The Role of WDGPH in Food Product Recalls

Report to: Chair and members of the Board of Health

Meeting Date: September 7, 2016

Report Number: BH.01.SEP0716.R14

Prepared by: Katherine Paphitis, Public Health Inspector, CID

Approved by: Rob Thompson, Director, Health Protection

Submitted by: Dr. Nicola J. Mercer, MD, MBA, MPH, FRCPC
                           Medical Officer of Health & CEO

 

Recommendations

It is recommended that the Board of Health:

1. Receive this report for information.

Key Point(s)

  • Public health plays a key role in ensuring food safety.
  • Under the Public Health Standards; Food Safety Protocol (2016), the BOH is required to provide support for food product recalls and must be available to respond to complaints, outbreaks and recalls on a 24/7 basis.
  • Participation in food safety recalls assists in ensuring that timely and relevant food safety messaging is provided to operators, the public and institutions which is subsequently enforced during premise inspections.
  • Case management of reportable diseases and interviewing of cases using a standardized process ensures that consistent case information is collected and reported by public health staff, further assisting provincial and federal health authorities in the timely identification of and response to potential food safety threats.

Discussion

The Canadian Food Inspection Agency (CFIA) is the federal agency responsible for food safety at the national level in Canada. Where the CFIA suspects that a food item is contaminated, potentially unsafe for consumption or does not comply with relevant federal regulations, the CFIA will undertake a risk assessment and may ask that the company producing the affected item initiate a voluntary recall of the product from the market1.

Wellington-Dufferin-Guelph Public Health (WDGPH) Inspectors ensure that food premises and retailers within the health unit’s boundaries are informed of the recall and have removed the recalled product from public sale or service. WDGPH staff will also visit local retailers to confirm recalled products are no longer on store shelves. Staff on the Control of Infectious Diseases (CID) team provide support for food recalls and ensure that institutions are informed of high risk recalls and that recalled items are not used in food preparation if implicated products are present within the food premise2,3.

In addition, the CID team asks individuals who are ill with food pathogens about different food items consumed within the relevant time frame prior to onset of symptoms 2,4-6. Any suspect food items that are identified as having been consumed prior to onset of illness and that may be a potential risk factor are reported to Public Health Ontario (PHO) and the Ministry of Health and Long-Term Care (MOHLTC) via the integrated Public Health Information System (iPHIS), with a goal of assisting the provincial health authorities in performing surveillance for food items that may need to be recalled 2,5,6.

To date in 2016, WDGPH has actively investigated 3 recalls due to microbiological contamination, including the well-publicized recall involving Hepatitis A-contaminated Costco frozen berries1. As Hepatitis A is a vaccine preventable disease, this recall investigation also involved providing vaccinations to persons who consumed the product and who were still within the appropriate time frame for interventions to prevent illness due to Hepatitis A. WDGPH was also asked to contact area institutions regarding outbreaks due to Listeria monocytogenes (one due to a Neilsen chocolate milk product and another due to PC and Dole pre-packaged salad and leafy green products). Timely response by public health units to recalls, public complaints and reported cases of reportable disease is required under the Public Health Protocols and Standards2,3.

The Food Recall Process

According to the CFIA, “a food recall is an action taken by a company to remove potentially unsafe food products or products from the market that do not comply with relevant laws. It is the responsibility of industry to remove the product from sale or distribution”1. When a food item is identified as being potentially unsafe for consumption, the CFIA will conduct a food safety investigation to determine how likely it is that the implicated food item will cause illness if ingested, and how severe the potential illness is likely to be1.
Where the CFIA determines that a recall is required, the recall will be assigned to one of three classes; Class I (high risk – a product may cause serious illness or death), Class II (moderate risk – a product may cause temporary illness and serious illness is unlikely) or Class III (low or no risk – a product is unlikely to cause illness)1. Public health units are generally requested by Ontario’s Chief Medical Officer of Health (CMOH) and/or the CFIA to assist in certain high risk (Class I) recalls to ensure that the recalled product is not used in food preparation and service to individuals at high risk of illness (including day care attendees, long-term care residents and hospitalized patients)1,3.

Public Health’s Role

Public health inspectors (PHIs) across the province enforce food safety requirements by performing unannounced compliance inspections of all food premises, with additional inspections in response to complaints, where a food premise is potentially associated with an outbreak of foodborne illness and to follow-up on any outstanding issues identified during routine compliance inspections2,3,4,7.

