Good governance for food safety management

If there’s one food, safety types will not eat, it’s raw sprouts. Alfalfa, mung bean, pea and clover, they tend to be the same microbiological shithole.

Costco and Walmart stopped selling them five years ago in the U.S.

It’s impossible to get a sandwich or salad in Australia without sprouts.

I’ve written chefs who should not be serving raw sprouts to immunocomprised people in hospitals.

They poo-pooed my concerns.

My South Australian colleague, Andrew Thomson, is the company director for Think ST Solutions, a food consultancy offering practical solutions to both management and staff in hospitals, aged-care facilities, restaurants, hotels and the food industry.

Thomson writes in his latest column for Hospital Health that it’s time for the health- and aged-care sectors to move beyond meeting minimum compliance requirements and strive for business excellence in food safety management systems.

Health- and aged-care organisations face challenges and high expectations from an array of stakeholders, regulatory and accreditation agencies, and consumers. The area of food safety is no exception. Despite this, many organisations are achieving minimum regulatory compliance and failing to recognise related risks until after a serious episode occurs.

It is essential that board directors of health- and aged-care organisations, or those about to take on these roles, understand their role and responsibilities. It is important to be aware of food laws and other regulatory requirements, and ensure that organisations abide by them.

As far back as 1997, Winsome McCaughey AO, the former chief executive of the Australia New Zealand Food Authority, outlined the broad policy framework for food regulatory reform in Australia. The reforms promoted a risk-based approach to food safety management, which is consistent with international guidelines on risk analysis. Central to this approach was the introduction of national food safety standards.

The national food regulator, Food Standards Australia New Zealand, has developed standards that require food safety programs to be implemented in high-risk sectors, such as those providing food services to vulnerable persons. Food businesses providing potentially hazardous food to vulnerable persons — including hospital patients, aged-care residents and children in childcare centres — are captured by these requirements, in addition to businesses that prepare and deliver meals to vulnerable people in the home.

Health- and aged-care organisations need to ensure that risks to food safety management within their business are properly identified, reported and controlled.

The key action points for boards of directors to embrace are:

Understand and accept their role and responsibility in food safety leadership.

Understand and accept, at an individual board member level, the accountability for the role.

Understand the organisation’s obligations under various (food) legislation.

Create clearly defined policies on accountabilities, risk and reporting.

Consider the food safety implications of board decisions.

Oversee management actions in food safety matters.
The board should also agree on how to incorporate food safety management into existing governance structures; how to set objectives and monitor performance of the business and food-related risks; and the appointment of a board member as its food safety ‘champion’ — a nominated food safety director who will take the lead on ensuring that the board’s food safety management responsibilities are properly discharged.

The governance of an organisation involves the establishment of a framework of values, processes and practices designed to regulate, monitor and provide effective reporting on organisational performance. Through this framework, boards and directors exercise their governing authority and make decisions to achieve the organisation’s purpose and goals. Directors ensure the organisation operates effectively and ethically, and complies with all laws and regulations.

Food safety governance is as important as any other aspect of governance. It is also a fundamental part of an organisation’s risk management strategy, which is a key responsibility of a board of directors. Both the board and its management team have a duty to exercise due diligence to ensure that the organisation complies with its food safety duties and obligations. Failure to effectively manage food safety risk has both human and business costs — this includes damaged reputations and potential prosecution.

It is important to distinguish between governance and management practices. Directors should focus on governance-related issues — determining the organisation’s purpose, developing an effective governance culture, holding management to account and ensuring effective performance and compliance. Directors work with management to develop strategy and business plans which are then implemented by management.

There is no ‘one size fits all’ solution for establishing effective governance for food safety management, as the structures and levels of engagement vary with the size and complexity of the organisations involved. There are a number of basic questions that a board of directors can ask itself to assist in creating the right business culture:

How does the board assure itself that the food safety management system has been fully implemented across the organisation?

How does the board assure itself that the organisation is demonstrating its commitment to food safety?

How does the board verify that the organisation’s food safety strategic and operational risks have been adequately identified and assessed, with appropriate mitigation strategies implemented?

What relevant information is the board receiving on food safety management? Is this reporting sufficient?

What processes are in place to inform board members of the results (and actions taken) from internal and external audits and comprehensive senior management reviews to ensure the food safety management system is fit for purpose?

How does the board satisfy itself that the organisation has food-handling employees and managers that are competent and adequately trained in their food safety responsibilities and accountabilities?

Does the organisation have sufficient resources (people, equipment, systems and budget) for managing its food safety management systems?

