Don't Eat Poop! A Food Safety Podcast

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Matthew Regusci: And if you're huge, like PepsiCo, what are your facilities doing? If you have a dozen, a hundred, 200 facilities, how positive are you that each of those facilities are abiding by what your expectations are at the corporate office?

Francine L Shaw: Ever as strong as your weakest link.

Matthew Regusci: Yep.

Francine L Shaw: Whatever that may be. That's your only ever that strong.

Matthew Regusci: Every other PepsiCo facility could be ticking like clockwork. Their SOPs could be awesome. And we're having this conversation today because of this one facility.

intro: And nobody likes getting sick. That's why heroes toil in the shadows, keeping your food safe at all points from the supply chain to the point of sale. Join industry veterans, Francine L Shaw and Matt Ragushi for a deep dive into food safety. It all boils down to one golden rule. Don't eat poop. Don't eat poop.

Matthew Regusci: Hello. Hello, Francine. Hey, Matt. Another day, another 50 cents.

Francine L Shaw: Another dollar.

Matthew Regusci: Well, at least the world is going to get our two cents.

Francine L Shaw: Yes, they are. Whether they want it or not.

Matthew Regusci: Okay, so this is an interesting one. You and I have discussed this Quaker Oat recall and the facility that was shut down for that Quaker Oat bars and all the stuff with Salmonella.

They shut it down because of Salmonella. And we did a whole entire thing because my mother in law basically did a recall of our, what did you say?

Francine L Shaw: Your mother put a whole recall plan into place, had procedures, written procedures and everything in your little convenience store outlet that you have in your home, otherwise known as your pantry.

Matthew Regusci: My pantry slash larger. And that was a few months ago, right? That was like in April. You can go back and listen to Our podcast on that, but there was just recently an FDA letter that got sent to PepsiCo, which owns Quaker Oats, and it was super fascinating because first off, in order for the FDA letter to be public, they have to have been writing back and forth for a while and allowing the company to come up with a lot of different corrective actions.

This is not the FDA's MO is to just shoot, particularly for massively large companies like PepsiCo. There tends to be a lot of back and forth of them really trying to fix this problem. And this letter is very interesting because it's seems like this was an ongoing saga.

Francine L Shaw: The magnitude of this recall was huge.

It was massive for PepsiCo and Quaker. Again, it's another reputable company. That, I guess, flew under the radar for a period of time. And then they were just lamb based in with the number of products that were implicated. 40 products, 40. Well, and then the recall was expanded, but with two dozen more products.

Matthew Regusci: Yep.

Francine L Shaw: So again, all preventable.

Matthew Regusci: Yeah. The Quaker Oats recall began December 15th, 2023 with more than 40 products. And then, yeah, I forgot about that. I'm looking at now, January 12th, 2024, two dozen more products were pulled. So what is that? 64 products. It's insane. That's so many SKUs that were pulled. And then this is the manufacturing facility is the Danville, Illinois manufacturing facility, which closed its doors in June of this year.

They told the FDA that they're going to start shutting this down in April. That's crazy. Letter revealed this letter from the FDA revealed that there was a history of testing positive for salmonella dating back to 2020.

Francine L Shaw: What do you say that they've not taken any corrective action? They've done nothing when they know that they've been finding salmonella and samples for four years.

Matthew Regusci: Yeah, so there's a lot of questions that we're going to be hashing through on this. One of them is, we'll go through in the facility, we'll do a deeper dive in the facility. As a corporation, PepsiCo has a really good food safety program. You and I know some of the key people at Pepsi that run their food safety program.

So was this like a catastrophic problem from the top? They're just not tracking. Individual facilities, or is this an anomaly? Because there's a lot of facilities that PepsiCo owns, right? A ton of different facilities. They do everything. Quaker Oats, Lay's Potato Chips. So they have a really good program.

Would they have bought, I'm assuming there's two separate entities running PepsiCo's food safety program, right? So each facility has their own food safety program, somebody at the top. Of them is making sure that each of those facilities are managing their food city program. So that's internal food safety.

The secondary is supply chain food safety, right? Making sure that their suppliers are abiding by their expectations. If the supply chain food safety person were to have decided to switch roles with the internal food safety program, would have the supply chain food safety program looking at each of their individual facilities?

