How Much Food Do Food Recalls Waste?
Or, one of the most esoteric rabbit holes I've ever fallen down and why we should all care about it
The phrase, “How much wood could a woodchuck chuck if a woodchuck could chuck wood,” is playing on a loop in my brain, and I think the only way to get it to stop is to write this and post it and move on.
Towards the end of last semester, we were tasked with a project to investigate a particular issue within our local, regional, or global food system. And I couldn’t stop thinking about how much food a food recall wastes since a food recall will waste food.
I approached it through my lens as a dietitian, with a handful of accepted truths:
Food recalls will occur if the food system works as intended to keep the general public safe from foodborne illness outbreaks and other contaminants in the food supply.
Food waste is a significant issue in America, with roughly 1/3 or more of the food produced for human consumption being lost or wasted.
When food is recalled due to a safety concern, there are only so many options if it can’t be consumed.
So, with recent headlines making it seem like large-scale recalls were happening with more frequency I wanted to know: how much food do food recalls waste? It turned out to be a pretty sticky question. The paper is submitted, and grades are in, but there’s so much more to learn about.
Join me and keep reading if you also enjoy extremely esoteric deep dives in the food space!
A Brief Intro to Food Loss and Waste
When we say, “food waste” you probably think of leftovers scraped into the trash or a spoiled fruit or vegetable tossed onto a compost pile. At the household level, that’s probably pretty accurate. But food loss and waste (FLW) occurs at every level of food production, retail, and consumption. As it’s grown and harvested, as it’s processed and packaged, as it’s sold, as it’s cooked, and on and on.
It’s a big deal. According to the United States Department of Agriculture (USDA) Economic Research Service, an estimated 31% of FLW occurred at the retail and consumer level in 2010. That was equivalent to approximately 133 billion pounds of food with an economic value of $161 billion.
If adjusted for inflation, that amounts to just over $233 billion in today’s money.
Something had to be done, right? Indeed. In 2016 the USDA and Environmental Protection Agency (EPA) jointly committed to the goal of reducing FLW by half before the year 2030. This aligned with the Sustainable Development Goals (SDGs) developed by the United Nations (UN), specifically SDG Target 12.3.
According to the UN, “reducing food loss and waste is critical to reduce production costs and increase the efficiency of the food system, improve food security and nutrition, and contribute towards environmental sustainability.”
The underlying causes of FLW are multifactorial, but I won’t really get into the weeds on that. Maybe that’s a post for another day. There are some really impressive things being done across the food system to address food waste and I think those people and organizations should be recognized and supported.
But for now, I’m focusing on the relationship between food recalls and FLW. The causes and drivers of food recalls primarily take place in production settings rather than the individual or household level. Currently, food recalls are a poorly understood contributor to total FLW in terms of measuring the amount and value they comprise.
In other words, this is an overlooked opportunity to develop more sustainable practices and policies within our food system.
Food Recalls 101
Food recalls are handled by the USDA’s Food Safety and Inspection Service (FSIS). They also issue public health alerts, and it’s important to understand the similarities and differences between a food recall and a public health alert.
Straight from the source (FSIS): A food recall is a voluntary action by a company to remove adulterated or misbranded products from commerce. A recall is intended to protect the public from unsafe and improperly labeled foods.
Some additional context from me: this applies to more than just pathogens or contamination. While these causes often get the most media attention, many recalls actually stem from improper labeling or a missing declaration of allergens. Improperly labeled food may not be unsafe for all people, but if you have a severe, life-threatening food allergy it hardly makes a difference. Some might argue this recalled food shouldn’t go to waste. However, the risk-reward proposition here is simply too risky, so it’s all categorized together under recalls. And for the most part, this system works as intended since the intention is to keep the public safe. It’s not 100% effective, but it’s much, much better than nothing.
The voluntary nature of food recalls is an important aspect, too. Issuing a recall or complying with an FDA-issued request for recall places responsibility on food manufacturers and distributors. The alternative for noncompliance is an FDA-initiated court action to seize adulterated product to prevent it from being distributed, sold, and potentially consumed. Significant legal costs and damage to a company’s reputation are all but guaranteed if noncompliance escalates to this degree.
