A research note that just appeared in the Journal of Food Protection (Vol. 82, No. 11, 2019, pages 1901-1905 and was co-authored by researchers at the University of Guelph and Dalhousie University) reported that between 2000 and 2017 a total of 10,432 products were recalled in Canada because of microbial contamination. Food safety risk is not establishment-size dependent. Some of the worst food-safety failures are attributable to small growers (e.g. E. coli) in sprouts in Europe and in cantaloupe in the U.S. This should come as no surprise as small operators frequently lack the financial resources and qualified personnel to develop and operate effective food safety plans. However, having the financial and technical resources only mitigates the risks of a recall.
All establishments face the same challenges when attempting to address their microbial hazards. These include identifying the potential microbial hazards in their ingredients and products, deciding on how, where and how often to test and, last but not least, doing it all cost-effectively.
Identifying and dealing with the hazards
Learning what microbial hazards are commonly associated with your operation is easier today because Health Canada, the CFIA, third-party labs and the U.S. FDA all provide this type of information. Once the microbial hazards are identified, one needs to decide what to test for because testing for all possible microbial hazards is neither practical nor cost-effective, what test methods to use, what and where to sample, how often to sample and where to have the samples tested.
Deciding what to test for
Narrowing down the list of which bugs to test for needs to be done carefully. Testing for the wrong bugs may give you good numbers but not any assurance that your product is safe. This is when an operator must rely on guidance from qualified company personnel, consultants and/or a third-party lab. IEH Laboratories & Consulting Group headquartered in Lake Forest Park, a suburb of Seattle, Wash. is one such third-party lab with considerable expertise in this matter. IEH operates labs across the U.S. and now has two in Western Canada. Mansour Samadapor, founder and CEO of IEH has seen cases where 20 to 60 per cent of the tests weren’t needed and what was really needed to manage risk was not being done. Some third-party labs, like IEH, may provide microbial-plan development consulting services at no charge.
In-house vs. third-party labs
If your operation has the physical space and qualified personnel, in-house testing can be more convenient and more economical than using a third-party lab. However, the tradeoffs are capacity, economies of scale (cost), technology, personnel expertise, reliability, accreditation and, more importantly, these days, liability. Even small third-party labs will have more testing capacity than most in-house labs and may be cost-competitive when the full cost of in-house testing is considered. Third-party labs will use newer equipment, which will be operated by highly trained personnel that are often dedicated to certain testing routines. Today, all larger third-party labs will be accredited by and compliant with either the ISO, Health Canada and/or the Standards Council of Canada standards for microbial laboratories. In the event of a recall due to microbial contamination, the operator takes on all of the liability if testing has been done by their in-house lab. When a third-party lab has been used the liability is usually shared.
As mentioned earlier, third-party labs benefit from economies of scale in many ways. Unfortunately, these cost benefits are rarely passed on to smaller operators with business volumes between $10,000 and $30,000 who often end up paying 15 to 40 per cent more than clients with business volumes over $100,000. However, as a small operator, the premium paid for testing may be a bargain if the third-party lab provides you with complimentary food-safety planning consulting services.
Small operators beware
My advice to small operators is that they should leverage all the help they can get to navigate through today’s complex and ever-changing food safety landscape.
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