In the course of our coverage of the Salmonella/pistachio recall, we’ve confirmed what we have found in previous outbreaks: The FDA has no one with deep expertise in these commodities.
Sometimes the failure shows up in terms of not understanding the industry and distribution systems; sometimes it shows up in terms of not really understanding the commodity itself.
Because the recent pistachio recall has left so many open questions, we turned to Linda Harris at the University of California at Davis. We spoke to many experts and all identified her as the person to speak to when it came to tree nuts. She is understandably busy just now, but was kind enough to work with Pundit Investigator and Special Projects Editor Mira Slott to fill in some of the gaps in industry understanding of the intersection between Salmonella and pistachios:
Linda J. Harris, Ph.D. Associate Director Western Institute for Food Safety and Security Cooperative Extension Specialist in Microbial Food Safety Department of Food Science and Technology University of California Davis, California
Q: Where do pistachios rank in terms of risk for contamination of Salmonella in comparison to other produce items? Are pistachios a common or uncommon host for Salmonella? Why or why not? Do different nuts, such as peanuts or almonds, pose higher or lower risks of Salmonella contamination?
A. There is relatively little information available on Salmonella in nuts. The largest body of work relates to almonds, with some early work about 30 years ago on pecans, a little recently on peanut butter and a few, relatively limited international prevalence studies. And that is it. So your questions simply cannot be answered. There is no data to compare risks among nuts.
Q: What is required in the processing stages to provide a kill step and eliminate any potential pathogens in pistachios? Does roasting act as a kill step? What needs to occur, i.e., reach a certain temperature for a particular time period, for example? What other methods would work as kill steps? What types of research is being done in this area?
A. Thermal (heat) processes are the most common applied to foods. Typically we think of a heat process in terms of a given time at a certain temperature. The basis of validated thermal processes is that this time and temperature combination will result in a certain predictable reduction of target microorganisms. In general, the greater the time at a given temperature, the more microbes you kill AND less time is required at a higher temperature to kill the same number of microorganisms. Most processes that are designed to kill pathogens target the most heat resistant pathogen that would be important for that food.
A reduction goal is also set (for example: 10,000-, 100,000-, 10,000,000-fold reduction — these are 4-, 5- and 7-log reductions). “Eliminate” is not a term used by regulators or microbiologists — we say “reduce to an acceptable level”. That acceptable level often can be considered “virtually eliminate,” but it isn’t scientifically correct to say eliminate.
Thermal processes for nuts include oil roasting, dry roasting, and blanching as more traditional practices, but heat can also be applied through steam, infrared heat, etc. Each nut type has different handling after harvest, and there is variability in the type and amount of heat that is/can be applied. There are also other treatments such as gas (propylene oxide).
We are all pretty familiar with temperatures that are given for cooking poultry and other meats. The USDA recommends cooking turkey to 165 degrees F. This guidance is designed to reduce Salmonella by 10 million-fold (7 log). The meat industry must follow validated guidelines for cooking roast beef. In this case, achieving a temperature of 158 degrees F is sufficient to reduce Salmonella by 10-million fold — the target set for this product. The time (or the time/temperature combination) is zero seconds for these two examples. For the roast, if you look at the USDA chart you can see that an equivalent reduction is achieved at lower temperatures in combination with longer times.
I understand why people might assume that these types of times/temperatures should be adequate for other types of foods such as nuts. However, this is one of the most common misconceptions about Salmonella. Meat and poultry are moist. Once Salmonella dries as it would be on a nut it becomes remarkably heat resistant. If we look at some of the validated processes for almonds — oil roasting requires 2 minutes at 260 degrees F to achieve a 100,000-fold reduction of Salmonella (5 log) — 100-fold less reduction than in the roast beef or turkey examples — yet we had to use 100 degrees F higher temperature and 2 extra minutes to achieve this. Even blanched nuts need to be exposed to hot water for 2 minutes at 190 degrees F to achieve a 100,000-fold reduction, which is much longer time and higher temperature than for turkey or beef.
[Note: Domestic almonds must be treated using a process validated to achieve at least 10,000-fold reduction].
(Editor’s note: you can read the Pundit’s coverage of the almond situation here and here.)
A second complication is that not all heating methods are equal. That is clear in my example above — there is a very large difference between heating in hot oil (260 degrees F) and hot water (190degrees F) to achieve the same reduction of Salmonella in 2 minutes. We do not currently know if the data for almonds and oil roasting or blanching apply to other nuts.
