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Listeria in pet food manufacture facility leads to FDA cautioning letter

As part of its enforcement activities, the Food and Drug Administration sends warning letters to entities under its jurisdiction. Some letters are not posted for public view until weeks or months after they are sent. Business owners have 15 days to respond to FDA warning letters. Warning letters often are not issued until a company…



Listeria in pet food manufacture facility leads to FDA cautioning letter

As part of its enforcement activities, the Food and Drug Administration sends alerting letters to entities under its jurisdiction. Company owners have 15 days to react to FDA cautioning letters.

A pet food business in Oregon is on notification from the FDA after inspectors found Listeria monocytogenes in the production facility. This warning letter acts as a pointer that family pet foodstuff can include hazardous pathogens and ought to be dealt with as carefully as other items.

Consumers should be careful of cross contamination from pet food on surface areas, such as kitchen area counters. Contamination in animal food can make individuals ill when cross contamination takes place or when good handwashing and other health practices are not followed.

Raw Benefit Processing LLC
Aumsville, OR

In an Aug. 18 warning letter, the FDA described Aug. 26 and 30 assessments at Raw Benefit Processing LLC’s family pet food production center. The inspectors found that the firm had considerable violations of the Existing Excellent Manufacturing Practice, Danger Analysis, and Risk-Based Preventive Controls for Food for Animals regulation.

In response, the FDA provided the company a Type FDA 483.

The considerable violations:

  1. The firm stopped working to recognize and examine each understood or reasonably foreseeable risk for each kind of animal food manufactured, processed, loaded, or held at their center to determine whether there are any dangers needing a preventive control.

The firm offered FDA private investigators with a document entitled “Raw Advantage Processing threat analysis raw, ground item for ( redacted) Processing” and another entitled, “Raw Benefit Processing risk analysis raw, ground product — with and without components” for ( redacted) items as part of their food security strategy. FDA evaluation identified that neither of these documents recognizes and examines all the recognized or fairly foreseeable risks for animal food in their center.

  1. The firm’s composed risk analysis for their raw ground animal foodstuff that do not undergo ( redacted) did not determine or evaluate Listeria monocytogenes as a known or fairly foreseeable threat. Raw meat animal food and its ingredients such as raw poultry, raw fruits and vegetables, and raw milk are understood to be a source of Listeria monocytogenes
  2. The company’s risk analysis for products that go through ( redacted) did not recognize or examine microbiological hazards from raw goat milk. Raw milk is known to be a source of a broad variety of microbiological risks (such as Escherichia coli( E. coli), Listeria, and Campylobacter).

The company’s Sept. 13, 2019, response shows their food security plan will be evaluated and acknowledges prospective bacteriological dangers. Nevertheless, their response does not include a revised danger analysis; therefore, the FDA is not able to examine their restorative action. The FDA will validate the adequacy of their restorative actions throughout a future assessment.

  1. The firm’s risk evaluation did not include an examination of environmental pathogens whenever an animal food is exposed to the environment prior to packaging and the packaged animal food does not receive a treatment or otherwise include a control step that would considerably decrease the pathogen.

Meat utilized in their raw, ready-to-eat items, in portions or after the grinding step, is exposed to the environment at numerous actions e.g., throughout ( redacted), during motion in open ( redacted) carts, during grinding, during staging before the final product is bagged and sealed. Ecological FDA sample INV1117248, gathered throughout the investigation, yielded isolates of Listeria monocytogenes in six different areas throughout their center, including the grinder/mixer room.

Their action dated Sept. 13, 2019, describes the restorative actions they prepare to take in response to their failure to determine and assess all known and reasonably foreseeable dangers for the animal food manufactured by their facility. The company has actually not provided their modified food safety strategy.

  1. The company failed to validate that the preventive controls recognized and executed are appropriate to control the threat.

Validation suggests acquiring and evaluating scientific and technical evidence that their control measure, or mix of control measures, or their food security strategy as an entire, when appropriately implemented, can efficiently controlling recognized risks, specifically, Listeria monocytogenes, E. coli O157: H7, and Salmonella

    Their company does not have appropriate recognition for their ( redacted) parameters.

  1. In their file “FSMA FDA Products Preventative Controls Program” for frozen animal food, code 190826, dated Aug. 26, 2019, the company recognizes ( redacted) as a process control for E. coli, Salmonella, and Listeria for animal food items that do not go through ( redacted).

