Peanut: Cumin Recall (The Big Thread)

[starlight]

In the Peanut Allergy and Anaphylaxis Awareness group on FB, someone wrote to Chipotle and Chipotle told them they use a different supplier that hasn't been affected by the recall. 

[CMdeux]

Thanks for that.

I'm going to collect up some food-service links and place them in a thread down in restaurants re: cumin-- I'll link to it here.

food service/restaurants and cumin recall

[starlight]

Thanks for that.

food service/restaurants and cumin recall

You're welcome. It's a closed group, but for anyone concerned, join the group and then use the search box for Chipotle. it's in the comments of the question about the cumin. the woman who contacted them copy/pasted the entire message with the service rep's name.

I also left a comment on Taco Bell's FB since they seem responsive. I'll post back if I hear anything.

CM, you may want to add Del Taco to your other post - I ate there last time I was in California, everything was peanut-free including desserts.

This whole thing is making me want a taco. 

[guess]

This is so, so scary.  It's getting bigger, just as we feared. 

I'd like to tease things out.  It seems to me that there are three US suppliers of the cumin. I think Adams and Schiff are separate.  I could be wrong about that, though. 

Schiff Foods
Schiff Foods Products Co., Inc.
994 Riverview Drive
Totowa, NJ 07512
Phone # (973) 237-1990
Fax #      (973) 237-1999
Email: Sales@schifffood.com

Adams Extract
Adams Extract & Spice LLCDirections
Address: 3217 Johnson Road, Gonzales, TX 78629
Phone:(830) 672-1850     (512) 359-3035

Con Yeager Spice Company
144 Magill Rd
Zelienople, PA 16063
(800) 222-2460
For a full listing of Con Yeager products affected, including some which have individual threads here, see the  exhaustive table on the FDA website: http://www.fda.gov/Safety/Recalls/ucm429688.htm

Adams hasn't named their third-party supplier/wholesaler. 

Con Yeager has-- it's Golombeck.


I'm guessing that Golombeck and Schiff are at roughly the same level on the supply chain-- so that probably means an imported primary supplier behind both.

I would love to believe that this is a single unscrupulous Latin American (probably) supplier of cumin who is "cutting" the product-- in the same exact way that melamine was used as an 'additive/filler' a few years ago in China.

Because the alternative is that it's common practice from a supply region.  {shudders}

Just using what was written as reference because it gave me enough to go on.

Golombeck is a wholesaler importer of record.  A lot of companies who use product do not want to enter it themselves.  They don't have the in country ties, the freight forwarder relationships, don't want to deal with supply chain, don't want to deal with the entry paperwork or the risk of having product on hold, fines, you name it.  Here's where your Golombeck or other trading company comes in.  For spices they aren't really bulky compared to say television because the product has more of a dimensional weight than per unit.  Likely that means LCL (less than container load) puzzled together with other items. 

I've personally only ever entered non-food products like aluminum frames, steel, and LCL grab bags of oriental trading like goods. However the Harmonzied Tariff Schedule is very specific about subtypes requiring the application of essential characteristics.  See below.

0909        Seeds of anise, badian, fennel, coriander, cumin or caraway; juniper berries:
0909.21.0000                          Seeds of coriander:
0909.21.0000                          Neither crushed nor ground
0909.22.0000                          Crushed or ground
0909.31.0000                          Seeds of cumin:
0909.31.0000                          Neither crushed nor ground
0909.32.0000                          Crushed or ground
0909.61.0000                          Seeds of anise, badian, caraway or fennel; juniper berries:
0909.61.0000                          Neither crushed nor ground
0909.62.0000                          Crushed or ground

I'm betting one of these two:

0909.31.0000                          Seeds of cumin:
0909.31.0000                          Neither crushed nor ground
0909.32.0000                          Crushed or ground

For example here's a bill of lading for Golombeck.  This is all open source information.

