Jeff Koeze's Blog Good Food, Good Business, and the Good Food Business

18Feb/090

My Post From the Daily Kos

My wife suggested I put some of my thoughts about the peanut recall on Daily Kos.  The text of my post follows.  There were a number of interesting and helpful comments, several of which I responded to.  I hope to copy some of the comments and my responses over to this blog later today.

One long month in the peanut butter business from an insider:

Last month I was trying to sell peanut butter at the San Francisco Fancy Food Show when people started showing up at my booth and asking me if my peanut butter contained salmonella.  This was not a good way to find out about a recall.  Since we do all of our own roasting from raw peanuts, I knew our peanut butter wasn't affected by the recall.  So I wasn't terribly concerned.

I then got a couple worried phone calls from our staff back at the office in Grand Rapids.  Customers are calling.  They want to know if our peanut butter is "safe."  Safe is a hard word.  Yes, our peanut butter is safe as in "he is a safe driver -- he's never had an accident, doesn't drink, drives a Volvo, doesn't speed."  And we haven't had a problem in our 80 years of making peanut butter.  But safe as in "100% guaranteed safe absolutely no risk under any circumstances" -- as the mother of a child with a chemotherapy-impaired immune system asked us -- no.  There is no responsible food manufacturer who can say that.

Back home from the food show, I watched this recall unfold like a slow-motion train wreck.  While our peanut butter wasn't affected, we needed to check our purchasing records for our retail stores.  A couple of our suppliers issued recalls on some products, but nothing we had purchased.  One bullet dodged. But we are still watching the FDA Recall List like a hawk.

We put a little notice up on our web site indicating that we weren't affected by the recall, and put ourselves on the primary list of unaffected products. We assured our wholesale customers that we were unaffected.

I next scheduled a series of small group meetings with all of our employees to talk about the recall, our responses, and to re-emphasize how important our sanitation and personal hygiene rules are.  I am fond of saying about business problems "lighten up a bit, nobody is going to die."  In the case of sanitation, that's not so.

I also told our employees that for a couple weeks every inspector in the nation was going to be tied up chasing down all the recalled products.  Once that was over, we could expect the FDA to show up.

For the next two weeks I spent most of my time on line following the reporting as carefully as I could.  This wasn't rubber-necking, but an attempt to figure out exactly what had happened at the PCA facility.  In the case of the Peter Pan recall in 2007 the explanation given for the salmonella contamination was a roof leak.  Fine. Keep the roof from leaking -- we're on it.

But now we had a second recall in two years.  Had something changed in the peanut supply chain -- practices in the peanut fields, in the shelling process, in the heat resistance of salmonella? -- that meant that industry practices which had previously prevented illness were no longer effective?  Was general nastiness in the PCA plant enough to explain to their problems?  (Maybe, but I have my doubts.) If it is general nastiness, why was the FDA considering moving peanut butter to the "high risk"category?  Political cover?  Or do they share some of my questions?

On February 5th we shut down our nut roasting, confectionery, and peanut butter lines for our annual preventative maintenance period in which we really tear apart the equipment.  Since we would be shut down for a couple weeks at least, I decided this was time to review all of our practices to see if we had holes in the safety net.  In addition to a complete internal review, I have hired a sanitation expert from the largest food safety consulting company to come and review our practices as well.

Last Thursday (2/12) I was just finishing up a conversation along these lines and informing my senior managers of our plans when there was a knock at the conference room door.  "Jeff, the FDA is here." Even though I was expecting this, I felt like I'd been called to the principal's office.

I met the inspector at the door with my production manager.  The inspector showed his ID and badge (yes, they have badges, just like the police), and we went to a conference room. He explained that we were due for our annual inspection and that today was the day because his supervisor had picked us out and moved us up the list. The initial concern was that we had covered all the bases in checking to be sure we had not purchased or sold any recalled items.  But in asking questions our inspector realized that we actually made peanut butter ourselves. After an hour or so of additional background questions on the company, products, distribution, and such matters, it was time to do the walk through the facility looking for Good Manufacturing Practice violations.  We gave him everything he asked for, and answered his questions forthrightly.

That took another hour (it would have been longer had we been operating).  The inspector left for lunch and checked with his office for additional guidance.  The main issue was whether to return and take environmental swabs for testing, and whether to pull product samples for microbiological testing.  Since we were shut down and hadn't run for a week, the decision was no.  We will, as a courtesy, inform them of our next few peanut butter runs should they desire to inspect.  We haven't received the written report of the visit yet, but I expect it will be clean, just as our last nine annual inspections have been.

A long story.  What's the point?   Much political energy is being put into reform proposals.  But the rubber hits the road when an individual inspector walks into a particular plant. In our case, that is for 3 or 4 hours, once a year.  The other 364 days it is up to me and my employees, working on food safety issues as I've tried to work through this one.

Is that a problem?  In PCA's case, yes. But would an additional annual inspection have prevented it? Two more inspections?  Three?  Would combining USDA's food regulation authority with the FDA's have prevented this?  How, exactly?  Would having federal inspectors replace state inspectors help?  The inspector who called on us had worked for the State of Michigan for years before moving to the FDA.  Would some enhanced ability to trace food help? Only after the fact, when it is too late.  HACCP plans for all food manufacturers?  PCA had one. How about reporting all salmonella and other microbial tests to the FDA? How many people would it take to police and follow up on millions of tests conducted by hundreds of labs, and by companies in house?

I'm OK with all of the above, and with having my taxes raised to pay for it all.  But the safety of our food is still going to depend on ordinary people struggling to do the right thing every day.

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