The Top 3 Reasons for Food Recalls Are…

This is a guest blog post by Richard Perlmutter, MS.

The federal Food and Drug Administration (FDA) requires that food companies inform the agency about any food (for both humans and animals) they have manufactured and released for sale that has a reasonable probability of causing a serious adverse health consequence or death.  In FDA jargon, these are referred to as ‘reportable foods’.

Note: Meat, poultry, and some egg products are not subject to FDA oversight, they are regulated by the US Department of Agriculture.

The FDA compiles information about these ‘reportable foods’ and releases it in an annual Reportable Food Registry Report. In May, the report for the twelve months ending September 7, 2012 was made available.

The report tabulates the major reasons why some foods were hazardous to health.  It also lists the types of foods that were most likely to be hazardous. In some instances the report makes comparisons with results from prior years.

The Main Reasons for Reportable Foods

  1. Undeclared allergens were the primary hazard for the most recent twelve month reporting period. They accounted for 85 of the total of 224 reportable foods.  That’s 37.9 percent.
  2. Second was contamination with Salmonella, 63 reports and 28.1 percent.
  3. Third was contamination with Listeria monocytogenes, 48 reports and 21.4 percent.  Another bacterial contaminant, but with a much lower incidence rate, was E. coli O157:H7 (4 reports, 1.8 percent).

Overall, undeclared allergens and microbial contamination were responsible for almost 90 percent of the reports.

If one were sickened by any of these hazards, the memory is distinct. But the total number of reportable foods was a tiny, tiny number when compared to all of the production batches of all the foods that were manufactured during the twelve months.

Aside from allergens and microbial causes, there were very few reports due to other causes.  In descending order, from eight reports to one report, were:

  1. nutrient imbalance,
  2. uneviscerated fish,
  3. drug contamination,
  4. miscellaneous,
  5. foreign objects, and
  6. undeclared sulfites.

All of the nutrient imbalance reports were for formulated animal foods.

‘Milk’ was the most reported undeclared allergen

Milk (and milk-derived ingredients) was the most common undeclared allergen. Of the 85 reports for foods with undeclared allergens, 35 were for this omission.  Peanuts and tree nuts were each responsible for 10 reports, eggs for 9, and soy for 8.  Fish only one, and none for Crustacean shell fish.  Multiple food allergens was also a category, with 15 reportable foods.

No data about, or even a mention of, the allergen wheat was presented. According to the FDA, reported reactions to wheat in foods with undeclared wheat ingredients have not resulted in serious adverse health consequences or death.  Therefore the foods with undeclared wheat were not classified as reportable foods, and were not included in the report.

The report names the types of foods that were most likely to contain undeclared allergens.  Bakery had the most, and undeclared milk and milk-derived ingredients was the most common reason. Second was the category Chocolate/Confections/Candy.  Again, undeclared milk and milk- derived ingredients was the most common reason.

Third was Dairy.  Again, milk ingredients were the most common undeclared allergen.   I realize that it seems unusual for dairy products to have undeclared ‘milk’ ingredients.

An example would be a whipped cream product that has cream as the main ingredient, followed by sugar, and some flavoring, emulsifiers, and stabilizers.  If the labeling does not indicate that the cream is a milk-derived ingredient, the product has an undeclared milk allergen.

Here is a summary of results over three years.  Milk and milk-derived ingredients was the most commonly reported undeclared allergen in each of the three years.

Year Ending September Total Number of Foods with Undeclared Allergens  Total Number of Foods with Undeclared Milk and Milk Ingredients
2010 60 20
2011 75 20
2012 73 35

The most recent report cites one specific occurrence of a food with an undeclared milk ingredient that had the potential to cause significant harm.

The food, a snack bar, was reported by the manufacturer to the FDA shortly after it caused a consumer to develop an allergic reaction.  A recall was quickly instituted and no other allergic reactions were reported. The supplier of a chocolate ingredient in the snack bar had added a dairy ingredient containing a lot of milk protein.  The manufacturer had not updated the nutrition labeling to account for the change.

The Payoff

According to the FDA, the Reportable Food Registry has proven itself as an invaluable tool for maintaining a safe food supply.  It acts as an early warning system, allowing the FDA to assist food companies recalling potentially dangerous foods before they become major public health concerns.

The FDA has indicated that the Reportable Food Registry reveals products and product categories that are associated with hazards.  Once these hazards are identified, the FDA works with food growers, trade groups, and manufacturers to institute procedures to reduce the risk of harm.  In the words of the FDA’s Deputy Commissioner for Foods and Veterinary Medicine, Michael Taylor, registry “data are being used to help target inspections, plan work, identify and prioritize risks, and develop guidance for industry.”

Richard Perlmutter is the owner of Abington Nutrition Services LLC which prepares nutrition labeling for products manufactured by food and beverage companies. He also takes an interest in seeing that government nutrition policy is in line with nutritional science.