Just like Johnny Cash, you need to be listening for any trains coming. So, what train am I talking about? The flour recall in Canada due to E. coli.
Should I be concerned since an active recall is in place? I would be because of the way supply chains can include many links. For example, you have the manufacturer who sells to different direct and indirect customers. The flour could go to one broker and then sold to another distributor who warehouses the flour next to another manufacturer for “Just in Time” deliveries to meet that day’s production needs. Or I am short of flour for a production run and procurement “spot buys” enough to get the factory through that day’s production. Do you keep a record of your “spot buys” in the Partner Management program or is the supplier just a broker or distributor’s name in the ERP database? Since you may have several different flour suppliers linked to one item number for the flour in your database, how do you keep track of how and where you are using the flour in your factory? Are the lot numbers of the ingredient documented during usage in the facility? Do you know who the lot numbers belong to? Broker?
Since flour usually does not undergo a thermal process to destroy pathogens and per FSMA the supplier should be notifying the customers of that potential risk and asking that the customer has preventive measures in place, everything should be ok, right? What if the customer says that their preventive measure is the supplier’s Certificate of Analysis that has all pathogens negative? Can you trust those results given the small size of the test sample against a 10,000-pound lot of flour? Does this message get carried all the way through the supply chain? If I am a distributor and just holding the product, where does my responsibility end? Of course, flour is always used in products that are cooked (not). Well, let’s not worry about cross contamination due to dusting flour on the work tables.
But I always think about cookie dough. I really like oatmeal raisin cookies, cooked not raw dough. Recalls for E. coli, then recalls for Salmonella, and when the cookie dough is used in ice cream, then recalls for ice cream due to Listeria. Any guesses on the next type of bacteria or toxin that flour will be recalled for? B. cereus? Or just aflatoxin?
So what is the potential risk that someone is using the recalled flour to make cookie dough in the United States? What about the individuals buying flour in the grocery store and making their own cookie dough in their kitchen? There is a risk, also what was the percent recovery of the distributed flour? Where and how was the missing flour used?
So, are you just going to rely on the recall notices to protect you from risk or are you going to actively look for the “train acoming” by asking all of your flour or products containing flour suppliers if they use or ever have used the recalled flour? And then, are you going to follow up with all of your flour suppliers to determine how they are protecting your from pathogen risk and what are you doing about the uncontrolled risk? While you are at checking with the flour suppliers, see how often they check their sweco screens, magnets, and metal detectors and their program for any chemical hazards.
Just think how the food safety world has changed, 20 years ago, no worries about flour.