Chain of events: a blog of Food Chain Intelligence

The Food and Drug Administration (FDA) is seeking comments on an advance notice of proposed rulemaking (Docket No. FDA-2010-N-0013—Implementation of Sanitary Food Transportation Act of 2005), in regards to the safety of foods during transportation. The FDA is also requesting data and information on food transport practices, contamination of transported foods and any associated outbreaks. FDA is taking this action as part of its implementation of the Sanitary Food Transportation Act of 2005, which requires the issuing of sanitary regulations to be followed by shippers, carriers by motor vehicle or rail vehicle, receivers, and others engaged in food transport. This action is also part of a larger FDA effort to focus on prevention of food safety problems throughout the food chain.

Recent US incidents involving food transport as a source of contamination include:

a) The contamination of corn gluten used in dog food while transported in a rail car in 1974. The corn gluten was determined to have been transported in a rail car that had been previously used to transport lead monoxide. Samples taken of the dog food in which the corn gluten was used revealed that it was contaminated with lead monoxide at levels ranging up to 28,000 parts per million. This case was investigated after FDA received reports of several sickened dogs.

b) The contamination of soybean hulls (used as animal feed), contaminated by barium carbonate in 1989. The aforementioned chemical is used in rat poison and paint. The contamination occurred in a rail car that had previously been used to transport barium carbonate.This incident resulted in the deaths of dairy cows in herds from both Louisiana and Texas, and high levels of barium carbonate were detected in milk from two of the affected herds by the State of Louisiana.

c) Several reports of some trucks that hauled garbage from the New York/New Jersey area to Midwestern landfills, and that were used subsequently to carry meat, poultry, and produce.

d) In 1994, a large multi-state outbreak of salmonellosis was associated with an ice cream mix that became contaminated during transport in tanker trucks that had previously hauled raw liquid eggs.

e) In 1999, an outbreak of Salmonella Muenchen occurred in 15 States and 2 Canadian provinces with more than 300 cases reported. The product was fresh orange juice, a portion of which was imported. Several serotypes of Salmonella were isolated from tankers used to carry the juice .

f) In 2007, the Motor Carrier Division of the Michigan State Police reported 22 cases of illegal and unsafe food transport on Michigan highways during 2006. The findings included:

-Raw poultry hanging from the roof inside the cargo area of a truck, with juices dripping onto open boxes of produce below, and with juices from the raw poultry dripping out onto the pavement from under the rear cargo box doors. The food was being transported in an unrefrigerated truck with an internal temperature greater than 21 degrees celsius;
-Truck(s) with no refrigeration unit;
-Truck(s) with the refrigeration unit turned off or not working; and
-Truck(s) with a working refrigeration unit that was not set at the correct temperature

g) In 2009, peanut butter and peanut paste were confirmed as the source of a large multi-state outbreak caused by Salmonella Typhimurium.The firm recalled a large number of its products, including products distributed in 1,700-pound tanker containers, because the products had the potential to be contaminated with Salmonella.

Although there are no less than 15 FDA regulations and guidance document that include points to be considered in the transportation of foods, there are only three guidance documents that specifically address the transport of foods: 1)Guidance on Bulk Transport of Juice Concentrates and Certain Shelf Stable Juices; 2) Guidance on Food Security Preventive Measures for Dairy Farms, Bulk Milk Transporters, Bulk Milk Transfer Stations, and Fluid Milk Processors; and 3) Guidance on Food Security Preventive Measures for Food Producers, Processors, and Transporters.

A few of the questions posed by FDA to the industry are:

-What are the amounts and percentages of foods that are transported completely enclosed by packaging, not completely enclosed by packaging (e.g., grain, some fresh produce items), or in bulk tanks (e.g., juices, oils)?
-What proportion of vehicles is exclusively dedicated to transporting foods? What proportion of vehicles transport both food and non-food products?
-What industry standards exist for the cleaning of food transportation vehicles?
-How is the adequacy of cleaning vehicles (including bulk vehicles and non-bulk vehicles) assessed?
-What procedures and practices are in place to prevent contamination of foods not completely enclosed by packaging during transport?
-How are the physical integrity and physical security of a food transport vehicle ensured during its run?
-What procedures and practices are in place to ensure temperature control for time/temperature control for safety foods?
-What types of food products are typically transported simultaneously?

