A Recall Done Right
When the Nunes Co. learned on Saturday, Oct. 7, that it had a high level of E. coli in a reservoir used to irrigate its lettuce crops, the company immediately took action to recall 8,533 cartons of its Foxy brand green leaf lettuce distributed in seven Western states.
Before the start of business Monday, Oct. 9, it had isolated 98 percent of the cartons.
“Even though it was the weekend, we immediately brought in our recall team—sales managers, product managers, cooler managers and shipping managers—to determine where the product was shipped in the last four days,” recalls Tom Nunes, president of the Salinas, CA-based grower.
Using its highly sophisticated, customized enterprise system—tested in two mock recalls a year for the last eight years, the company was able to determine where the affected products were sent within a matter of hours.
Much of the product was on trucks or in its own warehouses, but some had been already shipped out to customers in Arizona, California, Nevada, Washington, Oregon, Idaho and Montana.
“We had about 90 percent isolated by 7 p.m. on Saturday, and knew that the rest had been sent to receivers in seven states,” Nunes says.
The company reached out to its receivers right away, and, by midnight, had up to 97 percent of the product isolated. Only 3 percent, or 250 cartons, had made it into the hands of consumers.
Nunes reached out to the FDA and the media and got 90 more cartons back from people who had already bought the products. There were only 160 cartons that it couldn’t retrieve.
“Our distributors did a very good job in helping us recover 98 percent of the product,” says Nunes. “Our knowledge of what happened in the spinach crisis helped us in a lot of the decisions we made.”
Two days after the recall, Nunes’ tests on the affected product revealed that E. coli had not made it into its lettuce crop, but still, the company was commended for taking such swift and thorough action.
“In the current climate following the recent spinach outbreak…this is precisely the type of action required by the industry when a grower, packer or processor suspects something may have occurred not in keeping with good agricultural practices,” says Tom Stenzel, president of the United Fresh Produce Association.
“It is important for all of those who work so hard to bring safe and healthy foods to consumers that the public recognize and appreciate a precautionary action such as this recall,” he continues. “As an industry organization, our association will always recommend that our members err on the side of caution and take all the steps needed to avoid even the potential of risk if they have doubts.”
Even the FDA, the agency charged with oversight in cases like the lettuce recall, commended Nunes. The agency said it views the firm’s prompt action as commendable, noting too that it is better to be overly cautious than to potentially put consumers at risk of contracting a serious food-borne illness.
But despite the industry accolades, Nunes isn’t ready to have a repeat recall. “We do two mock recalls a year, and they are pretty detailed, but when you apply it to a real recall, things change,” he says. “It is very expensive to issue a recall, but the entire industry has been very responsive and supportive.” ––L.K.
Expect FDA To Tighten Bioterrorism Act Enforcement
If there’s one good thing that can be derived from the recent spate of high-profile food-borne illness outbreaks linked to fresh produce, it’s a strong belief that the U.S. Food and Drug Administration (FDA) will have to step up its enforcement of the major food-related provisions in the Bioterrorism Act of 2002.
The Bioterrorism Act contained provisions to help the government track the source of an outbreak of food-borne illness and help notify companies that might be affected. One requires all companies—foreign and domestic—that produce, process, package, store, transport, sell or otherwise handle food for consumption in the United States to be able to identify within 24 hours all the sources and destinations of food products in their possession.
The other requires those same companies to provide emergency contact information to the FDA as part of an early warning system in the event of a food contamination.
FDA officials knew their current system was flawed months ago when, during an internal test of their Food Facility Registration Database, authorities failed to reach the proper person one-third of the time. FDA officials were able to reach an emergency contact at only two of every three facilities from a sample of 800 facilities listed in the database of almost 300,000 facilities worldwide.
In the test, conducted from July 10 to Aug. 2, the agency got responses from or talked with the right contacts about 66 percent of the time. The rate was 72 percent for U.S. facilities and 59 percent for foreign facilities.
Also in the test:
- People told FDA they were not the emergency contacts at 10 percent of U.S. facilities and 11 percent of foreign facilities;
- FDA couldn’t be sure they had reached the right emergency contacts because people didn’t speak English in 1 percent of U.S. facilities and 9 percent of foreign facilities;
- There was no response to messages left at 18 percent of U.S. facilities and 20 percent of foreign facilities.
“As a result of this test, FDA believes that it is imperative that immediate steps be taken by FDA and owners, operators and agents in charge of domestic and foreign registered facilities to improve the accuracy of the information in the Food Facility Registration Database,” the agency said in a statement at the time.
But for many, it will take more than that to halt the spread of food-borne illnesses across the country.
“This will force the FDA to give Bioterrorism Act enforcement some more muscle,” predicts Bruce Bowen, vice president of retail/wholesale solutions at Aldata Solutions, a European supply chain solutions provider with U.S. offices in Atlanta. “The FDA will have to put some teeth behind its Bioterrorism enforcement.
“The Bioterrorism Act outlines penalties for a lack of compliance, and it will be interesting to see how strictly they are enforced now,” he says.
“The FDA has to change the way they think,” adds Tom Appleton, assistant warehouse manager at J&J Snack Food’s DC in Pennsauken, NJ. “Who thought of things like terrorism 10 years ago, so now they’ll have to be more aggressive.” —L.K.