Recall These Thoughts
Inanity from Scott Lougheed, PhD

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!

A spat of spice recalls have taken place over the last few weeks in the United States.

The JM recall seems to be small, affecting only small amount of product from a Georgia farmers’ market. The Gel recall expanded considerably over time, from a single lot to several different brand labels and lots. The Oriental Packing Company has recalled a whopping 188.5 tons of the stuff. While there doesn’t appear to be any official statement to suggest a link between the two turmeric recalls, nor between the turmeric and the curry powder, it seems likely to me that there is a single common source for all of them. Turmeric frequently appears in large quantities in curry powder, in part because it’s a traditional ingredient in many Indian spice blends, but also because it is relatively cheap compared to other common Indian spices and can bulk up a curry powder nicely.

There are a couple of possible explanations for these elevated lead levels. Since most spices are sold wholesale by mass, the addition of a substance like lead oxide could be a way to add bulk and thus increase margins. This is similar to a comment made in a blog post at The Acheson Group (which has subsequently been removed) suggesting the possibility that the spat of spice recalls in 2014-2015 due to the presence of peanut powder was also economically motivated food fraud. Peanut powder and ground cumin look awfully similar after all. The addition of lead oxide is, in fact, an old habit of less-than-scrupulous spice millers for a good long time. If this turns out to be the cause of the current contamination, it’s a reminder that old food habits die hard.

Another possible explanation is that turmeric, which is a rhizome like ginger, could have taken up lead that had (naturally or unnaturally) been present in the soil. The ability for plants to take up lead has been documented by the University of Minnesota.

Either way, a couple tons of turmeric and cumin powder are headed towards destruction. I wouldn’t be surprised if we see a recall in Canada for turmeric or turmeric-based products in the coming weeks, similar to the sprawl of the nut-allergen cumin last year.

Lidl has recalled some of its yoghurt and peanuts because the packets don't warn customers that they contain milk and nuts.

Allergen labels are immensely important in ensuring the safety of customers with allergies. No doubt there needs to be close monitoring to ensure that consumers with allergies can shop with confidence. Customers with allergies aren’t dummies. This recall is borderline insulting.

Either that or it’s a scary sign of just how far processed food has come and that consumers have now been trained to know that just because the label says the product is “nuts and yogurt” doesn’t mean it contains either of those things.

All of the recalled ground beef was produced on July 26. They all have the establishment number “EST. 337” printed inside the USDA mark or on the product packaging seam.

Note that this 30 tons of beef in a single day of production. I have always been curious about the impact of production scale on the size of food recalls. Being able to narrow down the affected product to a specific day of production – or detect an issue and resolve it within a day – is fairly remarkable. However, if a single day of production is 30 tons of product, perhaps we need to narrow this window even further. Food processors are stunningly efficient at making massive quantities of product very quickly. It seems to me that there is a need to step up detection and traceability to keep pace.

Regarding the recent signing of the DARK act:

In fact, according to Obama’s own Food and Drug Administration (FDA), if enacted, the bill would exempt most current GMO foods from being labeled at all. The FDA further commented that it “may be difficult” for any GMO food to qualify for labeling under the bill. And even for any GE foods that might be covered, the bill allows for food to be “labeled” through a digital system of QR codes that can only be accessed if the consumer has a smart phone and reliable internet connectivity.

Center for Food Safety

This is a shame. Regardless of how you feel about GMOs, denying choice and transparency is a bad move. When it comes down to it, no regulation is sometimes better than bad regulation, as it stands this flaccid new regulation just consumes resources with no returns.

My regular reader will have noticed recent change to the appearance of Recall These Thoughts. For the second time in one year I’ve changed blog platforms. You, dear reader, will likely remember the move away from Squarespace over to Wordpress. This was motivated as both a cost-saving measure and a way to gain a bit of additional flexibility. I love Squarespace, but a big part of having a blog for me is having a little toy to tinker with. Wordpress offered a bit more of that type of freedom.

But Wordpress has its downsides. For one, it was very difficult to modify templates. The CSS was was already condensed and extremely complex – thus largely inscrutable. This made some template modifications difficult to make. Moreover, if you neglected to make a child template prior to making all of your changes (as I did) and an update is issued to your template, you’re in for a world of hurt.

