FOOD INDUSTRY COUNSEL LLC

By SHAWN K. SteveNS

For the last couple of years, we have regularly reported that the number of recalls of USDA-regulated products had been dropping to stunning lows. From the high number of annual recalls consistently ranging between 120 and 150 between 2015 and 2019, there was a precipitous drop to 35 recalls of USDA-regulated products in 2020. In 2021 there were 46 recalls, and in 2022 there were 45. As I have repeatedly stated in the past, with over 6,500 USDA-FSIS-inspected establishments, the extremely low numbers of recalls in the past couple of years represent an accomplishment for which the industry should be proud.

With that background, however, I noticed recently that these positive trends appear to be slowing or, perhaps, even reversing. Indeed, so far in 2023, there have already been nearly 50 recalls of USDA-regulated products. Given the current trajectory, this could equate to as many as 86 recalls by the end of the year. If that were to occur, it would represent an increase of nearly 100% in the number of annual recalls when compared against 2022.

So, what’s driving the significant change in recall trajectory? The answer, as is usually the case, is hard to discern. It could be that, with COVID now mostly in the rearview mirror — notwithstanding the occasional short-lived pop in novel and unique variants — the agency has become more aggressive in focusing more on food safety and less on personal virus avoidance. It could also be that, as we have entered a new year, and the agency has announced new and novel policies shifts — such as the desire to target Salmonella as an adulterant in certain poultry products — that there is a new aura, incentive, and motivation to do more to protect the public health. It could also be that, having experienced a few good years with hardly any recalls whatsoever, the industry let its guard down slightly and now the consequences are beginning to show. All of these theories, however, are admittedly speculative. Some, all or none could potentially account for the rise in recalls we are now witnessing.

Another possible theory, and one which I think may have some substantive merit, is the increased collaboration between USDA, FDA and CDC in the pursuit of preventing foodborne illness. Indeed, the agencies are increasingly communicating their intent to work closely together to protect the public health. This comes in many forms, which can and does include mirroring policy where appropriate, collecting and distributing food safety data, and sharing information regarding food safety issues that arise in dual-jurisdiction facilities.

In turn, both FDA and USDA are routinely collecting environmental and finished-product food samples and testing them for the presence of pathogens. When present, Whole Genome Sequencing (WGS) is performed to show the genetic signature of the organism. This data is uploaded into the GenomeTrakr Database and is used to solve outbreaks. In turn, CDC, along with the state health departments, have become skilled in interpreting this data to identify emerging clusters of illness and identify their common source — all of which can lead to an increase in the total numbers of recalls.

So, regardless of the theory to which you subscribe, the fact is that the number of recalls of USDA-regulated products is increasing. As a result, now would be the time to review your programs, and button up any gaps, so that your company doesn’t become a part of this unfortunate but real trend.

www.provisoneronline.com   |   october 2023