Food Product Recalls – 2017 in Review

Posted in Food Recall and Crisis Counsel

Over the past few years, the numbers and types of food product recalls have increased dramatically. As we move into 2018, these trends are likely to continue.  By carefully studying the types and causes of food product recalls, however, we can identify food safety failures and develop strategies to avoid repeating past mistakes.  In turn, the following article looks at the leading causes of recalls in 2017, and offers some perspective on how the same problems might be avoided in 2018.

There were a total of 440 recalls of FDA and USDA regulated food products in 2017. 

The single leading cause of food product recalls in 2017 was the presence of undeclared allergens and the misbranding of products.  A total of 218 recalls were announced because the products at issue contained ingredients, such as wheat, peanuts, tree nuts, fish, shell fish, soy, milk, egg, MSG and/or sulfites, that were not declared on the product label.  When conducting food safety inspections, both FDA and USDA are increasingly focused on allergen control failures within food facilities, and both agencies will likely continue to discover labeling problems that will force additional recalls.

Although many companies struggle with allergen control programs that adequately mitigate supplier oversight, printing errors, and inventory management and processing challenges, there are some solutions that have proven helpful.  The pharmaceutical industry, for instance, struggled with similar issues in past years, and has since developed systems to effectively manage these challenges.  In 2018, consider partnering with solution providers who have confronted and developed solutions for these issues.  With some additional diligence focused on allergen control, we should see the numbers of recalls for undeclared allergens in 2017 decrease.

Undeclared ingredients in products weren’t the only problems that caused headaches for food companies in 2017.  A surprising number of products needed to be recalled because the labels were just plain wrong.  A raw pork product, for instance, was labeled as ready-to-eat when it had not, in fact, been cooked.  In another example, packages of “espresso beans” contained “almonds.”  One company labelled and then shipped jars of “tarter sauce” that actually contained “hot sauce.” 

In another example, cans of “chicken soup” contained “Italian Wedding Soup with Meatballs.”  Another company sold packages of “Pot Roast” that were actually “Meat Loaf.” In another surprising example, shipments of bags of “hamburger buns” were instead filled with loaves of bread.   Here too, each of these recalls of perfectly safe food could have been avoided if company employees were taught to be more diligent and more aware of the products they were handling.

The second leading cause of recalls in 2017 was the presence of harmful pathogens in ready-to-eat (RTE) food.  In total, 149 recalls were announced because the products at issue, if consumed, had the potential to cause adverse health consequences or death.  This represents about 34% of all recalls announced in 2017. 

The most prevalent pathogen discovered in food products was Listeria MonocytogenesListeria was the underlying cause of a total of 101 recalls. And, it seemed as if no food was immune. These recalls included a long list of products such as hummus, frozen vegetables, apples, seafood, bagged salads, cheese, soup, protein bars, nuts, pancakes, waffles, dog food, RTE meat products and, most recently, frozen biscuit pucks. 

Salmonella came in as second most prevalent pathogen, causing 23 recalls.  These recalls involved a wide-range of food products which included Twinkies, tuna loins, chocolate-coated candies, kettle-cooked chips, and mango ice cream.

The third leading cause of recalls involved the presence of foreign materials.  In total, 37 recalls were announced in 2017 because of the presence of unwanted or unexpected materials in the products at issue.  The more notable examples included the discovery of extraneous golf balls parts in hash browns, and bat body parts in “organic” – literally and figuratively – “spring salad.”  Fortunately, according to FDA, consumption of these salad products had a “minimal risk of rabies contamination.”  Other foreign materials that caused large-scale food product recalls included minuscule bits of soft blue plastic, rubber, Styrofoam, metal shavings, and glass. 

As we move into 2018, stay tuned.  As a food regulatory consultant and lawyer, I will continue to study and provide monthly reports on all FDA and USDA recalls.  Hopefully, we can use this information to drive recall numbers down.  And, with some additional diligence and, perhaps, a little luck, we will be able to eat more and recall less of the wonderful foods you make.

Thanks for all you do, and have a prosperous 2018!!