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Pundit’s Mailbag — Better To Look Beyond Packinghouse To Find
Bacteria On Lemons

Jim Prevor’s Perishable Pundit, February 8, 2008

Our piece, Lemon Wedges And Bacteria, featured a video passed around on the Internet that reported on a study by a community college professor who found bacteria on lemon wedges that had been placed on drinks such as iced tea or Coca-Cola.

Now we have received a letter from a respected citrus packer saying, “It sure as hell didn’t happen here!”

Having run a lemon packinghouse for 27 years, I see NO way that conventionally packed whole lemons could pick up ANY bacteria at the time of packing!

First, we in the lemon industry are required by our customers to pass an annual stringent third-party Food Safety and Food Security audit. The audit requires that we have written policies that include cleaning procedures for the entire packing facility, including ALL the equipment that conveys and/or touches the lemons.

These written policies and procedures are inspected by the third-party auditor prior to the actual facility audit … all the water used for cleaning and sanitizing is directly drawn from a delivery source of fresh city water … we are required and obtain annually an analysis report of the city water to prove to our third-party auditor that the CITY water is free of any bacteria.

The objective of the cleaning process is to remove ANY potential microbial organisms, food, and/or soil residues so the cleaning and sanitizing chemicals can be free to destroy ANY microorganisms on the lemon contact surfaces as well as in the facility environment … the following steps are stringently followed in the cleaning and sanitizing process:

  1. Place waterproof coverings over electrical motors, electrical boxes, etc.

  2. Remove as much dry residue from surfaces as possible by dry cleaning

  3. Rinse surfaces from the top downward

  4. Apply antimicrobial detergent beginning at the bottom and moving upward

  5. Do not allow the detergent to dry on the surface

  6. Rinse with city water beginning at the top and working downward

  7. Inspect the area for any missed particles or remaining solid residues and re-clean the area where remnants are discovered following Steps 4 thorugh 7

  8. Apply the correct antimicrobial sanitizer in the correct concentration. Begin sanitizing from the bottom and work upward to ensure complete coverage. Do not rinse the sanitizer off.

  9. Remove the coverings that were applied in Step 1

After each use, all cleaning items are either washed, rinsed, sanitized, and allowed to dry after use or deposited at the specified collection point for laundering or they are disposed of.

Second, all employees are continually instructed using the written policy for employee training, education, and practices relating to food and worker safety AND to ensure the safe and proper handling of lemons … this written policy and training sessions are checked by the third-party food safety and food security auditor.

The food safety portion of the ongoing employee training stresses the importance of personal hygiene and sanitation procedures … employees displaying symptoms of an active illness are not allowed to work … employees are instructed and continually monitored in the proper method of hand washing and sanitizing and must follow this procedure:

  1. Wet hands with warm running water

  2. Using antimicrobial soap, rub hands together for at least 20 seconds making sure to clean under the nails and between the fingers

  3. Rinse hands under warm running water

  4. Turn water off ONLY using the elbows on the hands-free knobs

  5. Dry hands using single use paper towels from a hands free paper towel dispenser

  6. Sanitize hands using the sanitizer dispenser at each hand washing station remembering that hand sanitizing shall NEVER take the place of proper hand washing

Any employee who touches the lemons are required by our Food Safety and Food Security policies to wear gloves … there is a separate written policy for what to do with those gloves during each work day relating to the work station, restroom breaks, coughing/sneezing, where to place the gloves when leaving the work station, and what to do IF the gloves become contaminated at ANY time during the work day … ALL gloves are returned to a laundering collection point at the end of each work day and only newly washed gloves are obtained by each employee at the beginning of each work day …

Third, how lemons are processed during the packing process virtually eliminates ANY possibility of contamination by some bacterial microbe … lemons actually go through two separate processes — pregrading and packing … during the pregrading process, the freshly harvested lemons are dumped out of the harvesting bins into a dump tank containing 200 PPM of Sodium Hypochlorite (chlorine) and a 3 percent solution of Sodium Bicarbonate to kill any spores that may be adhering to the rind of the fruit from the growing, harvesting, and hauling process.

