With the industry focused on traceability — which we deal with today here and have dealt with for some time — it is worth looking at the way food safety agencies and buyers react when there is both good traceability data and a foodborne illness outbreak. The short answer is they ignore traceability.
In this case, Freshway Foods announced a voluntary recall of a particular lot — tracking numbers starting with 117 — on May 6, 2010. They made this recall because the state lab in New York state had identified a dangerous variant of E. coli — E. coli 0145 — on a sealed bag of foodservice product.
So, for about 15 minutes a traceability system worked as intended. The FDA had no trouble tracing back to Freshway Foods, and Freshway had no trouble identifying the relevant lot, and the source in Yuma, Arizona, that supplied the romaine.
Back when this issue was first being raised, Bruce Peterson, then Senior Vice President and General Merchandise Manager of Perishables at Wal-Mart, urged the industry to emphasize traceability in large measure because sitting at his desk at Wal-Mart he saw that every day vendors of all kinds of products had to do recalls, but they didn’t paralyze the industry. Good traceability systems allowed them to delineate the extent of the problem and recall specific lots or batches without causing the kind of total industry chaos we saw in produce with the spinach crisis of 2006.
But Freshway’s virtually perfect traceability systems led to very different reactions both by government and buyers than typically happens if a batch of canned soup has to be recalled.
First, the FDA did not accept limiting the recall to the implicated lots and requested that Freshway Foods expand the recall to encompass any product with romaine from Yuma.
Acting with an “abundance of caution”, Freshway quickly complied. That was very cooperative of Freshway but, in fact, the FDA’s request made no particular sense. After all, this other product could come from totally different farms and fields, completely unrelated to the implicated lot.
But the buyers were actually way ahead of the FDA. The three colleges which received recalled product decided to remove everything from this supplier, recalled or not, from Arizona or not. More “abundance of caution”.
We mentioned before that one of the concerns of the industry is that buyers won’t ever actually care about lot-specific traceability. That if there is ever a problem, they are going to remove everything. This is partly out of an “abundance of caution” but mostly because they don’t trust their own workforce to be able to make careful distinctions between lot numbers. Recalls don’t cost buyers anything; they bill all costs back to the vendors, so why take any risk that their own employees will leave an errant bag… better just to dump it all.
Which raises this question: Traceability systems have to be calibrated to generate useful information. But if both the regulators and the buyers are going to implicate whole companies and whole valleys, regardless of how specific the traceability is, how specific do we exactly need to be when it comes to fresh produce?