Under the Public Health Standards; Food Safety Protocol (2016), the BOH is required to provide support for food product recalls and must be available to respond to complaints, outbreaks and recalls on a 24/7 basis 2,3. Upon request by the CMOH or the CFIA, the Board of Health (BOH) will respond and provide support for food recalls3. WDGPH monitors the CFIA webpage for food recalls and allergy alerts and will contact institutional food premises (including day care centres, long-term care homes and other institutions) within the health unit’s jurisdiction to advise of a recall. Public Health will monitor all food premises for recalled food items during regular compliance inspections and will notify the CFIA’s Area Recall Coordinator if recalled products are found3. Other food premises (including restaurants and grocery stores) are inspected to ensure the recalled product is not being used in food preparation, sold or distributed. This may involve on-site audits to ensure the recalled products have been removed.

In 2016, from January 1 through July 18, there were a total of 59 unique Class I recalls listed on the CFIA recall webpage regarding products distributed in Ontario and for which a public notification was issued by the CFIA in 2016.1 The majority of these recalls are due to the undeclared presence of food allergens such as milk, eggs, nuts or wheat whereas a few are due to contamination with microorganisms such as bacteria. 1

WDGPH was asked to respond and provide support for 3 of these recalls: 2 due to Listeria monocyotogenes (pre-packaged salads, salad blends and leafy greens; chocolate milk) and 1 due to Hepatitis A (frozen fruit)1. For each of these recalls Public Health contacted each individual institution within WDGPH to advise of the recall, request that the operator check to ensure that no implicated product was on site or had potentially been served to residents, and to notify WDGPH if implicated product was present on site and/or had been served to residents prior to the recall being identified. WDGPH also sent an email notification to all institutions, advising of the recall and providing details on the implicated product UPC codes, date range and general product description, with additional instructions to notify public health if product was found on site or served.

Public Health also has a role in identifying food products that may be responsible for causing illness. WDGPH staff on the CID team do this by interviewing ill people in a standardized way, in order to investigate whether there are common foods eaten which may point to the food causing illness2,4-6. Where a food product is suspected to be associated with illness it may be recalled1.

Conclusion

Food safety and reportable disease surveillance are multi-step processes that involve many agencies in the collection and analysis of relevant information and dissemination of results to individuals and organizations in order to inform the planning, implementation and evaluation of public health programming8.

Public health serves a vital role in the collection of food safety information via reportable disease case investigation and reporting, recall participation and the provision of ongoing food safety information to operators and members of the public.

Ontario Public Health Standards

The prevention of food-borne illness, inspection of food premises and increased public awareness of food-borne illnesses and safe food-handling practices are required under the Environmental Health Program Standards (2008), with the goal of reducing the burden of infectious diseases of public health importance. Case management of reportable diseases is required under the Infectious Diseases Program Standards (2008).

Specific requirements of the Environmental Health Program Standards – Food Safety are outlined in: Requirement #6: The board of health shall ensure that the medical officer of health or designate is available on a 24/7 basis to receive reports of and responds to:

  • Suspected and confirmed food-borne illnesses or outbreaks;
  • Unsafe food-handling practices, food recalls, adulteration, and consumer complaints; and
  • Food-related issues arising from floods, fires, power outages, or other situations that may affect food safety in accordance with the Health Protection and Promotion Act; The Food Safety Protocol, 2008 (or as current); the Infectious Diseases Protocol, 2008 (or as current); and the Public Health Emergency Preparedness Protocol, 2008 (or as current).

Requirement #7: The board of health shall inspect food premises and provide all the components of the Food Safety Program within food premises as defined by the Health Protection and Promotion Act and in accordance with the Food Premises Regulation (O. Reg. 562); the Food Safety Protocol, 2008 (or as current); and all other applicable Acts.

Specific requirements of the Infectious Diseases Program Standards-Infectious Diseases Prevention and Control are outlined in:

Requirement #1:

The board of health shall report infectious disease data elements in accordance with the Health Protection and Promotion Act and the Infectious Diseases Protocol, 2008 (or as current).

Requirement #2:

The board of health shall conduct surveillance of:

  • Infectious diseases of public health importance, their associated risk factors, and emerging trends; and
  • Infection prevention and control practices of inspected premises associated with risk of infectious diseases of public health importance, in accordance with the Infectious Diseases Protocol, 2008 (or as current); and the Population Health Assessment and Surveillance Protocol, 2008 (or as current). 

WDGPH Strategic Directions

The prevention of food-borne illness, inspection of food premises and increased public awareness of food-borne illnesses and safe food-handling practices are required under the Environmental Health Program Standards (2008), with the goal of reducing the burden of infectious diseases of public health importance. Case management of reportable diseases is required under the Infectious Diseases Program Standards (2008).

