Salmonella, food safety and potato chips

When last we visited the US food safety system during the Bush administration it was busy serving up peanut butter with a side of Salmonella. That one caused over 4 thousand product recalls, 700 Salmonella cases and at least 9 deaths. Now it's Salmonella serovar Tennessee in hydrolyzed vegetable protein (HVP), a common flavor enhancer used in all sorts of food products, including, according to the FDA, soups, sauces, chilis, stews, hot dogs, gravies, seasoned snack foods, dips and dressings. An important difference -- so far -- is that there are no illnesses traced to the contaminated ingredient. Progress, I guess. But in other respects the stories sound pretty similar:

Federal inspectors concluded that a food company that produced hydrolyzed vegetable protein (HVP) at the center of a series of food recalls continued to ship its products after it learned of Salmonella contamination in its processing facility, the FDA said yesterday.

The FDA said the company, Basic Food Flavors Inc., Las Vegas, continued to distribute its HVP paste and powder until Feb 15, despite the fact that its private lab found Salmonella in environmental samples collected at the plant on three different occasions, twice in January and once in early February.

The FDA said its inspection also exposed several problems with the company's building and its manufacturing procedures.

In a statement accompanying its inspection report, the FDA said the firm filed a report through the FDA's new Reportable Food Registry after one of its customers found Salmonella in the company's HVP, prompting an FDA investigation that began on Feb 12 and found Salmonella Tennessee on processing equipment. After discussions with the FDA, the company on Feb 26 announced that it was recalling all HVP it had produced since Sep 17.

According to the inspection report, called form 483, on Feb 19 the company's private lab reported finding Salmonella in a finished lot of product. (Lisa Schnirring, CIDRAP News)

But as Kevin Allen [an assistant professor of food microbiology at the University of British Columbia] observed over at Barfblog, it isn't just the supplier that has a responsibility. Food producers, especially very big ones, also have a responsibility to test the ingredients they put into their product. Instead, to cut costs, they are more and more relying on a "certificate of analysis" from the vendor (here Basic Food Flavors, Inc.) that the ingredient was microbiologically safe. Both this case and the Peanut Corporation of America case show why such certificates should be reasonably relied upon. Time to start testing again.

Meanwhile we see what can happen to a big food producer like Proctor & Gamble, makers of Pringle's. In keeping with a recommendation by the FDA, P&G is voluntarily recalling two flavors of their potato crisps, Pringles Restaurant Cravers Cheeseburger and Pringles Family Faves Taco Night potato crisps. But why should I tell you about this when there is a more authoritative source:

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"The FDA said the company, Basic Food Flavors Inc., Las Vegas, continued to distribute its HVP paste and powder until Feb 15, despite the fact that its private lab found Salmonella in environmental samples collected at the plant on three different occasions, twice in January and once in early February."
I hope the FDA prosecutes Basic Food Flavors Inc to the full extent the law allows; the fact they put profit before the health of millions is utterly inexcusable.

Dear Revere,

Interesting post. I was not aware that S. Tennessee was a serovar of significant public health importance. Is this an unusual event or has this serovar been associated with cases of human disease?

There are however a few points that I feel need some more clarification or fine tuning. The fact that the company kept producing product in spite of positive environmental samples is not particularly unusual or, indeed, too risky. Environmental contamination of food processing facilities is common on a day to day basis and does not mean necessarily that a significant contamination will occur on the finished product. It usually means that cleaning protocols need to be looked at. In fact any particular microbiological test should not be looked at with excessive attention because microbiology in general is quite poor at giving garantee of product safety. Food pathogens tend to be distributed in an extremelly un homogeneous way through the environment and product and random sampling (especially if we are simply sampling at level required by legislative requirements are wholly insuficient as a snap shot indicator of what is happening at a particular moment. They can only be usefull on a long term as trend indicators of underlying problems occurring.

To me what is really worth of criticism is the trend, which comes from many years which started in the states and has now spread through Europe, as I was saying the trend of de-regulation of the food safety sector, that companies will "self-regulate" that HACCP is some sort of Graal that will magically resolve hygiene problems and that therefore, legislation can adopt a "light touch2 approach and be less prescriptive in the requirements it imposes to the industry.

Reality is: HACCP is on it's conception and basis a voluntary system, success depends completelly on management in a particular factory being willing in adopting it. It is pure stupidity to force implementation through legislation. You can place market incentives for people to adopt it, but for the operators who work in the margins of the law, that are not sensible to these issues only prescriptive measures will force them to adopt a minimum set of hygiene procedures and only if they are under the constant surveillance of a regulating authority. The only reason why they set refrigetrators to 7 Celsius or 4 or even have them in tefirst place is because the law prescribes such measures of care.

In this context increased microbiological sampling should be adopted in principle but I do wonder if this should be a first priority. Microbiological sampling is incredibly innefective at assessing the safety of a particular batch of food.