Recall These Thoughts
Inanity from Scott Lougheed, PhD

In 2012, XL Foods issued an international recall of 1800 products potentially contaminated with E. coli O157:H7 and linked to 18 illnesses and zero deaths. The recall and outbreak were protracted affairs, with significant media attention beginning in October 2012 and continuing into 2013.1

The XL Foods recall and outbreak was also a political and public policy fiasco. The premier of Alberta, where XL Foods operated, was criticized for not responding to early signs of trouble.2 Meanwhile, political opponents fought to have Agriculture Minister Gary Ritz3 resign. Ritz was being blamed for crippling cutbacks the CFIA’s enforcement capabilities, was painted as generally lacking competence and leadership, and as “having failed consumers badly”.

In the wake of the recall and outbreak, there was significant debate and relatively prompt action taken by numerous stakeholders.4 There was an independent inquiry into the underlying causes of the contamination, outbreak, and recall; the branch of the CFIA responsible for food safety was re-assigned to report to the Health Minister instead of the Agricultural Minister5; and new labelling laws were proposed and introduced for mechanically tenderized beef.6

XL Foods was a truly massive recall, but in the history of illness outbreaks, it was not the largest, not the deadliest, indeed it was somewhat unremarkable.7 Yet it was a political firestorm.

Fast-forward a few years: Over the course of 2015-2017 there were three outbreaks of salmonella attributed to frozen breaded chicken products in Canada.8 In total there were 86 reported illnesses across Canada including one death. Most recently, Public Health Agency of Canada has announced that there had been an outbreak between May 2017 and February 2018, with 30 illnesses, all attributed to frozen breaded chicken products.9

It was industry that took action first, and in 2015 voluntarily established guidelines for more prominent “uncooked” labels and clear directives not to microwave products.10

The CFIA and Health Canada, responding to the 2015 outbreak and recall, the largest of the three, spelled out steps consumers can take to avoid illness:

If you are preparing frozen raw breaded chicken products there are precautions you should take to protect your health.

  • Wash your hands thoroughly with soap and warm water before and after handling raw poultry products.
  • Use a separate plate, cutting board, and utensils when handling raw poultry products to prevent the spread of harmful bacteria.
  • Frozen raw breaded chicken products may appear to be pre-cooked or browned, but some contain raw chicken and should be handled and prepared no differently than raw poultry products.
  • Do not eat raw or undercooked poultry products. Cook all frozen, stuffed, breaded or raw poultry products to an internal temperature of at least 74°C (165°F) to ensure they are safe to eat. Whole poultry should be cooked to an internal temperature of 82°C (180°F).
  • Due to uneven heating, microwave cooking of frozen raw breaded poultry products including chicken nuggets, strips or burgers is not recommended. Always follow package cooking instructions, including products labelled Uncooked, Cook and Serve, Ready to Cook, and Oven Ready.

The federal agencies went on to attempt to describe what the government planned to do to prevent consumers from getting sick:

What the Government of Canada is doing
The Government of Canada is committed to food safety. The Public Health Agency of Canada is leading the human health investigation of this outbreak and is in regular contact with its federal and provincial partners to monitor and take collaborative steps to address the outbreak. Health Canada provides food-related health risk assessments to determine if the presence of a certain substance or microorganism poses a health risk to consumers. The Canadian Food Inspection Agency (CFIA) conducts food safety investigations into the possible food source of an outbreak. The Government of Canada will continue to update Canadians as new information related to this investigation becomes available.

Similar responses from the government accompanied the two 2017 illness outbreaks. By the end of 2017, after one death and over 80 illnesses, no federal agency had made a clear statement about what they would do to prevent consumers from getting sick, and other than industry’s voluntary guidelines, no changes to labelling or pathogen controls were introduced.

The relatively trite and useless response, from all stakeholders, including government, media, and the public stands in stark contrast to that which quickly followed the XL Foods scandal.11 Nobody is calling for the current Public Health minister Jane Philpott’s head, nobody is publicly calling out industry, the media has published public notices without the additional commentary and editorializing that took place in 2012, and politicians have yet to play the political blame-game. In fact, in the case of the June 2017 outbreak, the CFIA dragged its feet in going public with the name of the affected products and implicated company.