From there the lemons are elevated into soak tank containing a 3 percent of Sodium Carbonate (dense soda ash) and 105 degree water, which act together as a cauterizing agent to heal minute injuries to the lemon that cannot be seen by the human eye … the lemons are then elevated out of the soak tank onto a bristle brush wash bed where they are rinsed and 3,000 PPM’s of Thiabendazole (a fungicide) is applied to inhibit mold spore growth/formulation, 175 PPM’s of Isopropyl ester of 2,4-Dichlorophenoxyacetic Acid is applied to fix the button to the stem of the fruit so that spores cannot enter the lemon if the button were to fall off, and a 1 percent solution of paraffin emulsion (wax) is added to seal the rind of the lemon and inhibit dehydration.

The lemons are then graded to remove injured fruit that is visible to the human eye … and, finally, the lemons are placed into plastic storage bins that are used ONLY in the packinghouse and are NEVER used in the harvesting operation eliminating the possibility of soil borne contaminates … during the packing process, the lemons are dumped onto a wide slow moving belt and over sprayed with 125 PPM’s of Sodium Hypochlorite (chlorine) … they then move onto a bristle brush bed where a foaming soap is applied to remove the pregrade and natural wax from the lemons.

Continuing on, a 3 percent solution of Sodium Bicarbonate is applied to the fruit on the brush bed to kill any errant spores before the lemons receive an aqueous wash of Imazalil (fungicide) to prohibit future growth of penicillium mold … the lemons are rinsed using city water and then partially dried by sponge donut rolls … a cosmetic “kosher and parve” wax is then applied to the entire surface of the lemon to seal off the entire fruit and inhibit future dehydration … the wax also contains either 3,000 to 5,000 PPM of Thiabendazole (fungicide) or 2,000 to 4,000 PPM of Imazalil (fungicide) to inhibit future mold/decay formation and increase shelf-life.

The lemons are then dried, graded, sized, and then packed … the lemons are either packed into NEW corrugated cartons or recyclable plastic containers … as part of our Food Safety and Food Security programs and policies and as is mandated by the third party food safety and food security auditor, we have “Letters of Guarantee” from our packaging suppliers attesting to either the method of manufacture of the corrugated cartons or the method(s) of cleaning of the recyclable plastic containers …

The above is but a brief overview of a manual that is as thick as my arm entitled, “Standard Operating Procedures and Policies at Associated Citrus Packers, Inc. For Ensuring Safe Handling of Fresh Citrus” … FRESH CITRUS GENERALLY, AND LEMONS SPECIFICALLY BY THEIR VERY NATURE, IS ONE OF THE SAFEST, IF NOT THE SAFEST, UNPROCESSED OR MINIMALLY PROCESSED (RAW) FRESH FRUITS AVAILABLE TO THE CONSUMER TODAY ! And our Food Safety and Food Security programs received yet another renewed rating of “SUPERIOR”, the highest score/rating achievable!

The lemon(s) in question in your article was undoubtedly delivered in perfect sanitary condition from this packinghouse or any other packinghouse in the citrus industry … as an industry, we have no control over how that piece of fruit is handled once it leaves the carton it was packed in by one of us in the industry … if someone TRULY found bacteria on the rind of a lemon, I am CERTAIN one needs to look beyond the packinghouse to find where the lemon became contaminated! It sure as hell didn’t happen here!

— Bill Spencer
President & Chief Operating Officer
Associated Citrus Packers, Inc
Yuma, Arizona

We appreciate Bill’s informative letter. The whole lemon industry has always intrigued us. Back in the days of prorate, the Pundit earned his supper exporting American lemons, the price of which were artificially depressed by prorate if the lemons were purchased for export. Simultaneously the Pundit was importing Spanish lemons to the east coast, where the price of lemons were maintained at an artificially high price, also due to prorate. The ships often passed each other in New York harbor.

Bill’s letter regarding the exhaustive practices that packers go through with their lemons is impressive and, as we mentioned in our piece, “The risk seems pretty slight,” but we still thought it worth showing.

Bill, quite reasonably, points out that “…we have no control over how that piece of fruit is handled once it leaves the carton it was packed in by one of us in the industry…” Yet we would say that, true as that might be, as an industry, we just can’t afford to leave the matter that way.

After all, if consumers start to get concerned about bacteria on lemon slices dropped in their drinks — whatever or whoever the cause — they won’t order them and that will wind up hurting lemon producers and packers far more than dirty-fingered waiters who might be causing the problem.

