Issue #56 | Recurring Contamination ('Concerning' 😕) | Learning from the Allergen Inquest | Food Fraud: 3 Simple Questions |
2022-09-19
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‘Concerns’, and a Little Action, Over Reoccurring Contamination (it’s E.coli in leafy greens again!)
Allergen Inquest - What Can We Learn?
News and Resources Roundup
Food fraud corner: 3 simple questions I ask every day
Food fraud news and emerging issues
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Hello!
Welcome to Issue #56 of The Rotten Apple. And thank you again to all you wonderful new subscribers. It’s great to have you here.
I’m starting to feel like a broken record: it seems to be all allergens and E. coli in leafy greens here in Rotten Apple land at the moment.
On the upside, I’ve been in the Riverina again (a major Australian food-growing region) and the canola is in glorious flower. The colour is so intense it’s almost hard to believe your eyes at times.
Today I’m sharing two updates that build on what we learnt together about the leafy greens outbreaks and the horribly-preventable allergen death in the past few issues. Then, as usual, we have a round-up of food safety news.
Also this week, the three simple questions you can ask yourself about food fraud. Finally, as always, our food fraud news for paying subscribers.
Have a marvellous week,
Karen
P.S. Need more info about paid subscriptions? Click here. Or….
‘Concerns’, and a Little Action, Over Reoccurring Contamination (it’s E.coli in leafy greens again!)
The same ‘bug’ in the same commodity from the same region has been causing at least one outbreak per year for the past four years. Oh dear.
No doubt about it, there is a problem with pathogenic Escherichia coli in lettuce in the USA. In fact, the US Food and Drug Administration (FDA) admitted that they are aware of a reoccurring outbreak strain - that’s a ‘strain’ of E. coli O157:H7 - that is causing reoccurring food poisoning outbreaks from lettuce from a single region, and that they have ongoing “concerns with the potential impacts of adjacent lands”… which means the FDA is worried that land(s) near the lettuce growing region might be the source of this particular pathogenic bacterial strain.
The outbreak strain (a strain is a closely-related genetic variant of a bacterium) has caused at least one outbreak every year for the past four years. That’s pretty bad. Even the FDA admits that it “appears to be a reasonably foreseeable hazard” in the affected region.
Great news: the FDA is currently performing surveillance (= microbiological testing) in the high-risk area, a follow-up on last year’s surveillance of lettuces from the area, which did not find conclusive evidence of the outbreak strain in lettuces. This time they may also test irrigation water, soil and scat (animal faeces) as part of their surveillance. Last time they only checked actual lettuces, and these were collected from “commercial coolers”, not from farms.
The aim of the surveillance is to “identify potential contamination events associated with lettuce grown in the Salinas Valley and to prevent contaminated lettuce from entering commerce, when possible.” The surveillance programs are part of the FDA’s Leafy Greens STEC Action Plan
Intriguingly, a write-up by Food Safety Tech said that
“… the FDA shared that recent outbreaks have raised concerns about the sanitary design of harvest equipment and how field production and processing practices may be contributing to contamination events”
This statement implies that the lettuce growers in this known-to-cause-frequent-outbreaks-region are actively contributing to the food safety risks, by
using harvest equipment that can’t be easily cleaned and sanitised, and/or
using growing, harvest, packing and processing methods that actually make the situation worse.
Takeaways
It’s great to see the FDA trying to prevent outbreaks by checking produce and environmental samples. It would be even better to see them enforcing the ‘new’ preventive controls rules in the Food Safety Modernisation Act which are supposed to stop contamination from happening in the first place.
🍏 See Issue #52 and Issue #53 for more on E. coli in leafy greens 🍏
Allergen Inquest - What Can We Learn?
A vegan coconut-based yoghurt-style dressing contained traces of milk protein that killed an allergic woman who ate it in a vegan flat-bread sandwich in the United Kingdom in 2017. Her inquest is underway and we are learning some not-very-nice things about supply chain practices.
This allergen-contamination incident inspired “Why We Care About Allergen Recalls” in Issue #54 of The Rotten Apple.
