Our 2020 Recall Review

Recalls in Review

Denis Storey
September 24, 2021

eBook: “9 Things Your Allergen Control Program is Missing”

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eBook: “9 Things Your Allergen Control Program is Missing”

TraceGains and AIB International have joined forces to produce “9 Missing Pieces to Optimize Your Allergen Control Program,” a practical eBook that can finally put your allergen control puzzle together.

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The COVID-19 pandemic influenced the number of food and beverage recalls, revealing a notable deviation from previous years but still paint a clear picture of where the industry needs to focus moving forward.

“If a recall happens, you need to understand that you can’t win,” Bryan Armentrout, Founder of The Food Leadership Group/The Food Safety Foundation, explained. “It’s not our nature to think like this, so you need to prepare. Your goal is to minimize the damage and get the business back on track as quickly as possible. Then, learn from it, teach others, and work to prevent a recurrence.”

The U.S. Food and Drug Administration (FDA) and the U.S. Department of Agriculture Food Safety and Inspection Service (USDA FSIS) issued 363 recalls last year. While that’s on par with prior years, the distribution of recalls diverged significantly.

While 2020 began with a modest 141 recalls in the first quarter, the pandemic hampered regulatory oversight activities at the start of the second quarter when recalls fell 44% year over year to just 79. As the year dragged on, quarterly recalls remained low with 52 in the third quarter, before rising to 91 by the end of the year. Regulators attributed these fluctuations to an overall inability to deploy oversight, resulting in missed food safety issues.

Unfortunately, specific recall trends persisted: 

  1. Undeclared Allergens: For the 16th straight quarter, undeclared allergens remained the top contributor to recalls in the food industry. Undeclared allergens accounted for nearly half, 48%, of all recalled food and beverages. Milk led the list with 83 recalls, followed by soy, (28) nuts (25), and eggs (15). Sulfates, wheat, and peanuts were also leading contributors.
  2. Foreign Materials: Coming in at a close second, and almost double last year’s rates, were 90 food products regulators recalled due to contamination by foreign materials. Though regulators mandated only nine recalls in the second quarter, they affected 672,000 lbs., or 69%, of all USDA meat, leading to a short-term shortage that pushed prices higher.
  3. Listeria, Salmonella, and E. coli: Salmonella increased substantially and emerged as the root cause of 69 recalls, the large majority relating to fruits or pet foods. In addition, regulators recalled 47 food products because of listeria contamination – many linked to frozen produce, ready-to-consume deli products, and eggs.

The Silver Lining 

But there was more to 2020 than lockdowns and recalls.

First, the FDA offered a cautionary tale in the second quarter when it brought federal charges against Blue Bell Creameries after 2015’s deadly listeria outbreak. According to regulators, the company failed to respond adequately to continued safety warnings while delaying recalls of contaminated products. This failure led to hundreds of millions of dollars in lost sales, legal fees, and massive damage to the company’s brand and reputation. This verdict sharpened the industry’s focus on recalls and reminded food manufacturers that they’re still accountable for recall activities and events.

Second, last year saw the FDA release its “New Era of Smarter Food Safety: Blueprint for the Future.” Though the outlined guidelines weren’t much different from what you’d expect from earlier years, 2020 helped drive an industry-wide resurgence in the importance of food safety culture.

All along the supply chain, a revival of cleanliness emerged. The pandemic put health guidelines into an entirely different light for essential workers. As a result, the industry shifted its primary focus to protecting its workforce through strengthened cleaning and sanitation processes. This renewed effort serves as a solid foundation for future food safety initiatives.   

Reducing Recalls in 2021 and Beyond 

The following approaches can help food companies reduce the chance of a recall:

  1. Label Allergens Correctly: If you make a product with an allergen, you must ensure it’s declared accurately on the label. The number one reason for the mislabeling of allergens is the wrong package or the incorrect label on a product. While there are various reasons why the wrong package or label is applied, the most common is that packages for similar products made with different allergens tend to look alike. In addition, workers can easily grab the wrong packaging from inventory to support a production run. Though it’s a simple mistake, it can be extremely costly.  A few best practices to keep in mind for your allergen control programs include:

    • Confirm the correct label is on the line at the beginning and end of the roll.
    • Create a transparency/acetate (i.e., transparent sheet of film) with the correct ingredient statement to confirm ingredient statements on the packaging for finished products and raw materials upon receipt.
    • When adding an allergen to a formula that didn’t previously contain it, the packaging or labels used for the old formula must be disposed of or otherwise made unusable.
  1. Environmental Pathogen Control: To help control pathogens conduct environmental monitoring at a consistent frequency for food and non-food contact sites. Create a baseline to generate continued monitoring data of the facility environment. This baseline helps identify microbial growth areas, contributing to Listeria monocytogenes contamination in wet environments or Salmonella contamination in dry ones. Additional best practices for a clean environment include:

    • Separate raw products from cooked/RTE (ready-to-eat) products.
    • Control temperature and moisture levels.
    • Implement pest controls.
    • Choose equipment employees can easily.
  1. Establish an Approved Supplier Program: For food manufacturers, the safety of finished goods depends not only upon the ingredients themselves but also on the suppliers used throughout the food supply chain. Having a properly managed supplier program can help to ensure quality and safety measures. It also encourages excellent working relationships between manufacturers and suppliers, and who doesn’t want that? One key component of having an outstanding supplier program is the benefit of a well-built and well-maintained supplier approval process. Not to mention, supplier verification in the United States is a big part of the Preventative Controls required by the Food Safety Modernization Act (FSMA).

Your reputation is on the line should something fall through the cracks. Ensuring that employees follow approved procedures and processes when you consider a new ingredient or supplier can significantly mitigate the risks.

“I only have one guarantee when it comes to recall and crisis management - it will not go the way you planned,” Armentrout added. “It will happen at the worst possible time. Key people will be unavailable. That makes training even more important so that people know what is expected.”

The industry won’t eliminate recalls altogether, but we can make a tremendous impact if every manufacturer does their part. Take the first step with TraceGains’ eBook, “9 Things Your Allergen Control Program is Missing,” here.