The FDA has recommended that consumers not consume pistachios or pistachio-containing products. It also encouraged a recall by Setton Pistachio of over a million pounds of product, and the company elected to close its plant. (In true fashion of press briefings given in moments of crisis, there is a great discrepancy of how much of Setton’s total crop was affected, but the fact that the plant is now closed reveals total shut down of pistachios currently distributed by the company.)
Although FDA has not urged people to destroy the pistachios and pistachio-containing products — instead to simply wait until the derivation of the product is ascertained — much product will be destroyed. Supermarkets and others do not have excess freezer capacity to indefinitely store pistachio ice cream and there is no final date by which consumers will get an “all clear.”
FDA is proud of its role in this matter. Its Commissioner for Foods, Dr. David Acheson, proudly declared to reporters: “This recall was not triggered because of an outbreak, in contrast to the peanut butter. This is an example of the FDA getting out ahead of the curve.”
Actually, it is more an example of the FDA’s need to make itself relevant than anything to do with public health.
When people are advised not to eat a particular product, there is no reason to think that they eat less food; instead they eat less of the “banned” product and more of other foods. In order to be acting to enhance public health and safety, Dr. Acheson would have to have reason to believe that the food people will eat in lieu of these pistachios will be safer. Unfortunately he has no data to support such a belief.
This situation was uncovered because Kraft received word from its supplier, Georgia Nut Company, that in the course of its routine sampling of ingredients it purchases, had identified Salmonella on pistachios it had purchased from Setton Pistachio. Kraft decided, voluntarily, to notify the FDA.
Where this salmonella contamination may have occurred is unknown. In theory, the roasting of the pistachios should have killed any salmonella, so this points to either improper roasting or a contamination after they were roasted. Most plants are designed and operated utilizing Hazard Analysis And Critical Control Point (HACCP) principles. Because cross contamination between raw and roasted product is a known critical control point, most plants are designed as a “one way street” where raw product enters on one end of the plant, finished product leaves on the opposite end and product should never go backwards where it could come into contamination with raw product.
The Washington Post reported that it was told by a top food safety official that Setton Pistachio was running both raw and roasted nuts on the same line, which would violate both Good Manufacturing Practices and basic HACCP principles. The article also states that at some unidentified time, Setton Pistachiofound Salmonella on pistachios and, in accordance with accepted practice, reconditioned them by roasting them again.
None of this has been publically confirmed but, even if true, wouldn’t prove anything about where these four particular strains of Salmonella came in contact with the pistachios.
It is also possible that the problem was at the plant but in an episodic way that we may never find and could happen in any plant on any product — a freak, once-in-a-billion bunching of the pistachios just a micron too thick to kill the Salmonella through roasting — in which case the FDA’s actions have helped nobody because virtually all the pistachios do not have salmonella and these freak events happen across all foods, so we have no reason to think that a consumer who switches to, say, roasted peanuts, is any safer.
There are several oddities about the case. 1) We can find no reference to salmonella ever being discovered on pistachios — so this is not a high risk item. 2) The FDA said there were four different serotypes of salmonella discovered — Montevideo, Newport, Seftenberg, and Larochelle. This is peculiar. 3) So far no other tests — by the FDA, Setton Pistachio, Kraft, or any others have turned up any positives either in the nuts or in the plants. 4) The nuts were apparently sitting at the Georgia Nut Company facility for a long time, they were actually received in late 2008 — adding to the possibility that any contamination could have occurred during the months it has been sitting around the Georgia Nut Company facility.
If one wants lessons, industry certainly should get the message that it behooves the food trade to work hard on traceability. Whether FDA acts prudently or rashly, the ability to quickly define where all the potentially contaminated product is at any moment would significantly reduce the scope of the problem when panic is in the air. Industry also would do well to consider the use of technology, such as irradiation, to provide additional assurance.
But FDA has to recognize that it has a problem as well. Its procedure of reacting to test results done by private industry has the perverse effect of implicating and sometimes shutting down the most rigorous and highest quality producers. Why? The customers with the most rigorous requirements — like Kraft — buy from the best producers.
Yet it is in the nature of pathogens that if we tested every single piece of food, pathogens would be found in a certain percentage of the food — call this a baseline level. This is especially true of items such as raw produce but is also true of any food that isn’t kept sterile.
There is no requirement for private industry to test and no requirement to report test results to the FDA. Quite possibly because Setton Pistachio was good enough to sell to Georgia Nut Company, which is rigorous enough to have a regular testing program, and because the product was going to Kraft, which elected to be conscientious and report it to the FDA, the FDA was alerted to some salmonella which it would never have known about if Setton Pistachio was a second-rate operator selling to food manufacturers who wouldn’t bother to test and wouldn’t bother to report the test results if they got them.
So the FDA’s definition of “getting out ahead of the curve” really means getting out ahead of the news cycle so its executives can declare themselves guardians of the nation’s food supply. But responding to random events as if they have statistical significance makes nobody healthier and impoverishes those people who depend, in this case, on selling pistachio nuts.