Despite the government shutdown, certain aspects of the USDA will continue to operate. On Friday, USDA issued a release in which U.S. Secretary of Agriculture Sonny Perdue outlined the services that will continue to be available, including the following:
Ensuring meat, poultry and egg products are safe
Inspect before and after bird and animal slaughter for food intended for humans
Apply foreign government inspection requirements and procedures
Conduct emergency operations related to voluntary meat and poultry products
Conduct epidemiological investigations related to foodborne health hazards and disease outbreaks, and provide pathological, microbiological, and chemical examination of USDA regulated products for disease, infection, contamination and adulteration
Robust, reproducible quantitation of pesticide residues in food is the most important step in ensuring food safety, and hence, forms one of the most important responsibilities of every food safety laboratories. The analytical process involves characterization and identification followed by quantitation of pesticides across different food matrices. Considering the growing list of pesticides and their adverse effects even for very low concentrations, quantitation with confidence for every sample can pose some significant challenges to the analytical scientist.
Typical practices of using pesticides to control pests and improve yields can often pose a serious risk to human health if and when used inappropriately. Improper use of pesticides in breach of approved procedures, or those that are applied to crops for which their use has not been authorized, unacceptable amounts of these potentially dangerous compounds can find their way onto the plates of consumers.
In order to ensure food is safe for consumption, laboratories require robust, reliable and cost-effective workflows, incorporating highly effective sample preparation steps, separation methods and detection techniques. Owing to its selectivity, specificity, sensitivity, robustness and universal approach, liquid chromatography coupled to triple quadrupole mass spectrometers (LC-MS/MS) are widely used for quantitation of pesticides in food.
Food standards are growing increasingly stringent, so leading laboratories must ensure they consistently meet the requirements of regulators. Thankfully, the latest comprehensive pesticide workflow solutions are helping laboratories deliver the very highest quality of pesticide quantitation, on time and on budget.
Optimizing Sample Preparation
Regardless of the food product that is being tested, pesticide residue workflows typically start with sample preparation, following homogenization and residue extraction steps. This stage is one of the most important parts of the workflow, however, very often they are not highlighted.
The heterogeneity of the sample matrix, as well as the wide variety of pesticide compounds that must be extracted, can significantly add to the complexity of this task. For example, pesticide residues can be lost during sample grinding, compromising the accuracy of quantitative analysis. Loss of critical pesticides can also occur through hydrolysis by water or enzymatic degradation as enzymes are released from cells, or by the formation of insoluble complexes due to interaction of the analyte with matrix components. Each of these factors can impact the quantitation of pesticide residues in food.
Homogenization is followed by solvent extraction and cleanup. Extraction could traditionally be a time-consuming process, often requiring relatively large amounts of sample, and involving use of multiple solvents and work-up steps. In addition, results from this step can vary based on matrix type and pesticides that are being monitored. Time-consuming sample cleanup steps, based on separation techniques such as gel permeation chromatography, could also be necessary, thereby adding another layer of complexity.
The widespread adoption of sample preparation strategies based on QuEChERS (Quick, Easy, Cheap, Effective, Rugged and Safe) methods has significantly simplified the process of residue extraction for a wide range of food types, especially for high-moisture content samples. These generic extraction approaches, coupled with “quick and easy” cleanup techniques such as dispersive solid phase extraction, are able to comprehensively extract residues with a range of different chemical properties, resulting in more consistent and reliable quantitation.
The universal and easy-to-implement nature of QuEChERS methods has also allowed laboratories to reduce the complexity of their workflows. Their simplicity is such that many suppliers are now offering all-in-one kits containing all of the necessary pre-weighted reagents and supplies, which laboratories can use straight from the box. And as they require very little sample material, solvent or equipment, and eliminate the need for time-intensive homogenization steps, they are also helping to reduce laboratory waste and cut operational costs.
The Need for LC-MS/MS Technology
Once analytes are extracted from the matrix, food safety laboratories require reliable, sensitive and precise separation, detection and quantitation technologies to determine their concentration.
