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Task For Center For Produce Safety? Pathogen-Testing Data Collection

Jim Prevor’s Perishable Pundit, May 1, 2007

United held its Food Safety Summit as a preliminary event to its FreshTech show in Palm Springs. This show is the renamed version of the old International Fresh-Cut Produce Association (IFPA) show. (Next year, it will be co-located with United’s main show, which, in turn will be co-located with FMI in Las Vegas.)

Among the most interesting things brought out at the conference was this little tidbit. Charles Sweat, COO, Natural Selection Foods, appeared at the conference and explained how the company was now conducting food safety testing on both raw product and finished product.

On raw material he explained that on a standard truckload of greens, Natural Selection Foods would take 460 samples. In the Q & A, many in the audience were surprised, even if pleased, with his candor:

Q: Any lots you’ve rejected since the testing?

A: We’ve had 39 positive tests on raw product; 23 E. coli and 16 salmonella. The contaminated products were from California, Arizona and Mexico. Our finished goods testing is only 8 weeks old, but so far we’ve found none testing positive. We started the raw testing in February.

The test takes 12 hours. You cannot test safety into your product. However, within 24 hours of harvest, we know of the problem through testing and we contact the grower.

With the 39 positive tests, it’s been very elusive. We haven’t been able to determine where the outbreaks occurred. That’s frustrating. The testing allows us to try and figure out in real time. Without that, you may have a delay of six weeks (with the product going through the supply chain to the consumer, etc.) until the problem was discovered.

Q: How did your discovery of the 39 positive tests compare to your previous testing?

A: This is a 100 percent change. We weren’t testing product prior to the outbreak.

It is a change just to hear from someone associated with Natural Selection Foods. As anyone who knows the ownership of this company realizes, their silence has to have been dictated by the company’s insurance company and lawyers. It is a shame because the company at the vortex of the spinach crisis probably has a lot to say.

We were a little confused by his use of the term E. coli, wanting to know if this was just E. coli 0157: H7 or other pathogenic strains of E. coli or generic E. coli.

We followed up with Natural Selection Foods, and Samantha Cabaluna, communications director for the company, provided some additional information:

As far as our finished product testing program goes, it is modeled on the same program as our raw product testing program. We are pulling 60 samples from packages off every packing line in every two-hour processing window. With 15 packing lines, that makes 900 samples per two-hour period.

Just as in our raw product testing program, that quantity is specified by the standards outlined by the International Commission on Microbiological Specifications for Food (ICMSF). We have adopted their Class 15 protocols, which are those set for the highest risk situations and offer the greatest level of confidence.

In addition to the manufacturing codes that we have stamped on our packages for years (which enable us to identify facility, date, line, shift the package was packed on), we also now stamp the time the bag or clamshell was packed. So, if we were to ever get a positive in our finished goods testing program, we can go right to that production lot.

Now, as far as our raw product testing, not all the E. coli positives were O157:H7. Some were other pathogenic strains in the family of Enterohaemorrhagic E. coli. When product tests positive, it is dumped and destroyed, and it triggers an immediate audit of the field where the product came from.

What’s so important to understand is this: these bacteria exist in our environment. By testing, we can detect it and prevent it from entering the chain of commerce. Until we know more about the bacteria or a kill step for fresh produce is discovered, we think this is the right thing to do.

Although 39 positive tests sounds like a lot, Natural Selection Foods does high volume, and we don’t have enough information to know if these numbers on raw product are high or not. What these numbers do demonstrate is that the processing plants are working well — perhaps because of enhancements since the spinach crisis, such as stronger chlorines and stronger agitation. Although the raw material testing shows pathogens on the arriving produce, the final product testing has so far shown up perfectly clean, meaning the plants are producing safe food for the consuming public.

This points to a very important task that the new Center for Produce Safety should undertake. With so many companies now testing both raw material and finished product, the CPS should build a repository of this data to be held on a confidential basis.

On a contemporaneous basis, the CPS could issue reports that would help processors do a better job by tying this data in with various factors. Is product from a particular country, state or county testing positive more frequently than other product? Does product irrigated with well water test positive less frequently than other water sources?

This report — with company names removed and even total numbers removed but, instead, incidence reflected as a percentage of pounds of product or other metric — would start to give processors information that can be useful in enhancing food safety right now.

In addition, maintained over time, these statistics can help us understand if our efforts at enhancing the Good Agricultural Practices documents are paying off in the reduction of pathogenic bacteria being delivered to processing plants on produce shipments.

Outbreaks are so rare that they defy statistical analysis, and the failure to have an outbreak this year means nothing in a statistical sense. So we can’t draw the conclusion that the new GAPs are achieving anything from an absence of outbreaks.

However, these Natural Selection Foods numbers would translate into several thousand pathogenic identifications each year on an industry-wide basis. That is enough to identify a statistically significant decline.

The Center for Produce Safety could show itself to be more than a mere conduit for passing out checks by stepping up to the plate and taking on this valuable task.

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