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Perishable Pundit
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Produce Business

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American Food & Ag Exporter

Cheese Connoisseur



Spinach Crisis Déjà vu:
Dr. Mansour Samadpour Retained By Chipotle To Boost Food Safety Efforts:
Increased Product Testing, Outsourced Processed Produce,
And New In-Store Kill-Steps Are Part Of New Moves To Keep Customers Safe

But Is Chipotle Over-Promising? Will Food Safety Be The Priority As Memories Fade?

Jim Prevor’s Perishable Pundit, February 3, 2016

The Centers for Disease Control and Prevention (CDC) issued its “final update” on the Chipotle E. coli 026 outbreak without identifying  a specific product that was at the source of the outbreak. Though finding a specific product at fault would have been satisfying, our experience is that it probably would have simply led Chipotle to change suppliers. Not finding a culprit may have helped the cause of food safety, as it has led Chipotle executives to order a comprehensive review of its operation, specifically focused on food safety. 

To help drive this process, Chipotle retained a brilliant, but controversial, food safety expert. We asked Pundit Investigator and Special Projects Editor Mira Slott to find out more:

Dr. Mansour Samadpour
Founder, Principal
IEH Laboratories & Consulting Group
Lake Forest Park, Washington

Q: Chipotle’s multipronged food crisis (E. coli, norovirus, and salmonella outbreaks) has generated relentless coverage and lawsuits. This includes a strong counter offensive by Steve Ells, Chipotle’s founder/co-chief executive, apologizing and reassuring customers with a  vow to aggressively implement improved, system-wide food safety procedures to alleviate future outbreaks.  Your role at Chipotle in this multi-faceted food safety strategy is of great interest.

A: In this case, I was required to get the OK for our interview due to my proprietary client relationship and sensitivity of the issues.

Q: We first connected for an interview back in 2007, following the spinach E. coli crisis, where you challenged our readers with a complex and controversial Q&A discussion on food safety testing measures: A Closer Look at Finished Product Testing. The interview triggered a dynamic discussion across the industry, and we’ve referred our readers to that interview many times in our ongoing analyses of outbreaks, recalls and other food safety issues.  What is the scope of your responsibilities at Chipotle?

A: Chipotle needed help and asked me to become involved in different aspects. One area was with the investigation and trying to understand what happened, and then after that to design a new food safety system.

Q:  What did you learn through that investigation? Were you able to isolate key reasons behind these different outbreaks? Were these random occurrences or a systemic problem?  With divergent pathogens behind the outbreaks, does this raise red flags?

A:  The investigation is not something I can go into. I can talk about food safety measures at Chipotle in general, as opposed to discussing the specifics of the outbreak cases.  It’s important to realize the difference between an E. coli outbreak linked by the same strain, and norovirus, a highly contagious infection, and that these are separate, unrelated incidents.

Norovirus has nothing to do with food.  You know the expression, ‘once in a blue moon.’ You have an E.coli outbreak and then someone comes to work sick and you have a norovirus outbreak, two things happening at once that aren’t related, but an unfortunate coincidence, magnifying the proportion of response.  [Editor’s note:  Media coverage also can be influenced by a well-known consumer brand such as Chipotle being involved. During the same time period of the Chipotle food crisis coverage with 60 cases, a much less reported multi-state outbreak of Salmonella Poona linked to cucumbers was also being investigated. According to the CDC, as of January 26, that cucumber outbreak has infected 888 people in 39 states, and has been linked to several deaths – but it was not associated with a well-known consumer brand].

Q:  The reports on the Chipotle outbreaks certainly were unyielding, but also confusing. For instance, the initial E. coli outbreak linked to food served at Chipotle appeared to be contained to two states, and some pundits speculated a local sourcing problem. But starting several weeks later, additional cases with the same rare E. coli strain continued to surface in many more states. Then reports headlined a second E. coli outbreak, suggesting it was of a different strain than the initial one. However, according to the CDC, this second outbreak turned out to be a variant strain of the first.

A: I can assure you none of the issues were caused by local suppliers.  In the beginning, the E. coli outbreak was focused on Oregon and Washington, and people thought it was a local outbreak connected to a local supplier, but it turns out, no, it wasn’t.  A lot of people had the misconception. Oregon and Washington did an amazing job of detecting the outbreak.  

