Going Public

  • Posted: January 31st, 2012 - 10:33am by Doug Powell

    When government health officials wrapped up a three-month investigation of a Salmonella Enteritidis outbreak that sickened 68 people in 10 states, the final report on Jan. 19 included nearly every detail -- except the name of the place that sold the food.

    JoNel Aleccia of msnbc.com writes the U.S. Centers for Disease Control and Prevention has refused to identify the source, other than as “Restaurant Chain A,” a Mexican-style fast-food chain.

    “It will eventually come out and it will be the company that looks bad,” said Doug Powell, a professor of food safety at Kansas State University and author of a food safety blog. “A lot of these problems could be reduced if government agencies were more transparent about how they decide when to go public.”

    Dr. Robert Tauxe, a top CDC official, defended the agency’s practice of withholding company identities, which he said aims to protect not only public health, but also the bottom line of businesses that could be hurt by bad publicity.

    “The longstanding policy is we publicly identify a company only when people can use that information to take specific action to protect their health,” said Tauxe, the CDC’s deputy director of the Division of Foodborne, Waterborne and Environmental Diseases. “On the other hand, if there’s not an important public health reason to use the name publicly, CDC doesn’t use the name publicly.”

    The trouble, say food safety advocates, is that it’s not clear when or why CDC officials decide to withhold the identity of firms involved in outbreaks and when they decide to go public.

    "No one is happy, and that's largely because there are no guidelines people can at least point to, whether they agree with the guidance or no," Powell said.

    Tauxe acknowledged there’s no written policy or checklist that governs that decision, only decades of precedent.

    “It’s a case-by-case thing and all the way back, as far as people can remember, there’s discussions of ‘hotel X’ or ‘cruise ship Y,” he said.

    Epidemiology, like humans, is flawed. But it’s better than astrology. The more that public health folks can articulate when to go public and why, the more confidence in the system. Past risk communication research has demonstrated that if people have confidence in the decision-making process they will have more confidence in the decision. People may not agree about when to go public, but if the assumptions are laid on the table, and value judgments are acknowledged, then maybe the focus can be on fewer sick people.

    I understand the flexibility public health types require to do their jobs effectively, but much of the public outrage surrounding various outbreaks – salmonella in tomatoes/jalapenos, 2008, listeria in Maple Leaf deli meats, 2008, the various leafy green recalls and outbreaks of 2010, and the delay in clamping down on Iowa eggs – can be traced to screw ups in going public.

    It’s long been a tenet of risk communication that it is better to default to early public information rather than later. People can handle all kinds of information, especially when they are informed in an honest and forthright manner.

     

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  • Posted: January 13th, 2012 - 6:38am by Doug Powell

    After the belated public notification about a salmonella outbreak linked to Rizzo's Pizza in Ballarat, Australia, the Herald-Sun uncovered a bunch of other incidents of people barfing in the state of Victoria that were never or belatedly made public.

    A poisoning outbreak at a sushi bar that left 84 people sick and 19 in hospital is among serious food safety incidents kept quiet by authorities.

    Other cases uncovered include 17 diners who fell acutely ill after eating Vietnamese chicken and pork rolls; 10 people struck down after eating eggs Benedict at a cafe; and 13 people who fell crook from chicken parmigiana at a hotel.

    Health department figures show a significant rise in salmonella cases in the past two years, many of them linked to eggs (a table of raw-egg related outbreaks in Australia is available at http://bites.ksu.edu/raw-egg-related-outbreaks-australia).

    Brooke Dellavedova, a principal at Maurice Blackburn, said she often heard about food poisoning outbreaks, but new laws meant class actions were difficult to mount on behalf of victims.

    "So the proprietors get a slap on the wrist, if that, and that's the end of the story," she said.

    Department of Health spokesman Graeme Walker said the department did not routinely reveal the names of businesses because its role was to identify and remove the source and investigate the cause.

    Acting chief health officer Dr Rosemary Lester said the information was not being kept secret and salmonella was common adding, "We do know that many cases of salmonella arise in the home and other outlets.”

    This isn’t about where salmonella happens: this is about accountability by publicly-funded health types.

     

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  • Posted: December 9th, 2011 - 5:08am by Doug Powell

    For those counting – which seems like a bizarrely gruesome fetish – the final tally for the listeria-in-cantaloupe outbreak of 2011 is 146 persons sick from 28 states, including 30 dead and one miscarriage.

