Ineffective Prerequisite Programs Fuel Food Recalls: Lessons from 2024 and 2025

M. DuBose
Jun 27
3 min read

Food recalls often trace back not to random mishaps or Critical Control Points (CCP) but to gaps in the foundational “prerequisite programs” that underpin safe food production.

These programs, covering sanitation, environmental monitoring, maintenance, allergen control, supplier verification, and more, are the bedrock on which hazard controls (like HACCP/CCPs) rely. When they falter, so does the safety net, leading to costly recalls, consumer harm, and brand damage.

1. Why Prerequisite Programs Matter

Prerequisite programs (PRPs) establish the hygienic and operational baseline for every food facility. These are the foundations for an effective FS/HACCP Program. They include:

Good Manufacturing Practices (GMPs): Personal hygiene, pest control, facility design and upkeep.
Sanitation Standard Operating Procedures (SSOPs): Cleaning frequencies, methods, validation.
Environmental Monitoring: Routine swabbing for pathogens in food zones.
Maintenance & Calibration: Preventive upkeep of equipment and infrastructure.
Allergen Management: Segregation, cleaning, labeling verification.
Supplier Verification: Audits, Certificates of Analysis, incoming‐goods testing.

Without rigorous PRPs, critical hazards slip through. Even the best FS/HACCP programs can’t compensate for a rusted conveyor belt harboring Listeria or mis‐labeled allergens from an unvetted supplier.

2. 2024: High‐Profile Recalls Exposed PRP Failures

Listeria Takes Center Stage In 2024, U.S. foodborne illness outbreaks soared by over 40% compared to 2023, with Listeria leading the charges, a stark departure from prior years when Salmonella reigned supreme. The largest recall was by Boar’s Head: over 7 million pounds of ready‐to‐eat deli meats pulled after environmental monitoring lapses allowed Listeria to establish in processing equipment. Poorly maintained surfaces, think pooled water and rust, created niches no cleaning regimen could reach, underscoring a breakdown in sanitation and maintenance PRPs.

E. coli and Cross‐Contamination Midyear, McDonald’s halted Quarter Pounder sales after more than 100 E. coli cases across 14 states, including one death, were linked to contaminated onions. The incident laid bare the absence of robust supplier verification and raw‐material testing programs, no effective inbound screening or vendor audits to catch a tainted onion lot before it hit the grill.

Salmonella Strikes Eggs & Produce Fresh eggs and multiple cucumber brands faced Salmonella recalls later in 2024. Investigations pointed out inadequate sanitation and biosecurity at farms and packinghouses. PRPs designed to control cross‐contamination between flocks, fields, and packing lines had simply not been enforced to standard.

3. Early 2025: A Surge in Recalls Highlights Persistent Gaps

Recall Volumes Climb FDA data shows 51 food recalls in January 2025, up from 45 the prior January, and 26 in February vs. 39 in February 2024. This uptick signals that despite headlines, systemic PRP weaknesses remain widespread across the industry.

Allergen Control Breakdowns In the first weeks of 2025, countless allergen‐related recalls traced back to missing or ineffective labeling verification programs:

Paras Premium Golden Raisins (undeclared sulfites)
Monkey Spit Barbecue Sauces (undeclared milk, soy, wheat)
Wabash Valley Farms Bacon Flavor Popcorn Seasoning (undeclared soy)
Colussi Cantuccini Chocolate Drops Cookies (undeclared almonds)
Pearl Milling Pancake & Waffle Mix (undeclared milk)

These incidents highlight failures in basic allergen PRPs—no proper lot segregation, inadequate clean‐down SOPs, and no final‐product verification testing to catch mislabeling before distribution.

4. Consumer & Business Impacts

On Consumers

Tens of people hospitalized (e.g., 57 from the Boar’s Head recall) and dozens of deaths (10 linked to Listeria) illustrate the human toll of PRP lapses.
Annually, CDC estimates 48 million Americans suffer foodborne illnesses; 128,000 are hospitalized and 3,000 die, a burden amplified when prerequisite controls fail. This doesn’t include the hundreds of thousands that get some form of food poisoning that goes unreported.
Recalls erode trust, today’s wary shoppers may shift brands or reduce consumption of fresh and ready‐to‐eat products.

On Businesses

Recall costs can reach tens of millions in direct expenses (product retrieval, destruction, logistics) plus legal settlements.
Brand reputation takes years to rebuild; many consumers never return.
Insurance premiums rise, and lenders may view food companies as higher risk.
Regulatory scrutiny intensifies, FDA and USDA inspections ramp up, forcing costly upgrades or even plant shutdowns.
Plant shutdowns
- Boars Head was forced to close their Virginia facility resulting in the loss of 600 jobs.
- Joriki – a large Canadian facility eventually closed all four (4) of their facilities (3 in Canada and 1 in US) due to a listeria recall in yogurt affecting approximately 150 employees in the US & Canada

The recalls rocking 2024 and early 2025 weren’t flukes, they were predictable outcomes of under‐resourced or poorly implemented prerequisite programs. By rigorously auditing and strengthening these foundational controls, food businesses can interrupt the chain of events that turn a safety lapse into a public health crisis, safeguarding consumers, and their own futures in the process.