By: James Peacock and Candess Zona-Mendola
In what amounted to be the largest food safety reform in 70 years, President Barack Obama signed the Food Safety Modernization Act in 2011. Its aim, among other things, was to modernize the food safety industry in order to prevent foodborne pathogen contamination and the illness outbreaks that result from it. Although there were some that continued to fight for further restriction and reform, the bill pleased many in the food and agriculture industries.
One of the key components to the bill was the Foreign Supplier Verification Program (FVSP), which began its roll-out on May 30, 2017. This part of the bill requires numerous food importers to adhere to better standards, such as determining foreseeable food hazards, evaluating the risk that a food poses, and conducting verification and corrective activities. With the United States relying more and more on imported products, it made sense to make sure that they are held to the same standard as food items that originated here in the United States.
According to the FDA, companies who import into the United States are subject to FVSP’s roll-out timelines unless:
- They are covered by the PC or produce safety rules;
- They are subject to the PC for Human Food rule and are not “small businesses,” “qualified facilities” (certain very small businesses) or subject to the Pasteurized Milk Ordinance; or
- “They are subject to the current good manufacturing practices (CGMP) requirements in the PC for Animal Food rule, and are not “small businesses” or “qualified facilities.
Sadly, the lack of funding to the FDA has caused issues in the expansion of the imported foods inspection programs. The original bill called for double the amount of foreign inspections to occur each year, but the FDA is short-staffed. With further budget cuts potentially occurring, it may be yet harder for the FDA to meet its goals in ensuring that imported products are up to a certain standard. Even without the incipient budget cuts, though, the FDA and other regulatory agencies are already dealing with a slew of outbreaks and recalls caused by imported food items.
Outbreaks Stemming from Imports
Hepatitis A in 2016
The problem presented by both the disparity in import standards and the understaffing of regulatory agencies was highlighted in the pair of Hepatitis A outbreaks that occurred in 2016. The first was a huge outbreak that mainly impacted the Hawaiian Islands. This outbreak was linked to frozen scallops that had been imported from the Philippines. By the end of the investigation, almost 300 people were infected with the Hepatitis A virus between June and October 2016. Although any further potentially contaminated imported scallops were embargoed and held at warehouses, a fair amount of product was able to be sold to the general public before the contamination was spotted. This outbreak was occurring simultaneously with an outbreak that mainly focused on the east coast of the United States. That outbreak was caused by strawberries imported from Egypt. Despite assurances that the strawberries were Hepatitis free, investigators got positive test results back from samples taken from the strawberries. The outbreak would eventually be investigated by the CDC, and would sicken 143 people in nine different states including California, Virginia, Oregon, Wisconsin, Arkansas, New York, Maryland, North Carolina, and West Virginia.
Hawaii was hit again with another imported Hepatitis A scare – that time involving Ahi tuna. Although the recall of the potentially contaminated products did not appear to end in the evolution of an outbreak, the concern over proper inspection of imports and how far they can circulate into the retail system before an issues is found was called into question.
Salmonella in Papaya
In an outbreak that is still unfolding, the CDC has launched an investigation into a Salmonella outbreak that has sickened 47 people in 12 states, and led to the death of one in New York. The outbreak was preceded by an alert issued by the Maryland Department of Health regarding Maradol papayas. The outbreak, which was announced shortly after, named imported yellow Maradol papayas as a cause of the infection. The papayas were grown and imported from Mexico by Grande Produce.
The FDA announced on July 25th that the distributor initiated a small (and relatively silent) recall concerning the papayas linked to the outbreak. According to the FDA’s website:
“Grande Produce has informed the FDA that the company initiated a limited recall of their Caribeña brand Maradol papayas distributed nationwide from July 7 – July 18, 2017. As of July 25, 2017, Grande Produce has not issued a press release to notify consumers of their recall. Therefore, FDA is advising consumers to avoid all Caribeña brand Maradol papayas. The FDA also noted that there are illnesses in states where Grande Produce did not distribute papayas and is continuing its investigation.”
It is likely that other brands of papayas, maybe even additional imported ones, could be linked to this outbreak or the potential sister outbreak involving Salmonella Thompson.
Cyclospora in Imported Produce
Texas is currently the center of another outbreak involving Cyclospora. At this time, a source has not been identified. However, it is highly likely this outbreak will also be linked to imported foods. Out of the last four outbreaks that have been caused by Cyclospora, two of them were eventually linked to cilantro imported from Mexico. The other two never had confirmed sources. In response to these outbreaks, the FDA installed an import alert on the imported cilantro, and the subsequent year upheld that alert after there was a noticeable decrease in Cyclospora infections. Canada and the UK are dealing with similar outbreaks of Cyclospora, which have also believes to be linked to imported foods and travelers returning home from Mexico.
There have been instances in which the new and improved food safety system has successfully prevented foodborne pathogen contaminated foods from entering the country. Late last month, the USDA halted imports of beef products imported from Brazil. The suspension of beef importation came after quite a few concerns arose regarding the safety of the imported products. Prior to the suspension, the USDA had decided to track and check all imports of Brazilian beef. In the days that followed, they held 106 lots of beef for various issues. Other nations, including the Philippines, China, Chile, Hong Kong, Japan, Canada, Mexico, and the EU have also taken measures against the importation of potentially contaminated beef from Brazil.
A Growing Concern
With the outbreaks linked to imported foods and the imports of poultry from China, there is a growing concern among the populace that we will only continue to see more and more outbreaks involving imported food. In times like these, traceability and transparency in the food supply web are needed more than ever. Efforts like the Food Safety Modernization Act have attempted to offer this transparency and keep the general public safe, but unless the Act is properly enforced, the foodborne illness issues that have plagued imported foods in the last year will continue to happen. Unless more funding is given to regulatory agencies, and more legislation allows them to properly act against potentially contaminated imported foods, events like the strawberry outbreak, the scallop outbreak, the cilantro outbreaks, and the papaya outbreak will not be seen as uncommon flukes, but rather inevitable semiannual occurrences. The way that things appear to be going, though, indicate that we may be heading in entirely the wrong direction.