The sign inside my favorite Trader Joe’s announced a recall of raw cashew pieces due to concern over Salmonella. The soup for my dinner party would switch from a cauliflower-cashew to a sweet potato one. Minor inconvenience for me; major one for the food producer and anyone potentially made ill from the contaminant.
Salmonella is a nasty pathogen. The Centers for Disease Control and Prevention (CDC) noted that most people infected with the pathogen will develop diarrhea, fever, and abdominal cramps within 12 to 72 hours. The illness continues for four to seven days. Yet, in some people the infection manifests as reactive arthritis where joint pain may last for months or even years, and in others the contamination moves to the blood stream where untreated Salmonella can become a death sentence.
This is not a minor matter. It is estimated by the CDC that 1.2 million people are sickened each year in the United States due to non-typhoidal Salmonella. Approximately 450 people will die as a result.
Go back to the same Trader Joe’s or Safeway or Costco or Publix of your choice and find other pathogens of concern. Within weeks of the cashew recall, Listeria monocytogenes was found in certain Dole leafy green products, Shiga toxin-producing E. coli O157:H7 was linked to a certain rotisserie chicken salad, and shell eggs from Good Earth Egg Company were recalled for Salmonella. All of these outbreaks and recalls can impact the health of millions of people and account for millions in lost revenue.
What is the thread that runs through each of these pathogens? Testing.
Recently, three additional final rules from the Food Safety Modernization Act (FSMA) went into effect. These most recent rules address produce safety, accreditation of third-party certification bodies, and the foreign supplier verification program for importers of food for humans and animals. Each one addresses laboratory testing in some manner.
Testing may take many forms. For example, in investigating the outbreak of listeriosis from leafy greens, the Food and Drug Administration (FDA) notes, “Whole genome sequencing (WGS) has been performed on clinical isolates from all ill people and showed that the isolates are highly related genetically to one another.” To the north, the Public Health Agency of Canada states, “Laboratory results from the Canadian Food Inspection Agency confirmed a link between recalled packaged salad products and the outbreak of listeriosis in five provinces.”
In the rotisserie chicken case, FDA explains that the producer “initiated the market withdrawal when five preliminary analytical tests run by the Montana Public Health Laboratory all indicated the presence of E. coli O157:H7.”
Laboratory testing is also conducted within a food facility before the product enters the marketplace. This helps to ensure that the manufacturing site is free of contaminants that may otherwise be tracked into the food product. As explained by Blue Bell Creameries in a statement released on January 8, 2016, “The entire purpose of our enhanced environmental testing is to identify locations where bacteria could be found in our facility in order to properly clean and sanitize the surface and prevent contamination.”
Testing is performed to detect and identify foodborne pathogens in order to reduce their presence in a food product. In response to an E. coli outbreak, the Chipotle Mexican Grill offered a written commitment to food safety which explains how it now addresses food product testing:
It takes about five cases of whole tomatoes to supply a Chipotle every day. While we carefully washed those tomatoes, it’s not realistic to test every whole tomato after washing. Even if we were able to test each tomato, this would not guarantee the absence of pathogens, as some tomatoes could be punctured or have a loose stem area that allows pathogens into the inside of the tomato where they cannot easily be detected by testing. Instead, the safe way to prepare tomatoes for our fresh tomato salsa is to also wash them and then test them after they are diced. The tomatoes that are now prepared in our centralized prep kitchens are washed, diced, and the washed again and tested before packaging and shipment to our restaurants. In addition, the water used to wash the diced tomatoes is carefully monitored to make sure that it doesn’t allow cross-contamination between batches of diced tomatoes.
The three most recent rules from the FSMA address produce safety, accreditation of third-party certification bodies, and the foreign supplier verification program for importers of food for humans and animals. Testing is a fundamental component to the food safety process, as indicated in these most recent final rules.
For example, in the produce safety rule, the FDA requires testing sprouts or the spent sprout irrigation water for E. coli O157:H7 and Salmonella spp. In the final rule for the accreditation of third-party certification bodies, the FDA states that it will require that food safety audit reports from an accredited third-party certification body must include “whether any sampling and laboratory analysis… is performed in or used by the facility.” In the foreign supplier verification program final rule, the FDA requires importers to “retain documentation of each sampling and testing of a food.”
Yet, despite these references to testing, a key ingredient that is missing among the FSMA regulations is oversight of food laboratory testing. Important components for achieving accurate and reliable laboratory test results exist, but food laboratories are under no obligation to follow them. Quality controls, proficiency testing, personnel competency, and accreditation all remain voluntary undertakings for the food laboratory. Considering the enormous impact on public health, business, and trade, food facilities and the public should demand better oversight.
FSMA Section 202 calls for laboratory accreditation and the implementation of model laboratory standards, but it has not yet been promulgated. With the reliance on the results of food laboratory testing and the FSMA final rules already in effect, it is time to issue this needed rule.