Addressing Consumer Complaints Samples in a Regulatory ... · PDF fileContaminants related to...

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Marc E. Engel FDACS, Food Safety Laboratories , Chemistry Tallahassee, FL [email protected]

Transcript of Addressing Consumer Complaints Samples in a Regulatory ... · PDF fileContaminants related to...

Marc E. Engel FDACS, Food Safety Laboratories , Chemistry Tallahassee, FL [email protected]

Complaints

Suspect health problem Food Borne Illness (FBI)

Food Fraud

▪ Economic adulteration

▪ Label does not comply with claims or NLEA guidelines

Suspect Contamination

▪ Macro (foreign material)

▪ Micro (chemical or biological)

The sample is sent or reported by Department of Business Regulation (DBR) ▪ Economic fraud

Department of Health (DOH) ▪ Connected to diagnosed illness

▪ Believed to have caused illness

FL Dept of Agriculture and Consumer Services (FDACS) ▪ Suspected cause of illness or physical discomfort

▪ Economic fraud

Tri-agency FBI survey form

Form sent to DOH to be evaluated

▪ No action

▪ Inspector collects a sample with the same lot number

▪ Information only samples

Collected from consumer by DOH

Usually meant to confirm a causative agent

Other government agency (customer) has a specific test request

Micro- section Performs routine tests as it would a survey

sample ▪ Sandwich example ▪ Test performed

Salmonella

Staphylococcus if counts >10k test for the enterotoxin

Listeria Monocytogenes

E. coli if any positives are found test for the toxin

On occasion the consumer sample is analyzed for information only

Chemistry section

Managers determine test (may consult analyst) based on complaint and sample type

Typical test

▪ Macro analysis

Metals analysis Organoleptic

The samples are collected from consumers by an inspector from the department.

When possible the inspector also obtains a sample from the place the consumer claims to have bought

Inspector tries to find the same product with the same lot number

NY also includes “feed” consumer complaints. These data were not included.

There is usually a test requested on the report that accompanies each sample

If no test is requested

Laboratory discretion based a description of the complaint

▪ Symptoms of an illness

▪ Organolyptic description ▪ Off flavor

▪ Off odor

Tampering (Poison Screen) Commodity Specific screen

FDA Recalls ▪ Common contaminates associated with a commodity

Most common cause of illness screen (CDC) Microbiological

▪ Bacteria enumeration and toxins ▪ Molds ▪ Viral

Chemical ▪ Contaminants ▪ Allergens and toxins ▪ Deleterious chemicals (inorganic, organic i.e. benzene)

Contaminants related to food borne illness

FDA

CDC

Commodity Specific

Commodity groups

Painter, J.A., et. al., Emerging Infectious Diseases, v. 19, no. 3, 2013

Aquatic (fish,

shellfish)

Land (meat, dairy and

eggs)

Grains and Beans Sugar and Oil Fruit and nut Vegetables

Mixed Salad Condiments

Sandwiches Bakery and Candy

Soup

Water and Ice Soda

Coffee and Tea (drinks) “Juice”

Painter et. al. 2013 Gold highlighted text are categories not used by Painter et. al.

Animals Plants Beverages Processed Food

2005- 2013 (complaint samples 441)

2014-2016 (complaint 137)

33 Adulterated

19 Macro

▪ Organolyptic

▪ Foreign material

10 microbiological

▪ E. coli and mold

4 Chemicals

▪ allergens and histamine

441: total samples

16 Misbranded

13 Label Claims

▪ Label claim not met (fat, sodium etc.)

▪ Label not NLEA compliant

4 Economic adulteration

▪ Short weight claim

▪ Authentication (fish)

2014-2016 Consumer Complaint Samples

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FL ComplaintSamples

NY ComplaintSamples

Total

Violative

FL 137 samples and 35 violative NY 466 samples and 26 violative

FDACS Beverages

▪ Water or ice (28) ▪ Juice or fruit flavored drinks (21)

Plants ▪ Mixed salads (19) ▪ Vegetable (7) ▪ Seafood (11)

NY Animal (220)

▪ Dairy (80)

Plant (154)

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Number ofViolativeSamples

Fish/Histamine Yellowfin Tuna (3)

Mahi Mahi (1) Dairy/Parmesan

Addition of starch (2)

Addition of lactose (1) Beef/Species

6 of the 10 violative samples were for species substitution ▪ Swine (5)

▪ Chicken (1)

Product Finding FBI or DOH Tests

Raw Shrimp Glazing and shrimp size

Crab Cakes Mold Visible

Cajun Style Shrimp Spread

Listeria Monocytogenes

DOH

Fish Fillet Tuna Decomposition (histamine)

