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Monday, 11 July 2016

Will it be getting tougher to hide certain food safety failures & trends?

July 2016: United States Department of Agriculture Food Safety and Inspection Service (FSIS) Publishes its Establishment-Specific Data Release Strategic Plan

According to the published information, "This Plan was developed, at the recommendation of the National Research Council (NRC) and with input from the National Advisory Committee on Meat and Poultry Inspection (NACMPI), to provide FSIS with a framework under which to responsibly and effectively release establishment-level data collected by the Agency." Below is a sample of what to expect:
Ideally, companies should not find themselves listed at all if possible. Being listed more than once is certainly not good advertisement. Perhaps some companies will now begin to take the idea of fortification before certification a bit more seriously.

Friday, 8 July 2016

Food Industry Tools of the Trade Presentations: Invitation to Showcase Your Stuff

Do you provide any tool or system management aid for implementing any of these?:
  • Employee Training Programs or Systems
  • Operation Control Systems
  • Quality Control Systems
  •  Food Safety Management Systems
  • Traceability Software; 
  • Record-keeping/Documentation Management Systems
  • Supplier Management Systems
  • Testing Tools, Test Kits, Rapid Testing systems; etc.
Would you like to showcase what you have to industry guests and students in Food Science, Food Technology, Food Processing, Food Safety  and Quality Assurance who are about to enter the work force?
Would you like to do so without being charged a fee for presenting your solutions or services?
Add Your Name to the possible presenters list - Send Email

Wednesday, 6 July 2016

GCSE-FHP – Co-Chair (Healthcare Expertise)


#inspirehealthprotection: GCSE-Food & Health Protection is looking for a volunteer Co-Chair with a public health and/or healthcare background. This role is needed  to provide health sector perspectives in the Coalition forums, lead meaningful discussions about current challenges and solutions, and provide guidance as the Coalition introduces public health improvement initiatives worldwide.

If you would like to help the Coalition in this role, or you know someone who might be interested, please contact the GCSE-FHP Team via email at: gcse@afisservices.com  or you could go to Contact Us. 

Saturday, 2 July 2016

FDA Says: "Raw Dough's a Raw Deal. . . "


General Mills Flour Recall
Original media release on May 31 

FDA Notice: For Immediate Release July 1, 2016

General Mills continues to collaborate with health officials to investigate a multistate outbreak of E. coli O121, and is expanding its recall of Gold Medal flour, Wondra flour, and Signature Kitchens flour to include flour made earlier in the fall that may still be in consumers’ pantries.

Products Reported to have been affected to date: 



Friday, 1 July 2016

GMO & Other Label Declarations - Compelling, Conflicting and Competing Realities


Increasing Volume of Mandatory Label Information but Insufficient Space on Labels