The story so far…
The inquest has heard allegations that…
🍏 The dressing contained a coconut yoghurt of the brand CoYo.
🍏 The brand owner (CoYo) provided licence(s) to a second company, Planet Coconut manufacture and distribute the ‘dairy free’ coconut yoghurt in the United Kingdom.
🍏 The yoghurt contained tapioca starch which had traces of the dairy protein that caused the fatal allergic reaction.
🍏 The manufacturer is blaming the brand owner for not providing accurate or documented allergen information for the starch ingredient.
🍏 The manufacturer also says they assumed that the formulation would be free from dairy as the product that they purchased the licence to make was called dairy free yoghurt.
🍏 For these reasons, the company that made the sandwich was not told about the risk of dairy contamination by the manufacturer, because the manufacturer did not believe there was a risk.
🍏 The starch for the original formulation of yoghurt was from an Australian source, while the starch in the UK-manufactured yoghurt was from a source in Wales.
🍏 The starch supplier in Wales says they warned the manufacturer of the risk, and used allergen warnings on the bags of starch they supplied, but the manufacturer says they believed the brand-owner’s (verbal) claims that the starch was allergen-free.
Note these are all allegations, and an inquest is not the same as a criminal investigation or trial.
What can we learn from this?
Tiny traces of allergens can be deadly, which means any potential contamination should be treated with the utmost conscientiousness. The managing director of the manufacturer relied on verbal assurances that the starch was okay, even after seeing allergen warnings on the bags.
Formulations (recipes) need to be thoroughly reviewed when moving production from one country to another. The original Australian-sourced tapioca starch may have been 100 percent allergen-free. However, the Wales-sourced starch should not have been assumed to also be allergen-free, even when manufactured to the same specification.
Product specifications are an important control for allergen contamination prevention. In this case, the inquest heard that the brand owner purchased starch on behalf of Planet Coconut, and it was the brand owner that supplied the specification, not the starch manufacturer.
Trust but verify? The food safety officer at the inquest suggested that the sandwich chain should have checked that the yoghurt maker was testing for dairy allergens, or should have performed their own testing. Note it isn’t clear whether occasional testing would have prevented the tragic outcome in this particular case, though it might have provided a warning of problems.
Takeaways for food businesses
Take red flags seriously (like warning labels on ingredient bags)
Get allergen-free assurances in writing (usually in a product specification) and ideally from the manufacturer/processor, not from a third party.
Review ingredients carefully when moving manufacturing to other locations, where there are different sources for the ‘same’ ingredients.
Perform testing to verify that processes are working correctly.
Source:
News and Resources
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Food Fraud Corner: The 3 Simple Questions You Can Ask to Decide if an Incident is Food Fraud or Not
Food fraud or not? This is a question I ask myself daily when making entries in our Food Fraud Risk Information database on Trello. To decide, I use a simple three-question process. If the answer is YES for all three questions then the incident counts as food fraud.
(1) Is there deception? (it could be consumers that are deceived but also could be customers like supermarkets, or government agencies, like border inspectors)
(2) Is food involved?
(3) Is there an economic benefit to the perpetrators?
A recent case of an international shipment of soup and cookies that was used to conceal drugs was an example of a time I had to ask these questions. In this case there was (1) food, (2) deception (of border agencies) and (3) the intention of economic gain.
So YES, that makes it food fraud in my book.
As for whether this type of incident should prompt a review of vulnerability assessment(s), I think most food businesses would consider such an incident (a) unlikely and (b) easily detected, so this incident does not point to a newly emerging risk for cookies or soup and shouldn't require any new mitigation activities.
What you missed in last week’s email
· Tropane alkaloids, a plant toxin that kills
· Calculating the environmental impact of processed foods
· Good eggs and bad chocolate
· News and Resources Roundup + Food fraud incidents, updates and emerging issues
Below for paying subscribers: Food fraud news, and emerging issues, plus 🎧 this email in genuine human-voice audio 🎧
📌 Food Fraud News 📌
Origin Labelling - the European Consumer’s Perspective
This new report systematically reviewed research to understand how food origin