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.