Tag Archives: CDC

By Melanie Neumann, JD, MS

During this global pandemic, the U.S. Equal Employment Opportunity Commission (EEOC) green-lighted employers to take temperatures checks of employees and to administer COVID-19 testing for workers prior to returning to work without running afoul of the Americans with Disabilities Act (ADA). This appears straight-forward upon first reading, however, several practical uncertainties about implementation, including confidentiality, discrimination, and how long to retain records remain.

As such, deciding whether to take temperatures and/or require COVID- 19 testing as a return to work strategy is more complicated than it may seem.

Temperature Screening & Testing Considerations

Temperature screening and COVID-19 mandatory testing are both permitted medical examinations during this pandemic but are otherwise prohibited during non-pandemic times. Before adopting, employers should understand the requirements impacting the records these tests generate, including the need to protect confidentiality and to retain records for longer than one may expect.

Temperature Screens
Under normal circumstances, temperature checks are considered a prohibited medical examination under the ADA. During a pandemic, however, the Equal Employment Opportunity Commission (“EEOC”) makes an exception, allowing employers to take temperatures/use temperature checks and exclude employees from the workplace should temperatures exceed public health recommendations. If employers keep records of temperatures, they must retain these records per applicable regulations. This is important because an “employee medical record” would likely result if employers take employees’ temperatures or collect temperature related records. As we will see below, there are regulatory requirements that require how we conduct these screens, and where and for how long we must retain them.

COVID-19 Testing

COVID-19 testing also constitutes a permissible medical exam under ADA during this pandemic, per the EEOC-issued guidance regarding mandatory employee testing.

For medical examinations to be allowed under the ADA, the test must be “job related and consistent with business necessity,” and employers must treat information as a confidential medical exam.

The initial guidance acknowledged that the spread of COVID-19 is a “direct threat,” hence meeting the requirement that a medical exam be “job related and consistent with business necessity” and that temperature screenings were therefore appropriate. For the same reasons, in updated guidance released at the end of April 2020, the EEOC expanded that guidance to clarify that employers may choose to administer COVID-19 testing to employees before they enter the workplace to determine if they have the virus for the same reasons.

When reading the EEOC’s language closely, the permission granted by EEOC appears to be for diagnostic tests, as the guidance states testing is to determine if employees have the virus before allowing employees to return to work. It is unclear whether antibody testing is included in the above analysis because antibody tests do not determine if someone is currently infected.

In addition, there are other considerations employers should assess before adopting a testing protocol. EEOC reminds employers that they must review the accuracy and efficacy of the selected test per FDA and CDC recommendations. Moreover, pragmatic considerations, such as how to maintain social distancing and employee privacy, determining who will perform the testing and at what the frequency, not to mention evaluating whether there is enough test capacity to perform employee-wide testing at a meaningful cadence should be evaluated.

Records Management & Retention

There is another often over-looked question: What do employers do with documented test records? This question applies whether the employer conducts the test, requires tests from employee’s healthcare providers to be off work to self-isolate, or as a return to work requirement.

It was clearly outlined above that temperature records and COVID-19 test records constitute employee medical records. Why is this important? Because there are specific requirements relating to employee medical records, including what appears to be a surprisingly long retention requirement.

Where to retain: An employer should store all medical information related to COVID-19 in existing medical files, separate from the employee’s personnel file, per the ADA, limiting access to this employee confidential information. This includes an employee’s statement that he has COVID-19 or suspects he/she has the disease, or the employer’s notes or other documentation from questioning an employee about symptoms.

How long to retain: That is the 30-year question. The Department of Labor’s Occupational Safety and Health Agency (OSHA) provides retention requirements for employee medical records in certain situations for a period of an employee’s employment plus 30 years.

While COVID-19 test results and temperature screening documentation are deemed medical examinations under the applicable regulations, are the documented results deemed medical records? We turn to applicable EEOC OSHA regulations in section 1910.1020 for answers.

