Insights On The Alfalfa Sprout Advisory
Jim Prevor’s Perishable Pundit, April 28, 2009
The FDA has issued a consumer advisory not to eat alfalfa sprouts. United Fresh also issued a statement urging sprout growers to follow good food safety practices. We turned to frequent Pundit correspondent Bob Sanderson to see if we can find a solution to this long running food safety issue with sprouts.
We asked Pundit Investigator and Special Projects Editor Mira Slott to see what we could learn:
Mira touched base with Bob Sanderson en route from a meeting in College Park, Maryland, between sprout growers and FDA officials…
Q: How did the meeting go?
A: The meeting included Dr. Stephen Sundlof, Director of Center for Food Safety and Nutrition (CFSAN), FDA, Dr. David Acheson, Assistant Commissioner for Food Safety at CFSAN and Jack Guzewich, [RS, MPH] Sanitarian/Epidemiologist at CFSAN. It was an extremely cordial meeting. The fact is that the cat is out of the bag, and while some retailers are continuing to order as usual, many retailers won’t accept products.
There is a question of what might signal an “all clear.” The details are that there were a few outbreaks in the Midwest, but the critical turning point was when an outbreak that started in Omaha was linked to a later outbreak of Salmonella Saintpaul in Michigan with the same fingerprint. The epidemiology implicated sprouts, but no pathogen has been found in any seed or sprouts. Jack Guzewich explained that a disproportionate amount of sprouts were found in the epidemiology, leading to the consumer advisory not to eat alfalfa sprouts. But this is not a recall.
Q: Are you satisfied with the information FDA provided to justify a consumer warning not to eat any alfalfa sprouts? Is there a reason FDA is unable to give a more targeted advisory?
A: Recent events have shown that epidemiology can be very tricky. While the "no smoking gun" (the Salmonella Saintpaul has, to-date, not been isolated from any seed or sprout samples) seems to put a big question there, it isn’t necessarily good evidence that it wasn’t sprouts. Contamination in seed lots can be very sporadic; a needle in a haystack. But on the other hand…? It is very tricky.
The other side of the question is, what’s FDA going to do when epidemiology, based on statistical analysis rather than direct detection, indicates huge probabilities of a particular disease vector?
This is further complicated by the fact that statistical analysis involves mathematics that can be very counter-intuitive. Like, if 20 people got sick, and 10 remember eating the food in question, and 7 don’t think they did, and 3 are sure they didn’t, and in a random survey, 1 person in 20 says they ate that kind of food….
The other issue is that these Saintpaul positives were associated with different seed lot numbers. That’s unusual. It suggests blending or mixing of lots, and that makes it very difficult to trace. The CFSAN folks didn’t know where the problem begins and ends. There is certain reasonableness to this, but realistically it probably could be handled better.
If FDA could trace to the source seed — and it has sort of implied it is getting close, but no names have been mentioned — then there could be an announcement, the mother load of seed found. What follows is that if a company is not using that seed, it is probably not in trouble. But FDA said, and repeated, that there won’t end up being an announcement to consumers that it is OK to buy sprouts. FDA has been squeamish about the safety of sprouts all along.
Q: I thought the sprouts industry had some of the strictest food safety measures in place. Why are these outbreaks occurring?
A: The guidance and recommendations are just that; compliance is not monitored with any consistency. The FDA very rarely inspects with its own people, while it does join with state boards. There are two main recommendations; one is very high levels of chlorine, and the other is high amounts of testing, hold product and don’t ship until results come back negative. We take samples of water running off sprouts, and 48 hours later we get the report from the lab. If it’s negative, we can ship.
Q: Are all industry producers operating under such stringent standards as your company — Triple testing procedures starting with the seed?
A: No one seems to know who’s doing exactly what. That’s part of the problem. There is no compliance-monitoring. Guidance is a recommendation. That was repeated over and over again today.
Q: What is the solution? Did you discuss this with FDA?