What approach does the board use to compare the performance of the food safety management system with comparable organisations? How does it monitor and rate its organisation’s performance?
In regards to competency and adequate food safety training, shrinking training budgets and providing employees with traditional training approaches to basic compliance training is one area for urgent change if an organisation is to flourish.

The decades-long and less desirable training practice used by many organisations relies on herding as many employees as possible to undertake (any form of) training and then show the regulator and/or accreditation assessors the training records. This approach fails on several fronts: it does not provide employees with the skills they urgently need for doing their job now and in the future; lacks the required processes when employees learn new skills and behaviours; and does not address developing the best employees for future roles. Questions relating to employee learning strategies, skills development, performance and systems improvement, and measuring training success are largely overlooked by senior leaders and the regulator.

RMIT Online and Deloitte Access Economics recently released Ready, set, upskill: Effective training for the jobs of tomorrow. This report provides fresh insights into post-COVID skill needs; how prepared Australians feel for a changing workplace; and where employers should invest in training to prepare for what’s ahead.

Modern approaches to learning in the workplace necessitate a model of continuous learning and supporting employee learning — it moves beyond designing and delivering one-off training programs.

A comprehensive table of sprout-related outbreaks can be found here.

Travel, sprouts (the raw kind) and reptiles significant sources of Salmonella in Ontario

Former hockey buddy and nice veterinarian Scott McEwen at the University of Guelph (that’s in Ontario, Canada) is one of the authors of a paper investigating Salmonella Heidelberg and Salmonella Typhimurium role in human salmonellosis in Ontario. Introduction of the Ontario Investigation Tools (OIT) in 2014 allowed for standardized case investigation and reporting. This study compared the risk factors and symptomatology for sporadic S. Heidelberg and S. Typhimurium cases reported in Ontario in 2015, following implementation of the OIT.

Multilevel logistic regression models were applied to assess associations between serotype and individual‐level demographic characteristics, exposures and symptoms for sporadic confirmed cases of S. Heidelberg and S. Typhimurium in Ontario in 2015. There were 476 sporadic cases of S. Typhimurium (n = 278) and S. Heidelberg (n = 198) reported in Ontario in 2015. There were significant associations between the odds of the isolate from a case being one of these serotypes, and travel, consumption of sprouts (any type), contact with reptiles and development of malaise, fever or bloody diarrhoea.

The S. Typhimurium and S. Heidelberg cases differed in both symptom presentation and risk factors for illness. Case–case comparisons of Salmonella serotypes have some advantages over case–control studies in that these are less susceptible to selection and recall bias while allowing for rapid comparison of cases to identify potential high‐risk exposures that are unique to one of the serotypes when compared to the other.

Comparing cases of two different Salmonella serotypes can help to highlight risk factors that may be uniquely associated with one serotype, or more strongly associated with one serotype compared to another. This information may be useful for understanding relative source attribution between common serotypes of Salmonella.

A case-case study comparing the individual risk factors and symptomatology of salmonella Heidelberg and salmonella typhimurium in Ontario, 04 May 2020

Zoonoses and Public Health

Katherine Paphitis, David L. Pearl, Olaf Berke, Scott A. McEwen, Lise Trotz‐Williams

https://doi.org/10.1111/zph.12709

https://onlinelibrary.wiley.com/doi/abs/10.1111/zph.12709?af=R

Jimmy John’s and sprouts — again

Remember when Jimmy John’s, the sandwich favored by university faculty department meetings and college students across the U.S., sickened hundreds of people across the U.S linked to raw alfalfa sprouts so they switched to raw clover sprouts and made more people sick?

It’s happened again.

Chris Koger of The Packer reported in late Dec. 2019 that Sprouts Unlimited, Marion, Iowa, is recalling clover sprouts, which have been linked to a cluster of E. coli cases under investigation in Iowa.

The Iowa Department of Inspections and Appeals is investigating the link between the outbreak and the product from Sprouts Unlimited, according to a Dec. 27 recall notice from the company.

The sprouts were shipped to Hy-Vee and Fareway Foods stores, and Jimmy John’s restaurants.

The retail packs in the recall are in pint containers with a blue label on the lid, according to Sprouts Unlimited. The Universal Product Code is 7 32684 00013 6 is on the bottom right side of the label.

The Iowa Department of Inspections and Appeals told Sprouts Unlimited the sprouts are epidemiologically linked to the outbreak. More tests are being conducted to determine the source, according to the recall notice.

We document at least 55 sprout-associated outbreaks occurring worldwide affecting a total of 15,233 people since 1988. A comprehensive table of sprout-related outbreaks can be found here.