As indicated above, LC-MS/MS technology with triple quadrupole mass spectrometers are often the go-to choice for quantitation applications. The high selectivity and sensitivity of these instruments allow analysts to confidently identify pesticides against target lists and accurately quantify even trace levels. Figure 1 shows the distinct separation obtained for a leek sample spiked with more than 250 pesticides at a concentration of 100 µg/kg. The mass range, robustness, specificity, selectivity of the triple quadrupole instrument ensures the ability to handle a wide variety of sample types and deliver reliable results in a cost-effective manner.
Figure 1. LC-MS/MS chromatogram of leek extract spiked with more than 250 pesticides at 100 μg/kg. Results were obtained using a UHPLC system coupled with a triple quadrupole MS.
Conclusion
To ensure the food on our plates does not contain potentially harmful levels of pesticides, laboratories require robust workflows for their analysis and targeted quantitation. Improvements in the sample preparation methods that are used to extract pesticide residues from food samples, as well as in the sensitivity, accuracy, robustness and reliability of the triple quadrupole instruments used for analyte detection, are helping food safety laboratories confidently quantify these compounds even in trace amounts.
Acknowledgements
This article is based on research by Katerina Bousova, Michal Godula, Claudia Martins, Charles Yang, Ed Georg, Neloni Wijeratne & Richard J. Fussell, Thermo Fisher Scientific, Dreieich, Germany, Thermo Fisher Scientific, California, USA, Thermo Fisher Scientific, Hemel Hempstead, UK.
The passage of FSMA sparked industry-wide tightening of food safety standards. Perhaps one industry that has been affected more than others is brewing. Prior to the passage of this sweeping legislation, brewers weren’t held to the same standards as other food manufacturers and food processors. The act’s new categorization for brewers as “food” means that the FDA now has some jurisdiction over the industry in conjunction with the Alcohol and Tobacco Tax and Trade Bureau (TTB).
This increased scrutiny, particularly in the event of a recall, has caused many brewers to look to color-coding as a measure to tighten up their quality assurance protocols. Fortunately for brewers, there are many benefits to incorporating color-coding, making the process a worthwhile one.
Happy Inspectors
Perhaps the most immediate effect of incorporating color-coding in a facility is delighting any inspectors that may drop in. A color-coding plan is a documented method for evaluating potential hazards and implementing precautionary measures to preventing contamination—all things inspectors want to see. Failure to live up to these standards can result in follow up inspections and, in some cases, fines.
Proper Tool Usage
A color-coding plan indicates where and when a tool is to be used. While mistakes can still be made, a clear plan that is reflected in all tools and paired with adequate signage and training makes it much more likely that a tool will be used properly. Much of the equipment in a brewery is very expensive and can be easily damaged by using the wrong tool. For example, if an abrasive brush were to be used on a stainless steel tank, there can be irreparable damage.
Higher-Quality Tools
Tools that are color-coded are generally made at a food-grade, FDA-approved quality. This means they are much less likely to leave behind bristles, a potential contaminant you wouldn’t want finding its way into the product. Additionally, many breweries make use of caustics and acids followed by sanitizers in the cleaning process. A low-quality tool will degrade at a much higher rate as a result of coming into contact with these chemicals than a higher quality tool will. Simply put, higher quality tools last longer, saving you money in the long run.
Less Tool Wandering
A color-coding plan should indicate where a tool is used and where it is stored when it is not being used. When tools have this designated storage area they are much less likely to be carelessly misplaced. And in the event of a lost tool, it becomes much easier to recognize these tool gaps and replace as necessary sooner rather than later to ensure that the proper tool is always used for the task at hand.
Higher Efficiency
When protocols are in place for tool usage, time isn’t wasted finding the correct tool for the job. This may seem insignificant, but over time those lost minutes can add up.
Removal of Language Barriers
For facilities that employ foreign speakers, color-coding is extremely helpful in breaking down language barriers. A brewery production area can be a busy, fast-paced environment, so it is helpful to have a plan in place that is easily recognizable and understood by all employees.