Would they have said, Hey, this is okay. That's one of my questions, right? Would there have been way more corrective actions internally if they had switched roles? Second, is where's the GFSI food safety program again? Last episode we were talking about Silk and I was asking the exact same question about where's the internal testing for environmental testing program for Listeria for Silk.

For this they're obviously doing internal testing but there was no corrective actions on it. So that's part of the GFSI audit. I am so confused on this. What are your thoughts?

Francine L Shaw: So it's, do they look at the results when they get them back or are they just filed or are they just sitting in somebody's email somewhere and they're never reviewed?

How can it go that long and nobody does anything? 13? Was it 13 bad reports?

Matthew Regusci: Yes. At least. Well, going back to 2020, they are finding Listeria in this facility multiple times. They said that they are going to do a corrective action, but no corrective action was reported. They're obviously tracking the environmental results.

They obviously have a system that you should be tracking corrective actions on, but they're not going back and doing it. If you were getting an audit done, you would pull that up and see that there was no corrective action response, both internally, or if this was an SQF audit or something like that.

Yeah. Who does, who, who does? So they're tracking it. But they're not doing it. And so this is a great case study for any other facility out there that's doing environmental testing, most likely, because that's what you're supposed to do. When a result comes back with a positive, are you actually doing the corrective actions internally?

And if so, are you tracking them? Because if you didn't track them and do them, it didn't happen.

Francine L Shaw: Are we only doing the testing? So we can say, okay, so we do the testing. And then the reports come back and we just don't even really look at them and then the labs responsibility isn't really to do the follow up.

I get that. But if you have a lab and you're doing this testing and there's something like that, that is. Out of kilter. I would like to think that throws up a red flag and somebody at a lab would say, hey, I just want to make sure that you're aware. Again, not the responsibility, but

Matthew Regusci: no, it's not the responsibility actually.

So what would happen is if the lab has a positive result. They will send the results over. They don't consult. Now, if somebody calls and ask the lab, what does this mean? Well, then the lab will have somebody who explains what it means. And then if they say, well, what do I do about it? It depends on the lab, but some labs will have somebody who will be like, well, usually you could find out what to do for your corrective action here, pointing them in the right direction.

Some labs will help companies create their own zone testing and then have a consulting type of arm that walks them through what happens if they find a contaminant. Probably not for PepsiCo. You would assume PepsiCo would have that internally.

Francine L Shaw: What good is a test result if you don't know what it means?

Matthew Regusci: Oh, that happens a lot.

Francine L Shaw: There is not any point and I'm not saying don't test, but there is no point in getting a test. If you don't know what it means. Somebody has got to know what that test result means, otherwise it's exercise in

Matthew Regusci: futility.

Totally agree. Mind you, if you've taken a preventive control class, they'll explain to you what the zones are, how to, what environmental testing means on a large kind of like a macro basis. If you go Google it, you can call a lab and sometimes your lab will actually. help you put your rotation up for that testing.

So there, I totally agree with you. There are a lot of people that do not understand what all this means, but ignorance.

Francine L Shaw: Can you imagine going to the doctor, having blood work done and your doctor being like, okay, I don't know exactly what that means. Let me Google that or they sit there and they Google it.

Matthew Regusci: Okay. First off, if the doctor is sending you out to go get lab results, say to lab core. LabCorp isn't the one that tells you what it means if you're outside of any type of No,

Francine L Shaw: they just tell you if you're outside.

Matthew Regusci: They tell you what's outside. Then your doctor tells you what that means. It gives you the consultation of what type of meds you may need to be on, or how you can fix your diet, or all that different type stuff, right?

So we're talking about the same thing because it's not the lab's job. The lab assumes you either know what you're doing, and if you don't, then you should ask the lab the question. Maybe they can help you out with that.

Francine L Shaw: There needs to be somebody that knows what those numbers.

Matthew Regusci: Somebody at PepsiCo knew what those numbers are.

This facility has no reason why they did not do this correctly. Because you and I both know senior directors and VPs at Pepsi that know exactly what to do here. We both know some of those people. So the fact that this got the way where it was, there was an issue either, and it could be, it's obviously on both ends.

One, the facility wasn't doing what it was supposed to be doing. Two, nobody was checking up on the facility to make sure that they were doing what they were supposed to be doing. I don't know where the data is being stored. But there was obviously they were collecting both the results and that it needed a corrective action response, but yeah, they were definitely not followed up on internally well enough.

