From July 2009 through February 2010, at least 252 people were infected by Salmonella as a result of consuming Daniele, Inc. salami products that were manufactured using contaminated pepper.  The salami actually contained two kinds of pepper, red and black, both of which may have been contaminated.  Daniele purchased the contaminated pepper from two different companies:  Mincing Overseas Spice Company and Wholesome Spice Co, who have since initiated recalls of their contaminated products.  Ever since, multiple food companies from across the country have inititated their own recalls because they contained pepper from Mincing and Wholesome spice companies.  And just this week, two more companies, CH Guenther and Sons and Spice Barn, Inc., have recalled their pepper products as a result of Mincing’s outbreak/recall.

A recall can be a very effective tool to prevent a dangerous product from injuring or killing somebody.  But the effectiveness of the recall process depends on the speedy and free flow of information, and particularly in the context of a raw food item subject to further processing, also the ability to effectively track where the dangerous products are ("traceability"). 

If companies are just now recalling pepper products sold by Mincing and/or Wholesome spice companies, there is a big problem.  Here are a few thoughts on what the problem might be:

1.  Maybe Mincing and Wholesome spice companies thought their obligations ended after recalling their contaminated product.  Not so.  Whether it appears in a statute or not, recalling companies have an obligation not only to announce the recall but also to act aggressively in (a) identifying what retailers or other companies may have received the contaminated product (b) identifying what consumers may have purchased the contaminated product and (c) using all means necessary to make the important details of the recall (e.g. what products are included) known to retailers and consumers alike.

2.  Another possibility that we frequently see in recall situations is that the recalling company has simply taken too narrow of an approach to the scope of its recall.  In other words, its initial recall efforts did not include all contaminated products.  There is no solution to this problem that perfectly balances a business’s economic interests with public safety.  Clearly, a company cannot recall all of its products because to do so may mean corporate death.  But in the name of public health, it absolutely has to take a broad approach to to assessing what products are potentially implicated by the problem.  Thus, it is critical that food companies are able to accurately track which of its products are potentially implicated in a contamination problem.

What has happened to prompt these pepper recalls now, a month and a half after pepper was first suspected to be the source of infection in the major national outbreak linked to Daniele salami, is not yet publicly known.  But the fact that these recalls are happening so late in the game is absolutely unacceptable.  True, a late recall is better than no recall at all, but if a company is discharging the obligations described above and is serious about its efforts to protect the health of its customers, then information leading to such recalls has to be disseminated much faster. 

There was certainly a failure, probably many, somewhere along the line in this large outbreak and recall.  The questions that now remain unanswered are (1) how many more companies still have contaminated pepper products from Daniele, Overseas, and Wholesome spice companies in the marketplace, and (2) how many more people will fall ill as a result of the brutally slow flow of information critical to the protection of public health?