While industry’s voluntary labelling efforts are better than nothing, they don’t address the underlying problem because you can’t label pathogens out of your food. Labels, and the oft-repeated advice from government to properly cook these products severely misses the point. It places the burden of food safety solely on consumers’ shoulders. The assumption that contaminated products are safe if they are cooked properly also misses issues of cross-contamination and assumes that consumers have the right skills and tools (e.g., an accurate, quick-read thermometer) to actually determine when something is “cooked properly”. Or as Doug Powell on Barf Blog put it: “why is a teenager popping a few chicken nuggets in the microwave after school the critical control point in the frozen chicken thingie food safety system?” It also assumes that small, back-of-package labels that indicate the un-cooked state of the product are sufficient. The producers of frozen breaded chicken products had really been given a pass.

Things, thankfully, are changing, although it has taken three years and over 80 illnesses to get to government to act. On March 13, 2018, the CFIA announced it is working with the poultry industry to reduce the risk from Salmonella in frozen, breaded chicken products. From the press release:

These new measures call for processors to identify salmonella as a hazard and to implement changes in order to produce an end product that reduces salmonella to below a detectable amount. The CFIA has granted industry a 12-month implementation period, to begin immediately, to make these changes.

If only the feds had, you know, thought to ask “WTF is salmonella doing in frozen chicken thingies that people cook in the microwave?” as Doug Powell of Barf Blog did eight years ago.

I remain curious about why XL Foods was a national scandal and why it took so long for Salmonella in frozen breaded chicken to register even a modest public and regulatory response. I’ll be interested to see how this goes over the next 12 months.

  1. See, for example: here, and here, and here


  3. To whom the CFIA reported at the time. 

  4. Of course, how effective that action has been could be debated. 

  5. a move seen by some opposition members of parliament as a punishment of Gary Ritz by diminishing his responsibility and portfolio 

  6. Mechanically tenderized beef—cuts of beef that are tenderized by being punctured by dozens of small blades—was identified as one of the most problematic products. While pathogens on the surface of whole muscle (“intact”) cuts is permissible, because it will be in direct contact with the cooking surface and thus inactivated, the blades used in mechanical tenderization can inject pathogens from the surface of the muscle to the interior of the meat where they can grow, and where they may not be inactivated by heat without thorough cooking. Mechanically tenderized meat therefore can be higher risk than truly intact cuts, but prior to 2012, where existed no regulatory nor labelling distinction, despite the well-established difference in risk. 

  7. Some Which is by no means to diminish how terrible any foodborne illness outbreaks are. 18 illnesses is 18 illnesses too many. 

  8. In 2015 there was a recall of No Name and Compliments brand frozen, breaded chicken products linked to an outbreak of 51 illnesses in four eastern provinces. In July 2017, there was a recall of President’s Choice brand frozen, breaded chicken products link to an outbreak of 13 illnesses across Canada. And finally, in October 2017, there was a recall of Janes Pub Style frozen breaded chicken products linked to an outbreak of 22 illnesses (including 1 death) across Canada. 

  9. It’s not abundantly clear where one 2017 outbreak ends and the other begins. 

  10. Though I have not found the actual text or documentation for these guidelines, so it is not clear what the actual requirements are, whether implementation of these guidelines is voluntary or not, and what the incentives to follow/punishments for not following them are. 

  11. Lets also not forget about the 2008 listeriosis outbreak that killed 20 and nearly sank Maple Leaf foods, which was also followed by massive public and political outcry as well as an independent investigation

I am delighted to announce that as of March, I am a postdoctoral fellow in the Department of Geography and Planning at the University of Toronto.

I will be working with Virginia Maclaren on issues related to the role of the consumer under extended producer responsibility in Ontario.

Recently, I’ve been increasing the amount of information I keep in Apple’s Notes application, which received a significant feature update in iOS 9. One thing I struggled with, however, was finding an easy way to surface needed information in Notes at a specific time.

I don’t like to store reference data in my task manager or calendar because the information in those applications is, by definition, transient, and a lot of the material I need to reference to perform those tasks is not. DEVONthink (and DEVONthink To Go), my information manager of choice, very easily creates links to anything you store inside of it. You can paste these links anywhere on iOS and macOS and they will be clickable and take you directly to the desired file. Very handy. I frequently paste these links into OmniFocus tasks or calendar events so I don’t have to manually browse for the information by digging through countless folders.