    Far more important is – will the cantaloupe industry in Colorado and elsewhere become overtly proactive, seeking the best research on the causes, prevention, and how to translate guidelines into actual actions in the field – where contamination starts.

    The U.S. Centers for Disease Control today issued its final report on the Multistate Outbreak of Listeriosis Linked to Whole Cantaloupes from Jensen Farms, Colorado—United States, 2011.

    (Sidenote: In the E. coli O157:H7 outbreak linked to Romaine lettuce served at Schnucks, CDC spokeswoman Lola Russell told The Packer yesterday the agency leaves announcements regarding names of growers and distributors to the regulatory agencies – state health departments and the U.S. Food and Drug Administration. But it had no problem fingering Jensen Farms? Maybe because the Food and Drug Administration named Jensen Farms on Sept. 14 it was open season after that. Maybe CDC was trying to protect other cantaloupe growers. Maybe they’d like to protect other Romaine lettuce growers? Is there a written policy on when to finger a farm? Consistency in communications helps build trust.)

    From the CDC cantaloupe report:

    A total of 146 persons infected with any of the four outbreak-associated strains of Listeria monocytogenes were reported to CDC from 28 states.

    Among persons for whom information was available, reported illness onset ranged from July 31, 2011 through October 27, 2011. Ages ranged from <1 to 96 years, with a median age of 77 years. Most ill persons were over 60 years old. Fifty-eight percent of ill persons were female. Among the 144 ill persons with available information on whether they were hospitalized, 142 (99%) were hospitalized.

    Thirty deaths were reported: Colorado (8), Indiana (1), Kansas (3), Louisiana (2), Maryland (1), Missouri (3), Nebraska (1), New Mexico (5), New York (2), Oklahoma (1), Texas (2), and Wyoming (1). Among persons who died, ages ranged from 48 to 96 years, with a median age of 82.5 years. In addition, one woman pregnant at the time of illness had a miscarriage.

    Seven of the illnesses were related to a pregnancy; three were diagnosed in newborns and four were diagnosed in pregnant women. One miscarriage was reported.

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  • Posted: November 19th, 2011 - 3:28pm by Doug Powell

    It’s not easy being a food safety investigator in the face of deep uncertainty.

    So says Ron Doering, a past president of the Canadian Food Inspection Agency who practices food law in the Ottawa offices of Gowling Lafleur Henderson, in his latest Food Law column.

    In the U.S., the largest foodborne outbreak in the last decade involved a rare strain of Salmonella Saintpaul thought to originate from tomatoes. The Food and Drug Administration (FDA) acted quickly, providing a public warning to avoid eating tomatoes until its investigation was complete. After several weeks and hundreds of tests and interviews, the FDA concluded that the problem was likely not tomatoes but rather hot peppers. Politicians rushed to microphones attacking the FDA for “destroying” the tomato industry. Of course, these are the same people who would have been outraged if tomatoes had been the source of the Salmonella and the FDA had not acted quickly.

    While the FDA probably did the right things in the face of so much uncertainty, they should have communicated better. Tracing the source of foodborne illnesses is very complicated, especially for produce like tomatoes where there are no bar codes, no packages, and they are quickly consumed, often with other produce.

    In the EU, the largest foodborne illness outbreak in the last decade, and one of the developed world’s most severe in modern times, took place this summer when a very rare strain of E. coli (O104:H4) got into the European food supply.

    The first death was reported on May 24. The next day, the Robert Koch Institute announced that the early epidemiology indicated that the likely culprit was cucumbers, tomatoes or green salads. And later that day German officials announced that the rare strain had been found in the stools of five of the sick patients. The following day a German state-level agency announced triumphantly that it had found E. coli on Spanish cucumbers, though it had not yet tested for the strain.

    On May 31, after testing for the strain, it was announced that the cucumbers were not to blame, by which time, of course, the Spanish cucumber industry was destroyed and German vegetable growers were suffering losses of $2.8 million per day as consumers quit eating all salads. Finally, on June 5 it was reported that “initial tests” (it was not tests, it was the result of epidemiological tracing) revealed that sprouts grown on an organic farm in Germany were “likely” the source of the problem, even though they couldn’t find a smoking sprout on the farm. Then on June 12 several victims of the O104 strain fell ill in France. They had no connection to the German organic farm. Attention turned to seeds, with the French blaming the British (I’m not making this up). Finally, on June 29 tracing determined the source of the problem as sprout seeds imported from Egypt in 2009. By this time there had been more than 50 deaths and well over 4,300 people seriously ill, including approximately 900 cases of patients with permanent kidney damage.