This research study uses ( redacted) cubes of beef that are ( redacted) for ( redacted) minutes.

The company’s Sept. 13, 2019, action states they will conduct new recognition research studies for ( redacted) that will consist of statistically valid sample sizes and shot of recognized quantities of various pathogens to substantiate a ( redacted) decrease. Even more, an email received from the company on Nov. 20, 2019, specifies that they have scientific proof revealing ( redacted) reduction kill rates for the ( redacted) and will perform a validation research study to show the log reduction under production conditions at their plant. The FDA will examine the adequacy and application of their recognition research study throughout their next assessment.

  1. The firm stopped working to identify and implement preventive controls to supply guarantees that any hazards requiring preventive control will be significantly decreased or prevented. Preventive controls consist of controls at vital control points and at other points that are suitable for animal food safety.

The company’s document “FSMA FDA Products Preventative Controls Program” for frozen animal food, code 190826, dated Aug. 26, 2019, recognized a ( redacted) as a preventive control for specific biological dangers.

In their Sept. 13, 2019, action, they specified their company will include the ( redacted) of all raw meat and poultry as a preventive control for the bacterial hazards. Additionally, their e-mail dated Nov. 20, 2019, specified that they began working on the validation and implementation of ( redacted) for all raw frozen diet plan items. While the FDA acknowledges this corrective action, their reaction did not provide a revised food security plan with changes in their manufacturing procedure and did not include appropriate documents for the FDA to completely assess their reactions. The FDA will confirm the adequacy of their restorative actions during a future examination.

Undesirable Microorganisms in Animal Food and Their Processing Environment
The firm produces pet food and a number of the scenarios described above are ways in which the pet food they produce might end up being contaminated by unwanted bacteria for which they have insufficient control. Unwanted microorganisms consist of microbes that are pathogens, that subject animal food to decay, that show that animal food is contaminated with filth, or that otherwise might trigger animal food to be adulterated.

On Aug. 27, 2019, FDA collected a sample of ( redacted) Beef Dish lot ( redacted) sample 1117252, that was manufactured on Aug. 26,2019 FDA laboratory analysis of this sample identified the presence of non-O157 Shiga Toxin-producing E. coli O88: H25 FDA conducted whole genome sequencing (WGS) analysis on the E. coli O88: H25 found in their animal foodstuff. As discussed with them on Oct. 18, 2019, the results exposed numerous virulence markers in the genome recommending it is pathogenic.

The FDA laboratory recuperated Listeria monocytogenes from 7 of 37 subsamples evaluated for this pathogen. FDA performed WGS analysis of the L. monocytogenes stress found in ecological sample number1117248 As discussed with them on Oct. 18, 2019, the WGS analysis found that the L. monocytogenes strain in subsamples 23, 30, and 31, from the cart wheel, drain near mixer, and drain near grinder, respectively, of the environmental sample is related to a strain found in ( redacted) in2016

On ( redacted), the Minnesota Department of Farming (MDA) gathered a sample of ( redacted)”, identified as “( redacted). The sample (MDA Sample Number # ( redacted)) was analyzed by the MDA Microbiology Lab and evaluated positive for Salmonella Dublin. We talked about the MDA test results and FDA’s WGS analysis results with them on Nov. 6, 2019, and Feb. 27, 2020, respectively.

The existence of undesirable microbes in their ended up product and processing environment is further evidence of the significance of their infractions of the animal food threat analysis and risk-based preventive control requirements and demonstrates that their practices are not sufficient to avoid or reduce biological risks.

The full warning letter can be seen here

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Release of PPP loan recipients reveal troubling patterns

Sweeping data released by the Small Business Administration on who benefited from pandemic relief programs raises questions about the equitability and distribution of loans intended for small businesses, an initial analysis by NBC News shows.The analysis found that properties owned by the Trump Organization as well as the Kushner Companies, owned by the family of…



Release of PPP loan recipients reveal troubling patterns

Sweeping data released by the Small Business Administration on who benefited from pandemic relief programs raises questions about the equitability and distribution of loans intended for small businesses, an initial analysis by NBC News shows.

The analysis found that properties owned by the Trump Organization as well as the Kushner Companies, owned by the family of Jared Kushner, President Donald Trump’s son-in-law and senior adviser, profited from the program.

After months of litigation, the SBA released the dataset Tuesday night on every small business that received a Paycheck Protection Program (PPP) or Economic Injury Disaster (EIDL) loan.