And they obviously were not followed up on well enough with whatever audits they were doing. I don't know what audit they're, what type they're doing. If it's FSSC 22, 000, then you can choose your own adventure in terms of a GFSI audit, like you create your own expectations. But if they have an expectation of environmental testing and a corrective action response, then it still should have been a non conformance in their FSSE 22, 000 or SQF or BRC audit, when they found that there were tests done and no corrective action completed when they found a positive.

That is one of the main things you do. You go through as an auditor and find Do you have environmental testing? Yes or no? Yes. Awesome. Are you, what are you testing for? What zones? What are you testing for zone four, for three, for two, for one? Are you just doing ATP testing for one? Okay. Well, let me see.

What are you doing? Are you testing for salmonella environmentally? Yes. Great. Have you had a positive within the last year? Yes. Okay. Let's pull up that positive. Let's see where it is in the corrective action response. Okay. So you have to do something. Where's the corrective action. You didn't do a corrective action.

Okay. We need to go find out what's going on in the facility. Let's go find out where this was swabbed and the auditor would go and see, is there standing water there? What's going on? And that would be a huge nonconformance. Why wasn't that done?

Francine L Shaw: Yeah, the fact that they are doing no corrective action. In particular, in a company like that just boggles my mind.

Matthew Regusci: Totally agree, and it's the same strain as well. It's the Salmonella Cubana. They've been finding it consistently in their facilities since 2020. Now it'd be very different if it was Salmonella Cubana in 2020. They went through, they ozone the hell out of the thing. They just seek and destroy. They found it.

They got rid of it. And then boom, another Salmonella came up someplace else. Or two years later it came back again and they're like, is that in the same spot? Oh shoot. We need to go zap that drain or call someone in to do some major cleaning in here, something.

Francine L Shaw: Or it was this area or yeah, it was a different zone.

It's very disappointing.

Matthew Regusci: It's disappointing. I love every single product Pepsi co creates like half of my fricking pantry is Quaker and Pepsi products. So it's just disappointing. Is this going to make I buy PepsiCo products? No, I'm still going to buy PepsiCo products because I know this is just a one off positive about that.

I assume it's a one off problem and they're going to figure out how to fix this moving forward. And this is going to be a great example of what not to do for every single facility. They probably are like cracking down and making sure that they're not missing corrective actions. I hope so.

Francine L Shaw: We know there was a big smack down that happened there.

We feel relatively sure. We know that as a whole, they have a good food safety culture. Did that particular facility have a great food safety culture? It does not seem so. As a whole, PepsiCo has a good food safety culture. That particular facility does not seem as though they did.

Matthew Regusci: Well, it's shut down now.

Francine L Shaw: Well, and what does that indicate? That indicates that they're probably not going to tolerate that going on for whatever reason. Is that how they decided to handle it? This went on this long, we're not dealing with it, or what were the reasons they shut down that facility? Was it old? Was less expensive to shut it down than to do what needed to be done to bring it up to par?

Or was it just, we can't deal with this and take the risks of continuing to operate in this facility?

Matthew Regusci: Great question. And it's, it just goes to show it doesn't matter how big you are or how small you are. Food safety is food safety. Everybody's battling with the same problem. They're battling with the same pathogens.

There may be a genetic strain that's unique to your facility, but ultimately it's still going to be salmonella, E. coli, listeria, something like that. And everybody can make the same mistakes, right? You can have a program that tells you, you create a program with lots of different SOPs, standard operating procedures, And you could be logging a lot of different stuff, but unless you're doing the appropriate steps with corrective actions and all that, this could be you.

And if you're huge, like PepsiCo, what are your facilities doing? If you have a dozen, a hundred, 200 facilities, how positive are you that each of those facilities are abiding by what your expectations are at the corporate office?

Francine L Shaw: Ever as strong as your weakest link,

Matthew Regusci: whatever

Francine L Shaw: that may be, that's you're only ever that strong.

Matthew Regusci: Every other PepsiCo facility could be ticking like clockwork. Their SOPs could be awesome. And we're having this conversation today because of this one facility.

Francine L Shaw: Right. And whatever the weakest link in that one facility was, somebody was a decision maker that made that decide.

