As most of you know, as a food industry lawyer, I have represented the food industry for over 20 years. During the course of that time, I have closely tracked evolving USDA policy, the strengthening of FSIS inspection and surveillance programs, the continuing parade of food product recalls, and the nearly monthly emergence of new foodborne illness outbreaks. I have mourned with and comforted industry when times were at their worst, and I have celebrated with industry when times were at their best.
So far this year, I am proud to proclaim, industry is performing better than ever before. So far this year, there have been zero foodborne illness outbreaks associated with the consumption of beef, and there have only been a total of 10 recalls. Importantly, there has not been a single recall in 2020 announced for the possible presence of a harmful pathogen.
When this number (only 10 recalls through late May) is compared with the historical averages, the results are stunning. In 2015, there were 150 recalls of FSIS-regulated products. By mid-May 2015, there were already 80 recalls. Nearly 10 of those recalls involved the presence of a harmful pathogen. Multiple meat products had also been associated with emerging outbreaks. Those trends continued with 121 recalls in 2016, 131 in 2017, 125 in 2018, and 123 in 2019. On average, by mid-May, there have historically been nearly 40 recalls. Thus, with only 10 recalls so far this year, and all workers in the food industry should be congratulated.
Based upon our review of the data, the most likely cause for this year’s success is that industry is producing a safer product. There is also no evidence that COVID-19 is causing the decrease in reported foodborne illness clusters or recalls. If the decline in recalls of USDA-regulated products were related to COVID-19, we would expect to see a decline in the recall of all products. So far in 2020, however, there have been nearly 150 recalls of FDA-regulated products, which is about average. Moreover, the declines in recalls of USDA-regulated products began long before COVID-19 was being debated on the news. There were only four recalls in January 2020, one in February, and zero recalls in March. In a statement issued by FSIS on March 17, 2020, the agency confirmed that, notwithstanding COVID-19, all meat inspection services would be “continuing as normal.” Finally, demand for meat products actually increased in recent months, making it more likely that, as production levels increase, more recalls would be announced. Yet, the opposite has proven true.
So far this year, the meat industry is doing a stellar job of not only keeping U.S. consumers fed, but also keeping them safe. As we move further into 2020, keep up the good work. When 2021 arrives, I hope to proclaim that “we won the food safety fight” with “the best food safety year in the history of meat.” NP