Meanwhile, a public health alert is issued to inform the public about potential health risks in cases where a recall cannot be recommended. Real world examples include a foodborne illness outbreak without an identified source, or illness due to improper handling of a particular product. In this case, it’s about reminding us to be smart at home and use safe food handling practices.
Shifting focus back to food recalls, there are two major categories: product contaminants and processing issues. They’re further divided into 11 groups and three levels of risk:
Class 1 (most severe): A reasonable probability exists that the consumption or exposure to a noncompliant food product will result in severe adverse health effects or death.
Class 2: Consumption or exposure to a noncompliant food product may lead to temporary or medically reversible adverse health effects, or the likelihood of severe adverse health effects is remote.
Class 3 (least severe): Consumption or exposure to a noncompliant food product is unlikely to cause adverse health effects.
At this point I was thinking that’s more than I ever wished to know about the specifics of food recalls. If you, unlike me, are craving more knowledge about this, check out the reference I used: An Analysis of Food Recalls in the United States, 2002-2023.
That analysis found there were 35,548 recall incidents. During this 20-year period, 91% of recalls were due to product contaminants, with 48% due to biological contaminants. This category also accounted for the highest percentage of Class 1 recalls (80%) compared to Class 2 or Class 3 recalls within the respective categories.
Regardless of the various causes of recalls in each classification category, the underlying drivers are similar:
Ineffectively implementing food safety knowledge into practice.
Incompletely accounting for and controlling human errors
A deteriorating sense of shared responsibility on the part of food manufacturers and agencies that provide oversight.
Impact of Food Recalls on Public and Planetary Health
Food recalls are, unfortunately, not entirely avoidable. As long as humans are handling food, there will inevitably be some human errors. We want to do the best we can, and we want food producers and manufacturers to exceed our expectations. But we also need a reliable and swift method of catching these errors and issuing recalls ASAP.
So while that number might be unsettling (an average of 1700+ recall events per year) it’s actually kind of a good thing. It means the system is working, and that’s 1700+ times food that shouldn’t be consumed wasn’t consumed. I’ll disclose my bias that I think this points to one of many reasons we should not attempt to undermine or underfund these efforts by the USDA.
But all these recalls add up, both for human health and the health of the environment. That’s why we need to pay attention. The Centers for Disease Control (CDC) estimates 3,000 deaths from foodborne illness in the United States each year. This burden extends to 48 million illnesses, 128,000 of which require hospitalization. Pretty serious numbers there, especially considering how expensive healthcare is in this country.
To see a list of current food recalls and public health alerts, follow this link to the FSIS updates. A few recent recalls include:
Approximately 24,870 pounds of frozen chicken and cheese taquito products
Approximately 7,485 pounds of raw pork sausage products
Approximately 167,277 pounds of ground beef products
All of that pales in comparison to the 2,698,101 pounds recovered through last year’s high-profile and extensive Boar’s Head recall due to Listeria monocytogenes contamination.
What happens to all that adulterated or contaminated food? If it’s deemed unsafe to consume it goes to a landfill, where it’s buried or incinerated. This not only contributes to methane emissions (a potent greenhouse gas), but eliminates any opportunity for it to be rescued, repurposed, or recycled. In an ideal FLW mitigation effort, prevention would be #1, followed by efforts to redirect food away from landfills as much as possible.
Generally speaking, an estimated 70-90% of FLW is edible. This doesn’t include food that is truly deemed unsafe, but I share that stat to add some context around how much food goes to waste that may not need to. We lose valuable nutrition and energy. Not to mention all other inputs that are waste at this point near the end of the supply chain: fuel costs, food miles, human labor, packaging materials, energy for cold-storage, etc.
And we can quantify the emissions that result from FLW. Again, generally speaking, FLW produces 170 million metric tons of CO2e emissions each year, or the same amount put off by 42 coal-fired power plants. The embodied scale of annual FLW in the U.S. is 140 million acres (about the size of California and New York combined), 5.9 trillion gallons (which could be used in 50 million homes), and 14 billion pounds of fertilizer (which would be enough to grow all the plant-based foods produced each year for domestic consumption).
