FoodHACCP Newsletter

Food Safety Job Openings

12/30. Auditor - Americas
12/29. Metro Food Safety Specialist – New Orleans, LA
12/29. Dir, Food Safety & Quality – Tigard, OR
12/29. Quality Control Supervisor – Lytton, IA
12/27. Env Specialist - Food Safety Specialist - Iowa
12/27. QA Specialist/Lead – Pittsburg, CA
12/27. QA Lab Technician – Batavia, NY
12/25. Food Safety Specialist – Houston, TX
12/25. QA Coordinator – Columbus, OH
12/25. Food Safety Trainer – Chicago, IL

01/01 2017 ISSUE:789


Food safety inspections, Jan. 1, 2018
Source :
For the period ending Dec. 21. To file a complaint, call the state Environment Department.
ALBERTSONS, 600 N. Guadalupe St. Previous violations corrected.
BLAKE’S LOTABURGER, 2820 W. Zia Road. Cited for broken soap dispenser, ends of paper towels soiled and not in dispenser, used gloves on prep table, outer back door not well sealed, black mold on ice machine and walk-in refrigerator, lack of proper air gap on sink and hoses not cut back to prevent siphonage.
BLAKE’S LOTABURGER, 404 N. Guadalupe St. Cited for employee drink in prep area, dishes in hand sink, lack of paper towels at hand sink, no sanitizer or wash bucket set up, food buildup on ice machine, towel out of sanitizer bucket, ice scoop improperly stored, carbon dioxide cylinder not chained to wall, drain line lacking proper air gap, toilet paper outside receptacle and not covered, dumpster lids open, grease buildup on floors in dry storage room and no posting that inspection report is available upon request.
ELOISA CATERING, 228 E. Palace Ave. Cited for lack of soap at hand sink, lint buildup on kitchen vents and dishwasher hot water not turned on.
ALLSUP’S, 650 Cerrillos Road. Cited for employee drink and phone in prep area, lack of paper towels at hand sink, mold on ice machine, exposed fiberglass insulation, used gloves on top of prep area, outside carbon dioxide cylinder not protected from bird droppings, excreta on outside of building, bottom shelves in walk-in refrigerator made of absorbent wood, sinks not sealed to wall, tape on ice machine scoop, grime buildup on refrigerator door, carbon dioxide cylinder not chained to wall, lack of sanitzer test strips, drain line lacking proper air gap.
LA CHOZA, 905 Alarid St. Cited for lack of posted procedures for responding to vomiting and diarrhea events, employee drink in refrigerator, ice in hand sink, lack of paper towels at hand sink, mold on ice machine, no documentation for start time of how and when foods are cooled, no advisory on menu to warn of possible food-borne illnesses, unapproved pesticides, outer back door not well-sealed, dead rodent in trap, rodent droppings on unmoved paint, broken equipment, sinks not sealed to wall, broken equipment, drain line lacking proper air gap, walk-in cooler floors are absorbent, inadequate lighting in walk-in cooler, recent inspection report not posted and information on new regulations and training is not posted.
LEGACY, 3 Avenida Aldea. Cited for employee drink on microwave and food in danger zone.
MANGIAMO PRONTO, 228 Old Santa Fe Trail. Cited for food buildup on equipment and food contact surfaces, improper thawing process and nonworking thermometers.
NOISY WATER WINERY, 219 W. San Francisco St. Cited for ends of paper towels soiled and not in covered dispenser, no hand washing signage, toilet paper outside of receptacle and not covered, no trash can at hand sink and most recent inspection report not posted.
PATINAS AND MEZCAL LOUNGE, 4048 Cerrillos Road. Cited for employee drink in prep area, sanitizer bucket in hand sink, lack of towels at hand sink, no dented can policy for adulterated food, food buildup on ice machine and scoop, ice pooling on food, no documentation on startup and how and when food is cooled, no advisory on menu about increased risk of food-borne illnesses, food stored on floor, sinks not sealed to walls, drain line lacking proper air gap, hoses not cut back to prevent back siphonage, walk-in cooler floors are absorbent, sewer gas smell at bar floor drain, inadequate lighting in walk-in coolers and recent inspection report not available.
PIZZA CENTRO, 410 Cerrillos Road. Cited for moldy caulking and employee drink in prep area.
RED ENCHILADA, 1310 Osage Ave. Cited for food in danger zone, employee drink and phone in prep area, raw meat stored improperly, no documentation showing start time of how and when food is cooled, no consumer advisory on menu about risk of food-borne illness, containers in ice are too full, food thawed improperly and most recent inspection report not posted.
RESIDENCE INN BY MARRIOTT, 1698 Galisteo. Cited for ends of paper towels are soiled and not in covered dispenser, employee’s nail file stored with silverware and drain line lacks proper air gap.
CHRISTUS ST. VINCENT HOSPITAL, 455 St. Michael Drive. Cited for hand sink in food prep area, ice in hand sink, dented can mixed with good stock, lack of dented can policy for adulterated food, pooling ice, exposed insulation, food temperature in danger zone, containers in salad bar too full, pigeon droppings on outside carbon dioxide cylinder, broken equipment, improper refrigerator temperatures, dirty fan guards and nonfood contact surfaces, lack of hot water at hand sink, drain line lacking proper air gap, toilet paper not in covered receptacle, inadequate lighting in walk-in coolers, grease on exhaust hood and most recent inspection report not posted.
BURGER KING, 3478 Zafarano Drive. No violations.
BURRITO SPOT, 5741 Airport Road. Walk-in refrigerator thermometers are not accurate.
DPS TRINITY SERVICE GROUP, 4491 Cerrillos Road. No violations.
EDIBLE ARRANGEMENTS, 825 Cerrillos Road. Cited for unprotected lights.
FAIRFIELD INN AND SUITES, 3625 Cerrillos Road. No violations.
HORSEMAN’S HAVEN, 4354 Cerrillos Road. Cited for spray bottle not properly labeled, joint seal separating at sink, particle accumulation on nonfood contact surfaces and wall by hand sink not in good repair.
INTERFAITH COMMUNITY SHELTER, 2801 Cerrillos Road. Cited for improper sanitizer concentration, some volunteers lack hair restraints, meat products improperly stored, dust on exhaust hood,
OPUNTIA CAFE, 922 Shoofly St. Cited for wrong test strip provided and improper hot water temperatures.
PAPER DOSA, 551 Cordova Road. Cited for particle accumulation on ice machine and nonfood contact surfaces.
SAN MARTIN RESTAURANT, 4250 Cerrillos Road. Cited for some food items not dated, insufficient food cooling practices, sanitation mixture not at proper concentration, light bulbs out and dust on ceiling vent.
SO CAL MOBILE CAFE, various locations. No violations.
THE GOOD STUFF, 401 W. San Francisco St. No violations.
TRES COLORES RESTAURANT AND CATERING, 8380 Cerrillos Road. No violations.