A: What’s needed is a way for industry to police itself better because FDA clearly isn’t going to, but if there are more problems, it will issue very severe warnings.
Q: What impact do these warnings have on consumers?
A: FDA didn’t blanket all sprouts, just alfalfa sprouts specifically. Sprout growers are dealing with concerned supermarket customers. How the public is responding we don’t know yet. People who like sprouts say, ‘What else is new?’ and eat them anyway.
The industry is really in a panic and that’s where my lack of sleep comes in. We need to make some kind of plan. I think it will be pretty much on our own. In terms of public reassurance, we have to generate it because it’s not going to come from FDA. If the retailers are scared off, they say they don’t want to buy.
Q: Could you share more information about the FDA investigation. Why are there so many lot numbers involved?
A: The tracing it to different seed lot numbers has raised questions. If people think FDA is hasty, they probably think CFSAN was not doing the epidemiology right, and it’s probably not sprouts.
Q: How are lot numbers determined? Could the lots be adjacent on the same farm, for example? Do producers mix different lots together, and if so, do they re-number them for traceability?
A: What determines what number gets put on an amount of seed? It varies. You could have lot 69432 and mix 50 tons with lot 78653, and the new lot mix is called 89245. That’s the mess. To the FDA, the outbreak indicates blending, which is common practice, not necessarily devious, but probably not a good idea because it becomes next to impossible to trace back. The bottom line is that blending of lots of seeds used for sprouting is not advisable.
Q: Are there lots of seeds that are specifically designated for sprouting?
A: Seeds don’t become sprouting seeds until someone determines this. I doubt if any alfalfa farmer says, ‘I’m going to plant for human consumption.’ They grow to sell into the raw seed market, and some of that becomes human food. And that’s a problem, because it’s treated like it’s not for human food, and then changes later on.
Q: There must be significant differences from a food safety perspective in the farming process for seeds grown for human food.
A: Food for animals doesn’t need to be grown using Good Agricultural Practices (GAPs). The main differences is that on an ag field you may have livestock to helpfertilize the field and help maintain it and save money, but the seeds can get contamination in the field.
Technically speaking, that seed in the bag coming to Jonathan Sprouts is not food for human consumption until it just enters the door. It’s a line that’s drawn.
Q: Why not just require sprout growers to use seed that’s grown with GAPs for human consumption?
A: If you did that, suddenly a big proportion of sprout crop would disappear if it were only allowed to be produced with GAPs. Maybe if there was a way to introduce the requirement incrementally. It’s much more expensive to grow seed using GAPs.
In the seed business, yields can change tremendously year-to-year, season-to-season. For a seed grower, this year Iowa will be good and Arizona won’t be good, for example; that’s why companies mix seeds in the raw seed business.
If a seed grower took a few acres and said he was going to grow this using GAP, he would have to be much more careful with intrusion of animals, water sources, how seed was handled and bagged. It should be the way starting seed is grown for human food. These issues are not just domestic.
Q: Has FDA determined that the seed source is domestic?
A: There has been mumbling that it might have come from another country. But I haven’t had it confirmed, and there are plenty of rumors going around. If someone goes to a field outside of the country and finds the same strain of Salmonella, that would be pretty big news, but so far we don’t know anything.
Q: Do you believe that FDA is being forthright with the industry regarding the information they’ve learned so far?
A: They clobbered us beforehand with the press release advisory but were thoughtful to bring all the sprout growers together for this meeting in College Park. We had a conference call, actually a couple; on Friday they made the announcement that they were going to issue a general advisory, not a recall, on all alfalfa sprouts.
Q: What actions did FDA want the sprouts industry to take following the advisory, if not a recall? Doesn’t an advisory to consumers not to eat any alfalfa sprouts put retailers in a precarious position about stocking the product anyway?