It is however important to consider the fact that you may need to keep in mind the visibility of these colors for colorblind employees. It’s best to try to use high contrast colors in your plan.
Greater Traceability
Finally, in the unfortunate event of a recall, a color-coding plan helps add traceability potentially decreasing the amount of product that needs to be pulled from shelves. Certainly color-coding helps to prevent contamination issues that can cause a recall.
A well thought out color-coding plan that is carefully implemented can have numerous benefits in breweries both small and large. For questions related to drafting a color-coding plan from scratch or updating an existing plan, contacting a color-coding specialist is recommended.
Earlier this week the USDA’s FSIS proposed to amend inspection regulations, modernizing food safety inspection systems, in an effort to make egg products safer. It would require official plants that process egg products to develop HACCP systems, sanitation standard operating procedures and meet sanitation requirements consistent with meat and poultry regulations.
“FSIS is proposing that official plants will be required to produce egg products in such a way that the finished product is free of detectable pathogens,” according to a USDA news release. “The regulatory amendment also uses agency’s resources more efficiently and removes unnecessary regulatory obstacles to innovation.”
FSIS will also be taking over jurisdiction of egg substitutes.
According to the agency, the financial impact of the proposed rule could be minimal, as it states 93% of egg products plants already have a written HACCP plan that deals with at least one production step in the process.
Once published in the Federal Register, a 120-comment period will go into effect.
Today Fieldbrook Foods clarified its recall, stating that the voluntary recall also includes 28,751 cases of Raspberry Cream Bars that were included with its orange cream bars in ALDI seasonal split-case purchases. These cases were shipped between March and August 2017.
–END UPDATE–
Yesterday Fieldbrook Foods Corp. issued a voluntary recall due to concerns that two of its products may have ben contaminated with Listeria monocytogenes. The recall is concerning the company’s orange cream bars and chocolate-coated vanilla ice cream bars that were produced last year at Fieldbrook Foods’ Hoyer 1 Line plant in Dunkirk, NY with a “best buy” date of January 1, 2018–December 31, 2018. The FDA’s website lists 21 merchants that sold the bars, including Acme, ALDI, BJ’s, Giant, Kroger and Price Chopper.
Thus far, no illnesses connected to this issue have been reported.
Steer clear of romaine lettuce, urged Consumer Reports yesterday. An E.coli O157 outbreak in Canada traced to romaine lettuce has sickened 41 people in the country, according to the Public Health Agency of Canada. In the United States, a multi-state outbreak of Shiga toxin-producing E. coli O157:H7 has hit 13 states and infected at least 17 people. However, the CDC has not issued an alert, because it has not yet confirmed the source of the infection. The latest CDC media statement was issued on December 28, but Consumer Reports stated that the CDC confirmed “the strain of E. coli detected in the U.S. is ‘a virtual genetic match’ with the one that has caused illnesses in Canada.”
The Consumer Reports article also quotes the head of the CDC’s Outbreak Response Team, Matthew Wise, Ph.D., who said that the agency is examining romaine lettuce and other leafy greens and that the investigation in Canada gave the CDC a “good starting point.” He also said that the CDC’s investigation should be completed within the next two weeks.
FDA will be exercising enforcement discretion for specific provisions in four FSMA rules, which means that the agency doesn’t expect to enforce the provisions as they apply to certain entities or activities. The agency made the announcement yesterday.
“In general, the FDA is exercising enforcement discretion to allow time to consider changes or other approaches to address concerns regarding the application of these provisions to certain activities or entities. FDA had previously extended the compliance dates for many of the provisions covered by this enforcement discretion guidance but is now exercising enforcement discretion.”