OSHA Requirements

The OSHA general duty clause, section 5(a)(1) requires employers to furnish to each of its employees a workplace free from recognized hazards that are causing or likely to cause death or serious physical harm. COVID-19 appears to rise to this threat level. But is that fact alone dispositive to falling under the applicable OSHA retention requirements?

OSHA regulation section 1910.1020 requires employers to retain employee exposure or employee medical records relating to employee exposure to certain hazards. This section applies to each general industry, maritime and construction employer who makes, maintains, contracts for, or has access to employee exposure or medical records, or analyses thereof, pertaining to employees exposed to toxic substances or harmful physical agents (Emphasis added).

Is SARS-CoV-2, the virus that causes COVID-19, considered a “toxic substance or harmful physical agent?”

Most would quickly assume the answer is ‘yes’. But it may not be as clear as the black and white letter of the law would hope. Let’s review some key definitions in the applicable regulation to help shed more light on this question.

What are Toxic Substances or Harmful Physical Agents?

The record retention requirement pivots on the last phrase of 1910.1020, that is “…pertaining to employees exposed to toxic substances or harmful physical agents.”

Toxic substances or harmful physical agents are defined as follows;

1910.1020(c)(13) “Toxic substance or harmful physical agent” means any chemical substance, biological agent (bacteria, virus, fungus, etc.), or physical stress (noise, heat, cold, vibration, repetitive motion, ionizing and non-ionizing radiation, hypo – or hyperbaric pressure, etc.) which:
- 1910.1020(c)(13)(i) is listed in the latest printed edition of the National Institute for Occupational Safety and Health (NIOSH) Registry of Toxic Effects of Chemical Substances (RTECS) which is incorporated by reference as specified in Sec. 1910.6; or
- 1910.1020(c)(13)(ii) has yielded positive evidence of an acute or chronic health hazard in testing conducted by, or known to, the employer; or
- 1910.1020(c)(13)(iii) is the subject of a material safety data sheet kept by or known to the employer indicating that the material may pose a hazard to human health. (Emphasis added by author).

The use of “or” clarifies that only one of the criteria need to be met. Based on the above, while subsections (c)(13)(i) and (c)(13)(iii) do not appear relevant, subsection (c)(13)(ii) appears to apply as SARS-CoV-2 has shown to result in acute health hazard, resulting in the disease COVID-19. Whether there is a chronic health impact remains to be seen given the novelty of this virus. That said, acute health impact appears sufficient to determine SARS-CoV-2 as a “toxic substance or harmful physical agent” for purposes of this analysis.

This alone doesn’t automatically place an employer in a 30-plus year requirement to retain employee medical records. What constitutes an “employee medical record” and “employee exposure record” for purposes of this regulation must be further understood before determining appropriate retention.

What are Employee Medical Records and Employee Exposure Records?

“Employee medical records” are defined in section 1910.1020(c)(6), and means a record concerning the health status of an employee that is made or maintained by a physician, nurse or other healthcare personnel, or technician, including: Medical and employment questionnaires or histories, the results of medical exams, lab test results, medical opinions/doctor’s recommendations, first aid records, employee medical complaints, and descriptions of treatment or prescriptions.

Section 1910.1020(d)(1)(i) goes on to specifically prescribes a minimum of a 30-plus year retention period as follows: “The medical record for each employee shall be preserved and maintained for at least the duration of employment plus thirty (30) years.”

“Employee exposure records,” are defined in subsection 1910.1020(d)(1)(ii), as: “Each employee exposure record shall be preserved and maintained for at least thirty (30) years,…”. Some exceptions are listed in this subsection for records relating to health insurance claims, first aid records and records relating to employees working less than one year.

What Constitutes Employee Exposure?

One must also look at what “employee exposure” means in light of this regulatory requirement to determine applicability of the 30-plus year retention.

1910.1020(c)(8) defines “exposure” or “exposed” to mean that an employee is subjected to a toxic substance or harmful physical agent in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.), and includes past exposure and potential (e.g., accidental or possible) exposure, but does not include situations where the employer can demonstrate that the toxic substance or harmful physical agent is not used, handled, stored, generated, or present in the workplace in any manner different from typical non-occupational situations.