A: FDA leaves it up to us. One of our big customers is taking all of our product off the shelves. FDA says it’s not a recall, it’s just an advisory. This customer may not buy from us, maybe they’ll charge us a lot of money for this recall. This isn’t a recall, but you’ve got a potentially dangerous food on the shelves. FDA is bound by legal, and they can’t be mandating certain actions.
My own point of view: I’ve been in this business 30 years, involved with the FDA the last 10, but it’s really only in the last three that I understand how they work. Solutions will have to come from the industry. FDA may provide huge problems and the most they can do is say the Salmonella Saintpaul strain has been isolated to seed lot such and such. We need to talk to the customers and say this is the problem and convince them it’s OK to start buying our product again. FDA doesn’t say it’s safe to start eating alfalfa sprouts.
Q: Will the industry start partnering with seed companies to grow with GAPs?
A: It needs to happen — people with courage and vision to take a risk and limit purchases to companies that only use seeds grown with GAPs. It also could be good public relations to say, ‘my seeds were grown using GAPs.’
Q: You’ve been progressive in food safety. Are you looking to start the process?
A: We’ve never gotten close to seed production before. Seeds come in bags or trucks and we take it from there. We are looking more to partner with seed farmers. What would it cost you to commit to GAPs? We must talk to the farmers about costs. They might get a failed crop. In the scheme of things, I doubt the cost will be beyond what the industry can handle. But it is a paradigm shift.
The industry is not even as big as it was 10 years ago because of all these food safety problems. I had a feeling from talking with people that the industry had lots of potential, but somehow we’re all stuck in first gear. We don’t have outbreaks for a year or two and everyone is holding their breadth. That is not the kind of investment most people would be attracted to. We could put in controls.
If the seed is an unknown quantity, we can do a lot of testing, and if the testing shows a problem, we have to throw it all out and it’s a big loss. Farmers would like the food safety mechanisms to move upstream and for processors to have better controls.
This is what concerns me about irradiation becoming widely accepted. Would there be a tendency to get lax before the finished product processing? I see the same issue with the pistachio recall, where FDA saw no need for going back to the orchards because of the kill step in the processing plant. Food safety must be applied across the entire supply chain.
Bob is a real insider with deep knowledge of the business, and he has given us two very simple changes that could make a world of difference. The FDA’s approach has been premised on the idea that the sprouter of the seeds will put them through a disinfectant procedure.
That is a good policy, but why not back it up and insist on seed more likely to be safe and traceable?
Most alfalfa is raised for animal feed, so they make no effort to avoid animals or animal excrement in the growing fields. Later on, when a sprouting facility buys the seed it suddenly becomes food for human consumption. Yet it was not grown under any procedures designed to keep it clean and free of pathogens.
Any buyers out there who want to make a productive contribution, here is an opportunity: Make a policy that next year you will only buy alfalfa sprouts that are grown from seed certified to have been raised on a third-party audited, GAP-compliant farm. This should also be added to the FDA’s Guidance Document.
Blending of seed lots makes traceability almost impossible, so the practice should be halted. Part of the GAPS for raising alfalfa seed to be used as human food should require its segmentation into traceable lots — no blending allowed.
Finally, buyers need to treat sprouts as one of the high-risk produce items. That means insisting on third-party audited product.
We still find that issuing these broad recommendations not to consume really makes no sense. The risk is still very small, and the FDA would gain credibility by releasing information — what the FDA believes the risk to be — rather than a recommendation.
Bob alludes to a sense of consumer complacency that sprout eaters have developed over these FDA advisories. Like the boy who cried wolf, consumers who kept eating spinach and then tomatoes and then jalapenos and then pistachios and now sprouts and never got sick start to turn a deaf ear to FDA advice. That could be deadly one day, and the food industry needs a credible FDA to give an “all clear.” The way to maintain credibility is by allowing people to take reasonable risks after they are informed with information.
Many thanks to Bob Sanderson for taking time out of a most hectic day to keep the industry informed.