I also found the backend to be “weighty”. There was a lot of stuff back there, a lot of things I didn’t need. The editor was a bit fussy, it didn’t always handle markdown very well, and it really just offered more than I needed.

Overall Wordpress was just too much and not really that fun to play with. It is a powerful and popular platform, but it didn’t offer me the type of tinkering I really yearned for. I wanted something a little simpler, a little faster, a little more fun to play with for this amateur coder.

I had tried to install Jekyll about a year ago. Jekyll is a Ruby and Liquid based static website generator. Having no familiarity with Ruby and only the most basic competence with the command line, I got hung up and frustrated with Jekyll.

Fast forward about a year. During an evening of being unable to sleep I poked around and worked on installing Jekyll once more. Sure enough I was able to get it installed, located a template that would make a good foundation for my site, and off I went learning and tweaking. At this point things moved quickly. While unfamiliar with SASS as a styling language, it’s a lot like CSS with which I am extremely familiar. I found my way around the single CSS file quickly and learned with little trouble the classes that were used in the various layout files.

I also got the hang of the Liquid variables that Jekyll uses, making theme modification even easier. I even went ahead and created a few conditional loops to auto-detect when I make a “linked list” style post and have it format that correctly and offer a permalink.

I used Ben Balter’s Jekyll Exporter Wordpress plugin to export my posts from Wordpress, which it did with amazing accuracy. There were a few things that needed tidying that got a bit messed up converting from HTML to markdown, but most of that could be accomplished using find and replace. Beyond that I had all my old posts locked and loaded, my theme thoroughly customized, and was ready to pull the trigger. I synced the built site from my development directory to my host, and the new site launched with only a couple hitches.

So what is the payoff? The biggest payoff is, perhaps, that the site loads about 4X faster and is about 1/8th the size. This is important for me because I have extremely cheap hosting, and I value the experience of my one regular reader.

The other payoff is portability. My posts are written in markdown and live in a directory on my computer. They are not in an SQL database with a bunch of auto-generated HTML. While there are ways to write and backup posts for Wordpress, Jekyll’s workflow has easy writing, local storage, and portability built into the process.

There is still work to be done, for sure. I have to migrate some more content over, fix a few posts that broke way back during the Squarespace migration, and I have a lot of little styling tweaks. But overall I’m very pleased with Jekyll and I look forward to making lots more content to enjoy.

Jesse Jackson, Centre for Food Safety writes:

In a letter sent directly to the president the renowned civil rights activist called attention to the “serious inequities [in the] GMO labeling legislation.” The bill would allow companies to use QR codes in place of on-package labeling to disclose product information. In the letter Jackson points out the discriminatory nature of such a labeling system;

“100,000,000 Americans, most of them poor, people of color and elderly either do not own a smart phone or an iPhone to scan the QR code or live in an area of poor internet connectivity….There are serious questions of discrimination presented here and unresolved matters of equal protection of the law. I am asking you to veto this bill and to send it back to Congress with instructions to correct this fatal flaw.”

There are so many issues with using QR codes to convey something a logo can do in the same space. The obvious classism, racism, and ageism are just the start. I’m a young, white, educated iPhone owner and I can’t be troubled to pull my phone out and scan every QR code on the shelf.

I think the emerging technology around QR codes on products to facilitate supply chain transparency, country of origin, and other detailed information about the product is a valuable pursuit and is very different from GMO disclosure. In most cases the information provided to the consumer by scanning these QR codes is considerably more detailed, including, as is the case of VG Meats sold at Longos in Toronto, measures of tenderness, recipes, and information about the specific cut of meat. This information is valuable to interested consumers and far exceeds what can be put on a table.

A GMO label, in contrast, is intended to allow the consumer to know whether that product contains GMO ingredients or not, just like the irradiation labelling that is mandatory on all irradiated products.

Yes, GMO and irradiation are complex, and the nuance can’t easily or accurately be conveyed by a mere indicator label. The reality is many people have already formed strong opinions about GMOs and even the well-crafted marketing that would inevitably be linked to by those QR codes is unlikely to change a consumer’s mind.

