Pundit’s Mailbag — Farmers Are Not
The Cause Of Food Safety Problems
Jim Prevor’s Perishable Pundit, January 9, 2007
Weighing in our coverage of the spinach/E. coli 0157:H7 crisis and food safety issues in general is a gentleman who wishes to speak out on behalf of growers. In fact, he sees much of the trade’s food safety effort, which has focused heavily on revising the Good Agricultural Practices for growers to follow, as not being focused where he believes the problem really is — the processor level:
It is quite a letter and Karl makes several key claims:
-
The basis for much of the growth in the fresh-cut salad industry, the claim that the product is “ready-to-eat” right out of the bag without further washing, is overstated based on the practices many processors have been following.
-
Raw agricultural products should be expected to arrive at processing plants “dirty,” the processing plant is designed to “clean it up,” and E. coli is part of the “dirt” that should be expected.
-
Processing plants can fail for many reasons. In some cases the issue is “someone got greedy” — or looked to cut costs at the expense of safety. In some cases “no one was watching the store.”
-
Specific problems at processing plants include:
-
Poor traceback mechanisms and records
-
Running out of chlorine
-
Using poor quality chlorine, such as pool grade
-
Not promptly processing raw product
-
Not rotating raw product
-
Allowing product to sit getting warn in field totes
-
Turbity issues, which are not promptly resolved
-
Poor sanitation
-
Many farmers and processors are not food safety-oriented and only want an audit or HACCP plan developed because they need it to sell their product.
-
There are no new controls to discover that will be important. There are three things for growers to do, remembering that growers are expected to bring dirty product to a processing plant:
-
Test the wate
-
Perform soil analysis
-
Follow label directions on inputs
-
Composting is not the culprit but we must hold, test and only then release compost for use.
-
E. coli does not enter the stem or leaf of lettuce except under certain laboratory conditions.
-
Even after years of attention to food safety issues, most sprout producers are more lucky than food safety conscious and the government focus on seed soaking is misplaced.
In many ways Karl’s letter takes us back to the first letter we received on the spinach crisis. It came from Alan Siger of Consumers Produce Co. in Pittsburgh and focused on the fact that, disproportionately, it was fresh-cut produce that was the source of food safety outbreaks on fresh produce. Alan wrote us again to point out when the CDC came to the same conclusion.
If the problem is substantially a fresh-cut problem, then Karl’s focus on processors rather than growers seems compelling.
Karl’s core thesis — that growers are expected to deliver product to the plant “dirty” and then the plants are designed to clean it and make it safe — is both true and controversial at the same time.
Certainly plants have to be designed and operated on the assumption that dirty product, including bad things such as E. coli 0157: H7, might arrive on the produce.
At the same time most food safety experts seem to feel that at every stage of the food production and distribution pipeline, each actor needs to make strong efforts to deliver to the next stage the “cleanest” product possible. So, new rules involving things such as fencing to prevent intrusion of animals and establishing minimum distances from cows seem reasonable.
Several of the things Karl is talking about do seem to be quietly being done. During a Pundit interview with Natural Selection Foods, Samantha Cabaluma, Senior Director of Communications, mentioned some of the things they are doing on the processing end:
Our facility had top notch food safety manufacturing procedures in place before the outbreak. We are adding to that, increasing agitation in the wash line, boosting filtration in the water and the water testing. We also put in a different type of chlorine that may be stronger at killing pathogens.
Karl’s focus on processors is important because, completely aside from cause or fault, the industry has a lot better chance of solving the problem if it is something that can be implemented and enforced in a few hundred fresh-cut processing facilities located in identifiable places as opposed to in tens of thousands of farms located all over the country and around the world.
It brings us back to that first Alan Siger letter referenced above, in response to which the Pundit pointed out:
“…the only answer is that processing facilities have to assume that E. coli contamination is present and the processing has to be developed so that even if it is present on the crop, it can’t wind up in the bag.”