|Picture from http://www.northstarseafood.com/|
JoNel was a pleasure to speak with. We discussed a process many are not familiar with - "reconditioning."
Reconditioning is a process whereby products currently NOT in compliance, are brought into compliance. This applies to ANY FDA regulated product, can be cosmetics, foods, medical devices, dietary supplements, etc.
The story came up when JoNel was investigating moldy applesauce. No one wants to think the foods they consume are not safe, who can blame us!
Reconditioning does not mean we now consume unsafe products, it is a process whereby adulterated and misbranded products can be brought into compliance. Here's an example of misbranding... a label that is not in English can be "reconditioned" - i.e., a new label in English can be put on the product -- in this case, a non-compliant label in Spanish would not be considered compliant (but, once you put an English label on you can sell it in the U.S.).
Reconditioning gets more interesting when you talk about adulterated products - basically products that contains any poisonous or deleterious substance. Most seafood consumed in the U.S. is imported. Some may enter the U.S. decomposed -- now, think of this. You are a small importer of frozen seafood, and pre-pay for your product. As your seafood enters the U.S., the FDA stops your seafood, and samples a portion of it. FDA finds that your seafood is decomposed and advises you of this fact. Now, here are your options, you can destroy all of it, and lose all the money you put into it -- and try to recoup whatever you can from your supplier (good luck!)... You can export it to another country... Or... You can "recondition" it - in this case, it may mean sending your product to a private laboratory, having that lab test and find out exactly which portion of your product is decomposed, and which portion is still safe for consumption and not decomposed. Basically, you'd file your proposal with the FDA (Form 766), once approved by the FDA, you can begin your reconditioning process. Once complete, you advise FDA, and FDA would review the private lab report to assure the product really now is safe for human consumption. The process is outlined here.
Here's what I had to say about reconditioning!
Many producers faced with faulty food simply want to minimize their losses without harming public health, said Peter Quinter and Jennifer Diaz, lawyers with the Florida firm Becker & Poliakoff, which represents importers of foreign food.
Such firms want to avoid having product refused, so they go to great expense to salvage products such as insect-infested rice for future consumption, Diaz said. Grain products can be sifted, re-inspected, repackaged – and sent on to grocery stores.
“Taking the ick factor away is that the product is no longer contaminated,” she added.