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Pathogens In Food
Not Same As Foodborne Illness

Jim Prevor’s Perishable Pundit, April 22, 2008

We ran a piece entitled, Little Food Safety Progress Leads Media To Look Closer At Our Industry, which featured an NBC Nightly News video looking at produce industry efforts to enhance food safety and included interviews with Jim Lugg, Food Safety Director of Fresh Express, and Dirk Giannini of Christensen & Giannini, who is a grower in Monterey County.

The news report was motivated by a new CDC report indicating that foodborne illness in the US has not declined since 2004. We pointed out that what this seemed to imply was that despite all the food industry’s efforts to enhance food safety, it seemed to be having little effect.

We received a letter from an extension toxicologist suggesting we need to think of this data in a different manner:

I think you have to be much more analytical about how you “keep score” in the Food Safety area when it comes to food safety and produce. The CDC is reporting food borne illness and the measures the production industry is taking reduces disease pathogens. These are very different issues. Illness is a human condition over which growers have little or virtually no control.

The occurrence of disease pathogens on produce is a biological reality that can be effected by food handling practices. Develop measures that acknowledge the occurrence of disease pathogens as environmental, biological realities and work very hard to MINIMIZE them. This is happening and it is not a new issue (but it is receiving new emphasis). It will be possible to show dramatic progress in that area and to demonstrate vigilance and success. Advocate a responsible amount of produce inspection and measurement as a purity issue, NOT as a means to prevent illness!

In the long term, such actions may impact the incidence of food borne illness, but since illness may result from many factors that are unmeasured and not part of production and shipment of produce, the role of the industry can be clarified and put in proper perspective. When illnesses occur (70 million cases per year and it is under-reported in the U.S.), if there is general recognition that disease pathogens are ever-present at some level and that agriculture minimizes their occurrence in the food supply, I think there will be lesser tendency to seek single causes and paralyze elements of food production.

Bob Krieger, Ph.D.
Extension Toxicologist
Personal Chemical Exposure Program
Department of Entomology
Environmental Toxicology Graduate Program
University of California, Riverside, CA

We thank Bob for his letter and agree we deserve a few lashes with a wet noodle for not pointing out the obvious distinction between pathogens on food and foodborne illness.

In all likelihood, the vast majority of the CDC’s estimated 76 million cases of foodborne illness each year, including 325,000 hospitalizations and 5,000 deaths, can be traced back to food preparation, storage and handling. In many products, such has hamburger and E. coli — proper cooking is 100% effective at avoiding foodborne illness.

Illness, as a human condition, depends on the vulnerability of one’s immune system. And food capable of causing a foodborne illness depends on many things other than pathogens on the raw material. Although it is a little dated, having been done in 2000, even a quick look at the report of the FDA Retail Food Program Database of Foodborne Illness Risk Factors points out how often the problem is not just a matter of a pathogen on the food from the source. Look at this table on produce at retail stores:

Table 10. RETAIL FOOD STORE — PRODUCE DEPARTMENT
% OUT OF COMPLIANCE OBSERVATIONS

Industry Segment — Retail Food Store Facility Type — Produce Dept.NTotal Observations% OUT of COMPLIANCE
Data Item
PHF Held Cold at 41°F (5°C) or Below759877%
Surfaces/Utensils Clean/Sanitized629963%
RTE, PHF Discarded After 4D/45°F (7°C) or 7D/41°F (5°C)335659%
Proper, Adequate Handwashing368741%

PHF stands for “potentially hazardous food,” and you see that temperatures are rarely maintained at retail.

Surfaces are typically not properly sanitized.

RTE — or ready-to-eat — foods and potentially hazardous foods are not discarded in accordance with time and temperature recommendations.

41% of the time the staff is not properly washing their hands.

Deli Departments had even worse problems:

Table 8. RETAIL FOOD STORE — DELI DEPARTMENT
% OUT OF COMPLIANCE OBSERVATIONS

Industry Segment — Retail Food Store Facility Type — Deli Dept.NTotal Observations% OUT of COMPLIANCE
Data Item
PHF Held Cold at 41°F (5°C) or Below7210072%
RTE, PHF Date Marked After 24 Hr54 8266%
Commercially Processed RTE, PHF Date Marked 60 9265%
Proper, Adequate Handwashing5410154%
Surfaces/Utensils Clean/Sanitized5310252%
PHF Held Hot at 140°F (60°C) or Above47 9052%
RTE, PHF Discarded After 4D/45°F (7°C) or 7D/41°F (5°C)34 6751%
Poisons/Toxics ID Store/Use Properly3610235%

Even in hospitals the out of compliance is substantial:

Table 3. INSTITUTIONS — HOSPITALS
% OUT OF COMPLIANCE OBSERVATIONS

Industry Segment — Institutions Facility Type — HospitalsNTotal Observations% OUT of COMPLIANCE
Data Item
PHF Held Cold at 41°F (5°C) or Below548861%
Commercially Processed RTE, PHF Date Marked327742%
RTE, PHF Date Marked After 24 Hr368841%
Proper, Adequate Handwashing369239%
PHF Held Hot at 140°F (60°C) or Above328936%
Surfaces/Utensils Clean/Sanitized329135%

This is important to be aware of and, as Bob Krieger is correct to point out “…if there is general recognition that disease pathogens are ever-present at some level and that agriculture minimizes their occurrence in the food supply, I think there will be lesser tendency to seek single causes and paralyze elements of food production.”

However, as we have just seen in the Honduran Cantaloupe situation, the current state of the law is that the mere presence of a pathogen justifies any measure the FDA feels like taking.

Bob Krieger is clearly right, pathogens on food are not the same as foodborne illness. Still, his suggestion that we seek purity strikes us as complex.

Yes, one can argue that we should pursue pure food. After all, many of the pathogens we are concerned with have their root in animal or human excrement. So as a matter of quality, we should want to rid this from our products.

It all costs money, though, and if it will not reduce the incidence of foodborne illness, one has to wonder if that money shouldn’t be directed in another manner.

It is a quandary and one the industry will eventually have to confront. One reason some oppose irradiation is because they perceive it as a license to sell dirty food which is then irradiated to make it safe, whereas they want to buy clean food that is naturally safe because it is clean.

We thank Bob Krieger and the University of California, Riverside, for helping us think through such an important issue.

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