At the same time, the outbreak was happening in other states, but they were three to eight weeks behind in detecting the outbreak. So for a period of time, there was this misconception this was a local outbreak, and if you buy local foods, you get local outbreaks.  This is not the case.

Q: In terms of supplier sourcing, and the enhanced focus on local, what is your view of proposals to exempt smaller growers from some of the more rigorous, costly government food safety regulations?

A: Usually big food doesn’t like small food. That said, it is never a good idea to exempt small growers from the same food safety standards as large growers. The idea moving forward is all local suppliers will follow the same exact food safety protocols as the large suppliers. 

Q: What key food safety issues are you working with Chipotle to address? How did you determine which changes to prioritize and advocate in designing Chipotle’s new food safety system? 

A: It’s critical to take a holistic approach, evaluating all the elements of a food safety program through the supply chain and at the restaurant. For example, you could have a heavily contaminated ingredient or heavily contaminated ready-to-eat product coming into your restaurant.  So, the sourcing is very important, and that was one element.

Then after the product goes through the supply chain, what are the practices in the restaurant.  So we did a hazard analysis to determine what steps can be taken in processing, cooking, etc., and to identify places where we can minimize risk and introduce interventions.

Taking the food safety system to the next level, another issue is employee health; again this is really important, making sure employees understand what can happen if they come to work when they are sick, what are the symptoms and decision-making, things like that. 

Another element is the environment, the contribution of building infrastructure and equipment. When you come to work, there has to be an operational inspection. You have to make sure you didn’t have a leak or a sewer backup, equipment is working properly, the cooler didn’t die in the middle of the night.  There’s a huge check list you have to go through.  There are many environmental things that can result in contaminated products.

Q: While taking a holistic approach, where did you see the biggest concerns?

A: The way I look at it, things can go wrong at many different levels.  I tried not to miss anything, and identify all the elements. They are not equal. If you have contaminated product coming into your restaurant you’re going to have an outbreak; there is no way around it, right? But you can also bring in a relatively safe product and mess it up in your restaurant.  

So, you have to consider all the elements, and not have tunnel vision — this problem happened because of this one supplier, and I’m going to fire that supplier and all my problems are solved. My task force put together a food safety system that limits the risk to as close to zero as possible; zero risk is impossible, but you can put a system in place to make it tremendously safe.

Q: Ironically, Chipotle has pinned its reputation and popularity on “Food with Integrity”, contrasting itself from fast food competitors by promoting its use of fresh, natural, local, unprocessed produce and meats, preparing raw items in-house with traditional cooking methods, while shunning  processed foods, “chemical additives” and “cheap artificial ingredients.” Do your food safety recommendations change these ways of operation?  Can you hone in on produce-related food safety improvements and challenges in dealing with fresh produce?

A: Chipotle uses romaine lettuce, tomatoes, red onions, bell peppers, jalapeno, avocados, lime, lemon, and cilantro, and I believe that covers the fresh produce items. One thing is these fresh products are coming in raw form.  We put together a risk assessment of Chipotle’s suppliers, making sure these are good companies with good food safety systems, and we designed a finished product testing program, at very, very, high resolution.

Q: What does that mean?

A: Every lot is defined between 500 pounds to 2,000 pounds, depending on the product, with 60 samplings per lot, a very intense specification.  After passing that testing, product ships to Chipotle.  This is for raw, untreated products. Then there is beef and chicken that you buy raw and cook, but there’s always a chance of cross-contamination. Every 2,000 pounds of those products are tested, and if the product doesn’t pass, it’s not going to get shipped. Then with the raw meats, we are cooking them.

At the same time, we don’t want to be chopping a lot of raw produce in the stores.  Instead of buying items like lettuce and tomatoes in whole form from suppliers and chopping them in the store, now Chipotle is buying the items already processed to reduce the chance of contamination and microbial activity. Doing less handling of products makes it inherently a better place.  

Q: But not all raw produce will be purchased in processed form, right? What items will Chipotle still be handling in house, and how will procedures change to reduce the risk of contamination?