But with more and more of my information going into Notes instead of DEVONthink, and as an adherent to the mantra that you never keep your reference materials in your task manager, I was a bit frustrated that I had to manually browse the Notes app to surface information I might need for a given task.

As it turns out, you can exploit the collaboration features introduced to Notes in iOS 9 to mimic DEVONthink’s file linking.

Open the note you would like to link to and tap the Add Person icon.

Add Person to Notes

You’ll be provided with a standard iOS share sheet. Locate the “Copy Link” action in the bottom row and tap it.

At this point you’re prompted to enter an email address or phone number of a potential collaborators.1 Since we’re collaborating with ourselves today, you can just tap Copy Link in the top right to copy the link to your clipboard and dismiss the share sheet.

Copy Link

Now you can easily paste this link into the Notes section of your task manager of choice, or the URL section of a calendar event, or anywhere else you please. Clicking on this link will take you straight to the note so you don’t have to do any time-consuming digging and browsing.

If you are interested in taking things a few steps further, Federico Viticci at MacStories has a great writeup on how he uses Notes on iOS.

  1. Which seems odd, since this is the same prompt you get if you select to share by Messages or Email, so I don’t see why you should also see it when using the generic Copy Link action! 

I’ve created a workflow to easily rename PDF files on iOS in the following pattern:

author year - title.pdf

Download the Workflow application for iOS

Download my PDF Namer workflow

The Basics

I love reading academic journal articles on my iPad. But what about finding those articles and saving the PDFs of those articles in an appropriate location with a nice title? Often, while reading, I’ll come across a citation to an article I want to track down. Ideally I’d be able to download and rename the file without switching devices (because lets face it, if I don’t do it right this moment, I’ll never do it). This can be somewhat cumbersome on an iPad, particularly if you don’t have your external keyboard deployed. It can be tricky to rename a file, while viewing that file, in iOS. You got to keep, in your frail human working memory, all the details such as the title and authors that you want to include in the name.

This was the perfect sort of problem to be solved by the very powerful iOS app called Workflow. If you aren’t familiar with Workflow on iOS, Workflow allows users to automate certain repetitive or complex tasks using a straightforward drag-and-drop interface ( it’s a bit like Automator on the Mac).

For a primer on Workflow, check out the great guide put together at iMore, and all the detailed articles put together by Federico Viticci at MacStories

I’ve written a workflow that walks users through the process of renaming a file stored in iCloud Drive, Dropbox, or Box. Once you install the Workflow app (if you don’t already have it installed), you can simply download my workflow to include it in your collection.

Once installed, all you have to do is run the workflow (either from the Today widget, or from within the Workflow application itself) and you’ll be walked through the process of renaming the file. Here’s how that should go:

  1. A dialogue box will prompt you to select the PDF you want from iCloud Drive
  2. Once selected, it will show you a preview of the PDF and ask you to copy the title to the clipboard and click “Done” in the top right.
  3. You’ll be presented with a text box containing the clipboard contents for you to confirm that you’ve got the title right.
  4. You’ll be shown a preview of the PDF again and prompted to copy the publication year to the clipboard and tap “done”. If there’s no easily-copiable year, you can just click Done and manually enter it in the next step.
  5. You’ll once again be presented with a text box filled with the date you selected. This allows you to confirm the correct year was selected, or manually enter the year if you didn’t copy it to the clipboard in step 4.
  6. You’ll be prompted to indicate the number of authors on the article.
  7. For each author (up to 3) you’ll go through the preview-copy-done routine we’ve been through several times. If you indicate that the article has more than three authors, the workflow will only ask you for the first author’s name and append “et al”. If there are superscript numerals attached to authors’ names, don’t worry about trying to avoid copying those, the workflow will remove them for you.
  8. You’ll be presented with a text box containing all the author names for you to verify or enter manually.
  9. Workflow will then delete the original file and prompt you to chose a location to save the newly renamed file.

Typically what I’ll do is save the PDF from Safari to the root directory (the bare /iCloud Drive or /Dropbox folder) and run the workflow from the Today widget. At the end of the workflow, I save the renamed file in the proper location (whichever folder matches the subject matter of the article) and the workflow simply deletes un-named file in the root directory.

Nitty Gritty

This seems like a lot of steps, but the beauty of this workflow is that you can go through the renaming process without having to touch the keyboard at all.

