Food safety is the victim of it’s own success.
When I wrote about why I decide to care about food safety, I mentioned how 3,000 people every year is a minuscule fraction of the total number of tragic, preventable deaths each year. For every death from a foodborne illness, there are 14 suicides, 12 fatal motor vehicle crashes, 5 homicides, and 18 drug overdoses/poisonings.
Frankly, you can take a lot of personal food safety risk before you run into trouble. That’s why people are skeptical about outbreaks, or don’t believe that they could possibly be making people sick. To actually have a food-borne illness, so many things need to happen.
- The pathogen (or toxin former) needs to get near the food
- The pathogen or toxin needs to get onto/into the food
- The pathogen or toxin needs to proliferate to an infectious dose
- The pathogen or toxin needs to survive any washing/cooking/freezing/processing/storage
- The dangerous food needs to be eaten in a large enough amount
- The food needs to be eaten by someone susceptible to that infectious dose
- That person needs to be susceptible that day
- Available medical treatments have to be unsuccessful
There are so many points that this chain can be broken, and the odds for any particular meal nailing all of them may be one-in a million or much lower.
At 3 meals per day, it will take a single person 913 years to eat one million meals.
But there are 325 million of us in the USA, so that one-in-a-million lottery gets won 975 times every single day.
Food safety experts know that all of the fancy industry terms: food safety culture, sanitation programs, lethality, environmental monitoring, prerequisite programs, HACCP…they’re not about trying to make a surgically sterile environment, we’re trying to raise the probability that the chain gets broken. That, if today the right circumstances came along, this thing we did would have kept it from beating the odds. It’s how we approach risk management when problems occur as well, just because a mistake was made today doesn’t mean the food is necessarily unsafe, it probably didn’t or won’t meet all the criteria above.
- Something touched the floor…it didn’t matter if there were no pathogens on the floor to begin with, or if we’re cooking later, or if transfer rates were negligible.
- Hand-washing isn’t happening as much as it should…our guys aren’t touching the food in this area anyway.
- Something was left out of the fridge…but if there were no bad bacteria on the food in the first place, they aren’t going to just appear out of nowhere.
Stuff happens, and it doesn’t necessarily mean things are unsafe, however, if you continue to have bad practices day, after day, after day, then the stars will eventually align, and you will have made it possible. Doug Powell summarized it quite well on a recent barfblog post:
“I’ve yet to see divine intervention as a cause of foodborne illness. Instead, illnesses and outbreaks are frighteningly consistent in their underlying causes: a culmination of a small series of mistakes…”
It’s a mixed bag that severe food-borne illness is so uncommon. Fortunate because even though there are tons of bad food safety practices out there, we as individuals will probably be okay. Unfortunate because those places with awful practices playing the lottery may never actually have to answer for their negligence, they may serve a low-risk product to a small population who will never associate their product with illness. Why should I think about my multivitamin when I ate seafood yesterday? Or my well water?
Some companies do hit the jackpot however, and leave us their statements of helplessness when either the FDA calls them out on it, or assigns an outbreak to them.
- Wait, there are regulations covering a product like this?
- We’ve never gotten sick and we’ve been eating our own foods for years.
- Hey, nothing is 100%.
- It must have been someone else.
- But we use only the best ingredients.
- Our test results don’t say what yours do.
- We’ve never heard of this requirement.
- It hasn’t been a problem before.
- I don’t understand what you want us to do, we don’t know how to fix this.
This is an open letter to those companies I see in warning letters every week, and eventually show up on FoodSafetyNews as the cause of an outbreak. One of the common threads I see when I research these companies is that they might have someone doing their food safety and quality…except it’s a promoted secretary-receptionist, or an afterthought on the R&D tech or the plant manager’s job description.
Organize all outgoing freight contracts and schedule
Hire and schedule all labor and materials
Order raw materials and establish supplier relationships
Repair all equipment on site
…Oh, and make sure we do the food safety and legal stuff too
I’ve seen these job descriptions, even from large companies, and they’re an immediate red flag that management does not think food safety demands time and expertise, but that it’s a quick afternoon activity. You just have to write some SOP’s, buy some thermometers, show the inspector around when they come. Heck, I’ve had bad 3rd party auditors that look forward to working in industry later since it “will be such an easy job“.
People like me and my colleagues are valuable because we know that you can’t just start making juice without determining if you have any specific regulatory requirements. We know why you shouldn’t just pick around the moldy nuts or add ” a few more glugs” to your sanitizer. We can also think like a bacteria and help you identify the areas where you are failing to break the chain of listeria contamination. We know what subjects can or need to be researched, and that a CoA with microbial results is meaningless without the ability to understand what it means (hint: not much). It takes time, details, and expertise, and it’s going to cost real dollars.
If your company is in the position where the outbreak is happening or the FDA is there and you don’t understand why, you need to call or hire someone with the requisite expertise and capacity to dig in and find out where you just won the lottery because there were too many opportunities for that chain to form.
The way of doing things in the past is blinding you to the problems that have always been present. You weren’t doing things right, you’ve just been lucky.
Jensen, Dane A., et al. “Quantifying transfer rates of Salmonella and Escherichia coli O157: H7 between fresh-cut produce and common kitchen surfaces.” Journal of food protection 76.9 (2013): 1530-1538.
CDC. National Vital Statistics Reports Volume 66, Number 6, November 27, 2017