Recently, there’s been a host of articles and media reports about the weekly drumbeat of foodborne outbreaks and recalls. In many of these reports, media outlets turn to a range of so-called food safety experts for reaction, comments, and interpretation.
The “spin” and rationalization by so many in the profession – previous regulators, consultants, and academicians – who have said that the outbreaks and recalls are a sign that the system is working is “alarming” and, in my view, off-the-mark.
I get the desire to try to convey a sense of calm but rationalizing away what’s happening is not serving the public well. In contrast, I think it does more harm to the public, longer term, than it helps, as it communicates that there isn’t really anything to be concerned about or that we shouldn't be working with a sense of urgency to prevent them.
Straight Talk About Foodborne Outbreaks and Illnesses
No, detecting outbreaks and illnesses is NOT a sign that our food safety system is working.
Imagine telling that to a victim of a foodborne illness or those that have lost a family member due to contaminated food?!
Food Safety 101, HACCP, and general public health principles are clear - the “primary” goal of a food safety management system is to PREVENT illnesses from happening in the first place - not detect them.
While I’m certainly grateful that our public health surveillance system has improved over the years and is increasingly able to detect clusters of illnesses often associated with food, so we can detect outbreaks earlier in their epidemic curve and remove contaminated foods from commerce, the fact that the outbreaks are still happening is of concern and unacceptable.
Moreover, if you look at the number of outbreaks regulatory agencies are investigating from year to year, after an initial decline during the pandemic, the number of outbreaks are back to a higher rate and not changing much year to year.
And the most damning of all is Food Net data published by the CDC, who are the ultimate score keepers of how our nation is performing in the area for food safety. If you take a look at that past 25 years of CDC tracking the incidence of illnesses due to pathogens often transmitted via food (number illnesses per 100,000 population), the results are very disturbing. For many of the pathogens of concern (i.e. Salmonella, Shiga Toxin Producing E coli (STEC), Campylobacter, & Listeria), the incidence of foodborne illness in our country has not changed much in 25 years, and in some cases, they’ve actually increased.
Think about that for a second. Despite the fact that we’ve passed FSMA, we’ve trained millions of employees, conducted tens of thousands of inspections by both the private and public sector, and tested millions of samples per year, the incidence of illnesses due to many foodborne pathogens has not changed in decades.
These results remind me of a quote by Albert Einstein who said, “Insanity is doing the same thing over and over again and expecting different results.”
It’s time for us as a nation to get serious about “food safety reform”, reTHINK what we're doing, and - in my view - return to something we started when I was at FDA called a “New Era of Smarter Food Safety.”
Straight Talk on Food Recalls
Now, let me set the record straight on food recalls. Here too, I’ve heard food safety professionals on the news say that recalls are a sign that the food system is working, because it’s allowing food that does not meet standards, some of it even harmful, to be removed from commerce.
Once again, the goal of any production system, as taught by Edward Deming, is to create processes that allow products to be produced free from defects – rather than trying to catch defective products after they’ve been produced.
Sure, if a contaminated food product is on the market, we need modern recall systems to retrieve it and prevent additional illnesses, but we should be clear that having to execute a food recall is a "failure" in the primary order. It’s a sign that a food production system was not under control for the product or lot number in question. For Class I recalls, it also indicates a potential safety issue with a food, which has or can pose harm to consumers.
And for recalls to be characterized as a good thing, beyond the contaminated food that may have been or might be consumed, this framing also misses the mark on many other fronts.
For example, recalls also result in:
Supply Chain Disruption – in many recalls, especially for products that serve as an ingredient in other foods, one contaminated item can result in hundreds to thousands of different food SKUs being affected. That often results in tremendous inefficiencies and subsequent ingredient-containing recalls throughout the food system.
Financial Costs - food recalls are not free. For every recall, food companies incur significant costs, including retrieving and disposing of the affected products, legal fees, and lost revenue. And while the cost of a recall can vary, one study suggested that the average cost of a recall to a food company is $10M in direct costs, in addition to brand damage and lost sales according to a joint industry study by the Food Marketing Institute and the Grocery Manufacturers Association.
Consumer Trust – in a recent survey conducted by PEW, slightly over half of Americans (53%) reported avoiding buying certain brands or types of food because of a recall or advisory. In my mind, that’s an alarming high figure. As someone who worked for a food retailer, I can tell you what we want is for Americans to go to the grocery store and buy foods not having to worry about their safety. Remember, food safety is first about human safety and public health, but it’s also about consumer TRUST.
In no other profession, whether it’s the manufacturing of medical equipment, medicines, airplane parts, would we accept the notion that recalls are a sign that the system is working – neither should we in food.
In conclusion, NO, foodborne outbreaks and food recalls are NOT a sign that the system is working.
While I do believe that on balance our food system is generally safe (when you think about food consumption on a per capita basis), I also believe that there are too many foodborne outbreaks, illnesses, and recalls… and that there is more the public and private sector CAN and MUST do. Consumers expect and deserve that of us.
But it begins with an unwillingness to accept the status quo.