Conclusion

Short of additional guidance issued by Department of Labor’s OSHA, ultimately this will likely be decided by the courts when the first lawsuit on this topic arises, known as decision via case law. What do employers do in the interim while these shades of gray are not yet adjudicated? It is recommended to err on the side of caution. Find ways to adjust your company’s record retention procedures and systems to be able to accurately retain these records for the duration of your employee’s employment plus 30 years.

Resources

OSHA Laws & Regulations. OSH Act of 1970. SEC 5. Duties. Retrieved from https://www.osha.gov/laws-regs/oshact/section5-duties
OSHA Standards. Part 1910, Standard 1910.1020. Retrieved from https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1020
OSHA. Access to Medical and Exposure Records. (2001). U.S. Department of Labor, OSHA. Retrieved from https://www.osha.gov/Publications/pub3110text.html
U.S. Equal Employment Opportunity Commission. “What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws”. (Updated May 7, 2020). Retrieved from https://www.eeoc.gov/wysk/what-you-should-know-about-covid-19-and-ada-rehabilitation-act-and-other-eeo-laws. See A. 6 and B.1.

April 28, 2020

Meat Shortage Threat, Facility Employees Can Still Work After Potential COVID-19 Exposure

By Maria Fontanazza

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–UPDATE April 29, 2020— Yesterday President Trump signed an executive order to keep meat and poultry processing facilities operational during the coronavirus national emergency. U.S. Secretary of Agriculture Sonny Perdue said the following in a USDA statement, “Maintaining the health and safety of these heroic employees in order to ensure that these critical facilities can continue operating is paramount. I also want to thank the companies who are doing their best to keep their workforce safe as well as keeping our food supply sustained. USDA will continue to work with its partners across the federal government to ensure employee safety to maintain this essential industry.”

–END UPDATE–

As critical infrastructure workers, employees at meat and poultry processing facilities have stayed on the job during the coronavirus crisis. Hundreds have fallen ill and many have died as a result; at least 100 USDA inspectors have tested positive for COVID-19 and at least one inspector has died, according to reports. Production facilities across the country have shut down over the past month, and the threat of a meat shortage is very close to becoming a reality, warns Tyson Foods Chairman John Tyson. “In small communities around the country where we employ over 100,000 hard-working men and women, we’re being forced to shutter our doors. This means one thing—the food supply chain is vulnerable. As pork, beef and chicken plants are being forced to close, even for short periods of time, millions of pounds of meat will disappear from the supply chain,” Tyson stated in a company blog. “As a result, there will be limited supply of our products available in grocery stores until we are able to reopen our facilities that are currently closed.”

Hog and cattle producers are altering rations to slow the growth of livestock. In Iowa, the National Guard was activated to conduct testing and contact tracing of plant workers from Tyson Foods and National Beef Packing Company.

Meat production is on a 25% decline and by the end of this week, America could be entering a meat shortage, according to Dennis Smith, an Archer Financial Services commodity broker and livestock analyst.

Access the COVID-19 Resource CenterProtecting Essential Employees

“To ensure continuity of operations of essential functions, CDC advises that critical infrastructure workers may be permitted to continue work following potential exposure to COVID-19, provided they remain asymptomatic and additional precautions are implemented to protect them and the community,” the CDC’s Critical Infrastructure Guidance states. The agency also notes that screening workers for COVID-19 symptoms is “an optional strategy”.

Meat processing workers are not exposed to COVID-19 through product handling; they can be exposed via close contact with other employees in a facility. The CDC and OSHA have released interim guidance for meat and poultry processing workers and employers that details how communal work environments should be laid out and how employers should be promoting social distancing. Engineering controls include the following:

Reconfiguration of workstations to allow employees to be six feet apart, if possible
Establishing physical barriers (i.e., plexiglass or strip curtains) to separate workers
Working with an HVAC engineer to establish proper ventilation that limits potential exposure to coronavirus; removal of any pedestal or personal fans
Setting up handwashing stations or hand sanitizer (60% alcohol) stations
Reconfiguring break rooms and other communal areas to promote social distancing

The CDC also recommends that workers wear cloth face coverings that fit over the mouth and nose.

