Steve Mills, a reporter with the Chicago Tribune and frequent contributor to the national food safety dialogue, wrote an excellent analysis of post-recall risks to consumer health for today’s edition of the Tribune.  The problem:  equal parts stores not getting recalled products off of shelves, manufacturers not being able to retrieve recalled product, and consumers not getting word that a product has been recalled. 

In addition to the ConAgra pot pie Salmonella outbreak in 2007, Mills highlights several major outbreaks and/or recalls that have occurred in the last several years:

In 2009, for instance, when the U.S. Department of Agriculture was involved in 59 recalls in which the amount of food sought and recovered was known, 56 came up short of the amount they identified as potentially tainted or produced at a time when factory controls were lax.

Two of those efforts highlight how far short recalls can fall. Last July a Denver processor announced a recall of more than 460,000 pounds of ground beef tied to a salmonella outbreak but recovered only 119,000 pounds. In October a New York processor announced a recall of 545,000 pounds of ground beef tied to an outbreak of E. coli; it recovered 795 pounds, according to the USDA.With today’s global distribution, this is a problem

To put a finer point on it, in the 2007 ConAgra pot pie salmonella outbreak that ultimately sickened over 400 people with confirmed illnesses, the CDC found that many, many people became ill after the recall was announced.  Here is a chart that shows how many became ill before and after the recall announcement:

Another situation that warrants mention is the 2010 ConAgra (actually, Marie Callendar’s brand) cheesy chicken and rice frozen entree Salmonella outbreak and recall.  In a June 2010 press release, the Oregon Department of Health announced concern that retailers had not yet removed all recalled product from store shelves.  The statement read:

Public health officials repeated today that an outbreak of salmonellosis has been linked to a boxed frozen entrée product manufactured by ConAgra Foods, Inc. under the Marie Callender label. The Cheesy Chicken & Rice item has been identified as the likely source of the outbreak, which has sickened at least 30 people in 15 states. Health officials worry that the entrée has not have been removed from grocery store shelves. Consumers may also still have the product in their freezers.

“We’re concerned that people and some retailers may not have gotten this information,” said Emilio DeBess, a senior epidemiologist at the Oregon Public Health Division. “This product was sold at grocery stores throughout Oregon and elsewhere. Consumers who have any of the Cheesy Chicken & Rice entrées in their home freezers need to throw them out or return them to the store. Retailers that have this product in their stores need to get them out of circulation immediately.

"Oregon Department of Agriculture inspectors checked in a number of stores on Tuesday and found the recalled product still available in a limited number of stores," DeBess added. "To protect consumers, store managers need to be vigilant about responding to recall notices."

As with many problems that we currently face in our food supply, this one is particularly potent in large part because of the nature of our production and distribution systems.  But despite the wider audience for these problems due to books like The Omnivore’s Dilemma and movies like Food, Inc., it’s a problem that’s not going away.  Bottom line is that manufacturers and retailers need to improve traceability and their dedication to the public health measure of actually making sure that information about recalls actually reaches consumers. 

Moreover, this is a discussion that is not only long overdue (see 2007 ConAgra pot pie outbreak), but has been raised multiple times before.  Phyllis Entis, at recently made several recommendations to address the problem:

1.  Provide a retail distribution list for all recalls. The list should include food service outlets, restaurants, cafés, and institutional kitchens – not just retail stores.

2.  Require retail stores to post a prominent recall notice on the store shelf or refrigerator/freezer where the recalled product is typically displayed. This is already done in some countries, including the United Kingdom.

3.  Fine retailers who ignore recall notices and neglect to remove recalled products from sale. This has been done in Australia.

4.  Post on FDA and USDA web sites in a timely fashion the reports for all inspections during which "significant violations" or "significant deviations" were noted (FDA does this selectively, based on its perception of the public’s interest in the results of specific inspections).

5.  Post on FDA and USDA web sites in a timely fashion all Warning Letters and other enforcement actions taken (FDA posts Warning Letters, although not always timely).

I would also add a report back requirement for retailers–i.e. that the retailer must report back to (agency/recalling company) within a certain number of days of receiving notice of a recall through dedicated channels, plus fines for each day that the retailer does not report back as required.  Something for the FDA to consider when the Food Safety Modernization Act is finally passed.