Another week brings us face to face with another recall in the food industry. Just as we were starting to recover from scandals involving potentially contaminated cookie dough (Listeria monocytogenes, Aspen Hills, Inc.), popcorn chicken (‘extraneous materials,’ Tyson Foods) and the perennially risky preserved lemons (undeclared sulphites, Roland Foods, LLC) another case of product contamination hits the headlines. And this time it impacts a very discerning segment of the consumer market: man’s best friend, the dog.
On October 7th, Mars Petcare US announced a voluntary recall of its CESAR® Classics Filet Mignon Flavor dog food due to a choking hazard.(1) Readily identifiable with its bold purple branding and image of a perky young Westie on the lid, this CESAR® Classics wet food is retailed both in individual serving trays and as part of multi-packs. But certain lot numbers had a secret extra ingredient, one that no pet owner wants to find in their dog chow – small pieces of hard white plastic.
Now, although dog lovers will be aware that several popular chew toys are plastic-based (the ubiquitous Nylabone being one), having plastic debris in a serving of wet food is certainly not ideal. The whole CESAR® Classics range, with its 3.5oz portion size, is marketed to small breed dogs and, unlike the pieces ‘no larger than a small grain of rice’ that can pass through an animal should they be ingested from a Nylabone-style chew, the plastic pieces in question may choke a dog, lodge in their mouth, throat or gums, or fracture teeth. Best case scenario, an unexpected and expensive visit to the veterinarian’s office; worst case scenario, death.
So how was this allowed to happen? According to Mars Petcare US the plastic entered the food during the production process, but the details of how that actually occurred remain sketchy. And to some extent, the provenance of the materials is also irrelevant. According to the Food and Drug Administration (FDA) the manufacturing of pet food is governed by the same strict regulations that pertain to that of human food. Per the Federal Food, Drug, and Cosmetic Act (FFDCA) all animal food must be ‘safe to eat, produced under sanitary conditions, contain no harmful substances, and be truthfully labeled’ which patently these recalled batches of CESAR® Classics are not.(2) Somewhere along the line, the production facility either failed to abide by their hazard analysis and critical control points (HACCP) or had none at all. HACCP? Let’s take a closer look at what that means…
After passage of the Food Safety Modernization Act (FSMA) in 2010 companies manufacturing food for public consumption – whether those consumers are human or animal – are required to have in place a raft of safety measures, codified into written, risk-based hazard control protocols – the so-called Hazard Analysis and Critical Control Points, or HACCP. Although intended for a variety of industries, the broad scope of the mandate vis à vis the food industry means that every part of the manufacturing process must be assessed – from the raw materials/ingredients to the types of equipment used. Emphasis should also be placed on the danger of several types of contamination – bacterial, microbial, fungal, or viral – and any physical hazards must also be detailed. These hazards would include, we suspect, the albeit accidental inclusion of small pieces of plastic in the finished product.
So in its first instance, HACCP covers the basics: ‘buildings, equipment, layout, process flow, vendor qualification, personal hygiene, zoning, pest control, sanitation, environmental monitoring, training, document control, etc.’(4)
But, on the broader scale, the guidelines go further. Even when the product is complete, the conditions under which it is stored and the avenues of distribution should be reviewed with an eye to assessing potential hazards and their effects upon consumers. The impacts should include both primary issues such as sickness or injury and secondary effects upon the company and the market. Each potential hazard should be cataloged, all risks assessed, and the impacts delineated, with intended countermeasures and mitigation efforts also laid out. The ultimate aim of the written HACCP is to ascertain which hazards are critical and which control measures are to be deemed ‘critical control points’ and to prioritize them.
This seems like a lot of regulation to get through but the HACCP are international standards and are absolutely effective when correctly applied. But according to David Rosenblatt, writer for PetfoodIndustry.com, the true power of HACCP lies in understanding its limitations.(3) Used by international partners such as the British Retail Consortium, the leading trade association for retailers in the United Kingdom, and the Safe Quality Foods Institute, a certification body for food safety verification, the HACCP system is simply a set of guidelines that ensures adequate training and the correct use of resources. It allows managers to determine the most efficient and cost effective allocation of personnel, time, and monitoring systems and, in the event of a critical product failure, such as the CESAR® Classics issue, the ultimate fate of any contaminated product. But it does not prevent failure from happening.
As is so often the case with questions of contamination control, sterility or cleanliness, protocols are great but human error remains the weakest part of any chain. Any set of standards – whether they are the simplest of SOPs or something as complex as the HACCP – is only as good as those who follow or verify it. Having a protocol – even the most stringent, detailed, and exhaustive – is essentially meaningless unless an organization’s personnel are trained in its use and motivated to conform to it. In an ideal world scenario, all manufacturers would issue and uphold guidelines for the safety and purity of their product, if only because their consumers would expect no less. But we don’t live in ideal times and, in an organization where consumer safety is not top of the list of priorities, the potential for failure is ever present. Although we cannot know for sure, it is reasonable to suggest that Mars Petcare US, maker of CESAR® Classics Filet Mignon Flavor dog food, either did not have – or did not conform to – a strong HACCP program. Had they done so, they would have immediately known the provenance of the white plastic contaminants and could have rectified the problem sooner rather than later.
When it comes to our food supply, to keep ourselves and our best friends healthy we have to work hand in hand. Whether we are consumers or manufacturers, our safety is a shared responsibility and protecting it entails asking some tough questions. Does our chosen pet food manufacturer have an HACCP program? Do they have Sanitation Standard Operating Procedures (SSOPs) in place – and in writing – and are these guidelines being followed by trained employees? How would we even find out? How do we know about a company’s history of recalls or, conversely, their excellent track record of product safety?
At time of writing, one of the best sources of reference on official recalls and withdrawals is the FDA’s own website through which any interested party can sign up to receive alerts relating to food, drugs, tobacco, or even medical devices.(5) And it is a powerful and extensive resource. Whether for our own protection or to get a jump on your business competition, taking a moment to subscribe to the list could be the best protective measure you take today!
Do you have thoughts on HACCP? We’d love to hear them!