When we move to dry roasting, things get really complex. Each type of dry roaster has a different heating profile. In addition, many dry roasters do not achieve uniform heating across the roaster. Data generated for oil roasting is not at all applicable to dry roasters, and each dry roaster must be individually validated.
For pistachios, dry roasting is most commonly used. Different companies will not only have different pieces of equipment but they may also have different times/temperatures that they use to achieve a certain end product quality. Validation of dry roasters is ongoing in the pistachio industry at the moment. Each company will be generating their own data for each roaster or roaster type. Most will probably hire a “thermal process authority” to do this as it is not an easy task, and it requires someone with expertise and experience with these types of validations.
Q. If raw pistachios carrying Salmonella were entering the processing plant, how likely would it be during periodic environmental testing within the plant where raw product was being handled during the processing stages for samples to test positive for Salmonella?
A. There is no answer to this question. There simply is no data.
Q: What is the significance of FDA discovering Salmonella in the Setton processing plant? Wouldn’t it be important to know exactly where the samples testing positive were taken in terms of the processing flow to make a meaningful assessment?
A: This demonstrates the presence of Salmonella in the processing facility. [Editors note: more on its relevance below]It would be useful to know this information but not critical at this point.
Q. What is the statistical/scientific significance that the Montevideo variety of Salmonella was discovered at the Setton plant in April and also in Georgia Nut Company’s testing of Setton product back in March? How scientifically significant is it that the same PFGE pattern of the Montevideo strain was discovered at both the Setton plant in April and also in the Georgia Nut Company’s testing of Setton product?
A. There are many different serovars of Salmonella. Montevideo is not uncommon but there are multiple PFGE patterns for this serovar. Finding a PFGE match between isolates from a finished product and the facility that produced the product provide further evidence that the two are linked. The fact that the organism is still in the processing facility indicates that it has been there for some time. In the 2000/2001 raw almond outbreak, investigators found the outbreak strain in the processing facility several months after the outbreak-associated lot was processed. It was also found at the huller/sheller and in the orchard. So we know that Salmonella strains can “hang out” in processing facilities and other environments.
Q. FDA said that four different strains of Salmonella (including Montevideo) were discovered in the Georgia Nut Company’s testing of Setton product in March. How common would it be to find four different strains of Salmonella in the same round of testing?
A. It depends. It would not be uncommon to find more than one type of Salmonella in a food product upon testing.
Q. Is it notable or inconsequential that the other three strains were not found during extensive testing at the Setton plant?
A. It is inconsequential.
Q. Is it notable or odd that Setton Pistachio had received excellent food safety ratings during regular audits from numerous reputable companies, and no one pointed out any violations of consequence?
A. There are a group of food microbiologists and food safety specialist that have been talking about the importance of Salmonella in dried foods for a long time. Unfortunately, the dogma has been that dried foods are not an issue for foodborne illness so not everyone paid attention to us.
A: More misconceptions:
1. Salmonella can’t grow in dried foods so they aren’t a problem. Actually it is true that Salmonella cannot grow in a food that is dried below a certain moisture level. However, they do survive on dried foods for very, very long periods of time. When the dried food is cooled down to refrigerated or freezer temperatures Salmonella levels will remain constant for years (another difficult concept for many people).
2. High levels of Salmonella are needed to cause illness. Not true. There are a number of outbreaks in dry foods where levels of Salmonella were documented and very low levels (10 cells or less per serving) were sufficient to cause illness. Salmonella doesn’t need to be able to multiply to cause illness.
If you couple these misconceptions with the “any kind of roasting will always eliminate Salmonella,” you can imagine that inspections/views of processing facilities for these products might have been inadequate from the perspective of Salmonella contamination. They weren’t looking for potential sources of Salmonella or for validated kill steps or for potential cross contamination points.
It is my hope that in 2009 we finally have enough evidence to convince the dried food industry that Salmonella IS an issue they should address — ALL DRIED FOODS — regardless of whether or not Salmonella has been isolated from the product and regardless of whether there has been a documented outbreak. RE-EVALUATE your safety programs with the view that Salmonella IS a potential hazard — that may just ensure it never is.
Q. This pistachio recall is massive. Does the size of the recall of Setton products seem weighted appropriately to the potential risk? What scientific methods can be employed to determine the size of a recall?