The loss of calories would meet the energy needs of more than 150 million people, which is more than quadruple the estimated number of food insecure Americans (35 million). The most commonly wasted foods are fruits and vegetables, followed by grains, dairy and eggs, and meat with the greatest share occurring at the household or consumption level, followed by the retail level. Generally, FLW that occurs further down the supply chain has a greater environmental impact compared to primary production or manufacturing stages.
Not all of that is due to food recalls. But here’s the kicker that kicked me pretty hard: we don’t actually know how much food is wasted due to recalls.
Challenges for Accurately Estimating Food Waste Due to Food Recalls
That’s right. There is no historical record to quantify the amount of food waste that results from food safety recalls.
And this kind of blew my mind because for the most part, there’s an archive of just about any and everything you might ever want to measure or track. So joke’s on me for assuming that would be case here.
But according to Mykayla Cheyenne Latronica, who may have never imagined her thesis project would be read by anyone outside of the Cal Poly committee issuing her MS degree, “food that is disposed of or destroyed due to food safety issues has gone unrecognized as food waste and has been excluded from food waste analysis.”
And I know there are a lot of big issues in the world, but I hope you can see why this is less than ideal.
Some efforts have been made in the private sector to develop more accurate methodologies to calculate the impacts of FLW. One example is the FLW Value Calculator; however, it remains in a beta-testing stage and is not capable of disaggregating FLW attributed to food recalls or foodborne illness outbreaks. Other databases, including the tools cited by Latronica, do not collect a sufficient amount of information or lack the detail necessary to generate an accurate estimate.
What Can We Do About It?
Let me first say this: I’m a registered dietitian, so this is not my primary area of expertise. I’m better equipped to help you avoid cross-contamination while you cook dinner or recommend nutritionally-equivalent alternatives to recalled ingredients.
There are people in the public and private sector who have dedicated literal decades and entire careers to this. I’m not one of them, but as I pivot to focus on sustainable nutrition I want to share a few ways we can get on top of this.
First, we have to close the data gaps. “What gets measured gets managed.” Or something like that, but you get it. Without the ability to accurately and efficiently trace the volume and value of FLW resulting from food recalls, how do we ever quantify the true scale of the problem?
If I were making a full-time income to focus on this, I’d start with a thorough assessment of currently available tracking tools, involving food waste and food safety experts as well as food producers, manufacturers, and distributors. There’s also a need to enhance current monitoring systems or, if appropriate, develop a new monitoring system that utilizes innovative technologies such as blockchain for increased traceability and efficiency at quickly identifying sources of food safety concerns, issued food recalls, and measuring the volume and type of food diverted from consumption.
Despite the lack of data for FLW specifically attributed to food recalls, there is sufficient evidence to identify major drivers of food safety recalls themselves. They include:
Poor or inadequate safety controls around allergens, either through cross contamination or mislabeling, and/or undeclared allergens or food coloring additives.
Lapses in food safety controls at the production level, resulting in biological contamination that leads to foodborne illness outbreaks.
Packaging defects or improper handling (human errors or mechanical failures).
To a lesser degree, foreign object contamination and refrigeration issues are also known drivers. Each of these categories presents unique opportunities for developing and implementing solutions. Many are being addressed through the Food Safety Modernization Act, which is focused on prevention. Compliance dates for the various rules and programs are variable depending on the size of the business (very small, small, or others) as determined by annual sales and number of employees. They may be postponed or modified, which again, is less than ideal. Modernization is urgently needed; according to Latronica, the FDA does not currently have the statutory authority to require electronic record keeping (or at least, it didn’t when she did her deep dive in 2021).
Second, more specificity about what is recalled (and when, and where, and why) would help. The impacts of food recalls on FLW extend beyond the contaminated or adulterated food products directly linked to the issued recall. Using precautionary principles, many recalls involve multiple products, entire categories of food products (i.e., “fresh berries” or “leafy greens”), or mandate sweeping recalls such as “all product in a facility”.