Now for some more technical details for those who want to get into the weeds a bit.

For such a simple task – renaming a file and saving it back to the location you choose – it looks somewhat complicated. I’ve included a number of conditionals and error-correcting steps to try account for as many contingencies as possible.

  1. Not all PDFs contain selectable text, or the actual text layer is corrupt. This is why you are prompted to verify the clipboard contents: if there are errors this allows you to correct it, if the text isn’t selectable, you can enter it manually. This adds an extra step to each part of the title, but it means that this workflow is still usable in most cases even for old or edge-case PDFs.
  2. I deal with strange capitalizations and strip special or unwanted characters like trailing spaces at each step. In many cases, journals will use superscript numerals to denote author affiliations. I’ve noticed that using the iOS text selectors, it can be hard to avoid these numerals, so in the Author selection stage, I use a REGEX query to find numerals and delete them. A similar issue exists with journal titles that span across a line. In some cases, this may actually result in a line-break being copied to the clipboard. Again, a REGEX query finds these and replaces them with a space.
  3. If there are more than three authors, I want to append an “et al” rather than have the user copy and paste a dozen author names. This required me to set up several nested conditionals for one author, between 1 and 4 authors, and 4 or more authors.


My default the workflow prompts you to select a file from iCloud Drive, which is my file sync of choice. If you want to have it prompt you to select files from Dropbox or Box, simply make the appropriate change to “Get File” and “Save File” actions at the beginning and end of the Workflow.

Unfortunately, if you would like to have the filename contain different information or ordered differently, that would require some extensive reconfiguring of the workflow. Feel free to dive in to try and do it yourself if you’d like, or reach out to me and I’ll see what I can do.

Reach out to me on Twitter and let me know how it goes!

I have a new publication with Myra Hird in the Journal of Crime, Law, and Social Change titled “Food Security and Secure Food in the Anthropocene”

Modes of Governing Abstract

Myself and my collaborators have a new publication in the Journal of Environmental Policy and Planning titled “Modes of Governing Canadian Waste Management: a case study of Metro Vancouver’s energy-from-waste controversy”

Modes of Governing Abstract

What it does

iMessageR is a small and simple package for the R statistics package that allows a user to send iMessages to any phone number or email address registered with iMessage service.

I know that there are a number of similar ways that this can be done, such as making a system call to mail, but this requires that postfix be properly configured on the system, and this is not always the case. Even when this is properly configured, mail would send to conventional email addresses without issue, but receiving messages sent to carrier-provided SMS email addresses (e.g., was unreliable. This was not ideal.

There are also a number of packages for sending messages from R using gmail. This is great but also requires some amount of additional configuration in R in order to function. I figured iMessages was the lowest friction option for Mac and iOS users.

I suspect this will be especially helpful for R users who run lengthy analyses and would like an alert to their phone (or any other iMessage capable device) indicating when the analysis is complete.

Since you can use this function any number of times and customize the message, you could even take things one step further and use iMessageR to help with debugging. For example, you could insert calls to this function at different locations in your script to indicate progress through your program. Alternatively you could insert it into a trycatch() or some other exception-handling system to alert you of an error.

No iPhone?

Since iMessages is available to any user with a Mac, whether or not that user has an iPhone, iMessageR could be used by a Mac user regardless of the type of phone they use. Without an iPhone, the user would, of course, only be able to receive notifications on their Mac (or any other Mac also configured with that iMessage email address or phone number). So while an iPhone (or iPod Touch) is ideal in order to receive the most benefit, even Mac users without an iOS device will likely find some utility here.


The iMessageR package can be downloaded directly from cran or can be installed from within R:


This will give you access to the function

send.imessage(recipient: STRING, message: STRING)

Known Issues

  • If the message string contains single or double quotes, the function will fail.
  • If the email address or phone number is incorrect or unrecognized, there is no notice to the user.

The future

I’d like to try to make this package more accessible to different platforms. I hope to add support for a wider range of platforms by adding options for different services. Presently I am thinking of Pushbullet or WhatsApp but this will depend on the level of API integration those services expose.

I should note that I am neither a computer programmer nor a habitual R user, so this is very new territory for me in a number of ways! As such I will try and address issues and add enhancements in my spare time, as my nascent skills allow.

Connect with me

Connect with me on github where you can submit an issue or fork away!