DOH

Fish Fillet Corvina Onset of decomposition

Staphylococcus Compliant

Ground Beef Foreign material Foam tray

Sliced Roast Beef Sour odor FBI L. Monocytogenes and Staphylococcus compliant)

Product Findings FBI or DOH Tests

Gourmet Granola* Misbranded Salmonella negative

Chocolate Granola*

Misbranded label

Salmonella negative

Cashew Cranrasin* Granola

Misbranded label

Salmonella negative

Organic Maple Almond Granola*

Misbranded label

Sliced Peaches Swollen can

Roasted Chicken Salad

E coli FBI

Product Findings FBI or DOH Tests

Ice Adulterated Coliforms

Alkaline Ionized Water

Misbranded label (consumer complained brand misrepresentation)

Alkaline Ionize Water

Misbranded label Coliforms

Orange flavored drink*

Adulterated Benzene

Orange flavored drink*

Adulterated Benzene 0.014 ppm

Apple Nectar Adulterated (As) Arsenic 18 µg/kg Authenticity

Most common cause of recalls 2009-2013

Salmonella

Allergens

Listeria Moncytogenes

Most common food items recalled

Produce Raw Agricultural Commodity (RAC)

Bakery

Seafood

THE REPORTABLE FOOD REGISTRY: TARGETING INSPECTION RESOURCES AND IDENTIFYING PATTERNS OF ADULTERATION Reports 1-4, September 8, 2009– September 7, 2013

THE REPORTABLE FOOD REGISTRY: TARGETING INSPECTION RESOURCES AND IDENTIFYING PATTERNS OF ADULTERATION Reports 1-4, September 8, 2009– September 7, 2013 (Feed data was excluded)

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Recalls 2014

TotalRecalls(183)

Dairy (24)

Bakery(23)

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UndeclaredAllergens

L. Mono

Salmonella7 5

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THE REPORTABLE FOOD REGISTRY: A FIVE YEAR OVERVIEW OF TARGETING INSPECTION RESOURCES AND IDENTIFYING PATTERNS OF ADULTERATION September 8, 2009 – September 7, 2014

Note: Undeclared allergens and L. monocytogenes. were the most common cause of recalls

When two or more people get the same illness from the same contaminated food or drink, the event is called a food borne disease outbreak.

Confirmed single etiologic agents Norovirus (35%)

Salmonella (34%)

Shiga producing E. coli (6.7%) Products implicated in greatest number of

outbreaks Fish (24%)

Mollusks (11%)

Chicken (10%)

Surveillance for Foodborne Disease Outbreaks , United States ,2013, Annual Report, Atlanta, GA:US Dept of Health and Human Services, CDC, 2015.

Ciguatoxin

Fish

Histamine

Fish

Salmonella

Chicken, pork, seeded vegetables

Vibrio parahaemolyticus

Mollusks

Most problematic commodities

FDA Recalls (2012-2013)

CDC Illness Associated (2013)

FDACS Consumer Complaints (2014-2016)

NYConsumer Complaints (2014-2016)

Bakery Seafood Water Animal

Seafood Meat/Poultry Seafood Plant

Nuts Dairy Meat/Poultry Processed Food

FDA Recall Cause 2012-2013

CDC Outbreak-Product Association 2013

FDACS Complaints (2014-2016)

Allergens Fish/Histamine Microbial (off odor or taste)

Salmonella Fish/CTX Chemical/Toxin

Listeria Monocytogenes

Mollusk/Vibrio parahaemolyticus

Fraud

Most Common Causative Agent

Food fraud is not included in the “federal data”

State complaint data does not seem to correlate well FDA recall data or CDC FBI (chemical) data

Need a broad screen

The top “chemical” causes histamine and CTX have well characterized food/illness association

Did the suspected food cause “the illness”?

Tri-agency form

Laboratory needs to see a copy of the “Tri-agency form”

Questions to be added

▪ Do you have food allergies?

▪ Do you take supplements? ▪ Have you recently changed your supplements

“Poison screen”

Does it make sense for a “minor” illness case?

Screen strategies Direct Analysis (DA) HRAM MS

▪ MALDI ▪ DESI and “modified DESI” ▪ DART ▪ REIMS ▪ Paperspray

Focus on known contaminates and product issues ▪ Limited focus screen QQQ on Qtrap ▪ Microbial and chemistry screen

▪ Allergens ▪ Bacteria ▪ Viruses ▪ Toxins

Targeted direct analysis screen for most likely analytes of concern

DART, DESI, Paper Spray, REIMS MALDI

Targeted analysis for analytes of concern

Confirmation Metals

Targets not amendable to

DA

Multiple extractions to cover a wide range of chemistries

“Non – targeted/semi-targeted HRAM MS”

Mark French Richard Stephens Tim Croley Robert Sheridan Robert Trengrove Brian Quinn Patricia Hanson Thanks to all of you!