Number One Food Poisoning Outbreak of 2017: Cyclospora
Source :
By Linda Larsen (Dec 31, 2017)
The number one food poisoning outbreak for 2017 was the huge Cyclospora outbreak that sickened more than 1,000 people in the United States. As of September 17, 2017, the last CDC update stated there were 1,054 laboratory confirmed cases in 40 states. This outbreak was not solved.
Every summer there is an increase in cyclosporiasis cases in this country and around the world. The illness is usually seen among people who travel internationally to countries where this parasite is endemic. But 592 of those sickened did not report any international travel.
The case count by state of those 592 patients is: Arizona (1), California (10), Colorado (6), Connecticut (23), Florida (78), Georgia (13), Illinois (17), Indiana (4), Iowa (14), Kansas (2), Louisiana (12), Maryland (12), Massachusetts (14), Michigan (3), Minnesota (13), Mississippi (1), Missouri (13), Montana (2), Nebraska (5), New Hampshire (4), New Jersey (19), New Mexico (1), New York (excluding NYC) (15), New York City (32), North Carolina (48), Ohio (17), Pennsylvania (2), Rhode Island (2), South Carolina (7), South Dakota (4), Tennessee (4), Texas (172), Utah (1), Virginia (9), Washington (1), West Virginia (2), and Wisconsin (9). The most recent case was reported on September 13, 2017.
Public health officials have not identified any possible vehicle. Outbreaks in other years have been linked to different kinds of imported fresh produce, including cilantro, mesclun lettuce, snow peas, and raspberries.
The symptoms of cyclosporiasis include loss of appetite, weight. loss, increased gas, nausea, fatigue, stomach cramps and pain, vomiting, and watery and explosive diarrhea. These symptoms can go away and recur and can last for months.
The parasite is spread through the fecal-oral route. That means contaminated feces gets onto produce in the field, during harvest, transportation, or processing. The illness isn’t spread person-to-person, since the oocyst must sporulate after it is expelled from the body, a process that takes about a week.
The only way to prevent this illness is to cook the foods you are eating. It is difficult, if not impossible, to rinse or wash the cyclospora oocysts off of contaminated produce.
If you have been experiencing the symptoms of Cyclospora food poisoning, see your doctor. The illness is treatable with antibiotics.

Salmonella Outbreak Linked to Imported Papayas Was 2nd Largest Food Poisoning Outbreak of 2017
Source :
By Linda Larsen (Dec 30, 2017)
The Salmonella outbreak linked to recalled imported Maradol papayas was the second largest food poisoning outbreak of 2017. At least 251 people across the country were sickened with nine different strains of Salmonella bacteria; that made this outbreak unique.
The case count by strain was: Salmonella Thompson (144), Kiambu (54), Anatum (20), Agona (12), Gaminara (7), Urbana (7), Newport & Infantis (4), and Senftenberg (3). Seventy-nine of these patients were hospitalized, and two deaths were reported; one from California and one in New York City. People of Hispanic origin were disproportionately affected by this outbreak.
This outbreak began on March 17, 2017, and ran through October 2017 and was comprised of four separate outbreaks. Four brands of Maradol papayas were recalled, imported from four farms in Mexico. In addition, papayas from three other Mexican farms tested positive for Salmonella strains that match illnesses not counted in this particular outbreak.
The recalled brands of papayas were Caribeña brand, Cavi brand, Valery brand, and Frutas Selectas. These papayas were all sold in the United States from December 2016 until July and August 2017. Illness onset dates ranged from December 20, 2016 to August 16, 2017.
The number of people sickened varied between the case counts from the FDA and CDC; no government official has explained this discrepancy. The CDC case count by state was: California (2), Connecticut (6), Delaware (4), Florida (1), Georgia (1), Iowa (2), Illinois (6), Kentucky (4), Maryland (11), Massachusetts (11), Michigan (1), Minnesota (4), North Carolina (7), New Jersey (41), New York (71), Ohio (2), Oklahoma (7), Pennsylvania (8), South Carolina (1), Tennessee (2), Texas (9), Virginia (18), and Wisconsin (1).
Isolates taken from patients were closely related genetically, which means they shared a common source of the bacteria. The Maryland Department of Health found two outbreak strains of Salmonella bacteria on papayas from a grocery store where ill persons bought the fruit. FDA also tested papayas imported from Mexico and found other Salmonella outbreak strains.
PFGE and WGS results of Salmonella isolates from papayas were compared to isolates from ill people in the PulseNet database, and the bacteria had the same DNA fingerprint. That was more evidence that people in this outbreak were sickened from eating contaminated Maradol papayas.
If you ate papayas imported from Mexico in the last year and experienced the symptoms of Salmonella food poisoning, which include nausea, diarrhea that may be bloody, vomiting, and a fever, see your doctor. The long term consequences of a Salmonella infection can be serious, and may include reactive arthritis, irritable bowel syndrome, and high blood pressure.





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We are so proud that more than 400 attendees successfully finished Basic and Advanced HACCP Trainings through FoodHACCP. All attendees received a HACCP certificate which fulfills all USDA/FSIS and FDA regulatory requirements for HACCP Training