Sample Shipment Record
AL MEHTAB TRADING CO LLC
P O BOX 6354, DUBAI, UAE TEL 971 4 2262145 FAX 2263369
sells to

MORRIS J GOLOMBECK INC
960 FRANKLIN AVE, BROOKLYN NY 11225U S A TEL 707963 551 FAX 707 963 1270

Arrival Date: 2008-01-18
Number of Containers: 1
Gross Weight: 24970 KG
Quantity: 454 PKG
Product Description: CUMIN SEEDS

They're not going to have a sole relationship with only one export supplier so even though you can see in 2008 Golombeck entered a shipment from UAE trading company that doesn't tell us much then nor now.  I didn't see the country of origin on there I don't even know if it was sourced UAE.  That's just the trading company exporter.

The point is no one is going to know if what they have is tainted because Golombeck isn't the supplier in the sense that he's the importer of record, unless the company further refines the product itself but there's equal chance they never see or handle the product they just handles shipment and entry then forwards.

A recall this size must be colossal in terms for cost so that leads us to a good number of smart W questions.

Why was peanut suspected?  Routine testing or other?
Who uncovered the contact?  Reports all say no reported illnesses.  Are we sure?  Then who thought it had to be peanut, and then confirmed it through testing?
When in the supply chain did this happen?
Where in the supply chain did this happen?
What does this recall mean?  Considering the cost it had to be gross amounts at the least.

If this was an issue within US manufacturing once the spices officially entered US commerce by the importer of record and out of that importers hands, then there's some hope of tracing.  A lot of ports of entry aren't even owned and operated by the US but under foreign owneship.  Last I was in the field it was Dubai/UAE was in the market to buy and operate quite a few US terminals.  So, you're not going to find out much at the terminal (like if it was stored next to peanut), or from the freight forwarder who may have 'puzzled' it in to fit a few LCL shipments together in one container.

If this happened pre-import, pre-terminal storage or transfer, pre-container load then all bets are off.  The most valuable tool they could give to us now is to give transparency on how it was determined, when, and by whom that peanut was present and what amount.  The hot potato of sourcing goes to a place we might not ever find despite knowing the exporter, importer and country of origin that appears on the paper.  It could have been an over the border transshipment that while not allowed, does happen often enough for a number of reasons.

Say it is Schiff that has a product that does not specify another country of origin on its label.  By law if a product undergoes a category shift that is not mere assembly it can then be considered a product of USA origin.  I'm not sure what grinding would constitute in this case (as stated didn't work with food don't have regs in front of me) but a ground spice mix like Ortega taco seasoning may have had cumin seeds that entered whole then were ground and added to other ground spices and other ingredients to make the taco seasoning.  Parts of foreign origin undergoing category change = new product with new country of origin. 

[CMdeux]

  The most valuable tool they could give to us now is to give transparency on how it was determined, when, and by whom that peanut was present and what amount




Absolutely.      That's PRECISELY what I'd like to know.

The only answer that makes any sense at all to me is deliberately adulterating a ground product, in which case.... yeah, where on the supply chain this occurred becomes super-pertinent info to me personally.


I keep going to some rather scary places in my own darned head over this.
_{Honestly, cilantro just isn't that hard to grow, and it has no problem producing seeds for ya.} 

[Macabre]

Well, what I want to know most is exactly which products have it. NOW.  Not two weeks from now. And exactly where else it has been used (restaurants).

[guess]

All related to the W's.  Because you can't trace what isn't established.  If it was a result of tampering to bulk at source that's one thing.  If it happened here somewhere past that entry into US commerce there's a good chance of fencing it in.

I'm no more or less concerned than I ever was, especially without any idea who performed testing on what and why.  Maybe someone in the lab had a PB&J for lunch or the equipment was tainted, or the samples mixed up or a false positive.  I need more information.

The only answer that makes any sense at all to me is deliberately adulterating a ground product, in which case.... yeah, where on the supply chain this occurred becomes super-pertinent info to me personally.