Failures in sprouts-related risk communication

Food Control.2012. 10.1016/j.foodcont.2012.08.022

Erdozain, M.S., Allen, K.J., Morley, K.A. and Powell, D.A.

http://www.sciencedirect.com/science/article/pii/S0956713512004707?v=s5

Nutritional and perceived health benefits have contributed to the increasing popularity of raw sprouted seed products. In the past two decades, sprouted seeds have been a recurring food safety concern, with at least 55 documented foodborne outbreaks affecting more than 15,000 people. A compilation of selected publications was used to yield an analysis of the evolving safety and risk communication related to raw sprouts, including microbiological safety, efforts to improve production practices, and effectiveness of communication prior to, during, and after sprout-related outbreaks. Scientific investigation and media coverage of sprout-related outbreaks has led to improved production guidelines and public health enforcement actions, yet continued outbreaks call into question the effectiveness of risk management strategies and producer compliance. Raw sprouts remain a high-risk product and avoidance or thorough cooking are the only ways that consumers can reduce risk; even thorough cooking messages fail to acknowledge the risk of cross-contamination. Risk communication messages have been inconsistent over time with Canadian and U.S. governments finally aligning their messages in the past five years, telling consumers to avoid sprouts. Yet consumer and industry awareness of risk remains low. To minimize health risks linked to the consumption of sprout products, local and national public health agencies, restaurants, retailers and producers need validated, consistent and repeated risk messaging through a variety of sources.

Health update, and sprouts still suck

Amy and Sorenne came to visit me last night at the Clinical Facility I’ve been staying at for the past two weeks and we went out for dinner (the seafood was fabulous).

That’s me and the kid last night at dinner (right).

I checked myself in because I have been randomly falling when walking — the sidewalk just sorta rises up and I smash my head yet again. The other day I endured two seizures while eating lunch in the cafeteria and the docs present shipped me off to Emergency.

Long-time skeptics are finally agreeing with me that these things are happening because of genetics, booze (which is primarily to provide numbness to the fog upstairs but I’m going without) 50 years of pucks to the head, dozens of concussions, epilepsy and whatever else may be happening in that precious organ known as the brain.

So I haven’t been writing much.

They shipped out to New Caledonia this morning for Amy’s work for a few days, so I made sure I was taken care of so she wouldn’t have to worry.

It is seemingly impossible to get a sandwich or salad in Australia without it being covered in raw sprouts.

This is Amy’s salad from dinner last night (left).

We document at least 55 sprout-associated outbreaks occurring worldwide affecting a total of 15,233 people since 1988. A comprehensive table of sprout-related outbreaks can be found here.

Frank talks about sprouts

Frank didn’t waste any time after leaving Wal-Mart for government.

Good on ya.

But guidance is not enforcement.

My group learned that the hard way 20 years ago.

And they still serve sprouts to immunocompromised people in Australian hospitals despite a ridiculous number of outbreaks.

“Over the past 22 years, the U.S. Food and Drug Administration (FDA) has investigated 50 reported outbreaks of foodborne illness associated with contaminated sprouts. Together, these outbreaks resulted in more than an estimated 2,600 cases of illness. Last year, there were two reported outbreaks associated with sprouts, resulting in more than an estimated 100 illnesses. Studies indicate that contaminated seed is the likely source of most sprout-related outbreaks, as this commodity is inherently more susceptible to these issues because they are grown in warm and humid conditions that are favorable for bacteria like Salmonella, Listeria and E. coli,” said FDA Deputy Commissioner for Food Policy and Response Frank Yiannas.

“The FDA is committed to taking swift action to respond to outbreaks related to sprouts and keep our food supply safe, but we also know that measures to prevent issues from happening in the first place are an important element of protecting consumers. By studying outbreaks related to sprouts over the years, we have been able to recommend changes in the industry to help lower the incidence of sprout-related outbreaks. Today’s new draft guidance is another critical step, like the Sprout Safety Alliance or sprout-specific requirements of the Produce Safety Rule, the agency is taking to prevent illnesses related to sprouts.”

FDA today released a proposed draft guidance, “Reducing Microbial Food Safety Hazards in the Production of Seed for Sprouting,” intended to make the sprout seed industry (seed growers, conditioners, packers, holders, suppliers, and distributors) aware of the agency’s serious concerns with the continuing outbreaks of foodborne illness associated with the consumption of raw and lightly-cooked sprouts.

