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Recent Recall and customer impacts

The recent recall of a range of non-dairy milks for botulism has highlighted that a sound understanding of food safety risks and food labelling requirements is essential.

The recall was initially triggered by a consumer contracting severe botulism symptoms and becoming hospitalised. This is unusual in today’s food processing industry for Clostridium Botulinum to be an issue with home-preserved foods being most likely associated with the biotoxin formation and resulting in food poisoning.

Symptoms of Clostridium botulinum poisoning include difficulty swallowing, muscle weakness, blurry or double vision, drooping eyelids, slurred speech, difficulty breathing, and difficulty moving the eyes and can lead to death.

Understanding the Microbe

To understand this recall, we need to understand two critical components that led to this issue:

1. The nature of Clostridium botulinum, and
2. The way that product has to be labelled to protect the consumer.

Firstly let’s look at the nature of Clostridium botulinum. It occurs widely in the environment from marine sediments to agricultural soils. We, therefore, have to assume that agricultural commodities like almonds and oat have exposure to this organism.

Like other food-poisoning organisms, Clostridium botulinum is not a single organism, but a group of related ones. While Clostridium botulinum organisms are all spore formers, the sensitivity of the spores to heat varies in crucial ways.

One group called non-proteolytic Clostridium botulinum can grow at refrigerated temperatures, between 3.3°C and 5°C. To achieve a safe, refrigerated food or beverage with a shelf life of over 10 days, a heat process of 90°C for 10 minutes, or equivalent, has to be achieved (Food Standards Australia New Zealand, Safe Food Australia 4th edition, Appendix 3, 2023). This heat process achieves a 6-Decimal (6-D) reduction for non-proteolytic Clostridium botulinum spores.

The other group of Clostridium botulinum grows at ambient temperatures and is a concern for low-acid foods (pH>4.6). Their spores are much more heat-durable and to achieve a safe food a heat process of 121°C for 3 minutes, or equivalent, has to be achieved (Food Standards Australia New Zealand, Safe Food Australia 4th edition, Appendix 3, 2023). This provides a 12-D reduction step for these spores.

Oat and almond milks typically have a near-neutral pH above 6. This makes it critical that the milks are kept refrigerated if they have been processed as a refrigerated product.

In the case of this recall, the issue arose because the product had not been kept refrigerated.

This leads us to the second critical factor that caused the formation of the botulism biotoxin formation.

According to the Food Standards Code Standard 1.2.6-2, a food must be labelled with the appropriate storage conditions and directions for use if specific storage conditions are required to ensure that the food will keep until the use-by date.

In this case, the requirement would have been to label the food as ‘keep refrigerated’. However, while legally required, no storage instructions were provided. This led to the consumer not knowing that they had to keep the product refrigerated to stop the formation of Clostridium botulinum biotoxin.

The result of the consumer not storing the product at the correct temperature, due to non-compliant labelling, and the resulting under-processing led to this failure of keeping consumers safe.

Professional training and consulting to reduce the risk of Clostridium botulinum

Food processors can benefit from training and consulting services that focus on food safety and microbiology. Quality Associates offers Food Microbiology consulting and training. We help businesses in the food industry better understand and implement effective controls for preventing the growth of Clostridium botulinum and all microbes in their products. Our expert consultants can provide guidance on developing and perfecting HACCP plans and other food safety management systems that are tailored to your specific needs.

Our Food Microbiology consulting and training can help you implement best practices for food safety management, while our Food Labelling training can help you comply with the relevant labelling regulations.

The impact of Clostridium botulinum on food production can be severe, with potential health and financial consequences for businesses in the food industry. However, by understanding food microbiology and legal labelling requirements, it is possible to significantly reduce the risk to the consumer.

Quality Associates Training (RTO 41341) provides introductory and advanced courses in Food Microbiology and compliant Food Labelling.

Please contact us 1300 737 193, training@qualityassociates.com.au or visit our websites https://www.qualityassociates.com.au/training/all-training-courses/ and https://onlinetraining.qualityassociates.com.au/.

Find the referenced recall here -> https://www.foodstandards.gov.au/industry/foodrecalls/recalls/Pages/Inside-Out-Almond-Milk-(Collagen+Calcium+Prebiotics)-1-L.aspx