There were some very interesting changes in food and beverage recall trends for Q4 2017. Most notably is that although undeclared allergens continue to be the #1 reason for recalls, when calculating by number of units, bacterial contamination soars well above allergens. As reported in the recently released Stericycle Recall Index for Q4 2017, 54.7% of all FDA food recalls were due to undeclared allergens. But bacterial contamination was the cause for 44.1% of all units recalled while 30.8% were due to undeclared allergens. On a positive note, the 150 FDA food recalls of Q4 2017 put recalls at their lowest level since Q1 2016. This was a 93% decline in food units (7MM), again the lowest level since Q1 2016, and lower than nine of the last 12 quarters. A little less positive was the USDA foods recall increase of 17% (28 recalls) compared to Q3. However, not only was this lower than four of the last five quarters, it was a 92% decline in pounds – the lowest since Q3 2013. Some further statistics from the report: The next closest causes of recalls in number of units were mislabeling (12.8%) and quality (10%), with “other” coming in at a very low 2.3%. Prepared foods took the top spot (20%) for category of FDA food recalled, though three other categories weren’t far behind: nuts/seeds (16%), produce (15.3%), baked goods (12%). For USDA recalled pounds, the vast majority (63.1%) were for multiple-meat products, vs. any single category of meat. Additionally, 49.9% were due to lack of inspection, vastly increased from the 0.2% of the previous quarter. What does it all mean to you? First and foremost, with more than half of all FDA food recalls caused by undeclared allergens, the industry really needs to put a full-court press on reducing cross-contact of allergens and ensuring accuracy of labels. We can only hope that at least the majority of these recalls are made before a person with life-threatening allergies consumes a non-labeled allergenic food. The increase in bacterial contamination recalls raises some very interesting points … and questions. The first lesson is, of course, that a strong focus needs to be put on bacterial preventive controls in all food facilities (whether or not you are subject to the preventive controls rules). Additionally, environmental and product sampling for contamination should be heightened. Not only does this keep contamination product from getting to market, but it helps you prepare for FDA inspections … which is where some question comes in. Have these recalls increased because of increased bacterial contamination? Or, have they increased because of increased detection? We all know that FDA is serious about environmental sampling in its Preventive Controls inspections, with its “swab-a-thons” including 150-200 sampling swabs. (If you don’t know about this, take a look back at the TAG article “How Serious Is FDA about Environmental Sampling? Don’t Wait to Get a Warning Letter to Find Out.”) We also know that FDA is now using whole genome sequencing in its testing of the sampling – which enables it to link pathogens from various facilities and times and illnesses. (If you want to know more about this, check out TAG’s “Use of Whole Genome Sequencing Increases Depth of NARMS Reporting.”) Additionally, with the increased sampling, it’s not really a surprise that prepared foods hold the top recall category – but it does tell you to increase your controls. As far as USDA foods, I’d say the key lesson is to ensure your food is inspected before you send it to market! I can’t really say what caused the increase from almost zero to nearly half of all recalls in a single quarter, but the agency is dealing with budget cuts for 2018, with even more proposed for 2019. All that said, there also are some kudos due to both FDA- and USDA-regulated companies. With greater than 90% decreases in recalled FDA food units and USDA food pounds, you are certainly doing something right there, so keep it up! About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com