For workers who have experienced COVID-19 symptoms and have self-isolated at home, the CDC advises they do not return to work until they meet specific criteria.

Read the CDC and OSHA interim guidance.

April 23, 2020

FST Soapbox

How to Prevent Foodborne Pathogens in Your Production Plant

By Megan Ray Nichols

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Foodborne pathogens, such as bacteria and parasites in consumable goods, can result in illnesses and deaths, wreaking havoc on residents of states and countries. The companies at fault often face severe damage to their reputation as people fear that continuing to do business with a brand is not safe. Moreover, if the affected enterprises do not take decisive steps to prevent the problem from happening again, they may receive substantial fines or closure orders.

Statistics from the U.S. federal government indicate that there are approximately 48 million cases of foodborne illnesses in the American food supply each year. Fortunately, there are proven steps that production plant managers can take to minimize the risk of foodborne pathogens. Being familiar with the preventative measures, and taking steps to implement them prevents catastrophes.

Engage with Suppliers about Their Efforts to Kill or Reduce Foodborne Pathogens

Foodborne pathogens can enter a production plant on items like fresh produce received from farm suppliers. Agricultural professionals commonly use chlorine to decontaminate goods before shipping them. However, researchers used a chlorine solution on spinach leaves to assess its effectiveness in killing common types of bacteria. The team discovered that, even after chlorine exposure, some bacteria remained viable but undetectable by industrial methods.

Foodborne pathogens can originate at farms for other reasons, too. Failing to take the proper precautions during animal slaughter can introduce contaminants into meats that end up in food production facilities. Water impurities can also pose dangers.

All production plants should regularly communicate with suppliers about the actions they take against foodborne pathogens. Food safety is a collective effort. Practicing it means following all current guidance, plus updating methods if new research justifies doing so. If suppliers resist doing what’s in their power to stop foodborne pathogens, they must realize they’re at risk for severing profitable relationships with production plants that need raw goods.

Consider Using Sensors to Maintain Safe Conditions

The Internet of Things (IoT) encompasses a massive assortment of connected products that benefit industries and consumers alike. One practical solution to enhance food safety in a production plant involves installing smart sensors that detect characteristics that humans may miss.

For example, the USDA published a temperature safety chart that explains what to do with food after a power outage. Most items that people typically keep in refrigerators become dangerous to eat if kept above 40^o F for more than two hours.

Food production plants typically have resources like backup power to assist if outages occur. But, imagine a cooler that appears to work as expected but has an internal malfunction that keeps the contents at incorrect temperatures. IoT sensors can help production plant staff members become immediately aware of such issues. Without that kind of information, they risk sending spoiled food into the marketplace and getting people sick.

Researchers also developed a sensor-equipped device that detects the effectiveness of hand washing efforts. In a pilot program involving 20 locations, contamination rates decreased by 60% over a month. Most restrooms at food preparation facilities remind people to wash their hands before returning to work. What if a person takes that action, but not thoroughly enough? Specialty sensors could reduce that chance.

Install Germicidal Ultraviolet Lights

With much of the world on lockdown due to the COVID-19 pandemic, many people want to know if germicidal ultraviolet lights could kill the novel coronavirus. Researchers lack enough information to answer that question definitively. They do know, however, that germicidal ultraviolet lights kill up to 99.99% of bacteria and pathogens.

Plus, these lights are particularly useful in food production because they get the job done without harsh chemicals that could make products unsafe. Ultraviolet lights can damage the skin and eyes, so you must only run them when there are no humans in the room. However, it’s immediately safe to enter the environment after switching the lights off.

These specialized light sources do not eliminate the need for other food safety measures. Think about implementing them as another safeguard against adverse consequences.