A: If you have onions chopped by an outside processor and use them five days later, they’re oxidized and tasteless. So a product like that is going to get processed in house.  Also, limes, lemons, jalapenos, cilantro and avocados are going to be handled inside the restaurants, but we’ve added various steps to significantly reduce risk.

When you go and look at the process, Chipotle was cooking the rice and waiting till it cooled off and then adding the cilantro. Why not add cilantro when the rice is hot, at a 190-degree temperature, which will kill any problem in the cilantro in a few seconds. These are not difficult things, but every step is one more safety assurance. 

In public health, you want redundancies and to have control at every possible step.  So, before the cilantro reaches the restaurant, you’re doing pre-harvest testing. Then after the washing and sanitizing, you’re doing the finished product testing for every 500 pounds at extremely high resolution. Then you’re bringing it in the restaurant, chopping it and adding lemon juice to reduce microbial counts, and then mixing it in the hot rice. It’s not to say a food safety problem will never ever happen with cilantro, but the likelihood has gone down so much it’s a remote possibility.

With onions, again you do pre-harvest testing and after-harvest testing, but that’s in conjunction with GAP and the grower’s own food safety system.  Then when product comes in the store, you’re putting the onions in a basket in boiling water for a minimum of five seconds. Now you know you’ve killed some contamination on the surface.  You peel and chop, and then you pour the lime juice over it to give you an extra level of safety. This needs to be combined with all the other steps. If you don’t take a holistic approach, one hole is closed, but another is open.

Q: Some of these in-house steps seem straight-forward to implement without much additional cost or training.

A: These are very simple steps, once having gone through intense finished product testing, and less chopping and processing. Another example is marinating the meat late at night and only once a day at the end of the operation, not multiple times during the day when doing other things.  

A lot of these changes together result in tremendous amount of risk reduction. Plus, now, for every shift there is a person in charge of food safety, and every restaurant has a food safety manager. Now with this structured food safety program, there is heightened attention to food safety, and employees get evaluated on the steps they are taking to create a safe food environment. 

Q: Would you say there is a cultural shift in the company?

A: There has always been an emphasis to use the best ingredients and fresh, natural products. Now food safety is on top and everything else follows after that.

Q: Would you recommend foodservice establishments move toward buying pre-processed fresh produce and away from in-house processing?

A: That has been our recommendation. I would much rather have product professionally processed and have an opportunity to do a finished-product testing. A lot of times when you buy things you could have contamination inside, but if a processor is sanitizing and doing chopping in advance, and the final product is being tested, you’re still able to detect it.

We have a lot of processors doing an amazing job, and the product quality and shelf life is good. One company chops for 5,000 restaurants, as opposed to 5,000 restaurants doing their own chopping. If they go with shorter shelf life and better logistics, they can use a product and have very good quality. Whenever the restaurant can start with processed product rather than chop it in house, the better.

Q: Isn’t this counter to Chipotle’s image and mantra of having everything prepared fresh in house?

A: Chipotle is still doing its own onions, limes, lemons and avocados in house, and there is still a lot of cooking going on. The other benefit Chipotle has is their supply chain is really good. They’re using the product up really fast.

Q: We’ve talked extensively about your product testing in the past, but could you elaborate on your recommendations for Chipotle, when and how often to do testing, what products to focus on, what types of testing, and why?

A: You are producing 100,000 tons of tomatoes, so every 2000 pounds is one lot; from that 2,000 pounds, you take 60 samples to send to the lab to get tested. We divided the universe into high risk, medium risk and low risk.  High risk are ready-to-eat that you’re not going to cook; those are tomatoes, lettuce, cilantro and things like that. Medium-risk products come in and can be contaminated but you’re going to cook them, but can cause cross contamination -- the beef and chicken. And low risk are things that come in already pasteurized, such as sour cream or cheese.  We’re focusing on the high- and medium-risk products.

Q: How do you determine recommendations on where, and how much money and resources to invest in different food safety enhancements, and what areas to prioritize?  Are there ways Chipotle operates that make the company unique in any way?  Are you customizing the changes to accommodate this uniqueness? 