A. I have not seen the data that FDA and Setton Farms used to determine the scope of the recall. I will say that recalls can be more limited in scope if the company has data to support that the contamination is limited to one or more well-defined lots.
Q. Could recalled pistachio products be sent out for re-roasting and safely be sold in the market?
A. Products can be “reconditioned” if they are processed with a validated kill step and they are protected from re-contamination after that kill step.
Q. What additional actions can pistachio companies take to alleviate the risk of Salmonella contamination?
A. As I said earlier — this applies to all dried foods. The new GMA Salmonella control guidance and appendix should be mandatory reading for all in the dried food business. I have begun to compile nut-related information at this site including the GMA documents.
There are many things that can be done. I think the GMA document covers the basics very well, and I have taken a section out of that document table of contents that covers all the points I would make:
SALMONELLA CONTROL ELEMENTS
1. Prevent ingress or spread of Salmonella in the processing facility
2. Enhance the stringency of hygiene practices and controls in the Primary Salmonella Control Area
3. Apply hygienic design principles to building and equipment design
4. Prevent or minimize growth of Salmonella within the facility
5. Establish a raw materials/ingredients control program
6. Validate control measures to inactivate Salmonella
7. Establish procedures for verification of Salmonella controls and corrective actions
We really are in debt to Linda Harris. She has clarified issues that hundreds of articles and countless interactions with government authorities have been unable to clarify. Here are the seven big points we take from this:
1. There is insufficient data. We need to get the various tree nut producers to start funding studies. Perhaps The Center for Produce Safety, all set up and operating, could extend a hand of outreach to the tree nut communities and offer to facilitate the research if the tree nut folks will fund it. We need to understand baselines, comparative risk, to know when we are experiencing the norm and when it is an exception. We need good, hard, scientific data. Which means we need money.
2. If you are going to use roasting as a kill step then every type of roaster must be individually validated. We don’t actually know if a particular type of roasting is a kill step or not unless it is validated.
3. Almonds have had more trouble and so have come to require a treatment validated to achieve a 10,000 log reduction. One possibility is that most of the roasters are already achieving this and so problems have been few on pistachios and we need a formal validation procedure to make sure no one errant roaster is causing a problem. More research in the field might tell us if Salmonella is more or less prevalent on the raw pistachios than it is on raw almonds.
4. We think it fascinating that Dr. Harris does not think, at this point, it is critical to know where in the processing plant Salmonella was found. The FDA and CDFA have not even attempted to trace the Salmonella back to the trees. They assume there is Salmonella on the raw nuts and count on the assumed kill step — roasting — to make the product acceptably safe. So the FDA and CDFA seem to be accepting that the plant will take in Salmonella laced product, which means they would expect to find Salmonella in intake areas and other parts of the plant prior to roasting. It seems Dr. Harris has different expectations.
We asked Dr. Harris if she thought the FDA and CDFA should go back to the fields as they did in the spinach crisis and she gave this answer:
I think you are trying to compare two very different things. In the case of the spinach outbreak — it was outbreak #20 associated with lettuce and leafy greens if I remember correctly. There was strong incentive to attempt to identify a source of the organism with the goal of potentially preventing future outbreaks. In addition, their traceback was able to narrow the investigation to 4 farms (I am going from memory on the number of farms) which helped improve the odds that they might actually find something.
In the almond outbreak in 2000/2001 they were able to identify the processor through microbial sampling, they narrowed the lot to 4 huller/shellers and then found the outbreak isolate at a single huller/sheller and were able to focus the “field” work on three farms (and they were able to isolate the organism from the orchards on those farms).
In both cases there was an outbreak. Both investigations involved huge input in terms of human resources and sample analysis even with the targeted analysis of a few farms. In many ways these types of investigations are needle in a hay stack and you really need to keep them as focused as possible so that you don’t spend a lot of money for zero results.
In this case I am not sure it is good use of limited state or federal resources to push this back further. Also, it may not be possible to narrow the investigation to a small number of farms or orchards at this point in time or given the records available.
Obviously resource allocation is always an issue but we would point out that this is not what the FDA and CDFA claimed when we spoke to them. We were told that the distinction had to do with the fact that spinach is consumed raw, without going through a kill step — so no pathogen is acceptable. In the case of pistachios, we were specifically told that the government assumes there is Salmonella on raw nuts and so doing trace back would not yield any important information.