Teach Workers about Safe Practices

Food contamination risks exist at numerous points along the supply chain. Mishandling is a major culprit that could make several parties partially responsible for a foodborne pathogen problem. For example, if a person does not wear the proper gear when handling food or stores items intended for raw consumption in places where meat juices touch them, either of those things and many others could cause issues with foodborne pathogens.

As you inform employees about which procedures to take to manage the risks, emphasize that everyone has an essential role to play in keeping products free from contaminants. If workers make ready-to-eat foods, such as packaged sandwiches, ensure they understand how to avoid the cross-contamination that happens when reusing cutting boards or utensils without washing them first.

The FDA requires domestic and foreign food facilities to analyze and mitigate risks. Employee training is not the sole aspect of staying in compliance, but it’s a major component. If a person makes a mistake due to improper or nonexistent training, that blunder could have significant financial ramifications for a food production facility.

Widely cited statistics indicate that food recall costs average more than $10 million, which is a staggering figure in itself. It doesn’t include litigation costs incurred when affected individuals and their loved ones sue companies, or the expenses associated with efforts to rejuvenate a brand and restore consumer confidence after people decide to take their business elsewhere.

Ensuring that workers receive the necessary training may be especially tricky if a human resources professional hires a large batch of temporary employees to assist with rising seasonal demands. If a higher-up tells them that time is of the essence and the new workers must be ready to assume their roles on the factory floor as soon as possible, training may get overlooked. When that happens, the outcomes could be devastating. Efficiency should never get prioritized over safety.

Stay Abreast of Emerging Risks

Besides doing your part to curb well-known threats that could introduce foodborne pathogens, spend time learning about new problems that you may not have dealt with before.

For example, scientists have not confirmed the origin of COVID-19. However, since early evidence suggested live animal sales and consumption may have played key roles, Chinese officials cracked down on the wildlife trade and imposed new restrictions on what was largely an unregulated sector cloaked in secrecy.

Much remains unknown about COVID-19, and it’s but one virus for food producers to stay aware of and track as developments occur. The ongoing pandemic is a sobering reminder not to blame specific groups or ethnicities, and to avoid jumping to hasty conclusions. It’s good practice to dedicate yourself to learning about any production risks that could introduce foodborne pathogens. Read reputable sources, and don’t make unfounded assumptions.

A Collective and Constant Effort

There is no single way to combat all sources of foodborne pathogens. Instead, anyone involved in food production or supply must work diligently together and know that their obligation to prevent issues never ceases.

January 16, 2020

E. Coli Outbreaks Linked to Salinas-Grown Romaine Lettuce Over, Deputy Commissioner Yiannas Releases Statement

By Food Safety Tech Staff

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Yesterday the CDC reported that the E.coli outbreak linked to romaine lettuce grown in the Salinas, CA growing region is over. The contaminated lettuce should no longer be available, and FDA states that consumers do not need to avoid romaine lettuce from Salinas. The agency will continue its investigation into the potential factors and sources that led to the outbreak.

The FDA did identify a common grower link to the E.coli O157:H7 contamination as a result of its traceback investigation. However, a statement released yesterday by FDA Deputy Commissioner for Food Policy and Response Frank Yiannas points out that “this grower does not explain all of the illnesses seen in these outbreaks.”

To be specific, the FDA, CDC and other public health agencies were tracking three outbreaks involving three separate strains of E.coli O157:H7 linked to romaine lettuce. During the course of the investigation FDA, CDC, the California Department of Food and Agriculture and the California Department of Public Health conducted sampling of the water, soil and compost of several of the fields in the lower Salinas Valley that were connected to the outbreak. “So far, sample results have come back negative for all of the three outbreak strains of E. coli O157:H7. However, we did find a strain of E. coli that is unrelated to any illnesses in a soil sample taken near a run-off point in a buffer zone between a field where product was harvested and where cattle are known to occasionally graze,” Yiannas said in the agency statement. “This could be an important clue that will be further examined as our investigation continues. However, this clue does not explain the illnesses seen in these outbreaks.”

