This morning during my commute to work (5.5 miles), I received 5 email notices regarding product recall notices. FDA recall notices include FDA and company generated news about any product that is under the FDA's jurisdiction, which is of course a lot – food, drugs, OTC products or medical devices.
"Five in a day," I thought, "that seems kind of excessive." It made me wonder if people wouldn't get recall burnout after a while on the one hand. On the other hand though with the advent of social media and more targeted, granular communications, perhaps the communications environment is such that overload would not occur if the messages are aimed at specific target audiences. Certainly, a lot of people want to know about FDA's recall notices – the FDA Twitter feed FDA Recalls has almost 100,000 followers and has issued 1200 Tweets.
In any case, the sheer number in one day was surprising and I decided to look into how many recall or product safety alerts go out on a monthly basis. Fortunately, the FDA keeps an archive that goes back to 2004. What I found was very surprising.
As one can clearly see, during the Bush years, the number of letters that went out ranged from a low of 154 in 2006 to a high of 253 the following year (which was the year of the melamine contaminated dog food resulting in a number of recall actions).
What is perhaps even more striking is the sudden nature by which the rate of recalls and alerts increased. Looking at a day by day rate for January 2009, one sees an impact almost immediately upon the inauguration of Barack Obama on January 20, 2009.
Up through the 19th of January, there had been 29 recall and safety notices. From the 20th through the 31st of the month, there were an additional 116 more. That means in an 11-day period, there were nearly as many recall notices as there were during the entire year of 2006. In February, there were 272 issued in the shortest month of the year, more than were issued in any single year during the second Bush Administration. That trend continued well through the Spring, when the numbers returned to a more moderate level. Still, for 2010, as of the first week of November, there have been 319 recall notices.
The page where FDA posts the recalls and press alerts about products states that the listing reflects those actions which are deemed the "most significant product actions" and therefore the change in number could be reflective of a change in the criteria for what is deemed "most significant". To get a true feel for enforcement, one would have to examine closely the weekly enforcement reports put out by the agency which are raw enough from past years to require manual counting for purposes of comparison – beyond my scope for today. But clearly, either the number of recalls has increased or the number that are being brought to the attention of the public have increased. And in any case, the number appears to have changed quickly.
And the number may continue to increase given additional authorities that FDA has or may be granted in the future with additional legislation. If that is so, the agency will have to consider ways to parse out the news in a more directed fashion – even more targeted than the recalls twitter feed, to subdivide the news by way of recalls of food, devices or medicines.