SGS Societe Generale de Surveillance : Undeclared Allergens and Pathogens Recalls, and Other Notifications

Everyday somewhere in the world food products are being rejected and or recalled because of a violation of the regulations of that country/area or a violation of basic food and feed safety parameters. Most of these violations are not quality issues, but issues that can result in harm or death to humans and animals. Most governments/areas have some sort of system for publishing this information to industry, government and consumers. Some of these information-gathering systems collect data from other sources as well.

One of the largest systems, Rapid Alert System for Food and Feed (RASFF), created in 1979, involves the governments of 32 countries. It operates around the clock to provide safety notifications to those governments, other agencies and consumers. Since June 2014, in addition to the standard RASFF portal¹ a consumer portal² has been added, which allows consumers to search recent notifications by specific countries. This consumer portal also provides a link to a specific country's consumer website. In addition to the recall or alert notifications, this portal also provides information on border rejections, information for follow-ups and information for attention. Another web portal that involves more than one government is the Food Standards Australia New Zealand (FSANZ) consumer level recalls³, which provides customer notifications to those two countries.

In the United States of America (USA), the US Food and Drug Administration (FDA)⁴ and US Department of Agriculture Food Safety Inspection Service (USDA FSIS)⁵ maintain separate recall notification sites and a combined site⁶ for a food safety recalls. Many of these sites allow anyone to receive notifications, via email, social media or phone applications. This availability is already apparent at the Canadian Food inspection Agency's (CFIA) recall web portal⁷.

In addition, all these notifications are tracked and traced. Whether this is done by the groups/agencies/governments providing the information or by external companies, this information provides insight into which issues are involved in/common to these notifications. This also provides feedback to the food and feed industry and indicates which areas need to be addressed.

In the FSANZ statistics, tracking food recalls from 2005 to 2014 reveals that 33% are from microbial contamination and 30% labelling/allergen issues. Of the microbial contamination, the top three causes are Listeria monocytogenes, Salmonella and E. coli. Most of the Listeria monocytogenes recalls were from ready to eat meat/poultry and dairy programmes which are typically held under refrigerated conditions for the long periods of time that allow Listeria monocytogenes to grow. The salmonella recalls are mostly attributed to a variety of items, including eggs, dairy, seafood and confectionery products. For the undeclared allergen recalls, the top three are peanuts, dairy and wheat/gluten recalls. The main product categories involved in these allergen recalls are processed products (33%), confectionery (18%) and baked goods (15%). After these two categories, foreign material and chemical contaminations are the principal causes of the remaining recalls.

If we look at the combined information from the US FDA, USDA FSIA and CFIA⁸, we notice that in the third quarter of 2015, 53% of recalls were due to undeclared allergens, of which the top three are dairy, soy and wheat/gluten. While peanut recalls were very high for the first quarter of 2015, industry action has reduced this recall activity significantly. Looking more closely at the big three pathogenic micro-organisms, that represent 41.5% of the recalls, Salmonella leads the way at 26%, Listeria monocytogenes follows at 13% and E. coli accounts for roughly 2.5% of the total recalls. This means that 94.5% of food recalls in the USA and Canada were because of either undeclared allergens or pathogens.

The RASFF 2014 annual report provides us with vast amount of information. For alerts, the number one issue is pathogenic micro-organisms, which account for 33% of the alerts. This is followed by heavy metals (13%), composition (8%) and undeclared allergens, at about 7%. Once again, the big three pathogens, Salmonella, Listeria monocytogenes and E. coli are the main concern. For Salmonella, fruit and vegetables, feed materials and herbs and spices were the categories of concern. For E. coli, meat and meat products made up almost all of the pathogenic issues. The Listeria monocytogenes problems centred around smoked fish. For the heavy metals category, there were issues regarding lead, arsenic and cadmium contamination, with mercury in fish still dominating the category.

Border rejections are slightly different to alerts. Mycotoxins is the number one issue, followed closely by pesticides, pathogenic micro-organisms, heavy metals, then adulteration/fraud. Most of the food fraud involved labelling non-compliance such as addition of water or ingredients, substitution of product or ingredients and false certification/documents submitted. Most of this activity was reported by the Fraud Network, which was established after the horsemeat crisis. The network information was mostly centred on meat products, fish products and honey fraud. Fraud is a growing area of concern for a majority of governments, as well as industry and retailers.

What is readily apparent is that the number of recalls from year to year isn't increasing rapidly, but unfortunately not decreasing either. Pathogenic micro-organisms worldwide are still the main reason for recalls. Some of these recalls could probably have been prevented by establishing a properly validated food safety plan that includes environmental monitoring, raw material and finished product testing. Additionally, the requirements of internal and external verification should indicate that the plan is functioning as intended.

Allergen control plans are an essential part of any food safety plan. Validating the cleaning process and the plan through testing is essential. Internal and external verification to confirm that the plan is functioning as required is absolutely necessary.

Heavy metals, mainly mercury, are associated with specific species of fish such as shark, swordfish, tuna, snapper and tile fish, so establishing a sampling plan with testing to assure compliance is a necessary requirement when shipping these products into the food supply chain.

Border rejections are happening in every country with most of the issues being the failure to comply with the regulatory standard of the receiving country. A supplier must assure the raw material is in compliance with pesticide, heavy metals or mycotoxins standards utilising proper sampling and testing plans. A food safety plan must be validated to control pathogenic micro-organisms. Specific products must have an environmental, raw and finished product testing plan. All these programmes must be verified through internal and external auditing to assure compliance.

Food fraud has been happening since time immemorial. The EU, US FDA and other countries and organisations are taking steady action to require the industry to combat these issues. With the finalisation of the Hazard Analysis and Preventive Control rules published by the US FDA, with the requirement to evaluate hazards in regards to intentional adulteration, it has become necessary for the food industry to establish this control in the food safety plan. Some industries, such as the olive oil industry, have taken tremendous strides in order to combat fraud, but others still need to resolve their problems.

Recalls will continue to happen; systems are in place to alert the consumers and receivers of the products. The monitoring of this information and feedback to the industry, hopefully will reduce the incidence of recalls, or at least reduce the incidence of those cases that result in illness and possibly death. Sampling programmes must be in accordance with the requirements of the receiving country and in compliance with accepted industry practice. Knowing what the testing results means and whether or not they are in compliance with the country that the product will be shipped to, is a necessary part of a food safety plan which must establish critical limits. Food safety plans must also be established to combat all known and reasonably foreseeable hazards and must be validated and verified for compliance.

For further information, please contact:

Jim Cook
Food Scientific and Regulatory Affairs Manager
SGS North America, Inc.
t: +1 973 461 1493

¹ Standard RASFF portal
² RASFF consumer portal
³ Food Standards Australia New Zealand (FSANZ) consumer level recalls
⁴ US Food and Drug Administration (FDA) recalls
⁵ US Department of Agriculture Food Safety Inspection Service (USDA FSIS) current recalls and alerts
⁶ FoodSafety
⁷ Canadian Food inspection Agency's (CFIA) recall web portal
⁸ US FDA, USDA FSIA and CFIA combined information