According to an FDA release, the enforcement discretion applies to provisions in: Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food rule (PC Human Food), Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food for Animals rule (PC Animal Food), Foreign Supplier Verification Programs rule (FSVP), and Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption rule (Produce Safety). The applications is as follows:
Facilities that would be farms except for certain factors and activities
Written assurances provisions in the four rules related to the control of identified hazards or microorganisms that could be a risk to public health
Animal food PC requirements for certain manufacturing/processing activities performed on human food by-products used as animal food
FSVP requirements for importers of food contact substances
“Specifically, we found that FDA could not always ensure that firms initiated recalls promptly and that FDA did not always (1) evaluate health hazards in a timely manner, (2) issue audit check assignments at the appropriate level, (3) complete audit checks in accordance with its procedures, (4) collect timely and complete status reports from firms that have issued recalls, (5) track key recall data in the RES [Recall Enterprise System], and (6) maintain accurate recall data in the RES,” according to the OIG report.
Food Safety Tech first reported on the draft findings in June 2016 when the OIG said the FDA recall initiation process was not efficient or effective. Although Gottlieb noted that the agency took action after the draft was released, “we still have more work to do,” he said in an FDA statement.
One of the action steps for 2018 is that FDA will issue guidance on recall communications in the first half of the year. The agency is also looking at situations in which it can assist consumers in getting information about the stores and food service locations that may have sold or distributed recalled food, as well as the company that supplied the product.
“Much work remains to be done if we’re going to provide the highest assurance of safety.” – Scott Gottlieb, FDA
Gottlieb stated that the agency will be revealing more early this year about policy steps it will be taking to improve food safety oversight and how the recall process is implemented. FDA is also examining how it can expedite the timeliness and scope of information provided to consumers about food recalls.
As we look to 2018, the need for food defense activity remains. Increased adulteration incidents in 2017, consumer purchasing trends and FSMA rules implementation drive this need and the work necessary to complete it in 2018.
Intentional Adulteration of Food. It was evident that intentional adulteration of food did not diminish over the past year and likely increased. Adulteration cases of spices with undeclared ingredients to extend the product or boost color were documented. Terrorists plans and food adulteration tests were uncovered and publicized. In Germany, a man threatened to put antifreeze in the nation’s baby formula supply chain. And disgruntled employees continued to adulterate food to get revenge on their employer or co-workers. Given the complexity of our food system and the limited transparency of supply chains from farm to fork, those willing and able to adulterate will continue to do so in 2018.
Consumer Demands. Look in your local grocery aisles and you will find an ever-increasing section of “freedom foods”. These are foods that claim to be free of something whether it be gluten, lactose, pesticides or GMOs. With increasing frequency consumers are also asking questions about the sustainability and agriculture practices of the food they buy. How have the oceans been fished? Are my eggs from cage-free chickens? Does the food I buy protect the environment. Based on current trends, consumers will continue to spend their food dollars on organic, free-of, and sustainability produced food. This means food defense needs to have a keen eye on where fraudsters could adulterate products representing these food trends.
Company Food Defense. Two things have increased in the requests we are getting from companies: New incidents and the nearing deadline for compliance of the FSMA Intentional Adulteration (IA) rule. First, adulteration incidents that affect your product or the ingredients you use changes the lens you see food defense through. Even an adulteration in an ingredient or product similar to yours makes you look twice at how protected you are. With the continued incidents, companies are taking a hard look at how they are affected. Second, food companies have completed their work to prepare for the early FSMA rules such as Preventive Controls and Foreign Supplier Verification moving their attention to the next rules. The IA rule compliance dates begin in July 2019, and we anticipate increased activities, questions and food defense efforts in 2018.
As you can see, there is a nexus of need to accomplish defense work in our food system. Perhaps 2018 will be “the” year of food defense where individually and collectively we close vulnerability gaps.
In today’s risk-based world, companies can’t just trust a third-party auditor based on a handshake, according to Melanie Neumann of Neumann Risk Services and Matrix Sciences. It is also a manufacturer’s responsibility to verify the auditor. Watch the following video, shot at this year’s Food Safety Consortium, to hear Neumann’s take on “trust but verify” and the importance of inspection and audit readiness both today and in the future.
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