Or reach out to me on twitter: @scottisloud.

The CBC’s Marketplace is focusing on retail food waste this week. Yesterday we heard from a former Walmart contractor that a ‘heartbreaking’ amount of food is trashed every day. Today, Marketplace reveals its findings from 12 days of sifting through Walmart dumpsters.
This is a great scoop for the CBC and I think this kind of coverage is just what is needed to bring light to a shameful problem. Food retail accounts for 10% of the food wasted in Canada. This is a small slice of the pie, but in absolute terms, it’s a substantial amount of food (it is, after all, a very big pie). These CBC stories can stand on their own, but I wanted to add some additional commentary and nuance based on some of my experience and research on food waste.

Marketplace found cartons of milk days ahead of their best-before date, and Parmesan cheese with months left before it needed to be thrown away.

Assuming these products are not contaminated or otherwise unsafe, this is troubling. Best-before dates on both of these products are largely unrelated to safety. A solid piece of Parmesan cheese can be safely stored for a very long time. Barring any cross-contamination in a retailer’s or consumer’s fridge, the worst that will happen is the growth of some mould, which is a quality, not a safety, issue, and will not cause someone harm.

Mevawala, formerly with one of the company’s Edmonton stores, says if a piece of fruit or vegetable didn’t look perfect, it had to be thrown in the trash.

Moreover, cosmetic imperfections are a reflection of arbitrary quality standards that are a large reason food is disposed of at the retail level. Retailers will claim that these arbitrary quality standards are the fault of consumers, but this is untrue. This is a marketing failure. There is demand for these products, they just need to be marketed correctly. Loblaws is beginning to dip their toe into this market segment with imperfect apples marketed under their No Name brand. This is also failure of retailers to capitalize on their own value-added departments. These cosmetically imperfect produce items, if not sold to consumers directly, should become part of value-added products in-store. Fruit salads, vegetable trays, pre-chopped vegetables, etc. could all be made from imperfect products.

Over the course of more than 12 visits to the stores, Marketplace staff repeatedly found produce, baked goods, frozen foods, meat and dairy products. Most of the food was still in its packaging, rather than separated for composting.

This quote highlights a significant issue with how retail food waste is often handled. In many cases retailers want to get ‘unsaleable’ goods (however they define that) off their shelves and our of their warehouse as quickly as possible. Typically this means disposing of it directly into their dumpsters or compactors. The above quote draws attention to several problems: all that organic material ends up in landfill where it is a significant source of methane; all that packaging is, to the dismay of brand owners, in-tact and visible to anyone willing to dip their nose into a dumpster or landfill; and that packaging, the majority of which is recyclable, also ends up in landfill.

Retailers regularly fail to take advantage of the services of depackagers. Depackagers, as the name implies, remove food from its packaging. They then send the food to anaerobic digestion, rendering, or some other destination where it is at least marginally more valuable and less environmentally harmful than landfill. They also shred and recycling the packaging, which conveniently obscures the branding (not that that is needed, as most depackagers are very security conscious and discreet, unlike the dumpster!). There is unused depackaging capacity in southern Ontario, and most retailers are not taking advantage of these services because:

  • It is disruptive – they are at the mercy of the depackager to pick up products which may not be as fast as the retailer would like. It’s hard to beat the convenience of tossing unsaleable goods directly and immediately into the dumpster or compactor.
  • It’s another contract to juggle in addition to standard waste collection.
  • It may not be available at 100% of a retail chain’s locations which makes uniform policy and best practice for store managers more difficult.
  • For some retailers it just isn’t even a priority, it’s not even on the agenda.

This needs to change. While we need to reduce food waste generation upstream, there will always be some amount of downstream waste. That downstream waste could be handled better, and there’s possibility for that to happen today.

Also in the garbage: bottles of water, frozen cherries that were still cold and tubs of margarine. In a statement, Walmart said it believes the food Marketplace found was unsafe for consumption. In many cases, however, the food was well before its best-before date and appeared to be fresh. Or, if it needed refrigeration or freezing, the food found was still cold.