Finding the contamination source(s) is critical, as it will aid romaine growers in putting safeguards in place to help prevent future contamination.

As for the final case count (with last illness onset on December 21, 2019) of this outbreak, there were 167 total illnesses and 85 hospitalizations across the United States. No deaths were reported.

January 2, 2020

Nearly 100 People Sick from Salmonella ‘Potentially Linked’ to Tailor Cut Produce Fruit Mix

By Food Safety Tech Staff

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Using whole genome sequencing (WGS), FDA has confirmed 96 illnesses in 11 states that were caused by Salmonella Javiana. Thus far, traceback evidence indicates that a fruit mix from New Jersey-based Tailor Cut Produce is the possible source of the outbreak.

FDA provided its latest update about the ongoing investigation today: Of the 96 illnesses, 27 have been hospitalized, and no deaths have been reported. The highest number of illnesses have been reported in Delaware (39), Pennsylvania (34) and New Jersey (12). The agency stated its inspection at Tailor Cut Produce continues and it is collecting records to support a traceback investigation.

Tailor Cut Produce recalled the Fruit Luau fruit mix earlier in December, along with its cut honeydew, cantaloupe and pineapple products.

December 16, 2019

E. Coli Update: FDA Advises Consumers to Avoid All Romaine Lettuce Harvested in Salinas, California

By Food Safety Tech Staff

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In the latest FDA update about the E. coli O157:H7 outbreak involving romaine lettuce, the agency has stated that consumers should not eat romaine lettuce that has been harvested from Salinas, California. Traceback investigations related to three different E. coli outbreaks (three different strains, all of which involve romaine lettuce) have pointed to a common grower located in Salinas. Frank Yiannas, deputy commissioner for food policy and response, called the identification of a common grower a “notable development” but also stated in a press announcement, “Because of the expansive nature of these outbreaks, our investigation remains a complicated work in progress, and it is too soon to draw definitive conclusions.”

FDA, CDC and California partners have sent out a team to conduct new investigations at ranches used by the grower as part of the process in finding the contamination source, according to an FDA update.

Thus far, 102 illnesses have been reported across 23 states, with 58 hospitalizations. No deaths have been reported. The last illness onset was reported on November 18.

Thus far Swedesboro, NJ-based Missa Bay, LLC has recalled more than 75,000 pounds of salad products because of a lettuce ingredient that might be contaminated with E. coli O157:H7. This lettuce was also found to be in packaged salad that the Maryland Department of Health said contained E. coli.

FDA states that thus far lettuce grown indoors has not been indicated in the outbreak.

November 7, 2019

The Value of a One Percent Improvement

By Food Safety Tech Staff

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During the past year, the headlines have been filled with stories of foodborne illness, product recalls, and consumers becoming sick from tainted food. In a Q&A with Food Safety Tech, Sean O’Leary, CEO at FoodLogiQ, talks food safety, traceability, and how small percentages can translate into big victories for the food industry and for the people they serve.

Food Safety Tech: From your perspective, what is the current sentiment of consumers with regard to food safety?

Sean O’Leary: Over the last few years, the consumer mindset has changed about food in general. We’ve watched fad diets come and go; however, the interest in healthy ingredients and the concern about where food comes from has graduated from a passing trend to a full shift into the public consciousness. Consumers are much more discerning about what they eat; they also demand to know where their food comes from, how it was produced, and how it got to their table. We are living in the age of transparency, and consumer expectations are high.

And who can blame them? CDC statistics tell us that approximately 48 million people get sick every year from foodborne illnesses—and that’s just in the United States; 128,000 of them end up in the hospital. When a person is admitted to the hospital, it affects more than just that one individual. If the patient is the sole breadwinner of their family, their illness affects the entire family. If the person who gets sick is a child, there can be long-term consequences that trickle down to his or her whole community. And when you consider that 3,000 people die every year from foodborne illness—that’s one 9/11 every year. That’s unacceptable, because this is a preventable issue, and unfortunately, these illnesses are an underreported public health problem.

