By Lisa Lupo
Photos by Keith Barraclough
On December 11, 2017, the Public Health Agency of Canada identified romaine lettuce as the source of an E. coli outbreak in Canada; on December 28, the Canadian agency advised consumers to eat other types of lettuce until more was known about the outbreak and cause. Concurrent investigations of a similar outbreak in the U.S. showed that the type of E. coli making people sick in both countries was closely related genetically, but neither FDA nor CDC were making any announcements or advisories. In fact, CDC’s first media statement came out December 28, but stated, “Because we have not identified a source of the infections, CDC is unable to recommend whether U.S. residents should avoid a particular food.”Thus, it was Consumer Reports (CR) who first advised U.S. consumers in early January to stop eating romaine “until the cause of the outbreak is identified and that product is removed from store shelves.” While CDC and FDA were pausing, the team of food safety and food science experts at Consumer Reports decided to take a stance. Based on Canada’s identification of romaine as the source, the limited information available from CDC and FDA, and the 58 people in the U.S. and Canada who had become ill from the strain of E. coli with infections occurring in 13 states, CR’s Food Safety Team said, “We didn’t know where it was coming from, or exactly what it was ... but rather than pausing and shrugging, we said, ‘Let’s stop eating it.’”
While CR is better known for its research and reviews of goods — such as the latest in automobiles and TVs — the nonprofit organization has a team of food safety, food science, and nutrition experts whose sole role is to advocate for and inform consumers on all things food. As with all its research, the goal is to inform consumer purchase decisions, improve the products and services that businesses deliver, and drive regulatory and fair competitive practices.
It was that very focus — on everything from consumer advisories (e.g., the romaine advice) to in-depth investigations of specific foods (e.g., heavy metals in baby food) to general quality and nutrition (e.g., breakfast bar comparisons) — that took QA to Westchester, N.Y., to meet with CR’s food safety team, learn about its work, and discover what the food industry should know about the organization’s research and testing “devoted to consumer interests.”
AT THE HEART OF CR. Although it may not be CR’s best-known area, “food safety goes all the way back to our first issue,” said Chief Scientific Officer James Dickerson. Back in 1936, Consumer Union Reports (as it was then called) reported on milk, finding that the only real difference between grade A and grade B was its price, and that even some pasteurized milk contained bacteria. “It was based on food safety even then, and goes to our fabric of trying to protect consumers,” he said.
“We’re not talking just literal safe consumption of food, but also the safety of the food itself,” Dickerson said. If something is not done right, if it does not protect consumer health or the overall safety of individuals or communities, it is of concern. Thus, CR has a multi-pronged goal:
- Helping consumers know more about what they know and don’t know about their food.
- Addressing various parts of the supply chain for consumers, with consumers, and on behalf of consumers.
- Applying the philosophy of safety to food.
- Focusing on the most significant consumer impact areas.
- Providing the acquired information to consumers to allow them to make intelligent purchasing decisions.
“I think that there is very little testing, communication, or advocacy done at the consumer level, so Consumer Reports provides a very unique lens on what the consumers are bringing into their homes and consuming,” said Food Safety Research and Testing Director James Rogers. “We bring this to them, along with alternatives.”
FOOD SAFETY TESTING. Having conducted food safety testing since its founding, CR research has been involved in some historical issues, such as that of the 50s and 60s on the effects of nuclear fallout on food, and its 70s pollution research which played a key role in the enactment of the Safe Drinking Water Act, said Food Safety and Testing Program Leader Tunde Akinleye, who has been with the organization for 30 years.
Although it has always been a part of the organization’s research, it was in 2012 that food research and testing became its own department. “Food safety was moved out of the traditional food department because we felt it needed its own department and needed more advocacy,” Akinleye said. A further reorganization in 2016 brought in Dickerson and Rogers.
Most testing for food safety involves the presence of something that shouldn’t be in it, Rogers said. But determining just what the next test will involve starts with a team brainstorming session. “We start with a group meeting where we talk about different foods, trends, and issues, then we make a risk-based decision on what to test, report on, and advocate for,” he said.
- Once the team has conducted its risk assessment and settles on a target (e.g., heavy metals in baby foods), it determines the scope and methods of testing to be conducted. Research is conducted to select the specific products to be tested (e.g., brands and types of baby food) focusing on foods that are readily available, preferably on a nationwide basis (unless a local test is being conducted).
- The products are then purchased exactly as consumers purchase them — at retail and/or online, buying from at least three lots of each item to be tested. CR does not accept samples from manufacturers as it wants to ensure it is testing the same items a consumer would purchase at retail. Once purchased, the products are blinded.
- Consumer Reports has 63 state-of-the-art labs and 140+ testing experts, but most food safety testing is sent to third-party labs. Those labs must meet stringent requirements, including being ISO certified, having a successful track record of the type of testing to be conducted, and usually having worked with Consumer Reports in the past. The CR food safety team is in constant communication with the labs, conversing at least once a week. Additionally, all food testing uses the regulatory agency methods as a base. Because, Rogers said, “When we go to FDA we can say we used your method, and our results will be more accepted by the regulators and manufacturers.”
- The resulting data is then matched with the blinded code so the products are revealed. The data is analyzed and a risk assessment conducted to determine if the resulting levels pose a risk (e.g., amount of heavy metals detected and risk to babies/children). Age ranges and consumption combinations are analyzed.
- From all this, CR writes its report. While there is a strong focus on the data, the articles in the magazine and online also include recommendations. For example, if one product is found to be particularly risky, alternatives are proposed.