I have to take issue with the CBC commentary here. Coldness, best-before dates, and appearance are all terrible indicators of safety. None of the indicators listed in the quote provide any particularly useful data to make a decent risk management decision. Best-before dates are often arbitrary, typically refer to quality (at their best) and not safety, and can’t account for variability in storage temperature and handling. Further to this point, just because something that is meant to be cold is cold, doesn’t mean it is safe. There’s simply not enough information for a gleaner to know how long the product has been at a given temperature or if there’s a hazard that can’t be seen.

Our senses are pretty good judges of quality: we can taste soured milk, which is perfectly safe to eat, if perhaps a bit unpleasant. But we can’t taste Hepatitis in still-frozen berries, or an undeclared allergen in a baked good that might result in illness or death if consumed unknowingly by a gleaner or someone that gleaner feeds, or a fresh apple contaminated with Listeria.The reality is, the majority of things that are going to make us sick cannot be seen, smelled, felt, or tasted. Our eyes, fingers, noses, and tongues are bad judges of food safety.

Dumpster-divers, gleaners, freegans, are doing good work recovering perfectly edible food, but it is really risky business unless you take great care (and even then, still risky). There are ways to reduce risks, such as keeping an eye on recall notices before gleaning and becoming familiar with which products are lower risk than others when temperature history and handling are unknowns.

But the reality is, in instances like this, products that look perfectly good may be perfectly bad. Products that are perfectly good may come into contact with harmful products and show no signs of that contact, resulting in cross-contamination. Again, these are things we cannot detect with our own senses. As long as legitimately good food and food recalled for posing a health threat are intermingled in the same bins, it’s impossible to, with any degree of certainty, separate the two.

But even the people in charge don’t necessarily know the difference between quality and safety:

“On some occasions, food which has not passed its best-before date is deemed unsafe for consumption,” Walmart said in its statement. “As a rule we don’t place fresh food items on display for sale if the quality is not acceptable.”

Here, the Walmart spokesperson is dangerously conflating safety and quality. There is a grand canyon that separates what counts as “safe food” and food that possesses “acceptable quality”. A statement like this erroneously reproduces the notion that quality is a safety issue, which is is not (though they may, in some cases be related). It also further occludes the rationale that underlies Walmart’s disposal practice: Is the food in the dumpster dangerous, or does it merely fail to meet some perceived quality expectation? Dangerous food should never be made, and if it is, shouldn’t be sold to consumers. Food that deviates from quality expectations but is safe should be sold and consumed by humans.

Marketplace staff looked for food waste at all the major retailers, including Costco, Metro, Sobeys, Loblaws and Walmart. While staffers found bins full of food at some Walmart locations, other chains had compactors making it impossible to see what they throw out.

This is some seriously bad practice from Walmart. No brand owner wants their products on display to anyone who walks to the back of a store. Retailers also generally “field destroy” recalled products, that is, when there is a product recall, they dispose of it on-site rather than send it back up through the supply chain. Compactors offer security from both a brand and public health perspective inasmuch as dangerous products are destroyed and inaccessible (though, of course, the use of a depackaging service is also secure and environmentally superior, but not typically used by retailers when handling recalled products). An unfortunate side-effect of compactors is that they prohibit informal recovery by gleaners and freegans, but the tradeoff is marginally improved brand and public health security. Walmart needs to prioritize security and switch to compactors. They’re playing a dangerous game with open dumpsters (though, as the CBC story notes, they’ve now started locking those dumpsters at least).

Food waste is a pernicious problem. We waste way too much food. What we can do today is reduce the impact of that waste. However, what is really needed is upstream solutions that reduce the overall generation of food waste. This means reducing contamination and safety problems that lead to product recalls. This means reducing over-production. This means reducing knee-jerk price-hikes that result in surpluses and subsequent blow-outs or disposal. It means disrupting the reproduction of arbitrary quality standards. We have a long way to go towards reducing food waste across the value chain, but what CBC is showing us with these stories is that there are some immediate steps that can be taken to reduce food waste and the attending environmental harm.

The September 1st deadline for public comments on proposed legislation that would allow firms to irradiate beef draws near. While the previous effort to bring irradiation to the beef industry in 2002 failed, there is hope that the events of the intervening 14 years might have shifted public attitudes. However criticisms of the potential plan are already emerging and not just from consumers. While it might be intuitive to assume that the beef industry in Canada is united in their support for this move – it was industry stakeholders who pushed for the first consult in 2002, and again this year – the beef industry itself is divided.