My challenge to the food industry is simple: What if we made just a 1% improvement in the number of cases of foodborne illness? That seems like such a small percentage, but when you do that math, that’s 480,000 people who don’t get sick this year; 1,280 people who aren’t admitted to the hospital; and 30 people who don’t die. Those are significant numbers.

Sean O’Leary joined FoodLogiQ as CEO in January 2019 with more than 25 years of experience in the technology industry.

FST: To help shed additional light on this subject, FoodLogiQ conducted a national survey to tap into how U.S. consumers feel about issues related to food transparency. What did you learn from those consumer responses?

O’Leary: We polled more than 2,000 people to gauge their sentiment around food traceability and their expectations for food companies regarding foodborne illness and product recalls. The survey also posed questions around consumer preferences regarding their food sources and how they are identified on food labels and menus. The results were enlightening, to say the least.

We learned that a brand or restaurant will pay a high price in terms of customer loyalty if they experience a food recall due to consumer illness. And those customers have some strong opinions regarding how quickly the brand or restaurant should address a food safety issue.

35% of survey respondents told us they would avoid an affected brand or restaurant for a few months, and maybe they would return after the issue had been resolved. Meanwhile, nearly 25% admitted they would never use the brand or visit the restaurant again.
Of the respondents who say they care about the quality of the food they eat, 55% say they expect a recall to be executed within 24 to 48 hours.

In reality, it sometimes takes weeks for a product to be pulled from the store or restaurant. This is frequently due to communication issues, since everyone along the supply chain—the grower, supplier, packing and distribution centers, corporate office, and the retailer or restaurant—all must be notified, and a recall plan must be set in motion. Unfortunately, that communication process takes time. When that communication takes place via email or by phone call, the people responsible for pulling product may not have the information they need or may have received misinformation. This can result in lag time, and potentially unsafe product can still get into the hands of consumers.

The faster a food company can address a recall situation and return to business as usual, the faster customers will come back. But comprehensive supply chain transparency is needed to be able to make swift, accurate decisions during this time of crisis. By having a robust end-to-end traceability program and technology that provides real-time data and visibility, companies facing a recall can isolate and surgically withdraw the tainted product out of the supply chain without recalling more items than necessary. That limits the disruption and the waste of good food, which saves the company money.

FST: You recently attended the FDA’s “A New Era of Smarter Food Safety” public meeting in Maryland. What do you think this new campaign will mean for the food industry?

O’Leary: FoodLogiQ was honored to have the opportunity to share our intricate knowledge of the food supply chain, as well as best practices regarding whole chain traceability during this monumental meeting with the FDA with more than 250 food industry leaders.

In retrospect, one thing is clear—we’re in the midst of a pivotal time of change for the world’s food supply chain. In the United States, the food industry remained status quo for decades, but the introduction of FSMA has brought increased scrutiny and accountability; I think it’s made every food company pause and evaluate where they are with regard to food safety, and that’s a good thing. And now, with the launch of the “New Era” campaign, we’re coming together in a collaborative fashion to map out how technology tools, prevention measures, new business models, and an evolving culture of food safety can be merged as a framework for a long term food safety solution. I agree with the FDA; ‘Smarter Food Safety’ is people-led, FSMA-based, and technology-enabled. It will take all of us working together to reach that goal.

Alec Senese, Bayer Crop Science, Digital Pest Management

October 31, 2019

Bug Bytes

If You Think Plague Is a Thing of the Past, Think Again

By Alec Senese

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Rodents are vectors of more than 50 pathogens, including plague.1 While plague may be considered a problem of the past, according to the World Health Organization, between 2010 and 2015, there were 3,248 cases of reported plague worldwide and 584 deaths. While it is clearly not the 1300’s when the plague killed millions, the CDC confirms, “plague occurs in rural and semi-rural areas of the western United States, primarily in semi-arid upland forests and grasslands where many types of rodent species can be involved.” While the fact that plague is still lurking is a bit surprising, it should be no surprise that rodents can spread more than 50 diseases. Not the least of these diseases is Salmonella braenderup, the cause of recall of approximately 206,749,248 eggs in 2018. The good news: In the age of IoT, new technology can enable an immediate response to help prevent infestations from growing out of control.