    In both cases, with the benefit of hindsight, academics and the media roundly criticized the regulators as incompetent.

    In a detailed review of the EU sprouts case, Peter Sandman, an expert on risk communication, concluded that the main failure of the regulators was in not being more forceful in proclaiming in their risk messaging the level of uncertainty in the case.

    To me it seems there is a more basic problem, and it flows from the use of the language of risk, because “risk” disguises the deep uncertainty inherent in complex cases like these. These regulators were dealing with uncertainty, not risk — they were engaged in crisis management, not risk management.

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  • Posted: October 5th, 2011 - 6:09am by Doug Powell

    Alex Paul of the Albany Democrat-Herald reports the first confirmed victims of a February outbreak of Salmonella Panama that eventually affected 20 people in 10 states and was traced to cantaloupe that came from a single farm in Guatemala, was in Albany, Oregon.

    “We found one person confirmed and two others presumed with a pretty rare form of salmonella,” said Jane Fleischbein of the Linn County Public Health Department.

    Fleischbein said the public wasn’t notified because Costco immediately pulled the product from its shelves.

    “It all depends on timing,” Fleischbein said. “Sometimes it takes a while to track down and by the time the source has been identified, the product has already been consumed or taken off the shelves.”

    Fleischbein said her office gets news of at least one recall per week.

    “If local public health departments sent a notice about every recall, we would be awfully busy,” Fleischbein said. “There are many recalls that go under the radar.”

    The three in Albany were among six people statewide who became sick. The investigation concluded they had eaten cantaloupe served at a church supper.

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  • Posted: August 30th, 2011 - 9:17pm by Doug Powell

    Del Monte Fresh Produce, a company that recalled its cantaloupes in March after health investigators in several states linked them to a Salmonella Panama outbreak, said yesterday that is plans to sue Oregon Health Authority and, Dr William Keene, one of the nation's most well-known disease outbreak investigators (right, exactly as shown), claiming that the company's products were wrongly singled out.

    Lisa Schnirring of CIDRAP news at the University of Minnesota interviewed several public health types, who say the company's suit is unprecedented, and some worry that it may inhibit future foodborne illness investigations.

    Lon Kightlinger, MPH, PhD, state epidemiologist with the South Dakota Department of Health, said some of his department's disease investigations have involved legal tug-of-wars. "Although we do have some worries of legal threats, that does not drive our investigation, but causes us to do a better job," he said.

    In Iowa, laws require public health officials to treat the names of entities such as restaurants or companies the same as people, said Patricia Quinlisk, MD, MPH, medical director and state epidemiologist for the Iowa Department of Public Health.

    She said that, before going public with names, health officials must discuss the issue with the state attorney general's office to make sure the action complies with a "necessary for public health" clause. "Thus something like this might have more scrutiny here than other places," she said, adding that she's never seen a legal threat like Del Monte's.

    Tim Jones, MD, MPH, state epidemiologist for the Tennessee Department of Health, said he's been bullied and subjected to implied threats in the course of epidemiologic investigations. "I've never taken them seriously, and legally I've never been worried," he said.

    Though Del Monte's legal threat could create an inhibitory effect, epidemiologists take pride in being able to respond to outbreaks faster and freer than federal agencies, which are often bound by legal restrictions, Jones said.

    "Our job is to protect people."

    Some measure of immunity is needed for investigators, Jones said. "If anyone in public health is nervous about getting sued, it could be dangerously inhibitory."

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  • Posted: August 20th, 2011 - 6:03pm by Doug Powell

    The Aug/Sept. issue of Food Quality magazine contains a package of articles about lessons learned from this year’s E. coli O104 outbreak in Germany linked to raw sprouts grown from seeds produced in Egypt.

    My own contribution was an attempt, at the editor’s request, to capture the uncertainty and vagaries that characterize outbreaks of food- or waterborne illness.