The data reveals the most complete accounting to date of the more than $700 billion in forgivable loans Congress and the Trump administration introduced in the spring for allowable expenses, including payroll, rent, utilities and mortgage interest payments.

The analysis by NBC News, one of 11 newsrooms that sued for the release of data, also shows:

  • Over 25 PPP loans worth more than $3.65 million were given to businesses with addresses at Trump and Kushner real estate properties, paying rent to those owners. Fifteen of the properties self-reported that they only kept one job, zero jobs or did not report a number at all.
  • The loans to Trump and Kushner properties included a $2,164,543 loan to the Triomphe Restaurant Corp., at the Trump International Hotel & Tower in New York City. The company reported the money didn’t go to keeping any jobs. It later closed.
  • A company called LB City Inc, which is at Kushner’s Bungalow Hotel in Long Branch, New Jersey, received a loan for $505,552.50 that it used to keep 155 jobs.
  • Two tenants at 725 5th Avenue, Trump Tower, received more than $100,000 and kept only three jobs.
  • Four tenants at the Kushner-owned 666 5th Avenue combined received more than $204,000, and retained only six jobs.

There were also some troubling signs of mismanagement revealed in the data. Over 100 loans were made to companies where no business name was listed, were listed as “no name available” or showed potential data entry errors, such as names that appeared to be dates or phone numbers. More than 300 companies appear to have each gotten more than $10 million in loans through their subsidiaries. Businesses were not supposed to receive more than $10 million per entity, except for those in the food, hospitality or hotels industries.

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The findings immediately raised concerns with government accountability groups.

“Many months and broken promises later, the court-ordered release of this crucial data while the Trump administration is one foot out the door is a shameful dereliction of duty and flagrant mismanagement of a program that millions of workers and small businesses needed to get through this pandemic,” Kyle Herrig, president of Accountable.US, an accountability watchdog, said in a statement.

Original intent

The PPP programs’ original stated intent by officials was to help with payroll for small businesses struggling under the effects of coronavirus lockdown measures. The loans aimed to provide a bridge through the summer for what was hoped to be an improved economic and health climate in the fall.

But almost from the start, the programs, particularly PPP, drew criticism for how they were administered and messaged, and whether it was equitable.

Large national banks initially gave loans only to customers with whom they had pre-existing lending relationships. Businesses owned by people of color without strong banking relationships found themselves with limited access and forced them to find other routes for funding. There was also the persistent question of what defined a “small business,” after lobbying by the hotel and restaurant industry ballooned the maximum number of employees allowable to 500, even though over 98 percent of the small businesses in America have fewer than 100 employees.

The administration tried to address the complaints, such as setting aside a day just for smaller community banks to apply for loans. But even that overwhelmed SBA computer systems. These controversies all increased the pressure for transparency.

But in contrast to previous government bailout programs, the agency previously released less detailed versions that it said for privacy reasons omitted the business names and addresses of borrowers who borrowed less than $150,000. And instead of specific loan amounts, loans were listed in ranges.

Mixed responses

The SBA defended its handling of the program when it released its data on Tuesday evening.

“SBA’s historically successful Covid relief loan programs have helped millions of small businesses and tens of millions of American workers when they needed it most,” an SBA spokesman said in a statement accompanying the release.

But as government accountability groups sifted through the data late into the night and uploaded them to publicly searchable databases like, they expressed regret about what has happened to so many small businesses partly from mismanagement of the loan program.

“Only now — after its hand has been forced, hundreds of thousands of small businesses have gone under, and millions of taxpayer dollars were wasted — has this administration pulled back the curtains to reveal the malpractice going on behind the scenes,” Herrig said. “Americans deserved an open, transparent small business aid program when this pandemic started, and any new small business relief program must take a lesson from the abject failures of this one.”

Ben Popken

Ben Popken is a senior business reporter for NBC News.

Andrew W. Lehren

Andrew W. Lehren is a senior editor with the NBC News Investigative Unit.

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‘Moonlighter’ Evaluation– Delve Dungeons, Develop a Company, and Discover History

Moonlighter ($11.99). A store, a story, a legacy, a game. First announced on mobile at GDC last year, it has finally been released. Part dungeon crawler, part shop manager, it is entirely fun. Players follow Will, proprieter of the Moonlighter, as he gathers materials for his shop, crafts weapons, potions and enchantments, and enters dungeons…



Moonlighter($1199) A shop, a story, a legacy, a video game. First announced on mobile at GDC in 2015, it has actually lastly been launched. Part dungeon crawler, part shop supervisor, it is completely enjoyable. Gamers follow Will, proprieter of the Moonlighter, as he gathers products for his store, crafts weapons, potions and magics, and enters dungeons to discover popularity, fortune, and just perhaps find out a bit more about them.

