The Food and Drug Administration (FDA) has posted the document Draft Guidance for Industry: Questions and Answers Regarding Mandatory Food Recalls. This document will be available for public comments for 60 days staring on May 7, 2015.


Before the enactment of FSMA in January 2011, the FDA relied only on voluntary recall of food products by manufacturers. But now the Federal Food, Drug, and Cosmetic Act (FD&C Act) has Section 423 that gives FDA the authority “to order a responsible party to recall a food if there is reasonable probability that the food (other than infant formula) is adulterated or misbranded under certain provisions of the FD&C Act.” This Section was added by Section 206 of the Food Safety Modernization Act of 2011 (FSMA).

The Consumer Federation of America, with the support of the The Pew Charitable Trusts, has compiled and released the report: The Promise and Problems of HACCP: A Review of USDA’s Approach to Meat and Poultry Safety. The document has six recommendations, one of which is “establish clear procedures for reoccurring violations.” I think that without incentives, we will keep seeing these reoccurring violations in the future.


The Food Safety and Inspection Services of the U. S. Department of Agriculture released the quarterly progress report on Salmonella and Campylobacter testing of meat and poultry for July-September 2014.


Another festival, Milk Makers Fest, has turned into a sad story again.



Some cases of botulism appearing in the last week in New Mexico and Ohio are kind of troublesome.






There are many different reason why you may want to start some testing programs in your food processing plant. An environmental monitoring program, for instance, is a good program to evaluate sanitation and to find out any potential environmental contaminants that can make it to your products. Here I provide a few considerations that you should keep in mind when choosing a testing laboratory.

Whatever reason you have for testing, make sure somebody helps you organize a testing protocol that provides you with meaningful results. I have seen many test results that are just isolated numbers without any good correlation to either processing steps or products, and therefore do not tell you too much about your overall process.

Choosing the right laboratory is also another challenge in itself. It is important to understand that not all laboratories are equal. Some are accredited and some are not. You want to work with a laboratory that has an ISO/IEC 17025:2005 certificate. The American Association for Laboratory Accreditation (A2LA) keeps a list of all the laboratories that are accredited in its website. The American Proficiency Institute (API) also provide certificates to those laboratories that successfully perform tests on samples provided by API. So ask laboratories for their A2LA and API certificates.

Another consideration is the test itself. Make sure the test has been validated by AOAC International, AFNOR, etc. for the food matrix and the application. For instance, if you want to determine E. coli in poultry carcass rinse, do not use an E. coli test that has been validated only for E. coli in milk.

The last consideration is whether the test is performed primarily by equipment or by laboratory personnel. In many cases you do not know this part unless the laboratory explains to you how they do the test. I tend to like more fully-automated tests. First, most fully automated tests by major test manufacturers (bioMerieux, Roche, etc.) are all validated and in many cases for many different food matrices and applications (foods, environmental swabs, etc.). I also prefer fully-automated equipment, although the actual test cost maybe higher, because people do commit mistakes and sometimes are very creative in concealing them. Machines, on the other hand, will let you know when an error happens.

The U.S. Food and Drug Administration has issued and amendment and update to its regulation on registration of food facilities related to the Food Safety Modernization Act (FSMA). Currently, establishments that are “retail food establishments,” farms, restaurants, and certain other entities are exempt from the requirement to register their facilities with FDA. The proposed amendment would expand the number of establishments that are considered “retail food establishments” and therefore more establishments will be exempt from registration.

The current definition of retail food establishment is: An establishment that sells food products directly to consumers as its primary function. If the annual monetary value of food products sold directly to consumers exceeds the annual monetary value of food products sold to all other buyers, the establishment is a “retail food establishment.” The proposed changes will clarify the process of determining the “primary function” of an establishment. Now, the sale of food directly to consumers from an on-farm establishment includes direct sales platforms as roadside stands, farmers’ markets, and Community Supported Agriculture programs.

FDA estimates that approximately 71,000 farms sell food products directly to consumers (farmers markets, roadside stands and CSA programs). These establishment will be exempt from the requirement to register and therefore would not be subject to the requirements of the FSMA preventive controls rulemakings.

You can read more here.



Today is World Health Day 2015: From farm to plate, make food safe.

But still some work to do. We have less than half the budget to get the Food Safety Modernization Act implemented. I like a couple of comments on this article: “public costs, private profits” and “it’s the 21st century and we are back in The Jungle.”

The Canadian Food Inspection Agency is cutting the number of meat inspectors, although the Agency says that the food safety system in Canada is strong, risk-based and outcome-based. Are only government inspection systems good for food safety? Not really. But a third-party inspection is fundamental to avoid “conflict of interest,” as the one that happened in 2012 when the Food and Veterinary Office of the European Union said that the Australian Export Meat Inspection System, at that time under the responsibilities of company employees, had only company employees as inspectors. Now, those inspectors respond to a third party.


And speaking of third parties, should third party sanitation companies take care of sanitation in restaurants? Or should we just change some state laws to allow for the public announcements of restaurants that make people sick? Read what happened recently in Philadelphia.


EPA is discussing restrictions in the use of glyphosate herbicide (Roundup).

A recurring theme in food safety violations is the lack or improper documentation by food processors. Remember a couple of years ago when horse meat was found in meat sold as beef in England? Apparently the documents were so bad, in this case intentionally done, that the owner was finally fined.


Today, March 4, is TB Day (tuberculosis day).  It has been only 133 years since the discovery of Mycobacterium tuberculosis by Robert Koch.

Pesticides residues in foods in Europe

Will KFC process antibiotics free chickens?

GMO crops approved in Europe

The 2015 document of the Dietary Guidelines for Americans keep reminding us of food safety tips, such as:

Fight BAC!
Be Food Safe
Is it Done Yet?
Consumer-friendly information

Cases of Cryptosporidium associated with consumption of raw goat milk

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