Until such time food companies can prevent all adulteration of food, one of the most effective public health tools for prevention of foodborne diseases in the United States is the surveillance for foodborne disease outbreaks and the identification of the adulterated food/product. Public health agencies have successfully worked for many years to improve food safety through identifying the cause of outbreaks of foodborne diseases, initiating food recalls — the intervention — and subsequently preventing the further consumption of adulterated foods.

The Centers for Disease Control and Prevention in collaboration with states and the Food and Drug Administration leads outbreak investigation efforts as part of its broader public health mission of surveillance and epidemic investigations of disease outbreaks. These efforts have prevented numerous illnesses and deaths as evidenced by the more rapid decline of reported foodborne illnesses associated with each outbreak once the source of the adulterated food has been identified.

Many outbreak investigations identify a link to a specific commodity of food, such as spinach, leading to subsequent recalls and reduced consumption of that specific food/product; a positive intervention step.

However, because consumers may only hear about the implicated commodity when they become aware of an active CDC investigation — before a branded product or commodity has been identified — or after an FDA recall, they often act out of sense of caution, and avoid all such food/product types. This has been the case for most outbreak investigations, but more significantly in the past decade during peanut butter and spinach outbreaks and a misidentified outbreak initially linked to tomatoes but actually caused by peppers. The cost in lost sales to the food industry just for these three outbreaks alone was in the billions.

Another important issue in the process of food recalls used as a means for public health intervention involves the communication of the recall information to the public. The primary purpose of the communication to the public is to prevent the further consumption of only that specific food or product identified as adulterated/recalled.  Often, when foodborne disease outbreaks are large, covering several states, many consumers who actually have the specific recalled product in their possession do not hear of the investigation or recall. These people continue to consume the food/products, likely leading to more cases of foodborne disease after the source of the outbreak is known. Take for example the multistate outbreak of listeriosis linked to whole cantaloupes from Jensen Farms in Colorado in 2011.

Without going into the details of how this outbreak occurred — some of which are still speculative — cantaloupes were linked to at least 147 illnesses, 33 deaths and one miscarriage across in 28 states, according to the CDC. The CDC and FDA reported that the source of the outbreak was cantaloupes from Jensen Farms on Sept. 14, 2011, and provided notice via the agencies’ websites and the national news of a voluntary recall of this product, telling consumers to inspect fruit and not eat these cantaloupes. However, the outbreak continued and cantaloupes continued to cause illnesses and deaths for 47 days after the announcement of the likely source of the outbreak.

Could the illnesses and deaths after the recall have been prevented with better communication to consumers who had the adulterated cantaloupes from Jensen Farms in their homes? Sadly another outbreak was reported with more than 141 illnesses in 20 states, with 31 hospitalized and two deaths, from cantaloupes again shortly after the Jensen farms outbreak; this time due to Salmonella Typhimurium. It had a similar illness onset curve as the Jensen Farms outbreak.

Some continuation of foodborne illness cases during an outbreak of foodborne diseases are also likely due to slow removal of recalled foods/products from retail store shelves. Although many major retail food chains have internal recall systems to alert their stores of foods/products that must be removed, thousands of independent grocery stores and other retailers, including gas stations, do not have sophisticated recall systems to track, identify and provide notice about recalled foods.

For example, when PHI members were facilitating a session on foodborne disease outbreaks at the Food Safety Summit in April 2015, retail grocery stores in the Baltimore, MD, area were still selling Blue Bell Ice cream with the exact code dates of that were recalled and reported to the public in January 2015. Thus, a recall monitor tool for consumers could also benefit food retailers who cannot afford sophisticated recall systems.

The challenge to public health then, is how can we more precisely improve communication of a food recall to the public.

First, we must better associate the recall specifically to a consumers’ purchases of the recalled food/product to increase the reduction of consumption of only that food/product. Second, we must improve consumer confidence with recall specificity, thereby increasing trust of related foods/products and protecting sales of similar foods/products.