Incorporating aspects of the Codex Code of Hygienic Practice for Fresh Fruits and Vegetables Annex II, Annex for Sprout Production; the International Sprout Growers Association-Institute for Food Safety and Health’s “U.S. Sprout Production Best Practices”; and Good Agricultural Practices, the FDA’s draft guidance issued today provides the agency’s recommendations to firms throughout the production chain of seed for sprouting. It states that if a grower, holder, conditioner, or distributor reasonably believes that its seeds are expected to be used for sprouting, we recommend that the grower, holder, conditioner, or distributor take steps that are reasonably necessary to prevent those seeds from becoming contaminated. We also recommend that firms throughout the supply chain – from seed production and distribution through sprouting – review their current operations related to seeds for sprouting.

During the 60-day comment period for this draft guidance, stakeholders will be able to provide comments on the draft provisions. For more information on this guidance, as well as instructions on how to submit your comments, please visit Draft Guidance for Industry: Reducing Microbial Food Safety Hazards in the Production of Seed for Sprouting.

Should we be afraid of eating sprouts?

I don’t eat much lettuce either.

But I eat a lot of fruit and veg.

 I revealed last week I was nervous about doing a media interview, because I’ve been out of the game for a while, and my brain, just don’t work so well.

Fell again today and it hurt.

I have no balance.

But I still have a brain.

So when a U.S. reporter agrees to chat at 4 a.m. EST (6 p.m. EST) I say sure, because I’ve always been a media whore. How else to spread the message.

I particularily like the lede.

Kate Bernot of The Take Out wrote, “If you ask anyone in food safety, ‘What is the one food you will not eat?’ Raw sprouts tops the list, always.”

That’s one of the first sentences out of the mouth of Doug Powell, a former professor of food safety and the publisher of barfblog, a frequently updated site that publishes evidence-based opinions on food safety.

I’ve asked him whether food-safety fears about sprouts—those tiny, crunchy squiggles in your salad or sandwich—are well-founded. He tells me the public isn’t concerned enough about them.

“Risk is inherent in the nature of the product which is why Walmart and Costco got rid of them,” he says. (Kroger also stopped selling sprouts in 2012.) “This is not a new problem. It’s been going on for decades.”

According to a paper he and three colleagues published in the journal Food Control in 2012, sprouts have been responsible for at least 55 documented foodborne outbreaks affecting more than 15,000 people globally in the past two decades. The Food And Drug Administration tallies 46 reported outbreaks of foodborne illness in the United States linked to sprouts between 1996 and 2016, accounting for for 2,474 illnesses, 187 hospitalizations, and three deaths. In an effort to reduce these outbreaks, the FDA in 2017 collected 825 samples of sprouts from across the U.S.; 14 of those tested positive for E. coli, listeria, or salmonella.

The first reason sprouts—whether alfalfa or mung bean or radish or other varieties—can carry E. coli or salmonella bacteria has to do with how the sprouts are produced. The conditions that cause a seed to sprout are the same conditions that cause bacteria to breed: warm, moist air.

“The sprout is made from germinating seeds and the seeds themselves may be the source of the contamination. When you’re germinating a seed and growing a sprout, you’re providing conditions for the sprout growth that are ideal also for bacterial growth,” says Craig Hedberg, a professor in the School Of Public Health at University Of Minnesota. “This is a product that went through incubator-like circumstances.”

The second reason is related to how most of us consume sprouts: raw. Because we value sprouts’ crunch, we rarely cook them before adding them to a dish. Powell notes that people in many Southeast Asian countries do blanch their sprouts before cooking with them, but that the West tends to consume them raw.

The third reason sprouts can pose a risk is because even rinsing them won’t generally remove enough of the bacteria to keep an infected sprout from making a person sick. Hedberg says that even romaine lettuce, which has recently been associated with foodborne illness outbreaks, has a surface area that’s easier to wash than sprouts.

“The seeds can get contaminated as they’re growing, so the contamination can be internal,” Powell tells me. “So you’re never going to wash it off.”

Sprouts do have their defenders, though, who note higher levels of soluble fiber, antioxidants, vitamins, and mineral bioavailability compared to non-sprouted grains and vegetables. The Academy Of Nutrition And Dietetics statesthat “in general, the health benefits associated with savoring raw or lightly cooked sprouts outweigh risks for healthy individuals. However, be aware that there is risk of food poisoning if you plan to eat them.”

The FDA recommends cooking sprouts thoroughly to kill bacteria, and further advises that the elderly, children, people who are pregnant, and people with compromised immune systems should not eat sprouts at all. To further reduce your risk of sprout-related foodborne illness, the FDA says consumers can “request that raw sprouts not be added to your food.” So, bottom line, if you’re concerned—yeah, just don’t eat them. May we suggest beet slivers or carrot ribbons for crunch?