Specific requirements of the Environmental Health Program Standards – Food Safety are outlined in:

Requirement #6: The board of health shall ensure that the medical officer of health or designate is available on a 24/7 basis to receive reports of and responds to:

  • Suspected and confirmed food-borne illnesses or outbreaks;
  • Unsafe food-handling practices, food recalls, adulteration, and consumer complaints; and
  • Food-related issues arising from floods, fires, power outages, or other situations that may affect food safety in accordance with the Health Protection and Promotion Act; The Food Safety Protocol, 2008 (or as current); the Infectious Diseases Protocol, 2008 (or as current); and the Public Health Emergency Preparedness Protocol, 2008 (or as current).

Requirement #7: The board of health shall inspect food premises and provide all the components of the Food Safety Program within food premises as defined by the Health Protection and Promotion Act and in accordance with the Food Premises Regulation (O. Reg. 562); the Food Safety Protocol, 2008 (or as current); and all other applicable Acts.

Specific requirements of the Infectious Diseases Program Standards-Infectious Diseases Prevention and Control are outlined in:

Requirement #1: The board of health shall report infectious disease data elements in accordance with the Health Protection and Promotion Act and the Infectious Diseases Protocol, 2008 (or as current).
Requirement #2: The board of health shall conduct surveillance of:

  • Infectious diseases of public health importance, their associated risk factors, and emerging trends; and
  • Infection prevention and control practices of inspected premises associated with risk of infectious diseases of public health importance,

in accordance with the Infectious Diseases Protocol, 2008 (or as current); and the Population Health Assessment and Surveillance Protocol, 2008 (or as current).

Strategic Directions
DIRECTION APPLIES? (YES/NO)
Health Equity: We will provide programs and services that integrate health equity principles to reduce or eliminate health differences between population groups.      YES
Organizational Capacity: We will improve our capacity to effectively deliver public health programs and services.       NO
Service Centred Approach: We are committed to providing excellent service to anyone interacting with Public Health.      NO
Building Healthy Communities: We will work with communities to support the health and well-being of everyone.      YES

 

Health Equity

Population Determinants of Health Unintended Negative Impacts Mitigation Monitoring
Premise operators who have English as a second language
  • Income/SES
  • Education and literacy
  • Culture
  • Employment
As recall information is normally only made available in English, this may result in some operators continuing to serve/sell affected product or may cause unnecessary distress due to misunderstanding of the risks associated with consumption of recalled product(s). Make more information / resources available in predominant languages to support positive practices (eg. alternate language fact sheets). Tracking premise compliance and providing additional supports to businesses where language may be a barrier to compliance.
Premise operators who do not have access to the internet
  • Income/SES
  • Education and literacy
  • Culture
As recall information is made available online by the CFIA and WDGPH, only actively investigates certain recalls by request from the CMOH and/or CIFA, lack of access to the internet may limit the ability of operators to stay abreast of current recalls and proactively take relevant actions to prevent distribution of affected product. Make recall information available in alternate formats to limit barriers to access to information. Tracking premise compliance in removing recalled product from public sale / service and providing additional supports to businesses where internet access may be a barrier to compliance.

Appendices

NONE.

References

1. Government of Canada. Canadian Food Inspection Agency. (2016). The Canadian Food Safety System: Food Recalls. Accessed online at: http://www.inspection.gc.ca/about-the-cfia/newsroom/food-safety-system/f…
2. Ontario. Ministry of Health and Long Term Care (2008). Ontario Public Health Standards: Accessed online at: http://www.health.gov.on.ca/en/pro/programs/publichealth/oph_standards/d…
3. Ontario. Ministry of Health and Long-Term Care (2016). Food Safety Protocol. Accessed online at: http://www.health.gov.on.ca/en/pro/programs/publichealth/oph_standards/d…
4. Health Protection and Promotion Act, R.S.O. 1990. Accessed online at: http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90h07_e…
5. Public Health Ontario (2016). Standardized Questionnaires. Accessed online at: https://www.publichealthontario.ca/en/BrowseByTopic/InfectiousDiseases/P…
6. Health Protection and Promotion Act, R.S.O. 1990, Ontario Regulation 569 – Reports. Accessed online at: https://www.ontario.ca/laws/regulation/900569
7. Health Protection and Promotion Act. R.R.O. 1990, Ontario Regulation 562 – Food Premises. Accessed online at: https://www.ontario.ca/laws/regulation/900562
8. World Health Organization. (2016). Public Health Surveillance. Accessed online at: http://www.who.int/topics/public_health_surveillance/en/