We at Public Health Innovations (PHI) believe that these challenges can be resolved by directly linking a specific food/product and its manufacture date/lot code to a national recall notice by FDA — which is what the FDA uses to trace an adulterated product to its source and initiate a national recall — using software and mobile technology including smartphones and tablets. This technology could also, in the future, enable an earlier warning to consumers for very high risk products like baby foods or formula and/or vulnerable populations of consumers even before a national recall is initiated.

Several mobile computer app companies have attempted to develop and market products to do just this type of monitoring and alerting for consumers. But, there’s a big drawback in that users are required to scan each individual food/product bar code for they buy or have in their possession.

Likewise, all of the apps only scan the FDA recall list once at the time of scan, with a charge per scan mode, or requires the user to go to the FDA website and look for the recalled item on the daily list of recalled foods.

Several retail grocery loyalty programs propose to alert members of recalled food products they have purchased. However, the programs require membership and only cover purchases made at the issuing retail chain’s locations. Users must link their purchases at each visit to the store at the time of their purchase via scanning their loyalty card or smartphone code, reducing efficacy of capturing all products when they forget their card/phone app.

PHI proposes development of a recall monitor computer program application for mobile technology for consumers to enable active monitoring of FDA recall notices related to food safety.

The proposed innovation would provide value to consumers, food retailers and government agencies in two ways.

First, consumers and non-chain retailers would quickly learn about recalls for products they have in their homes or on their store shelves and, thus, unnecessary illnesses and deaths would be avoided.

Second, a more effective recall tool would reduce costs to government agencies and the food industry as recall communications and consumer actions become more precise to only the food/products associated with the outbreak and as outbreaks resolve more quickly. It might also help government speed up outbreak investigations.

Editor’s note: Public Health Innovations LLC is a business-to-business consulting company with a focus on innovation for public health intervention to prevent diseases that occur in schools, healthcare environments, and from foodservice (restaurants), retail, and food manufacturing facilities. For additional details on the author, please click on the byline.

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• A comprehensive walk through of how to build a food safety plan for each product and group of products specific to any facility;
• An exercise where students work on a food safety plan for a mock food company that produces several different types of foods;
• Use of several different product types and hazards for discussions about correct food safety plan development.
• Design and discussion of process preventive controls for expected hazards for each product type;
• Instruction about other required types of preventive controls using the mock company product scenarios and food safety plans to cover areas where process preventive controls do not control a hazard, including food allergens, sanitation and supply-chain preventive controls;
• Use of the same food safety plan worksheets that FDA inspectors are being trained on;
• Instruction on exact verification and validation procedures; and
• Discussion of the best means to perform record-keeping and provide documentation as evidence of the preventive control of food safety hazards of all foods.

If your PCQI uses these worksheets and procedures to build your food safety plans and then implements the management of preventive controls, compliance is all but assured I highly recommend this course, not only to establish a PCQI for each of your food facilities, but also for every CEO or president who leads their company’s manufacture and sales of human food. You will learn exactly what FDA expects you to do, but, most importantly, you will learn what your company should do to prevent foodborne diseases and physical and chemical adulteration of foods, and also about the prevention of undeclared allergen risk to your customers. In a recent survey of about 400 food companies by The Acheson Group and SafetyChain, only 10 percent of the respondents reported that their Food Safety Plans were completely updated in the context of FSMA readiness. Take this course, develop your food safety plans for each facility, be prepared for FSMA requirements, and once and for all establish your company as an industry leader in food safety. One more tip: I also noticed that several IFSH students taking the course to become Preventive Control Qualified Individuals (PCQI) are also looking for jobs in the food industry. This is a good source of newly trained, expert food safety plan developers for your facilities to easily develop and then manage your food safety plan to achieve FSMA compliance. Editor’s note: Hal King originally published this blog on The Lab.

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