A: There is not a single formula that fits all. For each type of operation, you have to look at things and manage the risks, and then there are other some other elements.  How do they do things, unique to their processes, but just as important is what is their risk tolerance. There are some companies that have higher tolerance for risk and then companies that don’t.  In the program we design, one of the first questions we ask is: what is your risk tolerance and what is your food safety objective?  And if anyone says, ‘We want a food safety system that eliminates all risk and no outbreak at all,’ I respond, ‘I can’t do that, but  you can tremendously reduce the risk.’

Q: How do the food safety improvements you’re recommending for Chipotle compare to those being done at other foodservice establishments?  Is there a way to put perspective and context to this? Are these food safety improvements at a higher standard than other restaurants in this category? Is there a way to measure how much these food safety improvements alleviate the chance of another outbreak?

A: I stay away from claiming A is the best. That is not the issue. Certainly this is a program that makes this company a food safety leader and one of the leaders in the field.

Q: How far along is Chipotle in implementing your recommendations?  

A: Some are being implemented very fast, like the tomato and cilantro program. I believe poultry is getting implemented as we speak. Marinating meat at the end of the day was immediately done. A lot of these things were pushed, and the rest of them are getting implemented very aggressively.

As far as product testing, I can tell you very few companies test the tomatoes and lettuce using lots of 500 pounds to 2000 pounds. Some may be doing testing with lots of 8,000 pounds, 10,000 pounds or 20,000 pounds. The smaller the size of the lot, the higher the chance of finding a defect through statistics of sampling.

Q: Has Chipotle already started doing this testing, and if so, have food safety problems been caught?

A: Yes. Products have been rejected.  There’s proof it is actually working.

Q: What advice can you provide to produce suppliers to help companies like Chipotle in food safety efforts?

A: I’ve learned years ago, in the food industry, companies only move when they experience major outbreaks or bad events. These things are rare events, and people often don’t learn from someone else’s experience. There are companies that have actually done that, but the majority waits to have their own moment of reality to take action. Food safety risk is something that can be managed. It’s very possible and companies should want to do that, especially before it’s forced upon them.   

*****

We sense a mellowing of Dr. Samadpour as he carefully urges a more holistic approach to food safety then was emphasized during the fiery battles over finished product testing in the immediate aftermath of the Spinach Crisis. He is careful to avoid excessive claims for the food safety system that is being implemented.

Unfortunately Chipotle executives have not been as cautious. Even after the CDC announced the end of its investigation, the Chipotle statement was discordant with what Dr. Samadpour has carefully explained. The New York Times detailed Chipotle’s reaction to the news that the CDC had concluded its investigation:

A Chipotle spokesman, Chris Arnold, said in a statement on Monday that the company was pleased that the C.D.C. had concluded its investigation.

“Over the past few months we have taken significant steps to improve the safety of all of the food we serve, and we are confident that the changes we have made mean that every item on our menu is delicious and safe,” he said.

Of course, this is incorrect. There are many very good things to say about the new food safety program, but, as Dr. Samadpour makes clear, none of it is a guarantee of safety. So when the company makes claims such as that “every item” is “safe” — that is simply irresponsible.

And it is not just unknown spokespeople saying things in this manner. As we point out in our piece titled Chipotle, Bill Marler And Black Swan Events — How Much Money Do We Want To See Spent On Food Safety? the most important people in the company are saying things they shouldn’t say:

So, Steve Ells, the founder and co-CEO of Chipotle, makes some unfortunate pronouncements and CNBC uses his comments in this headline: Chipotle Execs: There is no E coli in Chipotle Today:

"I will say though, that we can assure you today that there is no E. coli in Chipotle," Ells said.

Dr. Samadpour needs to give the top executives and the PR team a lesson on the realities of food safety — including that despite many efforts, food safety cannot be guaranteed.

There are really three points to this program and they have important implications for the industry:

First is the issue of finished-product testing. Nobody is opposed to testing per se, but it can lead to a false sense of confidence and thus lead to less rigor in procurement than would be desirable. And the marketing of such programs is questionable if one can’t show that the degree in testing is statistically significant.

Second, utilizing culinary methods to enhance food safety, as in putting the cilantro on the hot rice rather than waiting for it to cool. Again, it is difficult to measure the significance of these changes but consciousness about food safety at all phases of the process can only be a force for good.