(side note: I wrote about precautionary principles in this post and it was quite the hit)
This is not an efficient method of controlling for food safety issues. However, it could be considered effective considering that prevention of serious adverse health effects or death is paramount.
Put another way, potentially hazardous foods are removed from the supply chain, but food products that likely are safe to consume are also removed through the recall process. “When in doubt, throw it out,” as they say. This, along with the deterioration of trust from the public, contributes more greatly to overall FLW and subsequent environmental impacts than more targeted recall procedures.
Another side note: I don’t think we have any type of review or analysis that looks at past recalls to determine the extend to which they were more extensive than necessary. If this exists, please let me know…I don’t think this rabbit hole could get any deeper than this.
To be clear, I’m not suggesting we’ve been frivolous in the past. We absolutely can and should maintain precautionary measures. But we should also develop a more robust and detailed processed for diverting recalled products specifically (as opposed to FLW generated for other reasons) away from landfills.
How? Here comes the seemingly boring but very important policy plug. If we assess existing policy recommendations and standard practices to gauge whether or not they are appropriate or applicable to FLW resulting from recalls, and where necessary, develop alternative processes alongside existing rescue, recovery, or recycling pathways, we’d be moving in the right direction.
And good news, it’s already happening! ReFED, a U.S.-based nonprofit working to catalyze the food system toward evidence-based action to stop wasting food, has a great resource that details specific policy recommendations to address FLW. Some examples include:
Better organic waste management via policies that disincentivize or prohibit food waste being added to landfills, increasing landfill tipping fees, or removing restrictions and barriers to feeding food scraps to animals or livestock.
Finding and increasing funding for infrastructure, such as cold storage for perishable food donations and increased capacity for storage in general.
Finding and increasing funding for innovations, such as farm-level research and spoilage-inhibiting technologies.
Consumer education (which is what I suppose this lengthy post is trying to do).
Improving tax law and expanding food donation policies (although these categories are less applicable to FLW resulting from food recalls due to heightened safety concerns).
So….hop to it and attend a city council meeting if you’re so inclined.
In Conclusion
Food waste expert Dana Gunders is quoted as saying, “We don’t talk about how much food gets wasted in terms of recalls because recalls are about food safety [and] the safety of our food trumps the amount of food that gets wasted”. The tragic deaths and serious adverse health effects caused by foodborne illness outbreaks reinforces a collective hesitation to consume foods that may be unsafe or contaminated.
We, as a society, should not be expected to lower our standards or expectations for a safe, high-quality, nutritious food supply.
However, what I learned through this case study was that we have a considerable gap in our understanding about how much food is wasted due to food recalls. We don’t even know where the standard is set at this point.
I truly did not predict I would stumble upon such a vastly understudied area of food waste. I quickly realized I bit off much more than I could chew, both for the scope of this project and the duration of the course. It’s stretching my imagination to develop other creative ways to address this, while also balancing the need and desire to work on other issues in the food system that are just as gnarly to wrestle with.
The Bottom Line: We cannot separate food safety from food waste. They are inextricably linked, and if we care about one we should care about the other.
The necessary nuance is that, for the most part, we have a safe, high-quality food supply in the United States AND there will inevitably be instances where food is not safe to consume.
For the most part, regulatory oversight and efforts by governmental agencies like the USDA are working as intended AND there’s room for improvement because when it comes to FLW resulting from food recalls, we have no idea how well we are or are not doing.
Many people care about eating more sustainably to mitigate climate change and are doing everything they can to waste less food AND we urgently need impactful policy change because personal and individual behavior change isn’t enough.
We should be careful about avoiding foods that can make us extremely ill (ahem…like raw milk) AND trust that some food recall situations don’t apply to what’s already in your fridge depending on where you live and what you bought.
Questions, comments, concerns, ideas? Let’s chat! Leave a comment, especially if you have some insider knowledge in this area that I overlooked. Thanks for reading!