by Jennifer McEntire and David Acheson on September 13, 2012 in Food Safety
They say that those who don’t know history are doomed to repeat it. Back in the days of PCA we saw recalls happening from January to July 2009 because companies just did not know who was in their upstream supply chain and did not have effective product tracing practices in place. The recent rash of mango recalls is not nearly as bad and will not go on as long, but still has some worrying parallels with the rolling PCA recalls of 2009.
It’s been over two weeks since the first public recall notice was issued related to mangoes associated with Salmonella Braenderup. And the very first public notice in the US was not from the source, it was from a retailer, Ahold, who on August 27, in the interest of protecting public health, pulled the product in response to information received from their supplier combined with their knowledge of an outbreak investigation in Canada. Up north, one mango importer issued a recall on August 24 and later that day the notice was updated to include the “Daniella” brand (a brand of the Splendid company, although that was not identified until the Ahold notices). For just about a week, recalls continued to be posted as other firms realized that these mangoes were part of their supply chain. This begs the question, how much evidence does a firm need before issuing a recall?
Why did Ahold alert its customers to this recall before others did? In the case of mangoes, the FDA was still investigating the outbreak when Ahold announced that they were removing the product based on a voluntary recall issued by their supplier. How does one balance the safety of consumers against the potential damage to a product category? In this instance, Ahold was aware of the Canadian outbreak and link to mangoes, likely alerted and probed their supply chain, and acted on the information they gathered. Rather than quietly pulling the product from the retail shelves upon hearing that the brand owner, in this case Splendid, was concerned that there was an issue, Ahold made the bold move to announce the issue and contact consumers who had purchased mangoes using loyalty card data. This was a prudent move, given that it’s evident that retailers are not without liability when they sell potentially contaminated product. In this instance, it also set in motion a series of events, including an article in USA Today that was followed by numerous retailers recalling mangoes in the days following the initial notice.
What about retailers who aren’t sure where their mangoes come from? How does a firm, in the absence of a recall from their supplier, find out if one of the products they are selling is in fact part of a contaminated batch and make an internal decision to recall a product? When a retailer learns that mangoes are associated with illness and that recalls are starting, proactive retailers call their suppliers to inquire about the source, as Ahold likely did. And often, the supplier needs to check on their source, and it may go back yet another level as the supplier’s supplier needs to check their source. Meanwhile what is the retailer to do? Should they wait and continue to sell what may be a contaminated product thus putting their customers at risk and creating potential liability issues? Or should they take a conservative approach and pull the product off the shelves until they know? With a short shelf life product this may result in the product spoiling before it can be put back into commerce, and it is unlikely the retailer will be able to recoup the cost from their insurance if ultimately the products were not deemed to be part of a contaminated batch. Additionally, this wait and see approach prevents the retailer from taking much meaningful action to protect their customers because delayed outreach likely means that the product has already been consumed.
What this does is put the retailer between a rock and hard place. One up/one back does not work the way it’s done today. FSMA does nothing to change the current 24 hours that firms have to respond to regulatory requests for product tracing information, and some companies use this as the standard for their communication with their supply chain partners as well. Tracking and tracing up and down supply chains is not swift, as evidenced by the week plus of announcements. Currently, most firms must wait as word travels through their supply chain – and then they must be confident that the information is correct, and that there wasn’t a spot market purchase three steps back in the chain that someone forgot about.
Why is this so complicated? In this instance, there were several importers in both the US and Canada. This is not unusual, but again, makes the one up/one back tangled rather than linear. In Canada, in at least one instance, the mangoes were repacked and the “Daniella” brand sticker was replaced with a different brand. Thus, a retailer or consumer looking at their “Catania” brand mangoes would have a false sense of security. Thirdly, the recalled mangoes were not only sold in their intact form, but were sliced and diced for use as ingredients in other items like fruit salads and salsas. It’s impossible to know the origin of those mangoes once the label is removed and the product is transformed just by looking at it, unless the inputs and outputs of this transformation are well documented and the information is readily accessible.
In some ways, this recall is reminiscent of the Michael egg recall earlier this year as well as the infamous PCA recall of 2009. One difference is that in both those instances, the manufacturer expanded the recall so that the amount of product recalled was substantially larger than originally thought. The widening of the recall net means that one day product may not have been associated with the recall, and the next day it was. This hasn’t happened with mangoes. Yet. The current mango situation mimics both of these prior recalls in that both eggs and the peanut products were ingredients, as were the mangoes, and thus the recalls cascaded and the number, types, and amount of recalled product grew exponentially.
Many companies tout their commitment to consumers and the priority they place on food safety. But when it comes to the unknowns of an outbreak, where firms know that they handle the product type, but are uncertain as to whether they have handled the implicated product, there are other factors at play. Simply recalling all products in that category (e.g., all mangoes) harms the entire industry, and that approach clearly creates innocent supply chain victims. However, as soon as a product is identified by the media (including social media), it’s likely that the category will suffer. The alternative is to “wait and see,” which puts consumers at risk while information slowly creeps from company to company. We’ve continually stressed the need to know who is in your supply chain so that when consumers, who’ve heard that mangoes are causing illness, ask you if your mangoes are involved, you know the answer. It’s also important that the decision making process within a firm is understood so that as information comes forward, decisions can be made quickly.
Each outbreak and each recall is different. While the challenges are often unique, themes emerge that firms should be learning from that can put them in a better place to protect both their customers and their brands. The situations discussed above are going to continue but, as we are now seeing, retailers are in the cross hairs of plaintiff attorneys, and thus want to move quickly and decisively when needed. That is only possible with good upstream supply chain visibility. Even if firms want to maintain the security of a one up/one back approach, it has to be built to allow much more rapid information sharing and verification. Of course the optimal approach is to have the prerequisite programs and preventive controls so that illness never happens in the first place. But even with the best preventive programs recalls will still happen.
This week, FDA Deputy Commissioner for Foods Mike Taylor addressed the Science Writers Symposium and provided an update on FSMA. While he acknowledged the tremendous amount of work to be done, he also highlighted FDA’s accomplishments. Stay tuned as we prepare our summary and analysis of them.