FDA to tomatoes: you are no peanut butter or bagged spinach

Okay, they don't exactly say so, but here the agency gives two best case traceability scenarios; more from the FDA document on upcoming public traceability hearings.


E. How Has Product Tracing Information Available in Records and on Product Packages/Containers Helped Us During Traceback Investigations?
In the following paragraphs, we describe how we used product tracing information to conduct two recent traceback investigations-one involving a nonperishable packaged food, and one involving a perishable packaged food. The information available to us included information available in records established and maintained by parties in the supply chain and information available on packages or containers of the packaged food.
• In February 2007, CDC notified FDA of a multi-State outbreak of Salmonella Tennessee infections associated with the consumption of peanut butter. Peanut butter is a nonperishable packaged food, sold in jars. Consumers who became ill had open jars of peanut butter available for testing. Investigators were able to test samples of peanut butter taken from the jars and confirm the presence of Salmonella Tennessee in the peanut butter. Investigators were able to identify the manufacturer through information required to be on the label of the jars (§ 101.5(a)) and through a product code the manufacturer had voluntarily placed on the jars. This information made it possible for FDA to visit the manufacturing facility the day after we learned of the outbreak from CDC. Investigators were able to use the product code to look in the manufacturing facility for unopened jars of peanut butter manufactured at the same time as the jars available from consumers. Investigators took samples of peanut butter from these unopened jars and confirmed the presence of Salmonella Tennessee in those samples. Investigators uncovered conditions at the manufacturer's facility that were likely to have caused the contamination and obtained a positive environmental sample so there was no need to further trace the peanuts back to the farm. Our traceback investigation was facilitated because the implicated food was a nonperishable, packaged food that was available to investigators and contained information about the source of the implicated food on, the product container.
In September 2006, CDC informed FDA of a multi-State outbreakof illnesses associated with the consumption of fresh spinach contaminated with coli 0157:H7. Fresh spinach is a perishable food that may not remain in consumers' homes after consumers become ill and CDC finds an association between the illness and the food. However, in this situation the spinach was sold in a package. The traceback investigation was facilitated because several consumers who became ill still had packages of fresh spinach in their refrigerators. As with the peanut butter, investigators were able to identify the processor through information required to be on the label of the packaged spinach (§ 101.5(a)) and through a product code the processor had voluntarily placed on the package. By looking at the processor's records, the investigators were able to identify the implicated farms associated with the identified production lot of bagged spinach. This traceback investigation was more complex than the investigation for the peanut butter, because it required traceback beyond the processor to the farms. However, as with the peanut butter, the traceback investigation was greatly facilitated by the information on the label of the packaged food and on the package itself.