As I Recall

There has been quite a lot of news concerning food recalls in the past few years topped off by last week's cantaloupe (it's really a muskmelon) recall for Salmonella contamination. Those of us in the food industry tend to keep up-to-date on recalls, but I wondered how much anyone else knows or understands about them.

A recall is a voluntary removal of product from the market; it could be due to contamination, adulteration, or misbranding. You noticed I said voluntary? Yep, these are voluntary actions taken by the manufacturer; the law doesn't authorize the FDA or USDA to order a recall, but I'll explain that in more detail in a bit. Depending on the food in question, it will fall under the jurisdiction of the USDA or FDA. Meat, poultry and most egg products belong to the FSIS (Food Safety and Inspection Service) division of the USDA, all other food products belong to the FDA (along with animal feed, vet supplies, medical devices, human drugs & cosmetics). The process for recalls and the recall levels are essentially the same for both agencies. They rank from least severe to most severe as follows:

• Market Withdrawal - minor violation not subject to legal action
• Class III - exposure to violative product is not likely to cause adverse health consequences (Examples: mold, yeast, off-flavor, leaking container)
• Class II - exposure to violative product may cause temporary or medically reversible health consequence or where serious health consequence is remote (Examples: hard or sharp object 7m - 25mm in size, Staphlococcus, unapproved color added)
• Class I - exposure to violative product has reasonable probability of causing adverse health consequence or death (Examples: botulinum toxin, Salmonella, Listeria, undeclared allergens present)

The Class I recalls are the ones you see, hear, and read about in the news, but all recalls are posted; the FDA recalls can be found here and FSIS recalls can be found here. Although the press often reports that the FDA 'ordered' a recall, as I stated before, the truth is recalls are almost always initiated by the company who calls the FDA and explains the issue.

Recalls can be requested by the FDA (or USDA) who may find a problem during an inspection or after receiving a report of a problem from a consumer or the CDC (Center for Disease Control). If a company does not recall a product on their own the FDA can ask a judge for the right to have a U.S. Marshall seize the product and/or issue an injunction against the company to stop the production or distribution of the product. Believe me, it is very rare for a company to refuse to recall a product after notification of a problem from the FDA. No company wants to have defective material out in the marketplace. Even voluntary recalls have put companies out of business - just imagine what the press would be like for a company who refused a recall!

There are strict guidelines for companies to follow concerning recall procedures outlined in the Code of Federal Regulations, which those so inclined can find here. What is important to know & understand is that there are rules in place for how a company handles a recall and what information is shared with both the FDA and the public at large. It is also important to know that the FDA (and yes USDA) follows-up on all recalls to make sure that the recalled product is accounted for and properly disposed. The FDA also makes sure a corrective-action has taken place so they and the company know how & why the problem occurred. I'll talk a bit more about what programs companies have in place to avoid a recall next week, but for those who are interested in food safety, this is a cool blog from the International Food Safety Network to tide you over!