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Imported Fish and Produce Becoming Increasingly Risky

Between the years 2000 and 2014, the number of outbreaks associated with a reported food dropped by more than half – from nearly 900 in a single year to fewer than 400. Yet in this same time period the number of outbreaks with an imported food went in the opposite direction, more than doubling – with the greatest increase being seen since 2011. This data, as reported in CDC’s Outbreaks of Disease Associated with Food Imported into the United States, 1996–2014, published February 15, pose further concern in the fact that the products most commonly imported into the U.S. are those which bear the greatest risk: fish and produce. (See chart, Outbreaks Caused by Imported Foods.) While consideration must be given to the fact that the proportion of food that is imported has increased steadily over the last two decades, the numbers are still significant because outbreaks associated with imported foods represent an increasing proportion of all foodborne disease outbreaks where a food was implicated and reported. Thus, the data show an alarming trend – particularly as we delve further into the specifics of the report to find that the imported fish and produce not only bear the greatest risk, they are, indeed, associated with the most outbreaks. According to CDC, approximately 19% of food consumed in the United States is imported: 97% of our fish and shellfish. 50% of fresh fruits. 20% of fresh vegetables. At the same time: Fish and shellfish were responsible for 55% of outbreaks and 11% of outbreak-associated illnesses. Produce was responsible for 33% of outbreaks and 84% of outbreak-associated illnesses. 25% of the outbreaks from imported foods were multistate. As to agents, illnesses and countries of origination: The most common agents reported in outbreaks associated with imported foods were scombroid toxin and Salmonella. 77% of the Salmonella outbreaks were associated with produce (including fruits, seeded vegetables, sprouts, nuts, seeds, spices and herbs). Most illnesses were associated with Salmonella and Cyclospora. With 31 countries implicated and 91% of outbreaks able to be sourced back: 65% of implicated fish and shellfish were imported from Asia. 64% of implicated produce originated was imported from Latin America and the Caribbean, along with all but 1 outbreak associated with dairy products. The top countries implicated were Mexico (42 outbreaks); Indonesia (17) and Canada (11). Among the conclusions drawn by the CDC and FDA report authors were that the number of multistate outbreaks not only reflect the wide distribution of imported foods but also indicate the increased ability to detect and investigate outbreaks through systems such as PulseNet. However, the finding that the number of outbreaks for imported foods is increasing while that of domestic foods has decreased highlights the need to strengthen regional and global networks for outbreak detection and information sharing as well as the importance of having standard protocols for molecular characterization of isolates and systems for rapid traceability of implicated foods to their source. With FDA having authority over 80% of all foods, and only a small portion of FDA-regulated foods inspected upon entry to the U.S., it should come as no surprise that nearly all the outbreaks involved foods under FDA jurisdiction. The data in this report clearly indicate two key factors. First, there is a greater relative risk for imported foods compared with domestic foods; second, the risks are heavily focused on FDA regulated foods. So where does this leave food companies and importers? These data set FDA up for greater focus on importers with regard to compliance with the Foreign Supplier Verification Program and for compliance with the supplier controls required as part of the Preventive Control rules. One clear exception is the exemption of fish from the PC rules. So, will this increase focus on seafood HACCP? Yes probably. Of course, the big unknown are the resources that FDA will have for focus on importers and seafood HACCP. But if you are reading this, and you are an importer of some of these higher risk products, then I suggest you pay close attention to current regulatory requirements, since, even with limited resources, FDA is being given a strong message of where to focus. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com

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