FDA Reader
Simplifying Food Regulation

Blog

FDA Reader: Simplifying Food Regulation

Posts tagged food scare
How to Understand a Food Recall

How to Understand a Food Recall

Outgoing FDA Commissioner Gottlieb released his 2nd letter concerning the legal fate of Cannabidiol (CBD) in the last 6 months

You are probably overreacting when it comes to food recalls. When an FDA food recall is issued, most people interpret it to mean “that food isn’t safe. I should stop buying it in grocery stores and eating it in restaurants.”  This is an understandable and cautious reaction, but it is completely unnecessary. Coupled with media-fueled fear mongering, it can lead to “food scares” which can shatter industries and wipe out small businesses and farms which played no part in causing the recall. Here are a few things to consider when you hear about an FDA food recall.

The Scope of a Food Recall is Much Smaller Than You Think:

When a recall notice is recalled, it typically refers to a single batch of product created in one factory under a single brand. The batch details are listed in the recall notice released by the FDA, although the media won’t likely include this detail when they report it. Let’s use the recent recall of Pilsbury Unbleached All-Purpose Flour(5lb) as an example: only lots 8 292 and 8 293 of Pilsbury Unbleached All-Purpose Flour(5lb) were suspected of being unsafe and therefore were recalled.

ucm633321.jpg


With that in mind, consider the following:

  • It’s probably unsafe to eat Pilsbury Unbleached All-Purpose Flour(5lb) labeled with lot code 292-8 or 292-9. That’s it.

On the other hand:

  • It’s safe to eat all other lots of Pilsbury Unbleached All-Purpose Flour 5lb

  • It’s safe to eat any other type of Pilsbury flour (there’s probably no safer time, in fact)

  • It’s safe to eat any other Pilsbury product

  • It’s safe to eat all other brands of flour

Unfortunately, most people who read the news will gloss over the details and simply stop buying flour or pilsbury products for a few months. The impact of this “food scare” may be sufficient to shutter smaller producers who, unlike Pilsbury ,may not be able to weather the dip in sales until public confidence is restored.

How “Food Scares” Occur

Of the Last 25 FDA Food Recalls (2019):

  • 14 were due to labeling errors.

  • 9 were due to the possible presence of illness-causing bacteria

  • 2 were related to the possibility of a foreign object in the food (soft plastic in one case, unknown in the other)

It’s rare that an entire group of foods (e.g. cantaloupe) is recalled. When this does occur, it’s in response to a widespread foodborne illness outbreak. The general nature of the recall is a reflection that investigators are still working to figure out the exact source of the problem. This type of urgent warning is always temporary, although the reverberations may harm those industries for years.

Let’s say that hospitals in three midwestern states have seen an unusual spike in Salmonella cases. Epidemiologists would use patient tests to see the if cases are related and also interview the patients to see what they had been eating. Eventually, they will be able to identify the commonalities in cases and determine use statistical analysis to determine that cantaloupe, for example, was the food to have caused the outbreak. 

Normally, epidemiologists would continue investigating and, by understanding where the victims shopped and ate, be able to trace the supply chain to a particular processing plant. Rarely, illnesses are reported at a faster rate than epidemiologists can trace the problem. If an atypical number of hospitalizations related to salmonella continue to be reported with cantaloupe as the likely culprit, public health officials may be forced to go public with whatever information they have collected at that time —  if only to stop the spread of illness. 

At worst, this will be a food-wide recall, which may recommend consumers in those midwestern states to discard and avoid eating all cantaloupe for fear that it is contaminated with salmonella. This sort of alert can be effective in curbing new cases of the illness outbreak, but it also prompts sensational media reports. This can create a “food scare”, where consumers who are not necessarily exposed to that risk (i.e. outside of those midwestern states where the danger has been identified) forsake cantaloupe in the misguided notion that they are preserving their safety. This can cause financial hardship for cantaloupe farmers globally and tarnish the reputation of the entire industry for years.

Ultimately, the epidemiologists will trace the illness to a farm or processing center and the scope of the recall will be narrowed to only concern the cantaloupe which is bears some risk to the consumer. But the resulting food scare may sink those small farmers who can’t weather the lasting decline in sales. They are unfortunate, collateral damage caused by a negligent food processor, sensational reporting, and misguided consumers.

Most Recalled Foods Are Still Safe to Eat

Most recalled food items won’t actually make you sick. In fact, 56% of the FDA food recalls so far this year were based on labeling errors. Here are two common scenarios where a labeling error would lead to a recall:

In one scenario, the manufacturer accidentally put coffee ice cream in the container labeled Strawberry Ice Cream. Here, a recall is required because the nutrition label and ingredients list — which are heavily regulated—  don’t match the product inside the packaging. From the perspective of the FDA, this is no different than a manufacturer lying about the ingredients in their product, so a recall is typically initiated.

A second common cause of recalls is due to “undeclared allergens”. This means that the manufacturer failed to state a major allergen that their product contains. For example, Bachman pretzels recently recalled a batch of their product for failing to state that it “Contains Milk”.  For the small group of people who are allergic to milk, this failure to disclose the allergen in the product could trigger an allergic reaction. This recall is important because someone with a milk allergy wouldn’t typically avoid pretzels and so the allergen declaration is a critical measure of consumer safety. For most people however, the presence of an undeclared milk allergen would not pose a health hazard.

You Are Unlikely To Get Sick Even If You Consume A Recalled Food

The complexity of our food systems and scope of supply chains present a statistical unlikelihood that you will become sick from a product implicated in a reported food recall. The following hypothetical aims to illustrate this point:

Recall Illustration (3).png