For a Safe New Year’s Buffet, Follow FDA Suggestions
Source :
By Linda Larsen (Dec 29, 2017)
Plan a safe New Year’s buffet with suggestions from the FDA. Many people have open houses for this holiday and offer food buffet style.
The first tip is to keep serving portions small. Instead of putting out all the food at once, divide the food among some small platters and dishes ahead of time. As the food is eaten, replace those serving dishes with clean ones with fresh food. Store cold back up dishes in the refrigerator, and keep hot dishes in a crockpot, or in the oven set at 200 to 250°F. Later arriving guests can safely enjoy the same food as early arrivers.
Make sure that you take the temperature of the food as it sits out. Hot foods should be at least 140°F. Some warmers only hold food at 110°F to 120°F, so make sure that your warmer will keep foods at the correct temperature. The danger zone is between 40°F and 140°F; that’s when bacteria grow quickly. Eggs and egg dishes can be refrigerated for serving later, but should be reheated to 165°F before you serve them again.
Cold foods need to be kept at 40°F or below. Keep cold foods refrigerated until serving time. If the food is going to stay out of refrigeration more than two hours, put ice under the food to keep it cool.
Make sure that you don’t add new food to an already filled serving dish. Replace nearly empty dishes with freshly filed ones. Also be aware that bacteria from people’s hands can contaminate the food.
Watch the clock during your party. If perishable food is left out at room temperature for more than 2 hours, it must be discarded unless you know you are keeping it below 40°F or above 140°F. And if you send leftovers home with guests, make sure they refrigerate the food within two hours after it has left the fridge, not two hours after you have packed it for them.
Watch out for old family recipes. Some call for raw or lightly cooked eggs, especially mousse, eggnog, Caesar salad dressing, and rice pudding. Use pasteurized eggs, or add eggs to the liquid called for in a recipe, then heat, stirring constantly, until the mixture reaches 160*F.
Finally, remember the four phrases of safe cooking and baking: Clean, Separate, Cook, and Chill. Clean your hands and cutting boards and rinse produce before eating. Separate raw meats from other foods. Cook foods to safe final internal temperatures as measured with a food thermometer. And chill  food promptly and make sure your appliances are operating normally.

State with biggest apple crop girds against more Listeria
Source :
By NEWS DESK (Dec 27, 2017)
Shaken by apple recalls back East for Listeria contamination, Washington State’s large apple industry has pinned its hopes for staying pathogen free on research.
Ines Hanrahan, the post-harvest physiologist at the Washington Tree Fruit Research Commission, told the Capital Press that studies currently underway should help the state apple industry get the maximum bacterial reduction.
Her comments came after the Dec. 12, and Dec. 13 recalls by the Kroger and Aldi grocery store chains of apples grown in Michigan and the Southeast over concerns about possible Listeria contamination.
Hanrahan says that’s something the Washington State apple industry wants to avoid. “We are very concerned in Washington about Listeria and have been trying to do everything possible to set up processes to avoid problems,” she said.
Every state in the United States grows apples, and 29 states raise apples commercially, but Washington State produces about 70 percent of the apples in the United States. And, the Evergreen State manufacturers about 40 percent of all U.S. apple juice products.
Hanrahan says the Washington Tree Fruit Research Commission, Washington State University, and the Center for Produce Safety at the University of California Davis are all involved in apple studies. She says these efforts will help the industry determine the best operating procedures to “get the maximum bacterial reduction.”
A Washington State apple grower, Crunch Pak, recalled sliced apples in 2013 for Listeria contamination. Then in late 2014 and early 2015, caramel apples all sourced to fresh apples from Bidart Brothers in Bakersfield, CA caused a major Listeria outbreak.
A total of 35 individuals in 12 states were sickened. All but one case required hospital care and seven people died. Bidart recalled Granny Smith and Gala apples after environmental testing found Listeria contamination in the firm’s apple-packing facility.
Hanrahan says apple growers “have no way of controlling or knowing when a potentially deadly strain enters our post-harvest environment,” but adds that they can set up extensive systems to make sure they are alerted as soon as Listeria enters storage and packing. Then she says: “we can eradicate them by thorough cleaning and sanitation programs for equipment.”
The Washington State growers are looking into various interventions–continuous flow ozone generators to controlled atmosphere storage–to bring about the highest bacteria reductions.
The apple recalls by Aldi, and Kroger so far has not been associated with any illnesses. Aldi’s removals of Fuji, Gala, Golden Delicious, and Honeycrisp apples involved sales after Dec. 13 at stores in Georgia, Indiana, Kentucky, Ohio, South Carolina, and North Carolina.
Kroger recalled Fuji and Gala apples sold between Dec. 12 and 19 at stores in Georgia, South Carolina, Alabama, Ohio, Michigan, Kentucky, Tennessee and West Virginia. It’s recall included 5-pound bags of Michigan-grown apples.
Listeria is a deadly pathogen with a fatality rate as high as 40 percent with its most significant threat to young children, the elderly, people with compromised immune systems, and pregnant women. In the caramel apple outbreak 11 of the 35 victims where “pregnancy-related” involving either pregnant women or new-born baby, and one resulted in the loss of an unborn baby.

Food safety always matters
Source :
By Karen Fifield, Michigan State University Extension (Dec 27, 2017)
Keep food safe even when cooking at home.
Most of us are probably guilty of thinking that it is okay to cut corners when it comes to food safety if we are just cooking for ourselves or our families. However, bacteria grow no matter who you are feeding. Why would you cut corners when it involves the ones you love?
Food safety comes down to four basic words - clean, separate, cook and chill. No matter who you are serving, these basic steps should always be taken.
Clean – clean up all spills, wash dishes, utensils and work areas. Wash your hands before handling food, after handling food and after using the restroom. This is just the beginning. Cleaning up garbage and properly disposing of waste or recyclables can be a chore that everyone in the household can do. Keep all pots, pans and utensils clean and free of debris and clean refrigerators and freezers regularly. Create a clean chore chart for everyone in the household to follow, and cleaning won’t take more time than you have.
Separate – when preparing food use separate cutting boards for each of these food items: fruit, vegetables, poultry, meat and fish. This will help ensure that cross-contamination does not occur. Be diligent about removing debris and wash, rinse and sanitize all cutting boards after use. Keep foods separated in the refrigerator by placing poultry and meat on the bottom to keep it from dripping onto other items in the fridge.
Cook – use a food thermometer when cooking. Bacteria can be killed during the cooking process if cooked to the proper temperature. The only way to be sure food has reached the proper temperature is by checking with a thermometer. Food also tastes better if it is not overcooked, which is another reason to use a thermometer. Use the chart listed on the website to find the proper cooking temperatures for different types of food. Chose a thermometer that is easy for you to read and calibrate your thermometer often.
Chill – when taking care of leftovers it is important to cool foods as quickly as possible. Place them in shallow storage dishes with large surface areas. This helps the heat escape and allows the food to be refrigerated quicker. You might even want to leave your leftovers uncovered in the refrigerator to cool them faster, then cover, label and date the item. When we talk about chilling food to save it, we also need to do the same when we are thawing food. Bacteria can grow quickly in food during thawing. The best option is to thaw food in the refrigerator, but you do need to plan ahead.
Michigan State University Extension recommends following food safety guidelines when cooking for your family or for large groups of people. Let’s keep everyone safe from foodborne illness. For information on this or other topics contact a local MSU Extension office.
This article was published by Michigan State University Extension. For more information, visit To have a digest of information delivered straight to your email inbox, visit To contact an expert in your area, visit, or call 888-MSUE4MI (888-678-3464).

