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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:

I have been in the middle of the spinach mess from the beginning and have successfully defended many of my clients (processors and farmers) in this debacle and many more recalls recently — it is not the farmer causing these problems.

Let me say it again, IT IS NOT THE FARMER CAUSING THESE PROBLEMS! The public, government and trade associations all are misled by a very expensive and well run PR effort by those who stand to lose the most money — the processors. The more they can shove the blame down hill to the farmer, the less they pay out in losses. Look at the losses they are facing — it is overwhelming. The US Mint does not have enough cash to pay their bill. Follow the money on this one, not the hog or cow standing in the field of green.

The farmer is expected to bring the product to the state-of-the-art, HACCP-certified, run like a Swiss watch, overly chlorinated, highly professionally trained personnel, highly publicized plant that cranks it out well advertised as “Ready to Eat”. What in this statement is the red flag? It is the plant! The problem is the plant, not the farmer.

You don’t need rocket science to figure this one out. The farmers would have killed us off years ago if they were at fault. It’s not that E.coli 0157:H7 is that much stronger, it’s that we are reading the “Ready-to-Eat” advertising and eating out of the bag. We are drinking the Kool-Aid!

Years ago as a kid growing up in San Jose, I would watch my Mother at the sink peeling the outer leaves off the head of iceberg lettuce and washing the core. Why? Because the farmer is not expected to clean it up. In our fast ready-to-eat society, we’ve lost along the way a lot of good ideas. Today, there is so much money in the lettuce business they don’t dare back off of the “Ready-to-Eat” advertising because our culture is so ready-to-eat-oriented that to add the washing step at the fast food restaurant or at home would be a marketing disaster.

I have clients that cringe at the ready-to-eat advertising. They either refuse to print it on the bags of lettuce or place a disclaimer on the back of the bag. Why? Because the brokers and super stores won’t buy it if it is not ready-to-eat.

However, it can be ready-to-eat. But it comes back to why the system failed not only in the spinach crisis but also many others. Look deep into the Taco Bell debacle and you will see the plants, restaurants and big taco corporation very much at fault. Not to mention they added a dimension to the produce industry’s problems by pulling the trigger early on green onions and then the lettuce.

We will never know where the contamination came from but bet me that the big taco corporation won’t take the blame. It all goes back to what I am calling “not watching the store”. It is not the farmer, as it is they who have the most to lose. What is so amazing is that as I watch Senate hearings, listen to technical review boards and other so-called experts on this crisis and the truly uninformed from the press that followed, no one, repeat, no one even dared to bring up the subject of management. Why?

Follow the buck. Who supports the trade association, the organic program, the government and so on? The big processors. Who makes the money — and a lot of it by the way? The big processors. And who pays the bills for all the big experts, the processors. The farmers don’t make it, especially the individual organic farmer. By the way, ask me some day to discuss what people are calling organics — Twinkies are more organic in my opinion, and healthier!

Inside the spinach and the other more recent debacles, you will find plants that lost track of the traceback of where the product came from, running out of chlorine to treat the water, using pool grade chlorine (not the good stuff), allowing spinach, which normally sits refrigerated for two hours before being washed and bagged, sitting for almost 5 days in many cases and not being rotated, left dirty, getting warm in field totes, turbidity issues that should have been taken care of routinely but allowed to remain in the wash system for days, little or no sanitation; the list goes on.

One little tiny cluster of bacteria can grow to tremendous colony counts in little time, and after days of sitting and then not being washed well, will grow to deadly levels. But why were these things allowed to happen in the state-of-the-art, HACCP certified, run like a Swiss watch, overly chlorinated, highly professionally trained personnel, highly publicized plant that cranks it out well advertised as “Ready to Eat”? BECAUSE SOMEONE GOT GREEDY — NO ONE WAS WATCHING THE STORE.

Take your pick which is the right answer, but both answers work equally well. How do I know these things? Because my company services many farmers and processors in this business, and we find mismanagement all the time. We will not work with a farmer or processor that provides lip service to food safety or indicates through their actions that they simply want our name on their product to sell it.

I have to take my hat off to those like George Boskovich, who hired my company years ago after they were wrongly implicated in the green onion crisis to turn his company upside down and find the problems and weak links again and again, day after day. Today, Boskovich Farms is one of the finest processors in the business because not only are they constantly challenging their systems but they also are not getting rich on it either. (By the way, they were doing a great job of food safety before the green onion crisis — another testament to their programs four years ago.)

Boskovich Farms is good, honest people doing their due diligence, as many others we service are also trying to do.

It’s not the farmer. Sure, there are some farmers out there that can do better but there are no new controls or technology to discover. Mother Nature has a great system and if we help her by testing well water, doing soil analysis and following label directions on inputs, then the product is delivered to the plant in great shape. Remember, the farmer is expected to bring dirty product to the processing plant.

For those who think composting is the culprit, it is not. It can be if not done correctly, but composting is not what is causing the problem. So you say, how did the E. coli get into the plant? Yes, it did come from the farm — where else could it have come from? Maybe someone not washing their hands but not to the degree that would sicken hundreds of people. But once again, the farmer is expected to bring it to the plant dirty. The plant is designed, let me say that again, the plant is designed to clean it up!

Our food safety programs are not broke and do not need more or different standards. They just need to be enforced beginning with the plant owners, managers and QA personnel. NOT THE FARMER, IT’S THE PROCESSING PLANT! Take composting out of the farm and you have taken away one of the most critical and important tools the farmer has — watch his production cost go up!

Removing composting is like asking the farmer to eliminate water. And kiss off the organic program. It rests on compost. When can compost be bad? If we don’t hold, test and release it after we manufacture it from manure and other materials. However, and again, the farmer is expected to bring it to the plant dirty.

And stop all this nonsense about E. coli being introduced into the stem or leaf of the lettuce. Nothing is farther from the truth. I have study upon study that disproves it and yes, there are studies that show it can be introduced into the plant. And you too would take E. coli into your blood stream if it was force fed into your veins. It does not take a rocket scientist again to figure this one out. If that were the case we would have all been dead long ago.

And, don’t think for a minute the sprout industry knows what they are doing. I am involved in that community, and they still have not figured out that food safety is the key to safe food; they seem to think nature takes care of food safety. Does nature prevent unwanted pregnancies? The government has it wrong (again) with seed soaking and not focusing on the tenants of food safety.

The sprout industry has some great people, but the vast majority are just lucky on outbreaks. My hat is off to people like Robin Taylor of Sun Grown Organic Distributors, who puts food safety above all things, especially his profit.

Someone needs to wake up and follow the money to find the problem and get this conversation off the backs of the farmer! Be a George Boskovich and do your due diligence.

— Karl Kolb Ph.D.
President and CEO
The High Sierra Group and the American Food Safety Institute, International

It is quite a letter and Karl makes several key claims:

1. 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.
2. 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.
3. 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.”
4. Specific problems at processing plants include:
   1. Poor traceback mechanisms and records
   2. Running out of chlorine
   3. Using poor quality chlorine, such as pool grade
   4. Not promptly processing raw product
   5. Not rotating raw product
   6. Allowing product to sit getting warn in field totes
   7. Turbity issues, which are not promptly resolved
   8. Poor sanitation
5. 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.
6. 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:
   1. Test the wate
   2. Perform soil analysis
   3. Follow label directions on inputs
7. Composting is not the culprit but we must hold, test and only then release compost for use.
8. E. coli does not enter the stem or leaf of lettuce except under certain laboratory conditions.
9. 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.”