers; all expiry dates between 01/07/21 and 07/06/22) to due anomalies in manufacture.

Food Safety Recall (France): MAXIME GERAUD recalls Maxime Geraud brand Salade 4 saisons aux tomates fraiches (250g; Lots 18169, 18172, 18176, 18179, 18183, 18186; Best by 09/07/2018, 12/07/2018, 16/07/2018, 19/07/2018, 23/07/2018, 26/07/2018) due to possible Listeria monocytogenes contamination.

Food Safety Recall (France): MAXIME GERAUD recalls MAXIME GERAUD brand Salade landaise et gésiers (1.8Kg; Lots 18172, 18179, 18183; Best before 09/07/2018, 16/07/2018, 20/07/2018) due to possible Listeria monocytogenes contamination.

Food Safety Recall (France): Casino recalls Sandwich polaire saumon fumé aneth (130g; Lot #819901; Best before 04/08/2018) due to possible Listeria monocytogenes contamination.

Food Safety Recall (Germany): LFO recalls Capitoul brand MIX SCHAF/ZIEGE cheese (4.5Kg; Batch codes 2018115126/2018116127; Best before 25.07./26.07.2018) due to Listeria monocytogenes contamination.

Food Safety Recall (Germany): Havers GmbH Direktvermarktung recalls Knackwurst (All batch codes from 5.07.2018 through 25.07.2018) due to Listeria contamination.

Food Safety Recall (Ireland): Whitworths recalls Whitworths Granulated Sugar (1.65Kg; Batch codes F301U81902 and F301U81933) due to foreign matter (small pieces of metal wire) contamination.

Food Safety Recall (Italy): G.S. S.p.A. recalls TERRE D’ITALIA brand Formaggio Fontina D.O.P. (approx. 250g; Lot #171; Best before 19-08-2018) due to Shiga-toxin producing E. coli.

Food Safety Recall (Sweden): ERIKSONS CHARK recalls GRILLKORV (8-pack and 16-pack; Pack date 23.07.2018) due to foreign matter (plastic pieces) contamination.

Food Safety Recall (UK): Tereos UK recalls various brands and batch codes of Granulated Sugar due to foreign matter (small metal pieces) contamination. Please refer to the recall notice for a complete list of affected products.

Food Recall (Ireland): PepsiCo recalls Tropicana Trop 50 Multivitamins Juice (1L; Best before 14/10/2018) due to fermentation spoilage.

Food Recall (UK): PepsiCo recalls Tropicana Trop 50 Multivitamins Juice (1L; Best before 14/10/2018) due to fermentation spoilage.

Australia and New Zealand

Allergy Alert (New Zealand): The Finger Food Shop recalls The Finger Food Shop brand Curry Rice Rolls (12-pack; All batch codes; All best before dates) due to undeclared soy.

Food Safety Recall (Australia): Protein Supplies Australia recalls Lactose Free Whole Milk Powder (1kg; Best Before 29/12/19) due to foreign matter (metal) contamination.

Food Safety Recall (Australia): Bovells Bakery recalls various Bovells Bakery Wholemeal Breads due to foreign matter (metal) contamination. Please refer to the recall notice for a complete list of affected products.

Food Safety Recall (New Zealand): Little Angels Baby Ltd recalls Little Angels brand Pure Baby Food (specific batches of 5 flavours) due to lack of process control.