Top 10 Food Poisoning Outbreaks of 2017: Number 6 I.M. Healthy SoyNut Butter E. coli O157:H7 HUS Outbreak
Source :
By News Desk (Dec 26, 2017)
The E. coli O157:H7 – HUS outbreak linked to recalled I.M. Healthy SoyNut Butter products was the sixth largest food poisoning outbreak of 2017. That outbreak sickened 32 people in 12 states, many of them children. Twelve people were hospitalized, and nine developed hemolytic uremic syndrome (HUS), a type of kidney failure.
Eighty-one percent of patients in this outbreak were under the age of 18, mostly because those products were used as peanut butter substitutes in schools and daycare enters. The median patient age was 9. No deaths were reported in this outbreak.
The patients lived in Washington state, Oregon, California, Arizona, Florida, Missouri, Illinois, Wisconsin, Virginia, Maryland, New Jersey, and Massachusetts. Illness onset dates ranged from January 4, 2017 to April 18, 2017.
Pritzker Hageman attorney Ryan Osterholm, who represented a client sickened in this outbreak, said, “Children should not get seriously ill simply because they ate an innocuous product for a snack at school. There is zero tolerance for Shiga toxin-producing E. coli bacteria in ready-to-eat products for exactly this reason. E. coli O157:H7 bacteria cause dangerous and possible deadly illnesses.”
The CDC used the PulseNet system to identify patients who were part of this outbreak. Whole genome sequencing (WGS) done on isolates taken from patients showed they were closely related genetically. The product was tested, and STEC O157:H7 was found in opened containers of the products taken from the homes of ill persons. In addition, California officials found the outbreak strain of bacteria in unopened containers of I.M. Healthy brand SoyNut Butter from retail stores.
All varieties of I.M. Healthy Soynut Butters, I.M. Healthy Granola Products, Dixie Diner’s Club brand Carb Not Beanie Butter, and 2020 Lifestyle Yogurt Peanut Crunch Bars were eventually recalled because of this outbreak. The inspection at the Dixie Dew Products facility, were the soy nut butter was produced, found serious food safety issues.
At the facility, inspectors found that forklifts were moving throughout the facility and were never cleaned. The hot water tank for employee hand washing was broken for two years. And there was no control of foot traffic in and out of the processing room.
The symptoms of an E. coli infection include diarrhea that may be bloody or watery, painful abdominal cramps, and a mild fever. Anyone who has eaten any of these recalled products and has been experiencing these symptoms needs to see a doctor immediately.
If an E. coli infection happens in a child, or if the infection is improperly treated with antibiotics, it can progress to hemolytic uremic syndrome. The symptoms of HUS include little or no urine output, easy bruising, a skin rash, lethargy, and bleeding from the nose or mouth. Anyone experiencing these symptoms should go to a hospital immediately.

Minnesota food plant worker gets jail time for contaminating chicken
Source :
By Doug Powell (Dec 26, 2017)
Elizabeth Licata of Fox News reports an employee at a chicken processing plant in Minnesota has been convicted of intentionally contaminating chicken and causing a massive poultry recall in 2016.
In June of 2016 the Minnesota-based GNP Company had to recall almost 56,000 pounds of “Gold’n Plump” and “Just BARE” branded chicken after it was found to be contaminated by sand and black soil. After an investigation, 37-year-old Faye Slye of Cold Spring, Minnesota, reportedly confessed to contaminating chicken with plastic bags of dirt and sand she’d filled from the plant’s parking lot.
Slye was reportedly filmed by the company’s surveillance cameras, and there was dirt and sand from the parking lot on her sleeves.
Slye has been convicted of two counts of causing damage to property in the first degree, a felony, and she’s been sentenced to 90 days in prison. She will also be on probation for five years, and she also has to pay $200,000 to the company in restitution for causing the recall. The tainted products were reportedly shipped to foodservice and retail operations nationwide, and nearly 28 tons of poultry had to be recalled and destroyed.

FDA responds to OIG Recall Critique
Source :
By NEWS DESK (Dec 26, 2017)
In August 2016, the Office of Inspector General (OIG) found that the Food and Drug Administration (FDA) did not have an efficient and effective food recall initiation process that helps ensure the safety of the nation’s food supply. Specifically, FDA did not have policies and procedures to ensure that firms or responsible parties initiated voluntary food recalls promptly.
Today, FDA Commissioner Scott Gottlieb announced improvements in the recall process.  According to Dr. Gottlieb, “the OIG reviewed a selective sample of 30 food recalls initiated from 2012 to 2015, including some very challenging ones, which occurred over this 3-year period.”
Gottlieb noted that the FDA does have mandatory recall authority, but allowed that “often the fastest and most efficient way to ensure unsafe foods are recalled quickly is by working directly with the involved companies while simultaneously providing the public with timely, accurate information that they can act on.”  On the significant step, which has been advocated by consumer groups for some time:
The FDA is examining in what situations it can help consumers get information about the stores and food service locations that may have sold or distributed a potentially unsafe, recalled food, and what company may have supplied the product. “If we’re able to disclose this information, consumers would have an easier time knowing if they might have or have been, exposed to a recalled product that could cause potential risks if it were consumed,’ the commissioner said.
In addition, in April of 2017 a team of FDA senior leaders, called the SCORE team (which stands for “Strategic Coordinated Oversight of Recall Execution”) were gathered.  In Gottlieb’s view, the Score team has made recalls quicker in the following situations:
Lead contamination of a dietary supplement,
Salmonella contamination of powdered milk,
E. coli O157: H7 in soy nut butter, and
Listeria in hummus, soft cheese, and smoked fish.
The SCORE team also “initiated or helped to expedite the process for suspending the registration of two food facilities, actions that block the facilities’ ability to distribute food to the marketplace.”
Further, the Score team in 2017 “developed a new strategic plan that outlines actions to improve FDA’s recall management.” According to Gottlieb, the plan helps to standardize how the FDA assesses a company’s recall efforts and provides additional training to our staff involved in recall efforts so they can properly monitor and assess the effectiveness of a recall.

Finally, the commissioner announced that in 2018 the FDA will take additional policy steps “as part of a broader action plan to improve our oversight of food safety and how we implement the recall process.”