With reference to the draft GMO bill released June 23, 2016 by Senate Agriculture Committee Chairman Pat Roberts (R-Kan.) and committee ranking member Debbie Stabenow (D-Mich.), Gillam states:
 “. . . under the law now proposed, food companies could avoid any mention of genetic engineering on their packages and “disclose” GMO ingredients through digital codes rather than on-package language. Consumers would be directed to “scan here for more food information” with a smartphone to find information about the food they want to buy. Another option would allow food companies to provide a phone number along with language that states “call for more food information.”
Gillam, C. (2016, June 27). For GMO Labeling Advocates, It Doesn’t Get Much Darker Than This. Retrieved June 30, 2016, from http://www.cornucopia.org/2016/06/gmo-labeling-advocates-doesnt-get-much-darker/
Different Rules from Different Parties Competing for Available Label Space:
In its response to the same proposed bill, the FDA said:
 “. . . Agriculture Department rules implementing the bill may compete with the FDA's own required labels for space on small packages.”
Wooten, C. (2016, June 30). FDA Critical of GMO Bill in Comments to Lawmakers. Retrieved June 30, 2016, from http://www.bna.com/fda-critical-gmo-n57982076308/
Label Claims:
Label claims (usually of the advertisement variety) that product manufacturers often place on labels also compete against mandatory declarations for the label space available. Due to the advertisement nature of claims, they are also made more prominent in contrast to mandatory declarations that tend to be in finer prints where complete transparency is not the governing ideal.
Possible Solution:
A solution to the quagmire could start with an understanding of a regulatory definition of “Label” and “Labelling”, using the examples provided in the United States Code of Federal Regulations (CFR) definitions. According to these definitions:
The term "label" means a display of written, printed, or graphic matter upon the immediate container of any article; and a requirement made by or under authority of this chapter that any word, statement, or other information appear on the label shall not be considered to be complied with unless such word, statement, or other information also appears on the outside container or wrapper, if any there be, of the retail package of such article, or is easily legible through the outside container or wrapper.
The term "immediate container" does not include package liners.
The term "labeling" means all labels and other written, printed, or graphic matter (1) upon any article or any of its containers or wrappers, or (2) accompanying such article.
If an article is alleged to be misbranded because the labeling or advertising is misleading, then in determining whether the labeling or advertising is misleading there shall be taken into account (among other things) not only representations made or suggested by statement, word, design, device, or any combination thereof, but also the extent to which the labeling or advertising fails to reveal facts material in the light of such representations or material with respect to consequences which may result from the use of the article to which the labeling or advertising relates under the conditions of use prescribed in the labeling or advertising thereof or under such conditions of use as are customary or usual.
U.S. Code of Federal Regulations, Title 21-Food and Drugs (21 USC 321: Chapter 9-Federal Food, Drug, And Cosmetic Act Subchapter II, [§321. Definitions; Generally, Parts k, l, m, n & o] (n.d.). Retrieved July 1, 2016, from http://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title21-section321&num=0&edition=prelim
Complete transparency in providing full disclosure of product information requires the use of all avenues available such as provisions that align with the US-CFR definition of “labeling” with emphasis on “accompanying such article”. Full product information disclosure could be provided on the "Label" that is affixed to the product or  with "Labeling" that accompanies the food product. For example, labeling that accompanies the product or is readily accessible could provide additional information for a GMO label declaration that merely states: "Partially Produced with Genetic Engineering" with no details about how much "partially" means, or what genetic engineering methods and materials were involved, etc. This calls for voluntary and complete transparency. Yet, even the most complete transparency is not enough. 

Even Complete Transparency is Short of the Goal:
Where the sense of moral obligation is lacking transparency means nothing. A food business may be fully transparent in declaring what could harm consumers and simply leave the consumers, some of whom may be addicted to whatever is being advertised, to make "wise" choices. This is morally and socially reprehensible. A morally and socially responsible food business (if the desire is genuine) would seek to sell food that does not harm consumers. Such a business would engage in product research and development that renders otherwise harmful food harmless. Given all of the advances in food science, this is not an impossible suggestion. Through good research and product development, foods that are known to be harmful (and often addictive) could at least have their harmful effects minimized.   

The real problem with food labelling is not the absence of law; but the lack of (genuine) care for the consumer. Hence calling for new laws is not the most efficient focus for the "Just Label It" advocacy. Companies that do not care will find ways to dodge both the law and the advocates. The " "Partially Produced with Genetic Engineering" declaration on some labels is a very good example of this type of law-dodging with pretentious transparency.
The ideas of scanning product bar codes for more information and the provision of readily accessible phone numbers for more product information as described in the article by Gillan are also good suggestions. Some of the challenges with these suggestions include the likely reluctance on the part of consumers to read through large volumes of information or make the call. However, there is good news: Those consumers and advocates who care enough, or those consumers who, due to actual health concerns would want to know the full details, would appreciate the complete and readily accessible provision of information. All such information is of course subject to the "misbranding" or "misleading" information clause. 
All of these suggestions require the development and implementation of morally responsible strategies. Those food businesses that will seek to exceed expectations with their labeling strategies are more likely to gain and retain the confidence of consumers as well as that of "label transparency" and consumer protection advocates. Everyone benefits.

Recommended Reading:
Case Study: GMO Labeling – A Conflicting Dilemma Robert Chon Strong Northeastern University March 26, 2017

Posted by Felix Amiri
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Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.