Of course, the real issue is a fear among manufacturers that explicit GMO labels will deter consumers from purchasing those products, opting instead for those without GMO labels (where an non-GMO alternative exists). This is a very real concern, but I don’t think hiding behind QR codes is the right approach No matter how you slice it this is a weasel tactic that is deceitful and ultimately undermines everything GMO labeling is supposed to facilitate. Just label it properly.

Health Canada recently announced a regulatory initiative which would allow beef processors to sell irradiated ground beef. I was invited to speak to Calgary’s Kingkade and Breakenridge on NewsTalk 770 about what this initiative might mean. The interview went well, and Rob and Roger are both thoughtful and insightful radio hosts, but there was a lot that didn’t get covered. I’ll expand on some of those thoughts here.

In 2002 Health Canada (not for the first time) put forward an initiative to allow for the sale of irradiated ground beef, but that was abandoned as a result of resounding negative feedback (from consumers, the public, or “activists” depending on your perspective). Between then and now, a considerable amount has changed. Landmark food safety events such as the deadly Maple Leaf Listeriosis outbreak in 2008 and XL Foods E. coli beef recall in 2012, which remains Canada’s largest – among numerous other high-profile recalls and outbreaks – have coincided with a growing public awareness of food safety and other issues related to food safety and provenance. More than ever, consumers want to know about where their food comes from, how it’s made, and most importantly that it is safe (e.g., Lockie 2002; Busa and Garder 2014). Indeed, the Canadian Cattlemen’s Association is confident that the public (or at least those outspoken members of the public) have changed course. Regardless of the changes in the last 15 years, there is doubt about whether or not Health Canada’s proposal will be successful. Putting aside the perceived risks, the court of public opinion is often a hard sell, and understandably so. The circumstances in which we encounter radiation are almost universally negative: cancer treatment, x-rays, air travel, nuclear disasters, and World War II to name a few.

Despite what critics say, the scientific evidence suggests that nutrient loss and toxics production is limited or non-existent, which is considerably less than what cooking itself would introduce. Moreover, consumers also seem to forget that their pre-washed salads, sprouts, and peeled carrots are treated with chlorine, while other products are treated with ammonia (let’s also not forget the many instances in which lye is used in very traditional foods like hominy, bagels, and pretzels).

Even if we accept that there is a small health risk associated with consuming irradiated beef, as many have pointed out, the risk from foodborne pathogens is far greater and far more immediate. As I said in my interview, if you want to avoid toxins and carcinogens, you’d best stop eating cooked meat altogether.

Health Canada will require beef producers to label irradiated products. I think this is a critical part of the proposal that is non-optional. Absolutely consumers should have the ability to identify irradiated food, and anything that enhances transparency in the food system more generally should be pursued. However, this will be hard for industry who have to convince consumers to buy the meat with the irradiated label, which may well be sitting next to a tray of meat that was not irradiated. It’s a difficult set of choices from a consumer’s standpoint: did something happen to the meat that required it to be irradiated? The non-irradiated stuff is fine as long as I cook it correctly (where’s my meat thermometer again?). Evidence of this consumer ambivalence is demonstrated by Costco in the US, where irradiated beef has not sold well. As Craig Wilson, Costco Food Safety Chief suggests of irradiated beef: “Mom wouldn’t buy it”, even if the risk from foodborne illness is in fact higher, and more dire.

Ultimately, while industry is one of the primary supporters of irradiation, I am not sure how quickly it will be taken up without a coordinated, industry-wide effort. Who in industry will have the guts to be the first on the shelf with the new irradiation label? How will industry and the Canadian government ensure there isn’t an “irradiated ghetto”? How do we prevent competition and marketing based on (non-)irradiation, such as the development of a premium niche of non-irradiated beef? I suspect we’ll see either an irradiated ghetto as demonstrated by Costco in the US, or a non-irradiated premium niche. Either way the beef industry has a marketing challenge on its hands here, should irradiation be permitted in Canada.