Eh, possibly.  I'm not sure it would have the same texture although a funky texture and color may be a reason someone was motivated to test it, assuming that was the case and it was not routine testing.  That's too much assumption for my tastes given the complexity.  What gives me pause is how much was voluntarily recalled.  Maybe there was some nasty bacteria found as well as peanut. 

It's why I don't call on a lot of products of foreign origin like Rao's sauce or seaweed or US trade company branded products like Eden.  Pointless.

[guess]

recall was initiated after it was discovered that the peanut-containing product was distributed in packaging that did not reveal the presence of peanuts.  Subsequent investigation indicates the problem was caused by contamination of the product from its country of origin.

Con Yeager Spice Company was notified by the supplier Morris J. Golombeck Inc. that the ground cumin product had tested positive for traces of peanut protein.

Messy cut and paste on the go.  All the basics are there.  Country of origin, routine testing sounds like, responsible importer reported results.

It would be nice to know if the testing is an industry standard or is importer exceeding standards.  It would be useful to know how testing is performed and what the results were in detail because if this was purposeful bulking it's an important distinction.

[eudaemon]

My question is related but more general.  I have long wondered, as a parent of a PA kid, if a food manufacturer DOES suspect contamination, why should I trust that they will do anything?  For some of these corporations that would mean a huge financial loss.  Packaging is usually ordered years in advance, so they are not going to change the packaging which contains the ingredients and allergen statements.  So they are really just going to throw out all that food, which in there eyes is money?  Does anybody else share these doubts?

This is why I try to only buy stuff that is from a nut free facility and not merely a "dedicated line"  because unless they have a program in place, why would they test for allergens?  and if they don't, how would they know if their dedicated line is contaminated?  And in this case with cumin, I'm not sure all nut free factories verify or check the provenance of their spices.  So... aaaaagh!

McCormick spices has told me that all there stuff is processed in a nut free factory.  But I imagine they must share the same suppliers as the rest of the world, so do I stop trusting McCormick?  I think I am getting a serious headache over this.

[guess]

I can break it down later on supply chain highly complicated through import regulations but the term manufacturer in this case would not be the supplier, broker, or importer - though they can be more than one.

If a properly entered item undergoes a shift in the Harmonized Schedule it then shifts country of origin to where it underwent the change. I need to at least try to track down one of those recalled products in store or find online to see how it's labeled.

[guess]

Finally on a computer. 

The short answer is I'm not aware how food products are tested as they enter the country's commerce - which is not the same as they are not tested.  All it means is that I don't know.  The FDA would somehow be involved as they are for any covered items including sunglasses. To reiterate I never cleared a food item although I have a dusty memory of FDA clearance for a shipment of sunglasses.

Note I use the term commerce.  Entering the country is separate from entering the country's commerce.  How that testing goes on will need someone with knowledge.  Nor do I have any idea, education or experience related to food testing in a lab.  CM might best know how that would take place.

I would hazard a guess that any food item entering would have to undergo routine testing for safety to make sure it's what it says it is beyond safety into genuine or fraudulent.  This is where it gets interesting because the regulations regarding the responsibilities for the importer of record are s-e-v-e-r-e.  Being an importer of record is extremely high risk, and the more you come under the attention of ICE in a not good way the more likely you are to face civil and criminal penalties.  There's no end to the civil penalties and they can accrue very rapidly.

Which leads us to the cost associated with this recall.  I would assume with great confidence that the FDA & ICE got this party started less under contact for allergens and more for bulked, misrepresented product.  If I were an importer of record that's what would have me quaking in my boots even if everything I did was by the book.

What we do know was that imported almond powder into the UK mislabeled almond powder by the country of origin supplier was bulked with about 50% peanut powder probably because it's cheaper.  The restauranteurs had no idea what they were using going by the product label.  Only testing uncovered the product tampering. 

Could this have been what was done with a spice that is expensive in dimensional weight compared to peanut?  Maybe.  The contact was traced to country of origin, the trade company from the country of export (not necessarily country of origin) did not disclose peanut innocently or no, and it was entered as such. 