While a store simulator and a dungeon spider are noticeably various, they are both RPGs, and it isn’t unexpected that they mix together well.

Store management games, on the other hand, have to get their product someplace. Most of the time basic materials are just … conjured up from the base code to be turned into beneficial products. Once in a while, however, you can purchase rare or fascinating components from travelers for a lot more expensive products. The question, nevertheless, is what if you integrated these two categories? What if you could crawl dungeons for materials to craft, therefore have a little action; then, when you go back to town, what if you could create the helpful items– weapons, armour, potions, magics and such– and offer the scrap? Well, then you would have Moonlighter

While the video game is called after the store, the balance in between handling the Moonlighter and trawling dungeons for loot and boss fights is quite reasonable. That stated … it is simple to spend excessive time doing one thing, focusing on one part of the video game, that makes the unavoidable return to doing whatever you were avoiding a lot more uncomfortable. Battering monsters is fun, for instance, but if you aren’t aware of which materials are worth selling later, which ones are required for much better devices, and which ones can safely be consumed for gold to leave the dungeon, sorting everything later when customers are piling through your front door can be rather stressful. If all you want to do is offer loot, you’re going to run out quite quickly. Balance is essential.

Disregarding all that, though, the dungeon crawling is rather fun, if easy. There are only so lots of enemy types in each dungeon, and it doesn’t take a strategic genius to figure out how to securely clear a space without taking damage.

After you’ve tired of beating up on mobs, or after a guardian has connected your sword in knots and tossed you out, it’s time to offer all the stuff accumulating in your backpack. Too far above the ideal variety, however, and not only will the product not offer, anyone who takes an appearance at the item will get upset, leave early, and considerably hurt the Moonlighter’s track record.

While the story isn’t exactly a heartrending tale of loss and love, betrayal and found friendships … it isn’t boring either. Other than a quick intro and routine chats with Zenon, your old mentor, narrative is delivered via notes discovered on dungeon floors and journal entries from Crazy Pete, an adventurer obsessed with finding a much deeper meaning in the depths.

A lot more excellent is the art and music. Creatively, Moonlighter utilizes a mix of colourful pixel art for gameplay and something a bit more stylish for cutscenes and such. Each dungeon provides a distinct visual, with a special soundtrack for that little extra something. The mix is delightful, and I completely enjoy it. I do, nevertheless, have but one problem: The caution animation on opponents. You see, it isn’t constant. Sometimes attacks trigger prior to the yellow flash, other times during it, and still others instantly after. It doesn’t even always seem to be consistent amongst enemies of the same type– I’ve been hit by attacks that I had simply dodged due to the fact that the timing had actually changed! It’s really rather frustrating, and I can’t help however believe it’s a bug.

Despite that, it is extremely enjoyable to play. In addition, there are buttons to switch weapons, an unique attack, potions, stock, a map, and a pendant to escape the dungeon spread along the edges of the screen.

I said it in the past, and I meant it: Moonlighter is a great game. It is a fascinating blend of dungeon crawler and shopkeep simulator, something not really delivered by other games that I have discovered.

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Business closures, partial reopenings due to COVID-19 might cost the United States $3-5 trillion in GDP over 2 years

Credit: CC0 Public Domain The COVID-19 pandemic could result in net losses from $3.2 trillion and up to $4.8 trillion in U.S. Real Gross Domestic Product (GDP) over the course of two years, a new USC study finds. The pandemic’s economic impact depends on factors such as the duration and extent of the business closures,…



Business closures, partial reopenings due to COVID-19 might cost the United States $3-5 trillion in GDP over 2 years
Credit: CC0 Public Domain.


The COVID-19 pandemic could result in bottom lines from $3.2 trillion and approximately $4.8 trillion in U.S. Genuine Gross Domestic Product (GDP) over the course of 2 years, a brand-new USC research study discovers.

The pandemic’s financial impact depends on elements such as the period and level of business closures, the progressive resuming process, infection rates and casualties, avoiding public places, and suppressed customer need, according to the research study by the USC Center for Threat and Financial Analysis of Terrorism Events (CREATE).