Here is something that makes one fear for the future of the civilization. A group of Greenshirts recently invaded a Carrefour store in France and took all the product they believed was Israeli or might be Israeli and removed it from the shelves. This included much fresh produce plus floral bouquets and other items.
Obviously people are free to purchase what they choose and to peaceably attempt to persuade others. Removing all the product from a store, often destroying it, however, deprives others of choice and is both thuggish and illegal. That there were no policemen means either the French police wouldn’t come or Carrefour was afraid to call them.
The real danger is intimidation. How many times does something like this have to happen before Carrefour decides it is not worth the trouble to carry Israeli goods?
Yet if our society surrenders to thugs, what can our future possibly hold?
The video is in French, but you won’t need a translation to understand what is going on:
We have often discussed the immigration issue, and our piece, Will US Citizens Harvest Crops? led those who are promoting AgJOBS to write quickly to assure us that we had misinterpreted the joint announcement of the two big national labor federations and that AgJOBS still had labor’s endorsement.
We ran the piece under the title, Pundit’s Mailbag — Guest Worker Programs, and the key component was a statement from Luawanna Hallstrom, who is, among other things, co-chair of the Agricultural Coalition for Immigration Reform (ACIR):
“Considerable media attention has been given to statements released this past week by the AFL-CIO and Change to Win Coalition regarding the conditions for their support for comprehensive immigration reform legislation. While media reports indicate that major national labor unions do not support expanded guest worker programs but would consider a Commission to study the need for future guest worker programs as part of comprehensive immigration reform legislation, there is no doubt that the guest worker policy positions of these labor organizations do not include the H-2A guest worker reform provisions of AgJOBS. This union support has been communicated by representatives of the United Farm Workers Union to leaders of the national agricultural coalition spearheading efforts to pass AgJOBS this Congress. To the contrary, these labor organizations have and continue to support AgJOBs, including its H-2A guest worker reform provisions, as part of comprehensive immigration reform. It is important that this accurate message be communicated to the grower and farm worker communities.”
Although we had no doubt about the sincerity of the people from ACIR, we know that politics sometimes makes strange bedfellows, and coalitions are built and collapse. We wanted to get a sense of what was behind the union endorsement of AgJOBS and thus how sturdy this coalition will be. One of the things we try to do here at the Pundit is not just talk about the past but also reflect on what the future may hold.
In order to get a better sense of union sentiment on this matter, we spoke to some union leaders privately, and Pundit Investigator and Special Projects Editor Mira Slott spoke to a representative of the AFL-CIO on the record. Here is what we were told:
A: The most controversial piece involves regulatory changes made before the Bush Administration left office. If the Ag compromise was successful, it could have prevented damage.
Q: Could you specify the regulatory changes?
A: The Bush Administration had eliminated the adverse wage protection, and many of the safeguards that had been associated with the H-2A program. We sent many letters citing our opposition.
Under the Obama Administration, the Department of Labor has acted to stop those changes from being implemented.
The AgJOBS bill hasn’t been reintroduced in Congress, but AFL-CIO has endorsed the AgJOBS bills in previous congresses. We haven’t seen any of the language in a new bill, so we wouldn’t be in a position to comment on it except to say we have endorsed previous versions. I was on the Hill (April 23) trying to find out from Diane Feinstein, who is sponsor of the bill, when it will be introduced.
Q: Could you clarify your position on guest worker programs?
A: We do not support expansion of guest worker programs, but we do support their reform. We can’t have a position on a piece of legislation not yet introduced.
H-2A is a seasonal program for ag workers. An agreement came about when United Farm Workers sat down with growers and concessions were made on both sides and we came up with an agreement. It streamlined the process for certification for employers. It freezes the wage protections, a concession for labor and in exchange, offers for the first time a path to legal residencies for guest workers. This was a tremendous victory, for no longer is this simply a transient labor force but it offers workers the chance to stay and have permanent residence. We’ve made specific concessions in AgJOBS compromises that we don’t like, but in doing so give ag workers a path to citizenship, which is a huge victory.
This agreement brings concession on the part of labor and growers. We think it’s the best way to arrive at compromise.
The Bush Administration slashed wages in H-2A programs without offering any aid to farm workers. What the Ag concession does, it freezes the adverse wage calculation; it was a negotiation, fairly entered into by labor and growers and resulted in concessions on both sides.