Matthew Regusci: Such a good point, Francine.

Francine L Shaw: That was somebody's decision. Whether they saw it, overlooked it, didn't pay any attention, or it was just a culture within that facility that they got away with for four years. And it's affecting all of PepsiCo.

Matthew Regusci: And they were in my pantry. Those skews were in my pantry.

Francine L Shaw: I thought you meant PepsiCo was in your pantry.

Matthew Regusci: They were. What did you have next for us?

Francine L Shaw: Hand washing. People always forget their thumbs.

Matthew Regusci: They forget their thumbs.

Francine L Shaw: When they wash their hands, they forget to wash their thumbs. They wash their hands and their fingers, but they always forget their thumbs. So, handwashing became a key to preventing disease in like the mid 1800s, like around 1840.

It was actually controversial.

Matthew Regusci: So you said it started back in 1840?

Francine L Shaw: The 1840s. Yeah. A Hungarian doctor, Ignaz, I'm not even going to try his last name, noticed that women whose babies were delivered by doctors who worked in a mortuary doing autopsies before going to the hospital were far more likely to die than those treated by midwives who only worked in the hospital.

Matthew Regusci: Wait, hold on. What? People that were working with dead bodies were then like, Oh, we got one coming.

Francine L Shaw: Delivering babies.

Matthew Regusci: Let me go and deliver.

Francine L Shaw: On the living the same day you work on the dead. Just saying. Holy cow. Those babies were more likely to die than the women who just worked on the midwives who only worked in the hospitals.

He believed that they were passing germs to the mothers and implemented mandatory hand washing. As a result, the mortality rate in the maternity ward plummeted. Father of hand hygiene.

Matthew Regusci: Fascinating. So the study was done with delivering babies. That is interesting. So they were able to see a huge difference in mortality rate and that they made the assumption or conclusion that it was based on washing hands.

One, maybe you shouldn't work on dead bodies right before you go deliver babies. But if you do wash your hands.

Francine L Shaw: Wash your hands, demonstrate the positive impact of handwashing and publish papers on the subject. But doctors continue to condemn the theories. Wow. So yeah, interesting, isn't it?

Matthew Regusci: That is fascinating.

So do we know when handwashing became universal? When all of a sudden the doctors were like, Oh, actually this is something that we should be doing all the time.

Francine L Shaw: It says here that the importance of everyday hand washing was not recognized until 100 years later. It wasn't until 1980s that hand hygiene was officially incorporated into the American health care.

It was the first national hand hygiene guidelines. I'm going to tell you, Matt, when I first started working in the industry, and now that I read this, I say this all the time, when I first started working in food service, they did not talk to us about washing our hands. That was in the 70s. Wow. They did not talk to us about washing our hands in the hand washing sinks.

We had one in the entire restaurant other than in the restrooms. Wow. Isn't that interesting?

Matthew Regusci: And so now it is really interesting because you and I both slid into food safety on our rear end. It was like we were at the college and we're like, Hey, we're going to do food safety, right?

Francine L Shaw: This is my dream. This is what I want to do forever and ever.

Amen. Even though it's important. And I love what I do. It was not,

Matthew Regusci: it really truly is. A new phenomenon, and it's hard for us to, we can't forget that we're just having this conversation about PepsiCo and the corrective actions. But really, all of that is only a couple of decades old.

Francine L Shaw: There's still a whole world out there that does not see the importance of it.

Matthew Regusci: And we're still trying to convince people to wash their hands today. It's going to be, what do you think, another generation before that totally becomes ubiquitous?

Francine L Shaw: If not more, because there's so many different facets to food safety. Thank you From farm to fork, there's so many different facets to food safety.

It's probably going to take another hundred years, but I'm not going to see it in my lifetime. And I don't think you will either.

Matthew Regusci: Yeah.

Francine L Shaw: I think we make more and more because of the advocates like Al and Darren and us that are out there and preach and talk about this every single day. But I don't think that we're going to see significant changes in our lifetime.

We will see change. But it happens so slowly.

Matthew Regusci: We are going to see a ton of change because we've already seen a ton of change. We will continue to see a ton of change, but for it to just be, you and I talk about food safety culture all the time. In fact, you and I are going to have some projects that we're going to be announcing soon about food safety culture that we're going to be doing.