Genuine GDP is a step, adjusted for inflation, that shows the value and the amount of last goods and services produced by a country’s economy in a given year.

” In a best-case situation, we would see containment steps, such as masks and social distancing end up being more prevalent, and possibly even a vaccine by next year, and after that services and institutions would be able to reopen at a sped up speed,” said Adam Rose, research study group leader who is the director of CREATE and a research study teacher at the USC Price School of Public Law.

” However in a worst-case situation, these countermeasures would not materialize, and reopenings would occur gradually, especially since we would continue to see waves of infection,” he said. More people would likely lose their jobs, and the impacts of this catastrophe would continue to install.”

The researchers discovered that the necessary closures and partial reopenings alone might lead to a 22%loss of U.S. GDP in just one year and an even higher loss of GDP over 2 years. Other crucial factors, however, will influence how dreadful the losses may be, they noted.

The research study team kept in mind that China has not continual such losses due to aggressive containment measures resulting in a shorter lockdown period. They predict that in a worst-case scenario, the U.S. GDP loss due to COVID will more than quadruple that of China.

The study was published on Nov. 30 in the journal Economics of Catastrophes and Climate Modification

In early March, numerous states responded to a rise in COVID-19 cases by buying the closures of non-essential companies such as dining establishments, bars, salons and retailers. Many likewise stopped or decreased civil services to restrict the spread.

Scientists at CREATE who are specialists on modeling financial repercussions of disasters evaluated the capacity economic effect in three situations ranging from moderate to disastrous.

Using a computerized economic model, the scientists represented these other factors in the 3 circumstances. They differed the decrease in the workforce due to workers becoming ill with or passing away of the virus, workers adopting new behaviors like staying at home to prevent infection, increased demand for COVID healthcare, prospective resilience through telework, increased need for communication services, and increased bottled-up consumer demand

The scientists conducted a synthesis of the literature of projections on the severity and possible duration of the pandemic.

Anywhere from 365,000 to as numerous as 2.5 million COVID patients might end up in the ICU, while another 860,000 to nearly 6 million clients may be hospitalized however not dealt with in the ICU. The forecasted number of individuals who will be dealt with for COVID as outpatients might differ from about 2.6 million to 18 million.

To name a few highlights of the research study, the scientists projected:

  • 54 million to 367 million work days would be lost due to individuals getting ill or die from COVID
  • 2 million to almost 15 million work days would be lost due to employees staying home to care for sick enjoyed ones.
  • Job losses might vary from 14.7%to 23.8%, and in the worst case affect an estimated 36.5 million employees.
  • A loss in need for some services– such as the use of public transit and school presence, dining establishment dining and travel– as individuals prevent public places and services to minimize their threat of exposure.

    A boost in pent-up need will occur since customers are unable to invest cash on big-ticket items such as vehicles, along with on travel, restaurants, hotels, product, fitness, sporting events and shows throughout the closures, and, to a lower extent, throughout the phased reopenings.

    While the scientists have actually discovered that the necessary closures and re-openings are the most prominent consider the economy’s decline, customer avoidance habits also has a significant result.

    For the research study, the scientists presumed that various individuals prevented work, did not go to in-person classes at schools, and stopped going to dining establishments, activities and social gatherings to lower their risk of infection.

    ” Due to the fact that people have actually had to prevent activities, this has had a significant effect on economic losses,” said Dan Wei, a CREATE research fellow and research associate professor at the USC Cost School for Public Policy.

    The economic losses from closures and avoidance behavior could be partially balanced out by increased customer costs after reopening, the researchers stated.

    ” Bottled-up need is one of the most influential aspects for the economy in this pandemic. While the obligatory closures and partial reopenings drive the majority of the economic decrease, the degree to which pent-up demand results in an increase in consumption after resuming, can be crucial to the economic recovery,” said Terrie Walmsley, a USC CREATE research study fellow and an adjunct assistant professor of practice in economics at the USC Dornsife College of Letters, Arts and Sciences.

    ” The crucial question is: When will we see a total reopening throughout this country? We simply can not predict that, particularly due to the fact that we have actually not acquired control of the spread of the disease,” Rose said.

    Organization closures, partial reopenings due to COVID-19 could cost the United States $3-5 trillion in GDP over 2 years (2020, November 30).
    obtained 1 December2020
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