U.S., Canada: under-the-radar ingredient implications
Source :
By KELSEY M. MACKIN (Dec 26, 2017)
Already the focus of two warning letters from Health Canada this year, Lithium orotate is a “questionable ingredient” used in some products for treating psychiatric disorders. However, NutraIngredients says that similar products are sold ‘south of the border’, and contain the salt mineral, but have not raised as high a concern for the U.S. Food and Drug Administration (FDA).
Advocates of orotates claim support of the salt’s ability (as an orotic acid) to deliver trace minerals like magnesium and lithium in treating various health conditions including alcoholism. However, in a Dec. 1 recall notice, Canadian officials warned people in Canada that “the unauthorized health product ‘Smart Brain Formulations Serotonin Support’ may pose serious health risks.” According to the recall, testing by Health Canada found bacterial contamination with E. coli and the company who sells the contaminated product “currently does not hold a site license or any product licenses with Health Canada.”
Under Canadian law, dietary supplement manufacturers must register their facility and apply for premarket approval in order to receive a Natural Product Number (NPN) for each product label.
Additionally, a May 30 ‘safety alert‘ by Health Canada warned consumers about The SmartBrain Formulations products; “multiple unauthorized products labelled to contain L?tryptophan or lithium orotate” were for sale on, “and may pose serious health risks”, as “L?tryptophan (at doses higher than 220 mg per day) and lithium orotate are prescription drugs in Canada and should be used only under the supervision of a healthcare professional.”
This drug concerns people in the US as well. Specifically, in 1989, L-tryptophan (an amino acid ingredient for mood support products) contributed to 37 deaths and 1,500 serious injuries to people in the US. Since then, “properly manufactured” versions of the ingredient have been used with no issues, along with drugs that contain “lithium formulations” according to the NutraIngredients report. However, Canadian officials are concerned that “lithium orotate has also been marketed apparently without adverse events as a dietary ingredient in supplements sold in the US.”
Although there have been few accounts, one 2014 warning letter (issued to Bio-Recovery Inc. by the FDA) concerned a company that was selling a lithium orotate dietary supplement that warranted “significant violations” of the Current Good Manufacturing Practice (CGMP) regulations for dietary supplements. Additionally, the firm’s website also contained “evidence of intended use in the form of personal testimonials recommending or describing the use of products for the cure, mitigation, treatment, or prevention of disease”, according to the website.
Vasilios Frankos, Ph.D., Director of FDA’s Division of Dietary Supplement Programs, advises the following information regarding supplements:
“Today’s dietary supplements are not only vitamins and minerals. They also include other less familiar substances such as herbals, botanicals, amino acids, and enzymes. Check with your health care providers before combining or substituting them with other foods or medicines. Do not self-diagnose any health condition. Work with your healthcare providers to determine how best to achieve optimal health.”

Top 10 Food Poisoning Outbreaks of 2017: Salmonella Associated with Raw Tuna or Salmon
Source :
By Linda Larsen (Dec 25, 2017)
A Salmonella paratyphi outbreak associated with raw tuna or salmon sickened at least 30 people in seven states, and was the 7th largest food poisoning outbreak of 2017. This outbreak investigation developed gradually in the fall of 2017.
This outbreak has not been solved. Relish Foods recalled raw frozen tuna loins and tuna steaks in mid-October, but the outbreak strain of Salmonella bacteria was not found on those products. Ill persons live in Washington, Oregon, Texas, Florida, California, Hawaii, and New Jersey.
The outbreak investigation began when five Salmonella cases were reported to public health officials in late August, 2017. The DNA from the bacteria in all of these cases matched.
Then in early September, Oregon Health Authority found 12 additional cases with matching DNA. Fourteen patients were interviewed; eleven of them said they ate raw sushi before they got sick.
Samples were shipped to Washington Public Health Lab for testing. Epidemiologists assessed the data and determined that raw salmon and raw tuna were primary food items of interest. The case count rose to 22 on September 8, 2017.
One tuna sample collected from “Seafood Company X” tested positive for Salmonella, and officials recommended that restaurants hold tuna sourced form that company. The case count rose to 25. Later that month, officials found that Salmonella from that tuna did not match Salmonella from ll persons. Still, the FDA issued a recall. The case count was 30 on October 20, 2017.
Not all food poisoning outbreaks are solved. But epidemiological evidence, traceback, and interviews with ill persons can prove that an outbreak occurred.

Faces of Food Safety: Meet Suresh Dua of FSIS
Source :
Editor’s note: This is a recent installment in a series of employee profiles being published by the U.S. Department of Agriculture’s Food Safety Inspection Service, republished here with permission.
Dr. Suresh Dua is a supervisory public health veterinarian (SPHV) and 39-year FSIS employee in the Raleigh district. Dua credits his longevity in the agency to his parents and to his tenacity in learning as much as he could about microbiology, bacteriology and epidemiology.
“Knowledge is very important to me and my parents taught me from a very young age, growing up in the Mhow district of Indore, India, that having an education helps you become independent,” Dua said.
Dua pursued his higher education, earning a Bachelor of Veterinarian Science in Animal Husbandry in 1965, and a Master of Veterinary Microbiology from Agra University in 1967. He chose these fields of study because he wanted to identify causes of foodborne illness with, hopes of curtailing it.
“I studied microbiology, a science that studies extremely small forms of life such as bacteria and viruses; bacteriology, which is the study of bacteria; and epidemiology, which is the study and analysis of the patterns, causes and effects of health and disease conditions in defined populations. These are the three scientific approaches to identifying, understanding and hopefully preventing human foodborne-related illnesses and hazards,” Dua said.
His parents believed that attending an American university would help their son obtain his goal of earning a Doctor of Veterinary Medicine degree. With their encouragement, Dua immigrated to the United States in 1972 and landed in his new hometown, Buffalo, NY. To Dua, Buffalo was a large city with foreign weather, and the living conditions were strange to him.
“The first week I arrived in the U.S., it snowed,” Dua said. “I didn’t like the cold of New York, my run-down apartment or the 40-minute bus ride to and from my job at the University of New York at Buffalo.”
After a year of work, Dua found his way back to what he loved — learning. He fulfilled his dream in 1978, when he earned a Ph.D. in microbiology from the University of Minnesota’s School of Veterinary Medicine.
That same year, Dua obtained a position at FSIS as a veterinary medical officer (VMO) in DeKalb, IL. In the years that followed, he assumed roles as a supervisory VMO, staff officer, international affairs coordinator and district epidemiology officer. Since 2004, he has been in his current role as an SPHV in Mt. Airy, MD, a city with less than 10,000 residents. Dua explains how his nearly four decades in the agency play a role today.
“I was fortunate enough to work in three different levels of the Agency over the years. I’ve been on the inspection line, in the district office and at the headquarters level. It has offered me a broad view of FSIS,” Dua said.
“All that experience is contributing to my performance in my current role as a supervisor of five consumer safety inspectors, who are assigned to nine very small red meat and poultry establishments. These establishments produce different products, such as sausages, smoked bacon, fully cooked hams, breakfast loafs, beef jerky and poultry. I’ve worked with each of these products in the past.”
As an SPHV, Dua is responsible for enforcing federal meat and poultry inspection procedures on a daily basis. This includes responsibilities associated with live animal handling, including humane slaughter oversight, as well as overseeing inspection procedures throughout the entire establishment, including processing operations. His actions help ensure a safe food supply for consumers.
Aug. 26, 2018, will mark Dua’s 40th year of service. He has no plans to retire, but looking back he says: “I really have enjoyed my career with FSIS. It has been my pleasure to work with different supervisors as they have been helpful in guiding me and keeping the focus on the Agency’s objective: protecting the public’s health by ensuring the safety of meat, poultry and processed egg products. I enjoyed working for them, although, many of them have retired. I’m not ready to leave though because I still haven’t completed my mission in FSIS.”
Dua and his wife Nisha, have two sons, three grandsons and a granddaughter. Dua loves watching his grandchildren practice and play in basketball tournaments.
To keep himself fit, he takes early morning and evening walks. He enjoys Bollywood movies, and watching football — the American version — including the Super Bowl. Of all the sports, Dua enjoys cricket most.