69 sick from Salmonella linked to raw sprouts in NZ

If there’s one food safety types will not eat, it’s raw sprouts.

Costco and Walmart stopped selling them five years ago in the U.S.

It’s impossible to get a sandwich or salad in Australia without sprouts.

I’ve written chefs who should not be serving raw sprouts to immunocomprised people in hospitals.

They poo-pooed my concerns.

According to Outbreak News Today there are 67 confirmed Salmonella cases and 2 probable cases linked to sprouts consumption in New Zealand.  Illness onset ranged from December 23, 2018 to April 1, 2019. 66 of the cases became ill between January 23, 2019 and January 25, 2019.  17 people required hospital treatment.

In the wake of the outbreak, GSF New Zealand recalled certain Pams, Sproutman, and Fresh Harvest brand sprout products.  GSF New Zealand said the recall was due to a “production process concern.” Regarding the Salmonella outbreak, New Zealand’s Ministry of Health reported that “Salmonella Typhimurium phage type 108/170 was the causative pathogen identified from cases, sprouts and spent irrigation water tested in this outbreak. Subtyping using Multiple Locus Variable-Number Tandem Repeat Analysis (MLVA) and whole genome sequencing methods were performed on isolates to confirm cases in the outbreak as well as the outbreak source.”

Fun with fermentations: Latic acid can maybe make sprouts safer

Legume seeds and sprouts are a rich source of phytoestrogens in the form of isoflavonoids. For the first time, lactic acid fermentation of four types of legume sprouts was used to increase the content of isoflavonoids and microbiological safety.

After germination, the highest content of isoflavonoids was observed in the clover and chickpea sprouts, which amounted to 1.1 g/100 g dw., whereas the lactic acid fermentation allowed the increase to as much as 5.5 g/100 g dw. The most beneficial properties were shown by fermented chickpea sprouts germinated in blue light.

During fermentation the number of lactic acid bacteria increased by 2 Log10CFU/mL (LU), whereas mold decreased by 1 LU, E.coli and Klebsiella sp. by 2 LU, Salmonella sp. and Shigella sp did not occur after fermentation, similar to Staphylococcus epidermidis, while S. aureus and S. saprophyticus decreased by 3 LU and in some trials were not detected.

Lactic acid fermentation of legume seed sprouts as a method of increasing the content of isoflavones and reducing microbial contamination

6.feb.19

Food Chemistry, https://doi.org/10.1016/j.foodchem.2019.01.178

GrażynaBudryn, ElżbietaKlewicka, JoannaGrzelczyk, IlonaGałązka-Czarnecka, Radosław Mostowski

https://www.sciencedirect.com/science/article/pii/S0308814619302675

Sprouts still suck: Seven in hospital, 14 more sick with Salmonella from alfalfa sprouts in South Australia

Brad Crouch of The Advertiser writes seven people are in hospital and another 14 sick from eating alfalfa sprouts, triggering a SA Health warning to the public not to eat alfalfa sprout products produced by Adelaide business SA Sprouts.

SA Health Chief Medical Officer and Chief Public Health Officer, Professor Paddy Phillips, said there had been 21 confirmed cases of Salmonella havana linked to the sprouts.

“We are advising anyone who has purchased the recalled SA Sprouts alfalfa sprouts products to return them to the place of purchase for a refund, or throw them away,” Prof Phillips said.

“We also want to alert cafes and restaurants to check their suppliers and not serve any SA Sprouts alfalfa sprout products until further notice.

“In cases of salmonella a common food source is not often identified, however a joint investigation between SA Health, local government and Primary Industries and Regions SA (PIRSA) has linked these cases to SA Sprouts alfalfa sprouts.

“We are working closely with the producer and suppliers while we continue to investigate.”

Sprouts still suck: Now Real Food brand Zesty Sprouting Mix recalled due to Salmonella

Puresource Inc. is recalling Now Real Food brand Zesty Sprouting Mix from the marketplace due to possible Salmonella contamination. Consumers should not consume the recalled product described below

This recall was triggered by a recall in another country. The Canadian Food Inspection Agency (CFIA) is conducting a food safety investigation, which may lead to the recall of other products. If other high-risk products are recalled, the CFIA will notify the public through updated Food Recall Warnings.

The CFIA is verifying that industry is removing recalled product from the marketplace.

There have been no reported illnesses associated with the consumption of this product in Canada.