The National Farmers Union (NFU), representing family-owned farms including cattle farms in Canada, has submitted a letter to Health Canada objecting to the potential changes. Their primary concerns are economic. The NFU are concerned that irradiation equipment would be too expensive for smaller beef packers, thus driving them out of business, while JBS and Cargill will easily distribute the capital outlays for irradiation equipment across their sprawling businesses. The ensuing consolidation of an already heavily consolidated industry would further establish Cargill and JBS, who already process 90% of the federally registered beef in Canada, as the only buyers of beef to whom farmers may sell their cattle. Such oligopolistic conditions, they argue, will ultimately produce downward price pressure. This would mean less money per head for farmers. It will limit the number packers to whom cattle ranchers could sell to and thus limit competition, and would further reduce already rather limited consumer choice.

Another concern is that the proposed change would allow for the importing of irradiated beef from the United States where beef processors have been permitted to irradiate beef for over a decade. Not only would this contribute to further downward price pressure on farmers to compete with cheap imported beef, it would displace domestically slaughtered beef and swaths slaughter and packing jobs. The NFU states that because the proposed Canadian regulation is nearly identical to that in the US that “it would effectively erase the Canadian border in regard to ground beef”.

While I am sympathetic to these concerns and I am an enthusiastic proponent of local, small-scale agriculture and family farms, there are some important considerations to make here. The first is that the proposed legislation allows beef processors to irradiate beef should they choose to, it does not require that beef producers irradiate their product. The new legislation isn’t going to suddenly put small firms out of compliance with the law. This is only a problem if irradiated beef is met with massive consumer demand and by not irradiating smaller processors would be severely disadvantaged.

With respect to imports, the majority of beef in the United States currently is not irradiated and thus would not be precluded from import anyway. Harmonizing legislation between Canada and the United States would pertain to the very small percent of US beef that is irradiated, very likely a drop in the bucket overall and not likely to pose an immediate threat to Canadian firms.

It might then be argued that while the proposed legislation doesn’t require irradiation, market demand will serve as an sort of proxy whereby if any firm that wants to compete they must irradiate. This seems to assume widespread, maybe even pent up demand for irradiated beef. The evidence from the United States, however, suggests demand is limited. Irradiated beef is available only under a hand full of brand names at a small number of retailers and restaurants. As I argue in a past post there are also unanswered question regarding what the market impacts are of irradiated beef. Will there be an “irradiated ghetto” off in the corner of the meat case touched by consumers only when the the grocer is out of the non-irradiated cut the consumer desires? Will brands begin competing on the premise of their beef being “non-irradiated” or vice-versa? Will it not matter and will consumers simply ignore the label because they don’t care, grabbing whichever tray of beef they need for tonight’s dinner regardless of the presence of a radura logo?

Given all of this, I can’t help but see the economic concerns of the NFU as a strawman. As I said before, beef producers and the government agencies that support them have an uphill battle. In over a decade in the US, irradiated beef is not a blockbuster, and I don’t think it will be in Canada either.

The NFU also raised concerns that eaters in institutional settings are not positioned to know whether the beef they are served is irradiated or not. Those who prepare the food would know – they’d see the labels on the boxes of course – but those labels won’t leave the kitchen. This is only a problem for human health or food safety if the considerable evidence indicating that irradiation of food does not pose a threat to consumers’ health is ignored. Even if there is a remote chance of human health impacts, there’s a very immediate and potentially fatal threat from fecal pathogens. This does point to a shortcoming with the labelling requirements in that in an institutional setting the labels are largely obscured from institutional eaters. This is something that should be addressed (most likely this will be in the hands of institutions themselves) in the interest of maximizing transparency for all consumers, but it is not an issue of public health or food safety. I imagine poor food handling practices at these retirement homes and schools are a far larger and far more immediate threat to the vulnerable populations that dine in those institutions than any possible threat posed by irradiation. Moreover, I suspect the majority of those institutional eaters have been consuming irradiated spices and onions for years without harm. If we are really concerned about allowing institutional eaters to make better risk management decisions, perhaps we should start posting food safety inspection scores on the doors of restaurants and institutions.