- At this point, the organization also determines whether the results will be accessible only by CR paid members or the public. “When there is a significant health issue, we put it in front of the (website) pay wall,” said Associate Director of Communications Douglas Love. The baby food research, for example, is in front of the pay wall detailing the problem, the findings, and alternatives for the products found to be most at risk.
MANUFACTURER INTERACTION. There is, in fact, one additional step between 4 and 5. Before publication, CR will contact the manufacturers of products included in the testing, stating, for example, “We’re going to publish an article on heavy metals in baby food on [date] and your [XYZ product] was included in the testing. Here are the findings on your food; do you have any comment?”
The purpose of such communication is two-fold:
- To give the manufacturer an opportunity to comment in the article on the findings.
- To serve consumers by informing the manufacturer of an issue it may not know exists and enabling them to correct it in future production.
When such corrections are made, updates will be included in the online product reviews. When asked if CR’s team follows up with manufacturers after publication, Rogers replied that the topic had come up in the team meeting that very morning — “We are discussing doing follow up after testing to see if the problem is fixed,” he said.
When subsequent CR testing does determine corrections are made, or a manufacturer informs the organization of correction (and it is verified by CR), an update will be made to the online review of the product.
The team also interacts with state and federal agencies and policymakers when applicable, sharing its testing data to invite comment and show the need for regulatory reforms and greater protections for consumers in the marketplace.
For example, as explained in the CR article, “Heavy Metals in Baby Food,” when the organization informed FDA of its findings, the agency stated that it has “made this a priority and is working to reduce the health risks these elements present, especially to those most vulnerable: children.” In the article, FDA said it also:
- “Plans to consider a wide range of policies and actions to reduce exposure” (e.g., educating consumers on how to reduce the risk and requiring or encouraging industry to lower the amount in products).
- Is looking into the risk posed by foods with multiple toxic metals.
- Is working to identify products “for which these combinations are most prevalent, and exploring options for dealing with the issue.”
Consumer Reports also recently reviewed the USDA FSIS data and reporting on drug residues in meats on behalf of several food safety organizations.
CR’s analysis of the data indicated that there was a higher degree of trace amounts of banned or severely restricted drugs in meats than were included in FSIS’ final report. “We believe the program was intended to test the kidney or liver — where drugs are retained longer; but FSIS tested the muscle because that’s what people eat,” Rogers said. “So we felt they were not being totally honest.”
Even with its advocacy, however, Consumer Reports understands that there is a necessary balance between consumer need, manufacturer capabilities, and regulatory requirements. But when something can be done for consumer safety, it should be done. “Whenever we have one manufacturer achieve, we ask, ‘Why can’t they all?’ and ‘What does the latest science show?’” Rogers said.
“Consumer Reports works on behalf of and with consumers to make this marketplace safer and fairer. But we also work with other parts of the marketplace,” Dickerson said. “We welcome working with other parts of the marketplace; we openly work with everyone.”
FOOD RANKING AND LABELING. As a registered dietician and nutritionist, Program Leader Amy Keating leads CR’s nutrition food ratings projects. As do many food manufacturers, Consumer Reports uses sensory panels in its food testing. But there are differences. CR’s panel members are hired specifically as sensory panelists — though they may be testing ice cream one day and strollers the next. As such, they receive in-depth and ongoing training and calibration. “The panelists are trained, but you also need to calibrate them,” Keating said.
To ensure an objective, scientific outcome, the panel’s responses need to be absolutely objective and analytical, not based on individual preference. Thus, through the training and calibration, the panel’s responses become about the quality of the product.
For food, for example, it is about the individual ingredients and the blends, with taste based on the objectivity of standards, such as a flavor wheel. Then it becomes about “number crunching” to compile the distinctive Consumer Reports’ ratings tables for the products.
While manufacturers also focus their sensory panels on quality and flavor, their ultimate goal is generally consumer preference vs. scientific qualification. Thus, the preferences of a panel will be important. Consumer Reports does not discount that, however. While it does not rate products as good or bad, it does rank them against each other. And, with food, Keating said, “Taste is the biggest factor, so we always marry our ratings with taste.”
Along with analysis of what is in the product is analysis of what is on the product, that is — the label. Take “natural” label wording as an example. As Rogers said, “If you’re going to use labels or designations, be sure it really means something, or don’t use it.” But what is that something?
In 2014, Consumer Reports filed a petition with FDA and USDA asking the agencies to develop a regulation for natural, said Senior Policy Analyst Charlotte Vallaeys who focuses on CR’s labeling research. Holding master’s degrees in nutrition science and policy and in theology, she said, “It is the combining of those two that brings me to food labeling and the ethics behind it.”
The organization’s was one of three petitions filed, with the other two coming from the food industry, she said. “It benefits the industry to have a solid definition,” she said. Not only can consumers be misled by unsubstantiated labeling, but competitors who are both using the claim may be basing it on completely different meanings. So, she said, “It also benefits the industry to have consistency in claims.”
To assist in this consistency, Consumer Reports Greener Choices group, led by Vallaeys, provides a check on, and consumer information about, the claims and seals on food packages. Its website includes a page dedicated to the “story behind the food,” featuring an image of the label or verbiage of a claim, discussing its meaning, and informing consumers as to whether it actually provides value.
“We ask questions of every seal we review,” she said, with focus placed on if it is backed by strong, verifiable standards and if it actually exceeds the industry norm.
As with other CR research, the team goes out into the marketplace to find labels that are actually appearing on food. And, as with all Consumer Reports research, Vallaeys said, “We make it as objective as we can, while recognizing that we work for and with consumers — Are they getting what they expect?”
The author is Editor of QA magazine. She can be reached at firstname.lastname@example.org.