Key New (and Not So New) Food Safety Challenges
Source :
By Larry Keener, CFS, PCQI
“Gluten-free diets becoming more common even if celiac disease isn’t.” “California adds glyphosate to list of cancer-causing chemicals.” “Flour recalled over possible link to E. coli outbreak.” “Huge recall of frozen fruits and vegetables after Listeria outbreak.” “Brazil’s largest food companies raided in tainted meat scandal.” “Recalls of organic food on the rise.” “Sally the salad robot is aimed at reducing the risk of foodborne illness by assembling salads out of precut vegetables stored in refrigerated canisters.” “Hurricane Harvey brings food safety challenges to millions.” As these headline news items attest, there are growing challenges in food safety that companies must address to remain innovative and grow their businesses.
Despite significant advances in detection tools, regulations, monitoring and consumer education on food safety, reports of foodborne illness outbreaks are expected to increase. More sensitive testing methods, changing consumer behaviors, climate change, modes of transportation and increasing complexity and globalization of the supply chain all contribute to this increase. The U.S. Centers for Disease Control and Prevention reports that foodborne diseases cause an estimated 48 million illnesses each year in the United States, including 9.4 million caused by known pathogens.
Food safety challenges exist along each step of the supply chain from concept to commercialization. The very name “supply chain” assumes that this is a linear relationship.  However, as we all know, the complexity of the current supply chain from farm to fork makes it difficult to accurately manage the challenges facing us today, so organizations must reduce the complexities within the supply chain to enable accurate control of the process. This will involve the proactive identification of potential risks and their mitigation, resulting in brand protection and meeting ever-changing consumer needs. Addressing these food safety challenges will require investments in information technology (IT), end-to-end management of the supply chain and building food safety capability from the CEO down to the line operators. The following key areas must be managed to address the new food safety challenges facing the food industry.
Information Technology
Capturing digital information across the supply chain is difficult. Most organizations are still using spreadsheets or have multiple stand-alone systems. The capability to harvest these data and gain insights is becoming more of a necessity than a luxury. A company cannot afford to not have these systems in place to mine vast amounts of data to identify and prevent risks.
Moreover, these IT tools can impact productivity as well as food safety and quality. An excellent example is the potential use of Blockchain technology to monitor performance and behaviors of supply chain partners. Blockchain has also been shown to be an effective tool in the management of food fraud and food defense issues. Leading multinational food companies have begun to take notice and invest in Blockchain technology. Yet, with these advances, we also encounter new vulnerabilities for the enterprise. Hacking, identity theft and other modes of internet-mediated fraud are major challenges. It is easy to imagine the possibility of having the company’s operations be brought to a grinding halt due to internet intruders gaining access to a company’s critical information and processes. This is most assuredly a new and evolving threat. The ramifications of these illicit internet activities for food safety must be given priority consideration in the company’s business plans and risk assessment activities.
Supply Chain Management
A chain is only as strong as its weakest link: Manufacturers need to maintain a strong perimeter defense. For many in the industry, the safety of the ingredients, packaging and equipment coming into our facilities is the weakest link. After all, the complexities of managing what comes into our buildings can be vast and overwhelming. The global food supply depends on highly efficient and well-regulated supply chains. Under the best conditions and with state-of-the-art controls, supply chains represent a monumental source of risk for food safety and also for an enterprise’s financial well-being. Shareholder performance correlates well with supply chain management.
The Food Safety Modernization Act (FSMA) recognizes the vulnerability of suppliers and heavily regulates minimum standards that every U.S. Food and Drug Administration (FDA)-regulated food facility must follow. For those overwhelmed by the prospect of building a supplier management system, FSMA is a good (and required) place to start. But is it enough? Does compliance with the regulations protect you against the unexpected, the “known unknowns”?  
The following are among FDA’s key new import authorities and mandates relating to the control of inbound supply chain management.
•    Importer accountability: For the first time, importers have an explicit responsibility to verify that their foreign suppliers have adequate preventive controls in place to ensure that the food they produce is safe.
•    Third-party certification: FSMA establishes a program through which qualified third parties can certify that foreign food facilities comply with U.S. food safety standards. This certification may be used to facilitate the entry of imports.
•    Certification for high-risk foods: FDA has the authority to require that high-risk imported foods be accompanied by a credible third-party certification or other assurance of compliance as a condition of entry into the U.S.
•    Voluntary Qualified Importer Program: FDA must establish a voluntary program for importers that provides for expedited review and entry of foods from participating importers. Eligibility is limited to, among other things, importers offering food from certified facilities.
•    Authority to deny entry: FDA can refuse entry into the U.S. of food from a foreign facility if FDA is denied access by the facility or the country in which the facility is located.
Food Safety Leadership
Management commitment is essential to ensure that food safety challenges are adequately controlled to maximize business performance and to minimize disruption resulting from failures to protect the consumer. To ensure that food safety is an enabler of business growth, company leadership must provide adequate and necessary resources and demonstrate behaviors that support the importance of food safety in limiting or mitigating enterprise risk.
Food safety professionals must move from a compliance function to the role of business partner who infuses food safety into the company strategy. They must become great storytellers when communicating or selling food safety initiatives to show both the ability to produce safe food and enable business growth. Food safety professionals must be able to show the benefits and return on investment of these key food safety initiatives. Food safety professionals must also build food safety knowledge with frontline operators to help change behaviors and ensure food safety plays a critical role in getting product out the door.
If we accept and understand that modern food processing can be traced to 1810 with the opening of a canning plant in France and that food safety as a subject was first codified in 1906 with the advent of the Pure Food and Drug Act, then we understand that food safety as a discipline is not really a new topic, but only in 2011 was the most comprehensive food safety legislation, FSMA, finally enacted. Food companies large and small are still grappling with the concept of food safety and how or where it fits into their corporate culture. CEOs and CFOs and their corporate boards are standing up and taking notice. Food safety is a critical business process that demands the highest level of visibility in the corporate structure and strategic plan. Leading food companies have made this calculation and understand the importance of ensuring that the products they manufacture and market will not cause irrevocable harm to the consumer or to the enterprise.