Those are fair questions you raise, eudaemon.  Where, when and how often is testing taking place?  Precautionary testing might happen much more than we know as end users.

In your McCormick example I believe them when they say their manufacturing facilities are nut free and to be fair that is an accurate statement.  As a manufacturer of finished retail product they are dependent on the system of checks and balances for safety, purity, disclosures before the bulk ingredients reach them.  There isn't much they can do beyond what is under their segment of allergen management control in the chain from crop to dinner table.

Why would they recall this much considering how much of a financial hit companies are taking across the board?  If I had to come up with an answer without knowing more it infers that the 'contact' wasn't just contact but rises to the level of fraudulent product.  Wild, wild guess.  I truly don't know.

[guess]

Or... before I light up the internet in conspiracy it might just be a source manufacturer that processes peanuts and cumin.

There are different trade markets where importers can find exporters, sort of like a dating site.  Alibaba is one of them please see the supplier example below.  This supplier offers peanuts, cumin, coriander and sesame in whole form.  It may have been lack of allergen management on the primary export source end, nothing more. 

http://www.alibaba.com/product-detail/Peanuts-Cumin-Seeds_101420237.html

[guess]

One more thing.  I emotionally wrestled with this because my intention is not to spread panic or instill anger but you all have the right to know, considering.



This is an image distributed of one of items in recall.  Note the product is labeled "Made in U.S.A.".  This is what I referred to earlier that when a product enters the commerce undergoes a process that causes a category shift in the Harmonized Schedule it is then legally considered a product of that country, hence it has a new country of origin.

It is the same for the other recent recalled ground cumin product under the brand La Flor.  The label of that packaging read Made in the USA.  It's legal but a little shady in marketing practice.  An item of USA origin for sale in US commerce does not need to be labeled for country of origin because it is a domestic product.  Therefore putting a mark that it is made in USA is not only unnecessary but is not really honest with a consumer -- though I repeat it is legal.

If these labels are current and accurate that would lead me to believe that the cumin entered the US as whole seeds and not ground, otherwise it can't have gone through a category shift.  That's splitting hairs on 'assembly' probably but I guess grinding is considered a process that satisfies a shift.  Again, no experience entering foodstuffs.

Confirmation would involve getting the bill of lading for this shipment to Golombeck.  Although if the reports are true that it was a country of origin contact then it implies not USA origin because that is considered a domestic product.

[guess]

Posting from FDA's site with current label prominent with Made in USA mark.

In 1996 the FTC[1] proposed that the requirement be stated as:

It will not be considered a deceptive practice for a marketer to make an unqualified U.S. origin claim if, at the time it makes the claim, the marketer possesses and relies upon competent and reliable evidence that: (1) U.S. manufacturing costs constitute 75% of the manufacturing costs for the product; and (2) the product was last substantially transformed in the United States.[2]

Wiki is the best source I have on a pressed schedule. 

[Macabre]

Penzey's

Stinky sent this email to me in case I could post it before she could.big typically don't post employee contact info, but in this case I'm going to. I think need to know who is telling us what in this situation.

From: Emily Barbeau [mailto:emily.barbeau@penzeys.com]
Sent: Monday, January 12, 2015 1:36 PM
To: Stinky
Subject: Penzeys Cumin

Hi Stinky,
My name is Emily Barbeau and I work with Penzeys Spices in Wisconsin. I was able to look into your question about our cumin. Our cumin supplier is in India, not Turkey.  Therefore, we were not connected to that recall of cumin at all. Rob, our Quality Assurance director, is requesting peanut-specific information from our supplier.  But, as we are aware right now, our cumin is not affected. Thank you for inquiring. I hope you have a wonderful week. Let me know if you have any other questions. Thanks
Emily Barbeau

--
Emily Barbeau
Penzeys Spices
Retail Operations

Edited to add subsequent email from Ms Barbeau:

The cumin sold at Penzeys currently (January 2015) is from India. 


Please see updated information about what may affect Penzey's cumin in this post:

Re: Peanut: Cumin Recall (The Big Thread)