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Category: food safety
USDA Secretary Vilsack touts “…significant steps toward keeping American consumers safe from foodborne illness.”
Just over one year ago, eFoodAlert reported on the USDA proposal to limit Salmonella to one live cell per gram in breaded, stuffed raw chicken products.
In our post, we called the proposal a “baby step” and a “recipe for disaster“.
Last week, the agency finalized the proposed policy and released an advance copy of the Final Rule.
In our opinion, the limit of one Salmonella per gram makes no more sense today than it did one year ago.
It is well past time for the USDA to face down the poultry lobby and place its emphasis on protecting the health and safety of the public whose tax dollars fund its programs.
Interested in learning more about food safety and the history of foodborne disease outbreaks and investigations?
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Why inspections matter. The TFP Nutrition affair
On November 16, 2023, Texas Farm Products Company (dba TFP Nutrition) informed its customers across the United States and Puerto Rico that the company’s pet food products (including dry dog food, dry cat food and catfish food) were being recalled due to potential Salmonella contamination.
The recall was announced after the Office of the Texas State Chemist found Salmonella in multiple samples of the company’s products and issued a Stop/Sale Seizure order.
About TFP Nutrition
In 1930, M.S. Wright established TFP as a fertilizer factory.
Later in the same decade, the company expanded into the agricultural feed business. In 1978, the TFP’s pet food division began operations in what the company described as “…a modern pet food plant to produce dog food, cat food, and other extruded feeds.”
TFP remains a family-owned business to this day.
According to the FDA’s Inspection Citation web page, TFP’s manufacturing facility was inspected on four occasions between 2010 and 2020. Each time, the plant received a satisfactory (No Action Indicated) classification result.
The 2022 incident
On December 16, 2022, TFP recalled a single production batch of H-E-B Texas Pets Indoor Complete Dry Cat Food (16-lb bags; MFG 13 NOV 22) after the Office of the Texas State Chemist found Salmonella in a sample of the product.
According to information obtained by eFoodAlert from the FDA in response to a Freedom of Information Act request, the company’s “root cause analysis” of the problem yielded the following conclusion, which was reported to the FDA.
From the investigation, it was determined the beginning of the Indoor Complete Dry Cat Food run did experience clumping, an unusual occurrence. When the extruder is shut down due to processing issues, it requires operators to disconnect equipment and conduct a clean out of the extruder, flushing it with water and using water to clean the equipment and area. When this occurs, some food contact surfaces could be exposed to the environment. It is our determination that the increased activitiy around the extruder clamshells and air takeaway system, during likely the second shut down event, became contaminated, ultimately affecting the Indoor Complete Dry Cat Food and it is an isolated incident.
Although the FDA monitored the effectiveness of the recall, there is no indication that the federal agency conducted an inspection of the manufacturing plant.
Instead, it was left to the state of Texas to review the firm’s updated Food Safety Plan and collect additional samples to monitor for Salmonella.
Fast-forward to 2023
On October 21, 2023, TFP recalled two production batches of Retriever All Life Stages Mini Chunk Chicken Recipe Dry Dog Food (50-lb bags; BEST BY 10 2024 3277 TFP and BEST BY 10 2024 3278 TFP).
Once again, the recall was triggered by a Salmonella-positive test result “…in a random sample test conducted by the Office of the Texas State Chemist.”
About three weeks later, the recall was expanded to include fifty-three different Brand/Variety/Package configurations of dry dog food, dry cat food, and catfish food.
On December 6, 2023, the FDA initiated an inspection of TFP’s Nacogdoches (Texas) manufacturing facility.
According to information obtained in response to a Freedom of Information Act request and in contrast to the company’s own “root cause” analysis of the previous year, the three-person FDA investigation team uncovered multiple problems, including:
- Sanitation controls that failed to prevent recontamination of finished products from pathogens present in raw ingredients (ie., cross-contamination)
- Four Salmonella-positive environmental samples reported during September/October 2023
- Inadequate environmental monitoring program that was developed “…without using a scientific methodology”
- Inadequate Hazard Analysis for mycotoxins in grain products
- Eleven samples of finished product found by the Office of the Texas State Chemist to contain aflatoxin at 50 ppb (2 1/2 times the legal limit)
- Six consumer complaints between January 6, 2023 and November 8, 2023 about mold in the company’s dry pet food.
In response to our request for comment, a spokesperson for the FDA’s Center for Veterinary Medicine replied, “As a general policy, FDA does not comment on ongoing investigations.”
The bottom line
It is a truism among food safety professionals that finished-product testing is the least efficient and least sensitive way to determine whether a production environment is contaminated with Salmonella.
Limiting the follow-up to the December 2022 recall to random surveillance sampling by the state of Texas was an inadequate response to a potentially serious situation, putting the health and safety of pets and their owners at risk.
“A complete and compelling account of the hidden and not-so-hidden ways the food we give our beloved pets can be contaminated.” – JoNel Aleccia, Health Reporter, Food & Nutrition, The Associated Press.
“An invaluable resource for busy pet owners” – Food Safety News
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