I don't see that every facility having food safety culture, any type of, we're still trying to get them to provide corrective actions. For some environmental testing, but in a PepsiCo plant,

Francine L Shaw: this is what needs to happen. They need to not be afraid to let people talk about the truth on national stages and quit talking about the same things over and over.

They need to let people be more open about when you say

Matthew Regusci: who is the day,

Francine L Shaw: the national organizations, people like the food safety summit. And I F P and the National Restaurant Association. They need to be willing to let people speak. About to not be afraid of a not controversy, but to talk about things that will instigate change.

Matthew Regusci: Yes.

Francine L Shaw: And everybody's so afraid of just even a little bit of controversy. And I'm not talking about bad controversy or negativity. I'm talking about things that consumers want to hear about things that consumers want to see change. And everybody's so afraid of what industry is going to think. But I think industry really wants to know that they're afraid to have these topics discussed.

at the conferences. These conferences are very good conferences and I attend them, but we always talk about the same things by the same people who are very good people. They're my friends.

Matthew Regusci: You're right. And it's a lot of the conferences. The talks are like big picture platitudes. This is why you should do this.

This is how you do this, but it's big picture stuff. Let's let's diagnose what happened in this facility. And what decisions could have been made when to make sure that this didn't happen again. Like, really diagnose. Individual outbreaks, individual recalls, individual issues that didn't even lead to an outbreak or recall because they found it.

Understanding that what we just did right now with the Quaker Oats, just that case study alone, it may be helpful for one or two facilities that are listening to us.

Francine L Shaw: Well, and let's break this down and make it meaningful for some of the people that are on the ground.

And the people that are running these companies should already know

Matthew Regusci: that's the problem too is getting down to a so you and I know some of the executives at PepsiCo, why? Because they go to these conferences that you and I go to, but that facility food safety manager, are they going to them? Probably not.

Sometimes if you look at the list of conference attendees, it's one or two people from these major companies

Francine L Shaw: we're talking about.

Matthew Regusci: Yes.

Francine L Shaw: It depends. Are they at the food safety tack? No, are they at the food safety summit? Some of them are. So it depends on what conference we're talking about. You have to know your audience and who's attending what conferences and would they be there if the topics were different.

Matthew Regusci: Yeah,

Francine L Shaw: so anyway, so. Is hot water better than cold water when it comes to washing your hands? What do you think? No.

Matthew Regusci: Oh, there's no difference? One of the audits I was at, they were talking about the reason why you use lukewarm water versus cold water is because they don't want to wash your hands super cold water for a long period of time.

So having warm water makes it more convenient for you to wash your hands.

Francine L Shaw: Which makes good sense, but it's friction and rinsing that are critical to removing harmful bacteria from your hands. Another fallacy. It doesn't have to be antimicrobial antibacterial. There's little benefit to using antibacterial soap for hand washing over plain soap.

Soap works because it's made up of molecules with different ends. End of the soap molecules attached to the water, while the other end of the soap molecules attached to the grease and dirt. I thought that was really fascinating. Drying your hands is very important. You need to dry your hands. Paper towels are better than air dryers because using paper towels helps pull off.

any of the bacteria that might have been missed by washing them. Hand sanitizers are not better than washing your hands. Soap and water is better than hand sanitizer. But if you are gonna use hand sanitizer because there's no soap and water available, make sure it's at least 60 percent alcohol. And 20 seconds is the magic number.

Wash your hands for 20 seconds, making sure that you get all of your fingers and your thumbs.

Matthew Regusci: Don't forget your thumbs.

Francine L Shaw: Don't forget your thumbs and make sure if you have nails, I could harbor enough bacteria under these nails to kill a small country. Make sure you get underneath your nails.

Matthew Regusci: Yeah. My wife works in the NICU, which is like a neonatal ICU.

So ICU for baby. She can't wear anything. She can't wear nails. She can't have nail polish. She can't have rings. So she tattooed her wedding band on her finger. Because, yeah, that's very bad. Those nails. You literally could kill a baby with those nails, right?

Francine L Shaw: I read a story one time about a woman who did.

Matthew Regusci: Yes, it's like a case study for all of them. All right, that was very interesting. And on that note, don't eat poop. Wash your freaking hands.