Food Companies Should Plan for Outbreak Response Before it Occurs, Act Quickly to Shape Outcome

A longtime industry colleague and friend recently told me it was the things he couldn’t see that he feared most. Lurking somewhere in his processing equipment or on a product sitting in a sales cooler, there are a few colonies of pathogenic bacteria waiting to wreak havoc in our business and lives.

Over the past decade, foodborne illness outbreak surveillance has improved significantly. As a result of improved surveillance, more illnesses are being identified, and more outbreaks are being reported. By extension, many of these outbreaks are being associated with an increasing number of food products, ranging from waffles to cookie dough, and more companies are being affected. While these improvements have had an overall positive impact on public health, they have also had a tremendous—and sometimes less than positive—impact on the food industry.

Indeed, thousands of “spotlights” are continuously crisscrossing the nation, searching for problems in our food products. They take the form of verification testing by processors, incoming product testing by customers, regulatory sampling by federal inspectors, and patient isolate testing ordered by concerned physicians. With such vast resources dedicated to looking for problems in today’s food, the question is not if your product will be caught in the spotlight, but when.

Assuming contamination is inevitable, and assuming that it will be found once a product leaves your control, all food companies should begin planning for how they will react when an outbreak or recall occurs.

Fortunately, with planning, a company can begin limiting the fallout from an outbreak-related crisis the moment it learns about a potential problem. After learning that its product may be associated with an emerging outbreak, any company should immediately and directly engage federal, state, and local health investigators. Proactive engagement is essential to (1) quickly identify and contain the problem; (2) help solve the immediate public health issue; and (3) ensure that the investigation is conducted appropriately. These steps are critical for numerous reasons.

First, in the food industry, we know that the potential downstream consequences of any upstream food safety problems can also be catastrophic. Consider the processing of ready-to-eat food products. If a single raw material supplier unknowingly introduces contaminated ingredients into the supply stream, each of the downstream products manufactured with those ingredients will be affected. When product contamination is suspected, it is critical to identify all potentially affected lots and notify all customers to contain all affected product. Doing so will help alleviate the impact of any possible contamination, while demonstrating to investigators that your company is committed to protecting the public. (In addition to being the “right thing” to do, this will also pay significant dividends in your dealings with the regulators following the recall.)

In addition, recognize that public health officials are increasingly being asked to investigate and solve a growing number of overlapping outbreaks. With limited resources to conduct investigations properly and methodically, federal and state investigators will sometimes embrace incorrect assumptions about the source of an outbreak. And, whether it happens because of inadequate resources, time limitations, or lack of individual expertise, once an incorrect hypothesis is adopted, it becomes very difficult for public health officials to admit possible errors, set aside potential bias, and identify alternative sources.

The moment any association is suspected, a food company should (1) engage public health officials to address their immediate questions and concerns; (2) learn as much as possible about the status, scope, and direction of the investigation; (3) aggressively identify the full range of potential causes and alternative sources; (4) politely but forcibly challenge (where issues are identified) developing assumptions and hypotheses; and (5) persuasively demonstrate, where possible, that the company’s product is not likely involved. Investigators tend to be more open and thorough when all parties are actively engaged and at least someone—even if only emblematically—is looking over their shoulders.

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