Date post: | 15-Jan-2016 |
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Lessons from the Food Safety Front: What if you had used peanut butter in
your products?
Wendy Campbell, Food Defense Coordinator
Food & Drug Protection Division
Timeline Earliest onset of illness, according to CDC 9/08/08
CDC monitors illnesses in 12 states11/10/08
MN identifies Salmonella in King Nut peanut
butter 1st recall by PCA initiated1/10/09
FDA finds 12 instances of PCA shipping contaminated product
1/13/09
PCA expands recall to include all peanut paste1/18/09
1/16/09 PCA expands peanut butter recall
Timeline
1/28/09 Recall expands to include all peanut products made in GA firm
2/12/09 PCA in TX initiates recall of peanut products
PCA (TX and GA) informs customers to stop
using all products2/20/09
4/04/09 Last illness reported
5/12/09 Last recall initiated
Impact of PCA Peanut Butter Recall
• Public health– US: 9 deaths and 714 illnesses– NC: 1 death and 6 illnesses
• Consumer confidence eroded– US: Over 3,000 food products recalled– NC: 3 food and 2 animal feed manufacturers
directly impacted
Impact of PCA Peanut Butter Recall
• Economic impact– US: Estimated >$1 BILLION impact
– US: 20% decline in peanut butter consumption in January
– NC: 23% decline in
peanuts planted
– NC: Substantial number
of employees laid-off
Why did the recall last for months?
All Firms Receiving PCA Peanut Ingredients Requested to Voluntarily Recall Product
• No validated processes to achieve 5-log kill for Salmonella
• One firm chose not to recall product– FDA issued Consumer Advisory– Other potential enforcement tools:
• Embargo• Injunction
New Science
Yesterday: Growth• Water activity < 0.9• pH < 4.6• Heat to approx 140-
150◦F. (pasteurization)• Drying
Today: Survival• Survives Aw < 0.3• Survives in acid foods• Resistant to heat • Resistant to drying• Known to survive
many months or more
9
Lessons Learned
• Firms must adapt to new findings in food science and regulations– How often are your processes evaluated?– How do you keep aware of new findings?– How do you keep aware of new regulations?
Lessons Learned
• PCA was receiving laboratory results after shipping product– What are your testing and reporting
requirements for your suppliers?
Lessons Learned
• Some firms were not receiving the original Certificate of Analysis (C of A)– Do you require your supplier to share results
on the original C of A?– How is the sampling and testing conducted?
• Is the sample representative of the lot?• Is the laboratory accredited?• What is the testing procedure being used?
Lessons Learned
• Some firms were re-testing presumptive positive test results?– Again, how do you require your ingredient
suppliers to report laboratory results?– Do you conduct testing of any of your
ingredients or finished product?
Lessons Learned
• Many ingredient and finished product manufacturers were secondary and tertiary receivers of PCA products– Do you know where your ingredients
originated from? – How quickly do you find out?
Lessons Learned
• While different lots of product existed, there was no clean break – How do you ensure there is a clean break
between different lots and products?– What requirements do you have of your co-
packer?
Lessons Learned
• Our regulatory and inspection strategy needed to change– We now conduct environmental and finished
product sampling in firms producing low moisture foods
– We now understand the transportation and processing of peanut paste better
– Extremely difficult to decontaminate a facility
QUESTIONS?