Discussions of “food safety culture” are very topical. The best food safety culture will only be a subset of a much broader corporate culture. Defining a corporate culture is the CEO’s prerogative. When food safety executives are effective in causing the organization to consider food safety proactively instead of as an afterthought, and when food safety is a part of every transactional conversation, it is then part of the company’s culture. Food safety is about risk and risk tolerance. A CEO’s propensity for risk will impact both corporate and food safety culture.
Other Important Challenges to Consider
Government officials have noted that the U.S. needs increased infrastructure investment to strengthen our economy, enhance our competitiveness in world trade, create jobs and increase wages for our workers and reduce the costs of goods and services for our families. It is further noted that the poor condition of the U.S. infrastructure has been estimated to cost a typical American household thousands of dollars each year.
Experts in the field report that infrastructure projects, like roads and bridges, should be designed to survive rising sea levels and other consequences of climate change (see below). They report that this approach to infrastructure enhancement would protect taxpayer dollars spent on projects in areas prone to flooding and also improve “climate resilience” across the U.S.—that is, a community’s ability to cope with the consequences of global warming.
Since 2011, the ongoing water crisis in Flint, Michigan, is compelling proof that the water distribution systems across the country are at risk and so too are the populations that they service. We have a very old water infrastructure in our nation, with many areas still maintaining Civil War-era cast-iron pipes, with an estimated useful life of 150 years (at the time of installation). “A major symptom of the aging water infrastructure includes 300,000 water main breaks in North America as a result of widespread corrosion problems, adding up to a $50.7 billion annual drain on our economy. Leaking pipes are also losing an estimated 2.6 trillion gallons of treated drinking water annually, representing $4.1 billion in wasted electricity every year.”[1]
From personal experience, a ruptured main in a 150-year-old distribution system in a northern Kentucky town took several weeks for public health authorities and FDA to pronounce it free of contaminants and its water safe for consumption and use in food processing operations. Moreover, affected food companies were required to destroy significant quantities of food that had been manufactured after a sustained pressure drop had been confirmed within the distribution system. Additionally, the impacted municipality did not have the laboratory capacity to monitor the microbiological safety of its water supply during and after the failure. Recovery and testing were aided by the labs of a large ice cream producer and food processor based in the town.
The inundation of water treatment facilities with floodwater, during some natural disasters, as described below, is an immense public health challenge. With such a catastrophic occurrence, it would be reasonable to conclude that the entire water distribution system has also been compromised. In older systems where potable waterlines and raw sewage lines are contained in a common subterranean vault, there is the real threat of dangerous microbes being introduced into the water distribution system. In this situation, the safety of the water supply depends on pipe integrity and on the pressure differential between the potable waterline and the raw sewage line. That is, the higher pressure on the waterline would preclude the entry of materials leaking from the sewage line in the event of a failure.
Natural Disasters
Between August 25 and September 11, 2017, the U.S. mainland was inundated by hurricanes Harvey (August 25) and Irma (September 11). Within weeks of those catastrophic storms, hurricanes Jose and Maria (September 20, 2017) ravaged the U.S. Virgin Islands, Puerto Rico and other islands of the Atlantic basin. The damage to the infrastructure in the affected communities varied. The preliminary cost of storm-related damage from Hurricane Harvey alone was estimated between $70 and $200 billion. Damage estimates from Puerto Rico, where the infrastructure was all but obliterated by hurricanes Jose and Maria, are currently beyond speculation. One month after September 20, only 45% of the island’s population has access to clean water; more than 80% of the island is without electrification; 50% of the main highways remain closed due to damage or debris; and 25% of the country’s ports remain inoperable.
The relevance to food safety management is that with the advent of global warming, new strategies are needed for control over supply chains and protection of public health. Imagine a food processing operation in Houston, post-Hurricane Harvey and what it will take to bring that facility back on line. Most assuredly, the water supply and sewer systems were heavily damaged. Owing to the density of the petrochemical industry in that area and damage to its infrastructure, an assortment of exotic chemicals could find their way into groundwater and water treatment facilities. It is inconceivable that absent federal intervention from the Federal Emergency Management Agency and the U.S. Environmental Protection Agency, these infrastructure challenges can be resolved. So, not only is the manufacture of food suspended, but there will also be questions about the public health status of previously processed food and food ingredients in the manufacturing supply chains. Raw materials and ingredients that may have been held up in transit due to failed roads, railways and ports will demand a comprehensive food safety assessment. One might also imagine a cold storage distribution center that has flooded and lost power. In this case, the food safety assessment would probably involve representatives of the U.S. Department of Agriculture Food Safety and Inspection Service, local public health officials as well as company food safety personnel. In this example, the disposition would most likely be straightforward and predicated on maintaining proper cold-chain integrity. If the cold chain were preserved and objective data available to document this, then the food might likely be judged safe. But in the absence of objective data, one could only conclude that the materials are unfit for human consumption. In the last several years, cloud-based monitoring technologies have emerged that may be helpful in the acquisition and preservation of critical storage temperature data.
In contrast, food safety assessments where packaged or canned foods are involved might not be so straightforward. A company taking a very conservative approach in managing the disposition of affected materials could encounter difficulty with FDA. That is, the agency would probably be inclined to conclude that the canned and packaged foods may have been held under insanitary conditions where they may have become adulterated and are not fit for human consumption. There is no one-size-fits-all solution for these sorts of disasters. It is understood that all concerned parties, the marketing and manufacturing company and the regulatory agency staff, are trying to do their best to protect public health. Planning and guidance for managing adverse weather or infrastructure failure events should be included in the company’s crisis management and special events procedures.
