Guilt by Association: The Impact of Secondary Recalls

1. Guilt by Association:The Impact of Secondary Recalls Erin Woodom Food Compliance Officer Rapid Response Team Microbiologist Food and Drug Protection Division

2. Big Picture A recall at any point in the supply chain can have an impact on your business

3. Weak Links in the Food Chain • Recall preparedness is a vital part of operating a food business • Even if you are conscientious, can you vouch for your suppliers? • Your supplier’s suppliers? • Your supplier’s supplier’s suppliers? • Your supplier’s supplier’s supplier’s suppliers?

4. Case Study: Ground Pepper • Starting in Summer 2009, an increase in persons infected with Salmonella montevideo was observed • Cases appeared across the country (see map at right) Source: Centers for Disease Control

5. Case Study: Ground Pepper • Public Health analysis indicated consumption of Daniele-brand sausage and salami linked to illnesses • Follow-up testing found Salmonella in salami products on market • USDA and State regulatory agencies began investigating salami manufacturer

6. Case Study: Ground Pepper • Investigation led to recall of approximately 1.3 million pounds of meat products • Three-month investigation suggested pepper used in sausages source of Salmonella

7. Case Study: Ground Pepper • FDA tested 3,600 spice samples during investigation • Two lots of bulk ground pepper from two different suppliers tested positive for Salmonella • Recall of ingredient led to recall of additional products from additional manufacturers

8. Case Study: Ground Pepper • Final Tally • 272 confirmed illnesses from contaminated products; 11 additional possible illnesses • 2 Ground Pepper Recalls • 6 Sub-Recalls from spice company customers • 75 products removed from market • Ingredient-driven recalls typically have larger impact and affect more companies

9. Food for Thought • Do you keep records of the lot numbers of your raw materials? • How quickly could you trace your product? • Do you have a good working relationship with your suppliers? • Are you prepared to respond quickly to a recall not of your own making?

10. 2009 PCA Peanut Recall • 3,907 products were recalled in approximately 2,100 sub-recalls • Estimated $1 billion in economic impact • Peanut product sales from all producers dropped due to loss of consumer confidence • Are you prepared to manage a crisis among your commodity? Are you prepared to take advantage of it?

11. 2006 Spinach Recall • E. coli in bagged spinach caused 199 illness and 3 deaths • Significant drop in spinach consumption nationwide • Spinach consumers shifted buying patterns to smaller, local growers • Some small farms have maintained increased leafy greens sales

12. Conclusion • Recalls from wholesale suppliers can quickly grow in scope and cost • Even if you are careful, another link in the chain can cause problems for you • Effective crisis planning and management reduces impact and protects your business • Recalls from other suppliers can be a business opportunity for prepared firms

13. Questions? Brett Weed Compliance and Preparedness Administrator Food and Drug Protection Division brett.weed@ncagr.gov 919-733-7366 NCFOODSAFETY.COM