Case Study

Perhaps the Biggest Victory You've Never Heard Of


When a facility of one of North America's largest supply chain companies was beset with a rodent infestation, state authorities issued a "no sell order" on tens of millions of dollars worth of prepackaged food items, while the FDA conducted a thorough investigation.

Our Involvement

The Freeborn Food Industry Team embarked upon a four-stage solution: (1) deploy to the client site in order to both assess the situation and recommend next steps directly to the team on the ground; (2) use our contacts within the state's agricultural department to work as partners as opposed to adversaries in remedying the issue; (3) develop a Joint Reconditioning Plan in conjunction with the client, the client's largest customer and the state department of agriculture to address issues specifically identified by the FDA and to clear all unadulterated products from the "no sell order"; and (4) oversee implementation of the Joint Reconditioning Plan to the state's and FDA's satisfaction.

The monumental challenge the Joint Reconditioning Plan addressed was how to inspect and clear nearly 1.5 million cases of food-grade items subject to FDA detention when the FDA declared the client's entire 1 million square foot facility to be infested and not safe for storing food products. Freeborn conceived the construction of several "ice rink" style areas to provide clean and contained inspection sites in which the inspectors could de-pallet, inspect and re-palletize all of the allegedly adulterated food products. Additionally, the plan called for the use of long haul trailers to house cleared items prior to shipment.


This was a case of several "silent victories." Freeborn helped the client avoid the FDA's planned seizure, greatly mitigating client losses with a process to clear a significant portion of the product for transportation and sale. No less significant was the fact that we saved the client tens of millions of dollars in liability, avoided the negative press associated with a food seizure of historic proportions and set a multi-state standard for handling large-scale food adulteration issues.