Guilt by Association:The Impact of Secondary Recalls

Erin WoodomFood Compliance Officer

Rapid Response Team MicrobiologistFood and Drug Protection Division

Big Picture

A recall at any point in the supply chain can have an impact on your business

Weak Links in the Food Chain

• Recall preparedness is a vital part of operating a food business

• Even if you are conscientious, can you vouch for your suppliers?

• Your supplier’s suppliers?• Your supplier’s supplier’s suppliers?• Your supplier’s supplier’s supplier’s suppliers?

Case Study: Ground Pepper

• Starting in Summer 2009, an increase in persons infected with Salmonella montevideo was observed

• Cases appeared across the country (see map at right)

Source: Centers for Disease Control

Case Study: Ground Pepper

• Public Health analysis indicated consumption of Daniele-brand sausage and salami linked to illnesses

• Follow-up testing found Salmonella in salami products on market

• USDA and State regulatory agencies began investigating salami manufacturer

Case Study: Ground Pepper

• Investigation led to recall of approximately 1.3 million pounds of meat products

• Three-month investigation suggested pepper used in sausages source of Salmonella

Case Study: Ground Pepper

• FDA tested 3,600 spice samples during investigation

• Two lots of bulk ground pepper from two different suppliers tested positive for Salmonella

• Recall of ingredient led to recall of additional products from additional manufacturers

Case Study: Ground Pepper

• Final Tally– 272 confirmed illnesses from contaminated

products; 11 additional possible illnesses– 2 Ground Pepper Recalls– 6 Sub-Recalls from spice company customers– 75 products removed from market

• Ingredient-driven recalls typically have larger impact and affect more companies

Food for Thought

• Do you keep records of the lot numbers of your raw materials?

• How quickly could you trace your product?• Do you have a good working relationship with

your suppliers?

• Are you prepared to respond quickly to a recall not of your own making?

2009 PCA Peanut Recall

• 3,907 products were recalled in approximately 2,100 sub-recalls

• Estimated $1 billion in economic impact• Peanut product sales from all producers

dropped due to loss of consumer confidence• Are you prepared to manage a crisis among

your commodity? Are you prepared to take advantage of it?

2006 Spinach Recall

• E. coli in bagged spinach caused 199 illness and 3 deaths

• Significant drop in spinach consumption nationwide

• Spinach consumers shifted buying patterns to smaller, local growers

• Some small farms have maintained increased leafy greens sales

Conclusion

• Recalls from wholesale suppliers can quickly grow in scope and cost

• Even if you are careful, another link in the chain can cause problems for you

• Effective crisis planning and management reduces impact and protects your business

• Recalls from other suppliers can be a business opportunity for prepared firms

Questions?

Brett WeedCompliance and Preparedness Administrator

Food and Drug Protection Division

brett.weed@ncagr.gov919-733-7366

NCFOODSAFETY.COM