There have been regulatory changes to H-2A, and concessions on wages, but what has never been done before is a path to residency. This is an historic win.
So, when all is said and done, this is what we come up with:
1. Labor unions are waiting to see the exact language of this year’s AgJOBS bill before they endorse or oppose.
2. Labor unions have supported AgJOBS in the past and probably will support it again.
3. However, there are a lot of things in the bill labor doesn’t like. The big win for labor is the offer of a path to permanent residency for currently illegal workers and to achieve that they will compromise.
We would add two caveats:
First, unemployment in Spain just broke 17%. If, God forbid, we see domestic unemployment go anywhere near that number, large segments of the labor movement will oppose both guest workers and legalization, and the whole AgJOBS compromise will collapse.
Second, the other variable is President Obama. If he was to decide to offer a transition to citizenship for workers already in the US illegally without regard to what industry they work in, then the reason labor is endorsing AgJOBS — namely the path to citizenship for ag workers contained in the bill — would be superfluous.
AgJOBS has many passionate devotees. Right now organized labor is with the bill. Yet it is a bill that contains many things unions don’t like. Let the dynamic change just a bit and the future of labor support for the bill would quickly become uncertain.
Now we have received a letter from an important participant in this field and one generous enough to have contributed to our efforts many times in the past:
The current Minsky Moment and after-effects that the global banking system is going through is a confirmation that a yes-no or pass-fail auditing system leaves a lot of “value in the table”. Even with all of those government and pseudo-government auditors, and government-approved rating agencies, they could not identify a systemic risk. One well defined by more than one school of economics.
A large number of banks refused to participate in the high risk financial tools, rather their conservative management sacrificed short term gain for long term value. Others participated and/or failed to regulate because there was no consensus regarding the level of risk these innovative financial instruments presented. The fresh produce industry shares a number of similarities with the banking system.
No sector of the food industry is audited by as many agencies with auditors as sophisticated as the US banking industry. Let’s take the comparison to an industry less audited than banking but still far more subject to government oversight than the fresh produce industry — the beef industry. Despite a 24/7 USDA presence and with most of their product being exposed to a “kill step” just prior to serving, there are still outbreaks in the beef industry and outbreaks that have destroyed some of that industry’s largest players.
While each and every incidence of food borne illness is unacceptable, the number of incidences of illness being vectored by fresh produce is small as measured against the number of successfully delivered servings. In fact, it would not be a stretch to refer to an incidence of illness vectored by fresh produce as the fresh produce industry’s “Black Swan” event(s), an event that can be considered an outlier by a statistician but cannot be ignored by a practitioner. The consequences are too catastrophic to be ignored. Today it takes a naive individual or someone unconcerned with credibility to make a blanket claim regarding one’s ability to guarantee against “Black Swan” events.
Primus will continue to utilize the “under promise, over perform” philosophy.
The Centers for Disease Control (CDC) has utilized computers to find the “needle in the hay stack” through PulseNet. The fresh produce industry needs to exploit the same technologies to prevent “the needle from falling into the hay stack”. Not only does the enhanced computing and communication capability improve the buyers’ oversight of suppliers but also the buyer’s oversight of the auditing firms and their individual auditors. This transparency results in the suppliers and the auditors being subject to competitive market conditions that force continuous improvement or failure.
Computerized audit review systems can and have been developed for buyers of varying sizes. Frequently, these systems emphasize concerns specific firms want to address as part of their unique corporate culture or in response to their client base’s concerns. While virtually each system is customized to the buyer’s specifications, all have a series of features that provide confirmations that: operations are audited, minimum requirements are met and corrective measures are implemented and in a timely fashion. In addition, all reporting systems are displayed in a management by exception manner.
Giving buyers a free pass regarding their responsibility for providing oversight would be a mistake and certainly a disservice to suppliers and buyers who have been working together for years to perfect various oversight systems. In fact it is a safe bet that the fresh produce industry is large enough and diverse enough that what is defined as safe production and handling practices will come in more than one form.
Certainly consolidators that are very small can piggyback off the efforts of industry leaders. This type of recognition of excellence has been going on for years when a buyer approved a supply based on the supplier’s current client list. What firm is not proud of their success in selling to demanding clients?