The industry challenges aside, I look critically, though not dismissively, on the prospect of irradiation. Numerous commentators, including Rick Holley, food scientist at University of Winnipeg suggests that we’ve run out of regulatory power and that because “pathogen contamination in processing plants cannot be prevented…if we really want to prevent outbreaks, we have to look at expanded use of irradiation”. However, he also suggests that irradiation will not protect against industry incompetence. I don’t entirely disagree with Holley and other commentators who seem to suggest that XL Foods is a shining example of why we need irradiation, that it might have prevented or limited the (already rather small) outbreak, but there’s a lapse in logic. A major contributing factor to the XL Foods recall was a “weak food safety culture” and that ultimately “it was all preventable”. The company failed to clean its equipment, maintain its plant, respond to CFIA corrective action requests, and actively practice its recall plan.

The conclusion of the independent reviewers of the XL Foods incident runs contrary to many commentators’ primary arguments in favour of radiation, using precisely the same case as evidence. I don’t buy the idea that we’ve run out of regulatory tricks to reduce foodborne pathogens upstream. 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. Based on the commentary from supporters like Holley, irradiation would have either done nothing at all (being incapable of overcoming industry incompetence, as he argues), or it would have allowed one or both to get away with a (rather protracted) moment of weakness, potentially leaving the profligate issues at the XL Foods plant to remain unresolved.

I hesitate to outright reject irradiation of ground beef and other products. Foodborne illness is a significant burden on the public health system of Canada and can profoundly impact the lives of victims. In line with my own research on food waste, it is also a non-trivial source of food waste. XL Foods alone resulted in over 5.5 million kilograms of beef being landfilled, which is equivalent to approximately 12,000 cattle. Just this week, General Mills announced that it is recalling over 10 million pounds of flour in the US due to potential E. coli contamination. There are over 300 recalls per year in Canada and over 1000 per year in the United States. If irradiation could prevent even a few of these recalls, it would be a significant improvement in terms of public health and food waste. For example, as Holley suggests (alas, we do not disagree on everything!), irradiating poultry alone would reduce foodborne illness in Canada by 25% and an inestimable quantity of recalled food from being destroyed.

Taken together, I don’t buy the popular criticisms of irradiation, but I think we need proceed with caution. I think irradiation is a reasonable compliment to a holistic farm to fork food safety system that includes regulators with teeth and clout working with competent food producers and processors who feel those teeth when they step out of line. It was the absence of this dynamic that contributed to the XL Foods recall, which has become the poster child for supporters of irradiation. As Health Canada moves forward with the public consultation over irradiating ground beef, let’s take a reasoned and critical approach without knee-jerk reactions that dismiss science, or conversely dismiss the concerns of the public (or activists therein). Most importantly, let’s take this as an opportunity to examine how irradiation can fit in to a comprehensive food safety system while we make the system as a whole stronger, because there’s plenty of room to improve.

Okay, so perhaps not precisely the month of May, but starting in late April there’s been a spat of recalls attributable to Listeria in Canada and the United States. Looking at the CFIA recall listings for the first 10 days of May:

And if we look into the last week of April we also get:

Needless to say, for the last two weeks Listeria has had a field day in Canada. The United States is not exempt! In what Juska et al (2003) refer to as the “amplification” of food safety threats, or what Stericycle call the “multiplier effect”, listeria contamination from SunOpta Inc., a sunflower seed supplier has resulted in a massive cascade of recalls across the United States.

This series of recalls includes Sunflower Seed Snacks, trail mix, protein bars, Brown and Haley Chocolate snacks, and perhaps most stunningly 17 tons of Trader Joe’s salad.

Similarly, frozen vegetables from CRF Foods in Pasco Washington were recalled on April 23rd and subsequently expanded on May 2 to include over 42 brands and 358 products (notably, just in time for Listeria Month!)

It is rather stunning how far an error at a single supplier can reach in the contemporary food system. It almost seems as if we are reaching a level of consolidation and concentration in which the industry is too big to fail. The last two weeks has seen tens of tons of food pulled from the market and destroyed as a result of mistakes made by only a few companies… and this is only the beginning of Listeria Month!