A recent survey from Dalhousie University conducted by Sylvain Charlebois and colleagues examined food recalls and food safety in Canada. While the study raises some important issues worthy of further investigation, I take issue with one area of concern cited by the study’s authors. The authors of the survey were troubled by their finding that most consumers did not feel they were among the “most responsible for ensuring food safety in Canada”, and that most consumers believed contamination generally took place before food reached their homes. Since cross-contamination in the home has been implicated in past foodborne illness outbreaks, one could conclude that consumers are not living up to their responsibility as guarantors of food safety. However, as I see it, placing primary responsibility for food safety on consumers is the troubling part for number of reasons.

First, it is important to disambiguate the location at which a foodborne hazard is introduced and where illness takes place. Of course most illness takes place in homes and restaurants since that is where food is typically consumed. However, this does not provide any indication of whether the product arrived at the home or restaurant contaminated or if it was contaminated during preparation. Illnesses take place where consumption occurs. Contamination can take place anywhere in the supply chain from farm to fork. Unless a consumer introduces a pathogen to otherwise uncontaminated food, the initial contamination that made cross-contamination possible had to have originated before reaching the consumer’s kitchen.

The evidence of where, on average, pathogenic contamination takes place, is not especially clear (see for example Jacob and Powell 2008). At a minimum, what little we do know suggests there is no strong evidence to support a claim that the majority of contamination takes place in the home. But since contamination originating in the home would not necessitate a recall, we can reasonably assume that any pathogen-related recall must be due to contamination that took place prior to the consumer. This is an issue currently plaguing frozen breaded chicken products, which until recently had been largely written off as a problem of consumer mis-handling.

Second, a consumer has no realistic way of personally assessing or verifying the activities of that supply chain. A consumer has rather limited agency in this regard. Instead, a consumer has to mostly to go on trust, brand reputation, regulations, laws, labels, and certifications to make up for the opacity and impersonality of the modern food supply chain (and no, blockchain isn’t a great solution either). In contrast, when a food packer or processor wants to ensure the safety and quality of incoming ingredients, they will often perform audits of their supplier’s facility and perhaps their supplier’s suppliers. They may also specify contractually-binding minimum quality attributes and bacterial loads. The packer or processor may also do their own tests of incoming raw ingredients. Consumers simply do not have the privilige of other supply chain participants to audit and inspect their suppliers, nor do they likely have the resources and knowledge to perform microbiological tests on products they buy.

It would, for example, be mildly absurd to blame the consumer for watery and limp lettuce purchased at the supermarket because that lettuce was likely grown, harvested, and processed half a world away. Why then should a consumer be blamed if the same lettuce was contaminated with E. coli? The consumer has about as much control over the quality of lettuce as they do the pathogen load. It may even be the case that they have less control over the pathogen load, since limpness—unlike microbes—can conceivably be detected by a human without the aid of technology or highly specialized skills.

Third, using cross-contamination by consumers as justification for making them the primary responsible party suggests that providing contaminated food to consumers is only a problem when a consumer “mis-handles” the product (e.g., by handling it in such a way as to cause cross-contamination). This echoes the longstanding reluctance of the food industry to take responsibility for pathogen reduction (see for example the beef industry’s opposition to new E. coli regulations in the 90s and here). However, history has shown that food producers often can do more to reduce pathogens in their products. The poultry industry, for decades, resisted the idea that they could take steps that would reduce the presence of Salmonella in poultry on retail shelves. When Walmart began requiring that its poultry suppliers introduce greater pathogen controls in order to remain on the retailer’s shelves, industry complied, and indeed the percentage of products contaminated with detectable levels of Salmonella decreased from 17% to 4%.

Finally, hazards such as mislabelling or undeclared allergens—which account for the majority of food recalls—by definition occur upstream of the consumer, and are neither detectable nor remediable by the consumer. In this instance responsibility for avoiding an adverse reaction or anaphylaxis cannot possibly be placed on the shoulders of a consumer. If we are thinking about consumer responsibility and recalls, then the number one cause of recalls is well beyond the remit of consumers. If we want to stay within the domain of pathogen-related recalls, the water continues to be murky. The number one product category responsible for foodborne illness as of the last few years is fresh produce, which unlike meat which we often associate with microbial hazards, is almost exclusively consumed raw. This leaves very little opportunity for consumers to take any preventative measures whatsoever.

There is a massive disparity in agency and power between consumers and almost every other member of the supply chain. Consumers are not empowered to be guarantors of food safety. Placing primary responsiblity for food safety on the shoulders of consumers is akin to blaming a passenger for not preventing a plane crash caused by pilot error. Consumers do have an important role to play in preventing foodborne illness, but food safety is a shared responsibility, and focusing on consumers may distract from the many ways that industry and regulators could and should be doing better.