Another scenario might involve raw material and ingredients delayed in transit. It is easy to envisage railcars, over-the-road transport vehicles or ships containing sensitive food ingredients that are unable to deliver because of infrastructure compromised by a natural disaster. In most cases, these items are to be delivered for a just-in-time production schedule, and shipments might include highly perishable materials. Imagine the predicament of a juice processor with a sea tanker load of orange juice, intended for further processing, stuck in port for a week or more without the ability to unload its cargo. This vast quantity of juice would most likely spoil before it could be offloaded and processed. There are many less dramatic but equally challenging examples involving shipment of mixed loads of food and other nonfood materials that should be considered. This situation represents a potentially insidious threat, depending on the nature of the products involved. These scenarios must be evaluated on a case-by-case basis to establish the threat and risk to food safety.
Weather- and infrastructure-related events are increasingly a challenge for food safety management. These threats must be considered in the company’s crisis management program. The food safety team, in conjunction with legal, logistics and others, should conduct a failure modes and effects analysis and consider storm events and infrastructure failures as part of the exercise. From experience working with clients in hurricane-prone areas, for example, where the risk assessment leads to the development of plans for the removal and relocation of the plant’s critical manufacturing assets, retorts, kettles, heaters and packaging line equipment were on the relocation list. This sounds extreme, but in fact, the company preserved its property and probably ensured a speedy recovery of its plant operations.
Among the myriad challenges facing the food industry is the new FSMA requirement for the validation of preventive controls. Validation seeks to confirm, with a high degree of confidence, that a preventive control measure of a food safety plan is effective at mitigating or reducing the identified food safety hazard to an acceptable level. Validation is a relative new concept for the food industry and is causing concern and confusion for both regulatory operatives and food safety specialists. The process validation scheme in Figure 1[2] depicts the steps involved in the validation process. Also superimposed beneath the validation scheme is the formula used for the food safety objectives. You will see when proceeding left to right that [H°] (risk characterization) is associated with the input to the process being validated. The sum of the reduction plus the sum of any increase of the hazard (–ΣR + ΣI) corresponds to the preventive control, and the output of the process is the performance objective (FSO/PO) for achieving safe food.[2]
The brave new world of food science and technology has been a boon for mankind. Today, we can produce food and foodstuffs more efficiently than ever before. The power of science and technology has transformed food processing. We have capabilities today that we dared not dream about a mere 20 years ago. Whole-genome sequencing, gluten-free grains, metagenomics, nonallergenic peanuts and high-pressure thermal sterilization are all prime examples. More and more often, the regulatory agencies are demanding that companies prospectively validate the safety of novel and emerging technologies. Innovation is disruptive and often involves a high level of risk taking. For this reason, food companies are often reluctant to lead innovation. The prevailing attitude, among industry-leading companies, toward innovation is “me too” or “we’d prefer not to be first.”
It was absolutely revolutionary 225 years ago (circa 1790) when Nicolas Appert was able to stuff food into glass bottles and immerse them in boiling water to preserve them for ambient storage. It is interesting to contemplate the potential harm that this breakthrough technology harbored. Neither Appert nor other scientists of his day had any understanding of anaerobic bacteria and most assuredly had no concept of the consequences of exposure to the deadly neurotoxin produced by Clostridium botulinum. The reader will recall that germ theory (by Louis Pasteur, Joseph Lister and Robert H. Koch) was not fully elucidated until about 1880. Yet, the canning industry has thrived and, in a very real way, changed the world and the world’s economic development. Perhaps the only other technological advancement in food to surpass the societal impact of the canning industry has been the development of mechanical refrigeration. In developed countries, the demand for food in the cold chain is rapidly expanding, so much so that the modern supermarket has been reengineered to accommodate more and more refrigerated and frozen products.
In addition to advancements in preservation technologies, we can now manipulate crops and select for specific plant attributes that would have caused Gregor Mendel to pause and ponder. The ability to genetically manipulate food and food crops is controversial. George Washington Carver, the great American food scientist of last century, reported that “farmers had every right to encourage the abundance of their crops including the use of genetic modification.” Carver studied, among other scientific disciplines at Iowa State College (1896), the genetic modification of cacti.[3] In fact, the food industry has been on the genetic modification journey for many years and with good outcomes for mankind. The truth is that man has been modifying food crops since we transitioned from hunter-gatherers to an agrarian society. Risk is an element of innovation. The food industry and its regulatory companions must be vigilant to safeguard the public from potential harm arising from the use of novel processing and preservation technologies. But at the same time, we should discourage the hunt for phantom risks that will probably impede innovation.
There is also increasingly risk to the food supply associated with natural disasters: Floods, hurricanes and wildfires are prime examples. These disasters can devastate and disrupt supply chains, which may cause great harm to the stability of society. The food industry is at great risk and the foods they manufacture susceptible to the devastation caused by flooding, fires and storms. In fact, these climate-related natural disasters may be the biggest contemporary issue facing the food industry. Climate change, an extrinsic risk, is causing the food industry, and especially food safety leaders, to rethink business plans and strategies to cope with this new reality. 
In food processing operations, there are myriad risks, both intrinsic and extrinsic. It is also understood that there is, during the mass production of human food, no such thing as zero risk. Yes, we can make exquisite measurements to a precision level of 6–7 × 10-9, but this is still not zero. There is always a residual risk, and it is the responsibility of those who manufacture and market food products to manage that risk to a level that will do no harm. It is only with this mindset that the industry together can meet these and other future challenges in food safety.  
Larry Keener, CFS, PCQI, is president and CEO of International Product Safety Consultants. He is a member of the Editorial Advisory Board of Food Safety Magazine.
2. Anderson, NM et al. 2011. “Food Safety Objective Approach for Controlling Clostridium botulinum Growth and Toxin Production in Commercially Sterile Foods.” J Food Prot 74(11):1956–1989. doi:10.4315/0362-028X.JFP-11-082.
3. Hersey, MD. My Work Is That of Conservation: An Environmental Biography of George Washington Carver (Athens, GA: University of Georgia Press, 2011).
9. Keener, L. 1999. “Mechanistics of Selling Food Safety,” Food Testing & Analysis 5(4).
10. Keener, L et al. 2014. “Harmonization of Legislation and Regulations to Achieve Food Safety: U.S. and Canada Perspective.” J Sci Food Agric 94(10):1947–1953.



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