    My friend Jim called on a Friday afternoon. Jim is a dairy farmer located on the edge of a town in Ontario, Canada, called Walkerton, and he said a lot of people were getting sick. The community knew there was a problem several days before health types went public.

    On Sunday, May 21, 2000, at 1:30 p.m., the Grey Bruce Health Unit in Owen Sound, Ontario posted a notice on its website to hospitals and physicians to make them aware of a boil water advisory and inform them that a suspected agent in the increase of diarrheal cases was E. coli O157:H7.

    There had been a marked increase in illness in the town of about 5,000 people, and many were already saying the water was suspect. But because the first public announcement was also the Sunday of the Victoria Day long weekend, it received scant media coverage.

    It wasn’t until Monday evening that local television and radio began reporting illnesses, stating that at least 300 people in Walkerton were ill.

    At 11 a.m. on Tuesday, May 23, the Walkerton hospital held a media conference jointly with the health unit to inform the public of the outbreak, to make people aware of the potential complications of the E. coli O157:H7 infection, and to warn them to take the necessary precautions. This generated a print report in the local paper the next day, which was picked up by the national wire service Tuesday evening, and subsequently appeared in papers across Canada on May 24.

    These public outreach efforts were neither speedy nor sufficient. Ultimately, 2,300 people were sickened and seven died—in a town of 5,000. All the gory details and mistakes and steps for improvement were outlined in the report of the Walkerton inquiry
    (www.attorneygeneral.jus.gov.on.ca/english/about/pubs/walkerton).

    The E. coli O157:H7 was thought to have originated on a farm owned by a veterinarian and his family at the edge of town, someone my friend Jim knew well, a cow-calf operation that was the poster farm for Environmental Farm Plans. Heavy rains washed cattle manure into a long abandoned well-head, which was apparently still connected to the municipal system. The brothers in charge of the municipal water system for Walkerton, who were found to have been adding chlorine based on smell rather than something minimally scientific like test strips, were criminally convicted.

    But the government-mandated reports don’t capture the day-to-day drama and stress that people like my friend experienced. Jim and his family knew many of the sick and dead. This was a small community. News organizations from around the province descended on Walkerton for weeks. They had their own helicopters, but the worst was the medical helicopters flying patients with hemolytic uremic syndrome to the hospital in London. Every time Jim saw one of those, he wondered if it was someone he knew.

    I’m not an epidemiologist, but as a scientist and journalist with 20 years of contacts, I usually find out when something is going on in the world of foodborne outbreaks.

    The uncertainties in any outbreak are enormous, and the pressures to get it right when going public are tremendous.

    The public health folks in Walkerton may have been slow by a couple of days while piecing together the puzzle; what happened in Germany this summer in the sprout-related outbreak of E. coli O104, a relative of O157, was a travesty.
    Worse, bureaucrats seemed more concerned about the fate of farmers than that of citizens. By at least one count, 53 have died, and more than 4,200 have been sickened.

    Raw sprouts are one of the few foods I won’t eat, and as many epidemiologists have pointed out, sprouts top the list of any investigation involving foodborne illness.

    We at bites count at least 55 outbreaks related to raw sprouts beginning in the U.K. in 1988, sickening thousands.

    The first consumer warning about sprouts was issued by the U.S. Centers for Disease Control and Prevention (CDC) in 1997. By July 9, 1999, the U.S. Food and Drug Administration (FDA) had advised all Americans to be aware of the risks associated with eating raw sprouts. Consumers were informed that the best way to control the risk was to not eat raw sprouts. The FDA stated that it would monitor the situation and take any further actions required to protect consumers.

    At the time, several Canadian media accounts depicted the U.S. response as panic, quoting Health Canada officials as saying that, while perhaps some were at risk, sprouts were generally a low-risk product.

    That attitude changed in late 2005, as I was flying back to reunite with a girl I had met in Kansas and 750 people in Ontario became sick from eating raw bean sprouts.

    Unfortunately, what food safety types think passes for common knowledge—don’t eat raw sprouts—barely registers as public knowledge. It’s hard to compete against food porn.

    Sprouts present a special food safety challenge because the way they are grown, with high moisture at high temperature, also happens to be an ideal environment for bacterial growth.

    Because of continued outbreaks, the sprout industry, regulatory agencies, and the academic community in the U.S. pooled their efforts in the late 1990s to improve the safety of the product, implementing good manufacturing practices, establishing guidelines for safe sprout production, and beginning chemical disinfection of seeds prior to sprouting.