Is that fair? With all the food safety efforts our industry has undertaken, is it fair that we should be required to take on even greater burdens? In this political season, with troops in Iraq and Afghanistan, we are reminded of a rare dip into extemporaneous philosophy for then-President John F. Kennedy.

At a press conference, he responded to the resentment of some reservists that had been called up due to the crisis in Berlin and the beginning of war in Vietnam. These reservists felt they had “done their bit” for America and it was unfair to call on them again. President Kennedy responded this way:

“…there is always inequity in life. Some men are killed in a war, and some men are wounded, and some men never leave the country, and some men are stationed in the Antarctic, and some are stationed in San Francisco. It’s very hard in military or in personal life to assure complete equality. Life is unfair. Some people are sick and others are well.”

And the bottom line is, fair or not, we have to get involved and do everything possible to make sure our products are safe when consumers eat them.

In our article, we had referenced a piece we had done on the watermelon industry, and in that piece, Mark Arney, Executive Director and Leslie Coleman, Director of Communications for the National Watermelon Promotion Board recounted a story in an interview with Pundit Investigator and Special Projects Editor Mira Slott of how the watermelon industry suffered as a result of a cross contamination incident:

Q: Do you have examples of incidents within the watermelon industry that required strong crisis management skills?

MARK: Go back to cross-contamination issues we had with watermelon in Milwaukee in 2000. A young child died from E. coli poisoning after eating watermelon. It turned out to be cross-contamination at a restaurant where the cook had cut up some watermelon with a knife previously used on raw meat. The Milwaukee Health Department conducted an investigation. It was a terrible, unfortunate accident.

LESLIE: Mark and I both came on board following that event. From what I’ve seen in the files and from media coverage, the health department moved quickly in determining the source of the problem. I did not see tremendous evidence of mistakes in managing the incident. People on the Board were quick to get the word out that it was cross-contamination.

MARK: On August 1, 2000, immediately after the event occurred, the Milwaukee Sentinel released an erroneous article. “E. coli Traced to Watermelon” was the headline. It reported “…watermelon served on the salad bar of a south side Sizzler restaurant from July 14 to July 21 appears to be the source of the E. coli bacteria that killed a young girl and sickened 41 other people that Monday.”

LESLIE: One of the unfortunate things that happens with the Internet is that these stories never go away. One of these initial stories indicating watermelon as the source of the contamination ended up being picked up again and re-reported around Christmas time just this past year. Apparently a reporter writing about a new food safety incident went on the Internet to do research and picked up that first incorrect story. Through Internet news sources, Mark found the article that mentioned this Milwaukee incident from years and years ago falsely linking it to watermelon.

The danger with the Internet is that you can go back to find one bit of information about an outbreak but don’t necessarily find the whole story.

MARK: Shortly after, the City of Milwaukee Health Department and Wisconsin Department of Health linked the contamination to two Milwaukee Sizzler restaurants and isolated the problem to raw meat from the restaurant, manufactured by the company Excel. Lawsuits were initiated against Sizzler USA and Excel but none against the watermelon supplier because of a lot of work our staff did to get the word out that watermelon was only the vehicle for the contamination.

Even food poisoning attorneys I would describe as the equivalent of ambulance-chasers looking for victims admonished the watermelon industry of any responsibility in that case.

Good communication skills saved the watermelon shipper from legal action, but it didn’t stop the issue from hitting the newspapers and, very likely, depressing sales.

So what can the industry do? Well, some of it is to support organizations such as the Partnership for Food Safety Education and its Fight Bac! and Be Food Safe — Clean. Separate. Cook. Chill campaigns.

All to often, the production end of the produce industry gets jumped on a little too quickly by every other link in the food safety chain. We have to make sure our associations always demand that restaurants and retailers do their part as well.

This particular study took place on the foodservice operator end of the business, and the most likely source for fecal bacteria on those lemons is the restaurant employee who cut them or the restaurant employee who placed them on the glass. NRA has been very quick to issue all kinds of demands on produce producers. Shouldn’t someone ask them what they are doing, other than posting a sign in the bathroom, to make sure employees thoroughly wash their hands?

Many thanks to Bill Spencer for helping us to think through this issue.

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