Third, what may wind up being most important… a public recognition of the dangers of processing things at store level. It is not only a foodservice issue — how can retailers cut fruit at the store and also claim food safety is their top priority?

Still, there are many elephants in the room and there is a lot not being said.

On the procurement side, we are not hearing commitments made publicly, such as to only buy from Global Food Safety Initiative  (GFSI) certified suppliers. There also were indications of traceability issues in this case. Yet there is no public commitment to only purchase from Produce Traceability Initiative (PTI) compliant suppliers. Doing these things constrains a buyer’s supply chain and thus raises cost — but these are prices one has to pay to deal with the best suppliers.

On the store operations side, rather than vague promises that employees will be taught the importance of staying home when sick, etc. — how about a public commitment that all employees hired are hired on a probationary basis, and they lose their job if they don’t get certified by the National Restaurant Association’s ServSafe program for food handling.

The biggest issue is sustaining the emphasis on food safety. Right now, there is heightened sensitivity and good decisions are being made. God willing, there will be no more outbreaks for a while and time will pass. Inevitably over-confidence sets in, they will stop paying Dr. Samadpour, and Chipotle executives will think the problem is licked.

But it is not, and a lack of outbreaks may mean no more than the odds are playing out and such rare events just don’t happen on predictable and regular schedules. So the question is what is changing that will lead to a priority on food safety when memories dim?

It is great to learn that, as Dr. Samadpour mentions, now Chipotle “employees get evaluated on the steps they are taking to create a safe food environment.” We once wrote a piece titled, Pundit’s Pulse Of The Industry: Cheesecake Factory’s Kix McGinnis Nystron Everclean Services’ Jack McShane, which detailed how Cheesecake Factory incentivized managers based on the results of audit scores and that this was quite effective.

The more difficult issue, though, is incentivizing buyers and top executives. We still remember when Karen Caplan, CEO, President at Frieda’s Inc., listened to a panel of retailers expressing that food safety was their top priority, she then raised her hand and humbly asked how these retailers had changed their Key Performance Indicators (KPIs) to reflect these corporate priorities — the silence was deafening.

For all the talk of food safety cultures, we find that food safety is just not a part of day-to-day procurement decisions. A buying organization — retail or foodservice — sets a standard. That standard may be high or may be low — it may be GFSI Certification or just a GAP audit. But that standard being set, the buyer has no incentive to pay more to get any higher standard.

Years ago Costco, a real world-class company on food safety, had a problem on carrots in Canada. We wrote about it in a piece titled, Costco Recalls Mexican Grown, U.S. Packed Baby Carrots From Canadian Stores. Carrots are basically a duopoly with only two world class US shippers. Yet, even in a food-safety-sensitive company such as Costco, nothing compelled a buyer to pay a quarter more to get product from Grimmway or Bolthouse — and the company wound up with a food safety issue. Chipotle hasn’t laid out how it has changed executive compensation to incentivize the highest food safety standards.

Dr. Samadpour is a useful and important addition to Chipotle’s culture. There is a smidgen of anti-science gobbledygook in Chipotle, and we mentioned some of this in an assessment of the company’s stance toward GMOs in a piece we titled, Organics, GMOs And Irradiation: The Voice Of Science. Unfortunately, food safety is very much a scientific project.

This whole episode has been so damaging to Chipotle because it has raised the issue of what “food with integrity” actually means. Even today one looks at the Chipotle web site and sees things such as this:

…sourcing the very best ingredients we can find and preparing them by hand.

But Dr. Samadpour is saying the opposite: Prepare by hand in store only if it is necessary for good taste, only if it is low risk item, etc.

Lincoln, echoing Jesus, famously warned that a House divided against itself cannot stand. The question that is still open is whether there is a cultural split at Chipotle that, ultimately, will prevent the company from prioritizing food safety. Dr. Samadpour’s most important task is not any specific food safety plan; it is whether he can leave a long term imprint on the culture of the company.

Many thanks to Dr. Samadpour for sharing his thoughts with the industry, and many thanks to Chipotle for allowing him to do so.

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