    But are such guidelines being followed? And is anyone checking?

    Doubtful.

    This was demonstrated by two sprout-related outbreaks earlier this year linked to sandwiches served by Jimmy John’s, a chain of gourmet sandwich shops based in Champaign, Ill.

    Sprouts served on Jimmy John’s sandwiches supplied by a farm called Tiny Greens sickened 140 people with Salmonella, primarily in Indiana. In January, Jimmy John’s owner Jimmy John Liautaud said his restaurants would replace alfalfa sprouts, effective immediately, with allegedly easier-to-clean clover sprouts. This was one week after a separate outbreak of Salmonella sickened eight people in the U.S. Northwest who had eaten at a Jimmy John’s that used clover sprouts.

    If the head of a national franchise is that clueless about food safety, can we really expect more from others?

    Sprout grower Bill Bagby, who owns Tiny Greens Sprout Farm, said in the context of the German outbreak that, for many like him, the nutritional benefits outweigh the risk:

    “Sprouts are kind of a magical thing. That’s why I would advise people to only buy sprouts from someone who has a (food safety) program in place (that includes outside auditors). We did not have (independent auditors) for about one year, and that was the time the problems happened. The FDA determined that unsanitary conditions could have been a potential source of cross-contamination and so we have made a lot of changes since then.”

    Independent auditors? Like the ones who said everything was cool, everything was OK, at Peanut Corporation of America (nine dead, 700 sick in 2008-09) and Wright County Egg (2,000 sick in 2010)?

    Like the Walkerton E. coli O157:H7 outbreak in 2000, too many are using the filters of their politics to advance their own causes and saying too many dumb things in light of the sprout outbreak of 2011.

    It’s really about biology and paying attention to food safety basics—no matter how much that interferes with personal politics.

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  • Posted: August 9th, 2011 - 8:27pm by Doug Powell

    Federal officials said in recent days that they turned up a dangerous form of salmonella at a Cargill Inc. turkey plant last year, and then four times this year at stores selling the Cargill turkey, but didn't move for a recall until an outbreak killed one person and sickened 77 others.

    Bill Tomson of The Wall Street Journal reports Cargill and the U.S. Department of Agriculture announced the recall of ground turkey from the Cargill plant in Springdale, Ark., on Aug. 3. The USDA said the third-largest meat recall in history affected 36 million pounds of ground turkey.

    Food-safety specialists said the delay reflected a gap in federal rules that don't treat salmonella as a poisonous contaminant, even if inspectors find antibiotic-resistant forms such as the Heidelberg strain implicated in the latest outbreak.

    "We have constraints when it comes to salmonella," said Elisabeth Hagen, the USDA's top food-safety official, in an interview. She said that unlike E. coli, salmonella isn't officially considered a dangerous adulterant in meat unless that meat is directly tied to an illness or death.

    Meat plants are expected to pass a performance standard that allows up to 49.9% of tests to come back positive for salmonella. A Cargill spokesman said the Arkansas plant has passed all USDA performance standards despite what he called "routine" findings of salmonella Heidelberg.

    Government agencies were "clearly too slow" in informing the public that there was a contamination in ground turkey, said Doug Powell, Kansas State University professor of food safety. He said the USDA should have contacted Cargill earlier about the contaminated store samples.

    The USDA didn't contact Cargill about suspected contamination of ground turkey until July 29, officials said.

    I also told reporter Tomson, but it didn’t make it into the story, that Cargill and its customers – in this case Kroger – should be doing their own testing and striving for continuous reduction in salmonella levels, from farm to processing. For Cargill to say it met government standards is like Ford saying its Pinto automobiles, which had a tendency to blow up when struck from behind, met all government standards. Government standards for food is are minimum, the lowest common denominator. Consumers should demand that food folks do better, but they can’t because food safety is not marketed at retail.
     

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  • Posted: August 4th, 2011 - 11:34pm by Doug Powell

    communication.jpg

    The massive ground turkey recall that Cargill Inc. announced this week is raising questions about whether federal food safety regulators should have moved faster to limit a nationwide salmonella outbreak.

    I told Mike Hughlett and David Shaffer of Minnesota Star Tribune that, "Part of the problem is the absence of clear guidelines about when to go public."