I am, however, sympathetic to the other concerns articulated by the NFU related to food safety. The NFUS are concerned that irradiation may “be used as a final control point to kill some (but not necessarily all) pathogens…that occurs when processing high volumes at high speeds without adequate inspection of lines”. I too am concerned about the possibility of irradiation becoming a food safety crutch. There are commentators who claim “we have run out of regulatory power”, and that it is a necessity to deal with ubiquitous pathogens in the context of a regulatory system that has exhausted all possible options. I couldn’t disagree more with this idea that we’ve run out of regulatory power. The XL Foods recall didn’t take place because we’re at the end of our regulatory rope; it happened because both the CFIA and XL Foods dropped the ball. There is room to improve food safety regulation, the decision is whether that is something that the government wants to do. Claims that we’ve run out of regulatory power is really a disguised claim to shunt responsibility for food safety away from government.

Further to my point, recent changes made by Walmart to reduce the presence of Salmonella and Campylobacter on their chicken have been fairly effective. There is room to improve food safety without irradiation, and Walmart has done it on its own – not in order to comply with direct government regulations. This isn’t to suggest we forbid irradiation, just that there is room to improve food safety upstream given the will to do so, and such improvements can limit how heavily we lean on irradiation as a final kill step. The NFU also point out that while irradiation is permitted in the United States, there have nevertheless been no shortage of outbreaks attributed to pathogen-contaminated beef. Were it to become a crutch it may not be the most reliable.

If Canada’s food safety system hasn’t shown itself to be so easily fallible, and if industry didn’t seem to capable of flouting their commitment to it, I might feel differently. As it stands we are clearly not at the end of the regulatory rope. When Canada’s largest beef processor fails to comply to existing food safety requirements and persistently fails to address corrective action requests from the CFIA who then does nothing to intervene, the idea of irradiation becoming a crutch doesn’t seem too far fetched.

What I do think is that irradiation should be available as a tool in a company’s food safety toolbox. If irradiation can contribute to the reduction of foodborne illness outbreaks and wasteful food recalls, then I think the benefits outweigh the costs. That said, my support is qualified. Any allowance of irradiation needs to coincide with more robust regulation, monitoring, and enforcement. It behooves regulators to demonstrate they can compel those they regulate to make improvements. Walmart has shown that companies have room to improve without relying on radiation, and regulators need to push the rest of the industry to follow suit. (For a similar sentiment, see Coral Beach’s recent article on Food Safety news)

Overall, I don’t think that irradiation poses the economic threat that the NFU assumes it will. Strawman. While I advocate for consumer transparency, I think the NFU’s concerns about the safety of institutional eaters is overblown. However, I share the NFU’s fear of a lack of effort on the part of industry and its regulators to maximize the effectiveness of existing options. Industry has demonstrated how much more can be done to improve food safety. There are a lot of unanswered questions about what irradiation might mean for the beef industry, but I don’t believe it is the threat it is being made out to be. In fact, I suspect any impact, positive or negative, will be disappointingly modest.

Stericycle this month published their Q2 report on product recalls in the United States, which they’ve called “Tainted Table”. I love these quarterly reports from Stericycle, and I think this one has some interesting bits worth highlighting.

In Q2 there were over 80 times more FDA recalls (measured in “units”) and 45 times more USDA recalls (measured in pounds) compared to Q1. The USDA recalled 1.1 million pounds in Q1, and a whopping 53.3 million pounds in Q2. (I always appreciated the USDA’s use of mass compared to the FDA’s reliance on “units”).

Of the FDA recalls, there were more pathogen-related recalls than in any of the past two years. This could likely be a result of increased testing and a large number of recalls linked to past outbreaks thanks to whole genome sequencing.

The report also highlights the role played by the “multiplier effect”, which I have written about here. Their example of the sunflower seed recalls that resulted in over 600,000 units of product being recalled highlights this multiplier effect well. Not only were many brands of plain-ol’ sunflower seeds affected, so were cereals, granola bars, and store-prepared salads. It was a mess. It shows one of the consequences of the immense consolidation and centralization of certain aspects of the food industry as well as just how serious “ingredient” recalls can be.

More recently, and not covered by the report, the recent E. coli contaminated flour recalls (see here, here, here, here, and here, and the original recall here) demonstrates this phenomenon well. The spread of this recall across so many different brands and products is quite remarkable. The original recall took place on July 1, and here we are 6 weeks later and we are still seeing recalls related to this flour.

It’s shaping up to be an interesting year for recalls in the United States. Looking forward to Q3!