Having performed some assessments in perishable supply chains that require answers to these questions, I think that the task of FDA is huge.

In Australia, there are no reliable statistics on food poisoning outbreaks caused by unsafe transportation. Of particular concern are imported ingredients and products: for many of these, the supply chain is so complex that no effective trace back is possible. For example, 14 outbreaks of foodborne disease were linked to imported foods between 2001 and 2007. In 2009, a multi-state outbreak of hepatitis A was associated with semi-dried tomatoes. Trace back of semi-dried tomatoes consumed in Victoria revealed a complicated supply chain with multiple suppliers to multiple brands and imported product that may be mixed or re-packaged for sale. The OzFoodNet Working Group suggested improvements to the documentation of the supply and distribution chain of tomatoes and other components used for the production of semi-dried tomatoes in Australia.

Naturally, an integrated electronic traceability program would be much more effective than simply improving documentation flows. A full example of implementation for fruit and vegetables is given in the PMA website.

The USDA released a report on the potential health effects of pesticides on food. The report was written by a panel of experts from the Environmental Protection Agency,the University of California, the Robert Wood Johnson Medical School, the University of Michigan and the University of Kansas.

In the report, the authors analysed the validity of the “dirty dozen” list, or products that were deemed to contain the highest detection rates of pesticides residues in a Guide published by the Environmental Working Group, a non-profit organisation that focuses on disseminating information on public health and the environment.

The ” dirty dozen” includes (starting with the worst “offender” and in a descending order): peach, apple, capsicum, celery, nectarine, strawberries, cherries, kale, lettuce, grapes (imported), carrot and pear.

EWG assembled the list by analyzing databases of pesticide residue measurements collected by the U.S. Department of Agriculture (USDA) in its Pesticide Data Program (PDP) and the Regulatory Monitoring Program and Total Diet Study of FDA’s Center for Food Safety and Applied Nutrition.

The key conclusions about the validity of the “dirty dozen” list were the following:

1) The list of products was not built using a “risk analysis” approach, which is the standard method for risk assessment in organisations that regulate national food safety. There are methodological issues that critically affect the credibility of the list.

2) There are no studies that specifically link pesticide residues in the diet with health effects. Those epidemiologic studies that posit a link to health effects evaluate populations living in primarily agricultural environments and who are also exposed via other pathways. However, the report agrees in that pesticide intake should be limited.

3) In relation to the differences between organically-grown vs conventionally grown agriculture,the authors concluded that

a small number of differences in nutrient content exist between organically and conventionally produced foodstuffs and that, whereas these differences in content are biologically plausible, they are unlikely to be of public health relevance.

The currently-available scientific data do not provide a convincing argument to conclude
that there is a significant difference between the nutritional quality of organically grown
food and food grown with conventional agricultural methods.

Overall, the assessment was that the “dirty dozen: list was:(a) misleading to consumers, (b) an impediment to public health because it discourages consumption of fresh produce and (c) lacks scientific evidence that the pesticide levels found pose any risk.There is no reason why a consumer should use this list to guide their purchasing decisions for fruits and vegetables.

The website containing the report also has an online calculator to see how many servings a man, woman, teen or child could consume and still not have any adverse effects from pesticide residues. I was pleased to see that, if I consumed US products all the time, I would need over 10,000 servings of lettuce per day to reach dangerous toxicological levels. This is even assuming that the lettuce consumed contained the highest pesticide residue recorded for lettuce by USDA. I am not likely to reach this level, even now that I am dieting to lose those extra kilos after my 1-month visit to Mexico (I utterly enjoyed each kilogram gained!).
Cheers.