    Doug Powell, a food safety expert at Kansas State University who felt that the recall process was slow with the ground turkey, said food regulators appeared to become more conservative after a big salmonella outbreak in 2008. The U.S. Food and Drug Administration first linked it to tomatoes, only to find out later that jalapeno peppers were the most likely cause. The tomato industry cried foul after it got crushed financially.

    The recall that Minnetonka-based Cargill announced late Wednesday covers 36 million pounds of ground turkey, one of the biggest U.S. meat recalls. It's linked to a particularly virulent strain of salmonella that has infected 78 people in 26 states and led to one death.

    The recall involves ground turkey produced as early as February, and the U.S. Department of Agriculture had indications going back to at least July 20 that the culprit might be a Cargill plant in Arkansas.

    The timing of the recall highlights a dilemma for the nation's food regulators over when to go public with recall information. Go too late, and public health could suffer. Go too early and make a mistake, and a corporation or industry's reputation could unduly suffer.

    In Sacramento County, Calif., where a woman older than 65 died in June from the latest outbreak, the county's health officer brought up another factor bedeviling food regulators these days: budget cutting.

    Dr. Glennah Trochet said her department now responds more slowly to outbreaks, sometimes delaying investigations a week or two. Public health workers often aren't available to interview possible victims. She suspects other agencies face the same constraints. "If you want rapid response, you need to have the resources to do rapid response," Trochet said.

    This is something I hear from public health types across the country; it’s almost amazing outbreaks get tracked down at all given the fiscal mess at the state and local levels.

    The salmonella outbreak linked to Cargill ground turkey began in early March. Chris Braden, the Centers for Disease Control and Prevention's director of foodborne diseases, said on Thursday that it was a slowly building outbreak in the beginning.

    After recognizing an "unusual clustering" of Salmonella Heidelberg cases, the CDC began investigating on May 23, Braden said. About the same time, routine surveillance by a federal food monitoring system found the same strain of Salmonella Heidelberg in ground turkey in stores.

    The monitoring service found four positive samples, one each in April, May, June and July, Braden said. Those four samples were traced to Cargill's Arkansas plant, he said, though he didn't elaborate on when.

    David Goldman, a public health administrator in the USDA's Food Safety and Inspection Service, told reporters that by July 20 or 21, the agency had traced back two cases from the salmonella outbreak to Cargill's Arkansas plant. A third traceback to the same plant was confirmed last week.

    Late Friday, the USDA put out a public warning about salmonella dangers in ground turkey, without naming the suspected source. Recalls are often initiated when food regulators tell a company they suspect it's the source of an outbreak.

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  • Posted: April 7th, 2011 - 8:12pm by Doug Powell

    The Montreal Gazette is reporting tonight that public health authorities are still trying to pin down the source of an E. coli O157:H7 outbreak that has claimed the life of one Quebecer, caused severe kidney complications in another, and sickened 11 others in Canada.

    Not much new, other than a few quotes from some of the players.

    Adel Boulos, vice-president at Amira Enterprises Inc. said Thursday none of the walnut samples — collected from the individuals who got sick, from stores and from the food importer's warehouse, adding, "We have decided to do the recall even though none of the walnuts have tested positive. The investigation is going on and we are co-operating fully with the government to make sure that nobody gets sick."

    Nathalie Levesque, a provincial Health Department official, said, "The Canadian Food Inspection Agency has serious doubts as to whether the infections are related to walnuts, but it's the most probable source.”

    Read into that what you like. If this was a homegrown product, CFIA would not be saying anything public, based on their past track record (see Maple Leaf). But when it’s imported, CFIA tends to rediscover the basics of epidemiology. Or maybe I’m wrong. If CFIA publically disclosed how, when and why they inform the public about potential food risks, and was consistent, perhaps there would be some confidence in the system.

    Alice D'Anjou, a Canadian Food Inspection Agency spokeswoman said, “We got to trace these nuts right back to their source. We're still trying to identify where the contamination happened, where the problem is, and how to fix it.”

    In an advisory issued on Monday, the agency declared that "at this time, the outbreak investigation indicates that several individuals have reported consuming raw shelled walnuts.

    The recalled walnuts, all imported by Amira from California, include products sold under the brand names Merit Selection and Tia. The walnuts were sold pre-packaged as well as in bulk bins.
     

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