Learning from past mishaps is one of the food industry’s most valuable food safety tools.
The ongoing peanut butter recall is truly an embarrassment to the food industry. While critics scream for more government inspection and Congress says increased scrutiny is needed, one thing is clear: the company in question didn’t have a clue. Perhaps what is most embarrassing to me as a food safety professional is that the company failed to learn from past lessons. Remember what happened to ConAgra a few years ago? Salmonella in peanut butter, sanitation issues in the plant, serious structural problems. As Yogi Berra said, “Its déjà vu all over again.”
With more than 600 illnesses and seven deaths associated with the outbreak, the incident underscores that more attention must be paid to sanitary design and maintenance, “lab shopping,” proper cleaning verification, procedures for evaluating suspect lots and third-party audits as a means of ensuring safety.
Sanitary design and maintenance is essential for safe food production. Peanut butter and other products associated with outbreaks often will not support the growth of pathogens, but when contaminated, the pathogen may survive and be hard to eliminate. Processors must take a harder look at ventilation systems, air flow, traffic patterns, associates and cleaning procedures. Plants with drop ceilings must look at what is above those ceilings.
The California Almond Board mandates that US almond processors must, not only pasteurize almonds, but also develop and implement systems to minimize potential for cross-contamination of processed nuts. It is very likely that a similar program may be mandated for the peanut industry.
Laboratory shopping has increased over the past few years. A number of importers were implicated in shipping and shopping samples to different laboratories to ensure the desired results. Investigations revealed that these operations would ignore samples testing positive for contaminants. A similar finding cropped up during the peanut investigations. This also illuminates the fact that many foods and ingredients-including peanut butter-are not uniform. Work done after the e. coli 0157:H7 outbreaks in ground beef have shown that pathogen is not uniformly distributed in such products.
How should companies handle lots in which pathogens are found? Simply retesting a second sample is not adequate, effective or honest. Whenever a positive sample is found, the suspect lot must be put on hold and destroyed or made safe. Ground beef containing a pathogen can be diverted to an operation such as canning, which will ensure the pathogen is destroyed. However, this solution won’t work with peanut butter. In low water activity products such as peanut butter, the amount of heat needed to pasteurize the product would probably render it inedible.
Cleaning programs are essential for food safety. Following proper sanitary design principles, including the American Meat Institute’s guidelines for ready-to-eat products, simplify the process. Processors must verify on a regular schedule that the sanitation crew is performing work properly.
Finally, let’s look at third-party audits. All audits and auditors are not created equal. Most third-party audits ask specific questions about prerequisite programs, quality systems and other issues. Auditors are trained, but that doesn’t mean they are skilled and experienced. If audit systems have a gap, it is that they frequently do not allow the auditor to offer an overall opinion of plant operations or any assistance to the plant. Just because you do well on the day of the audit, does not mean that you can be complacent. Maintaining your systems and facilities is a constant battle.
The food industry should never rest on its laurels. Just because the product being produced appears to be “bullet-proof” doesn’t mean it is. No one suspected potato chips or breakfast cereal would be outbreak vehicles. Quality, safety and sanitation systems must be constantly evaluated and their efficacy reviewed.
All of this leads into one of my favorite quotes: “People who fail to understand history are doomed to repeat it.”