With rodent populations on the rise due to climate change and the resultant public health issues in major cities across the United States, public health officials and pest managers face unimaginable challenges in staying ahead of rapidly growing and spreading rodent infestations. Earlier this year, Los Angeles had a typhus outbreak that resulted from a rat infestation near an encampment for those experiencing homelessness. The unsanitary conditions created a harborage for rats that spread the flea-borne illness. Cases of typhoid have doubled in the area since 2012. When and where will the next pathogen outbreak from rodent activity hit?

If that’s not frightening enough, it is important to highlight that once an infected, flea-carrying rodent enters a facility, eliminating the rodent does not always necessarily mean eliminating the presence of plague pathogens. The World Health Organization explains that once vectors have been introduced through rodents and their fleas, it is not enough to eliminate rodents. Vector control must take place before rodent control because “killing rodents before vectors will cause the fleas to jump to new hosts.”

Controlling the spread of pathogens via rodents is becoming increasingly important, particularly in sensitive environments like food processing and manufacturing facilities. Effective management begins with early and accurate detection and sustained through continuous monitoring. However, the traditional method of manual rodent inspection by its very nature cannot provide facility and pest managers with either early detection or continuous monitoring.

Thanks to IoT, monitoring systems can now be used in a wide variety of rodent monitoring devices inside and outside a facility. The systems transmit messages in real time over wireless networks and provide pest managers, facility management and public health officials with 24/7 visibility of rodent activity in a monitored location, which will enable more timely responses and help improve the effectiveness of mitigation efforts. Digital IoT technologies are rapidly becoming the modern proactive tool used to help predict and control rodent issues before they occur in an age when traditional, reactive methods are insufficient.

Reference

Meerburg, B.G., Singleton, G.R., and Kijlstra, A. (2009). “Rodent-borne Diseases and their Risk for Public Health”. Crit Rev Microbiol.

July 18, 2019

Possible E. Coli Contamination in Ground Bison, Recall Issued

By Food Safety Tech Staff

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Northfork Bison Distributions, Inc. has issue a voluntary recall of its Bison Ground and Bison/Buffalo Burgers following a multistate outbreak of E. coli O121 and E. coli O103 linked to its ground bison. The ground bison was produced between February 22, 2019 and April 30, 2019, and has expiration dates through October 8, 2020.

Thus far, 21 people have become ill, and eight have been hospitalized, with cases reported in Connecticut, Florida, Mississippi, Missouri, New Jersey, New York and Pennsylvania.

The FDA regulates bison meat, as the authority is not assigned to USDA’s FSIS. Several images of the affected products have been posted on the agency’s website.

During the investigation, the FDA and CDC used traceback and epidemiological information to link to affected ground bison to Northfork Bison, which the agency noted was quick to initiate the recall.

January 10, 2019

CDC Reports Romaine Lettuce Outbreak Over

By Food Safety Tech Staff

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Although FDA is continuing its investigation into the source of the E.coli outbreak involving romaine lettuce grown in California, the CDC has declared the outbreak over. Contaminated romaine that caused illnesses should no longer be available, FDA stated in an outbreak update. Consumers will not need to avoid romaine lettuce, and retailers and restaurants do not need to avoid selling or serving the product, according to the agency. Suppliers and distributors need not avoid shipping or selling any romaine that is on the market either.

FDA has recommended that romaine lettuce is labeled with the harvest location and date, as well as whether it has been grown hydroponically or in a greenhouse. “ In case of future product withdrawals or recalls of romaine lettuce, this will help to limit the amount of product to be removed from the market and it will help consumers, restaurants and retailers determine that the romaine lettuce they are buying is from an unaffected growing region,” stated FDA. In addition, the detailed labeling should be available in stores, the agency states.

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