Robert F. Stovicek, PhD. President Primus Group Santa Maria, California
We think Bob makes several crucial points:
First, people may be looking to audits for more than audits can provide. His point that all the auditors surrounding the banking sector could not assure solvency is telling indeed.
Second, round-the-clock USDA inspectors and the fact that the product is cooked have not prevented foodborne illnesses from beef. Why believe that any amount of inspections could end foodborne illness for produce?
Third, foodborne illness is such a rare result of produce consumption that any normal “advance” — a 10% improvement in some metric or other — can only have a statistically inconsequential impact on food safety outcomes.
Fourth, perhaps most pointedly, Bob also points to the importance of keeping the buyer involved in food safety. With a new administration in Washington, one more inclined to put government in the forefront of food safety solutions, there is real chance that the role of buyers in food safety could be depreciated. After all, if the government makes everything safe, why spend money on safety?
Indeed we’ve been disappointed as the President has sometimes downplayed the important contributions of the industry on food safety and given excessive credit to government employees.
President Obama showed he is blinded by the liberal conceit that the government is the most important factor in food safety: “There are certain things only a government can do. And one of those things is ensuring that the foods we eat are safe and don’t cause us harm.”
This is nonsense. The government does not farm or process anything, it does not distribute, market or cook, and it cannot possibly monitor the hundreds of millions of people in over 100 countries and every state, from field to fork, that have a role in food safety.
Food in the United States is generally safe for four reasons: First, because there are moral precepts that make the vast majority of producers intent on doing no harm to their customers. Second, because the value of a brand and a company dissipate rapidly if they sicken or kill their customers. Third, because those who prepare meals at home mostly love those they cook for and so try to serve wholesome foods. Fourth, because the United States is an affluent, western society with advanced technologies and procedures for making foods safe and we are both willing and able to spend money to have safer food.
Of course, government is important. It sets up the legal and economic ground rules within which we operate. But its specific effect on food safety is dramatically overstated by those, like the president, who seem able to identify virtue only in public employees.
What else could the president mean when he says, “The men and women who inspect our foods it is because of the work they do each and every day that the United States is one of the safest places in the world to buy groceries”? It seems the president has this notion that the entire private sector for food production and distribution is filled with bad actors being held back by an army of federal inspectors.
The president says this but in the same address he contradicts himself by pointing out that “the FDA has been underfunded and understaffed in recent years, leaving the agency with the resources to inspect just 7,000 of our 150,000 food processing plants and warehouses each year. That means roughly 95% of them go uninspected.” Obviously it is impossible to both hold that we barely inspect anything and yet it is these inspections that are responsible for the overwhelmingly safe food we have in America.
In the end the government has a role, the auditor has a role, the buyer has a role but it is, in fact, always the producer and the preparer of food that really makes it safe.
Even then, even with maximum care, as Bob says, only a fool would assume that safety is guaranteed. Food safety events in produce are outliers, but, as Bob indicates, they are of such consequence that neither a company nor the industry can ignore the possibility of such an event.
We have written before about the terrible flaw in thinking that people fall under when considering regulation. If you give a responsibility to business, the assumption is that businesspeople have many divergent interests and that, therefore, the responsibility may not be honored.
But just as fools thought that by “outlawing war” through the Kellogg Briand Pact, so people, exceedingly skeptical of the ability of the private sector to obtain food safety, assume that the mere passage of a law ensures food safety.
Yet, here at the Pundit we’ve looked at the controversy over the 7th Street Market in Los Angeles and the Taco Bell/KFC with the rats in New York, and we see clearly that merely passing a law or hiring an inspector, assures nothing.
One wonders if instead of deemphasizing the role of buyers in food safety we shouldn’t increase their legal responsibility. After all, in the aftermath of the spinach crisis, we interviewed Jo McDonald of the British Retail Consortium, who made a specific claim:
“I believe that if all companies had adopted BRC standards, the spinach E. coli outbreak very well could have been avoided.”
— Jo McDonald Technical Services Manager British Retail Consortium
The BRC standards, though, were developed in a different legal environment, in which a combination of common use of private label combined with legal requirements for due diligence made buyers more deeply involved. In the US system, buyers have often focused on indemnifications and making sure vendors have adequate insurance because it is the producer that is typically liable.
One wonders if looking at legal changes, reshuffling liability, might be the key to safer food.
Many thanks to Bob Stovicek and to Primus for contributing such a thought-provoking letter on this important subject.