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Pundit’s Mailbag — Marketer Of BroccoSprouts Calls For Strict Adherence To FDA Guidelines

Jim Prevor’s Perishable Pundit, June 23, 2009

Our extensive analysis of events in the sprouting industry has brought a letter with a different perspective:

I am a fan of yours, and, in the last few weeks I, like most people I know in the sprouting industry, have been following your articles on our industry with great interest.

I am writing this note in part to relay to you another part of the sprouts story. These matters involve issues that are not going to go away as long as the industry insists on varying from the FDA recommendations and not continually trying to improve the processes.

Let me start by telling you a little about me. I am in my mid-60’s and have been in the sprout industry for the last 25 years. I started by growing sprouts in the early 1980’s. I took a small sprout company (Life Force Foods) from sales of mid-300’s to over $1.5 million per year in a few years. Back then $ 1 million would buy you a lot of sprouts!

By the early 1990’s, I sold the sprout business and started a company that made equipment for the sprouting and vegetable processing industry, Sunshine Systems.

In 1998 I sold that business to Caudill Seed Company to help develop a company that was based on the discovery at Johns Hopkins Medical School that certain varieties of broccoli sprouts contained very high levels of cancer-preventative compounds and that was the basis for the founding of Brassica Protection Products (BPP), the marketer of BroccoSprouts®. We started as a science-based company with roots deep into the labs at Johns Hopkins University.

Consequently, we recognized the importance of food safety and have expended a lot of resources in developing and maintaining our food safety program. Some of the people involved in our program are Dr. Doug Archer of the UF and the FDA, Dr, Art Davis of Sholl Group & IEH, and Dr. Bob Strong of Steritech and many others. We employ a national food auditing company to independently audit our sprout growers to insure they are following the guidance completely.

BPP operates through a licensed network of 14 sprout growers in the US and 15 other growers around the worldd. In the US, these growers produce about 50 to 60% of all the green sprouts, that is, alfalfa, broccoli, clover and radish, sold. Our sprouts are sold in some of the most safety-conscious retailers in the US, ranging from Whole Foods to Safeway to Wal-Mart.

I would like to add to some of the statements of the last few weeks, for the sake of clarity:

1. Caudill Seed Company sells approximately 70 to 80% of all the green sprout seed used in the sprouting industry in the US. I have known the principals for over 25 years. I have purchased (directly or through our organization) millions of dollars of seed from him. I can say I have found him one of the most honest brokers of seed out there. He is very concerned about the issues facing the sprout industry but approaches them very differently from Bob Rust and Bob Sanderson. He will be spending a lot of his capital on new ways to combat the problems.

2. The basic science behind the FDA Guidance is based on work developed by The Sholl Group/Green Giant Fresh and Brassica Protection Products with Dr. Art Davis directing the effort. We have been a constant supporter of the guidance in its entirety. Our Food Safety Program is based on the FDA Guidances and includes an audit to ensure compliance with all the guidances. Unlike Bob Sanderson, whom I have a great deal of respect for, we believe in seed sanitation with the 20,000 ppm of calcium hypochlorite and insist it be followed. It may not be the best or the only method of seed sanitation, but right now, it is the only one that FDA explicitly supports.

3. The FDA wants all sprout growers to adhere strictly to all the guidance (including using 20,000 ppm chlorine), not just the parts they are comfortable with. FDA has noted in its investigations that there are many failures in following the guidance’s properly and that these have resulted in problems for the industry.

Our Food Safety Program is not fool-proof — nothing is — but it is good and it is based on science and the FDA Guidance. We have had problems, but far, far fewer than the industry as a whole. Every time there is a problem, we try to learn by it and adjust our program to eliminate similar recalls in the future. This is true of the latest problems. We are totally reviewing our food safety program and auditing approach to make sure we catch any future situations before they become a problem.

With regard to seed, it is completely untrue that all the outbreaks have come from Caudill Seed Company and that none have come from Bob Rust’s ISS. By my reckoning, of the 11 recalls/market withdrawals of alfalfa sprouts in 2008 and so far in 2009, seed from Caudill was implicated in only 5, seed from others, primarily ISS, was implicated in 5 and 1 was facility-related. If Caudill sells 75% of the alfalfa seed in the US and their seed is responsible for less than 50% of the outbreaks, then that’s a pretty good indicator of the care he takes with his seed. Any outbreak is one too many, but to say that Caudill Seed is responsible for all the outbreaks as some have said, is simply not true.

While we endorse the idea of your challenge to the sprout industry to have alfalfa seed grown for sprouting with particular attention to not getting farm animal contamination, I know Caudill’s seed contracts specify that seed cannot be grown within ½ mile of any animal feed lot and cannot be grown on land that was grazed by animals in the previous 6 months. I am sure that Bob Rust/ISS has a similar policy in place. We do know that some outbreaks occurred when sprouters bought seed from less experienced or less specialized seed growers who did not take these precautions. The FDA has urged sprouters to buy only from experienced and careful seed suppliers. Most sprouters I’ve talked to have learned their lesson and only buy from Caudill and ISS.

I think the sprout industry faces many challenges right now and the industry needs to band together to ensure that sprouts are grown as safely as possible, before other outbreaks destroy the industry. Right now, it only seems prudent to follow all the FDA guidances strictly. We support the industry in finding other superior methods that can be demonstrated to be supported by real science on the lab bench and in practice at sprouting facilities.

Earl Hauserman
VP Business Development
Brassica Protection Products LLC
Baltimore, MD

We thank Earl Hauserman for writing this letter as it is an important contribution to the industry debate. The Brassica Protection Products LLC growers have taken the food safety issue seriously and contributed significantly to many of the parts of the current FDA guidance of growing safe sprouts. They continue to invest a significant amount of money looking at alternative ways to sanitize seed and improve their food safety program.

The sprout industry seems to be ridden by faction and there is no love lost between International Specialty Supply (ISS) and Caudill and between the leadership of the International Sprout Growers Association (ISGA) and Brassica Protection Products LLC. In fact for weeks now we have been receiving phone calls accusing others in the industry of nefarious practices.

Earl Hauserman’s letter is important because it brings into the industry dialog a very important industry segment. Let us look at a few of Earl’s key points:

Caudill Seed Company sells approximately 70 to 80% of all the green sprout seed used in the sprouting industry in the US. I have known the principals for over 25 years. I have purchased (directly or through our organization) millions of dollars of seed from him. I can say I have found him one of the most honest brokers of seed out there. He is very concerned about the issues facing the sprout industry but approaches them very differently from Bob Rust and Bob Sanderson. He will be spending a lot of his capital on new ways to combat the problems.

Caudill Seed Company is the “licensed seed supplier” for Brassica Protection Products, so it is nice to have Earl speak up for the company. Still, it is odd that the company can’t speak up for itself. We ran an interview with a spokesperson for Caudill Seed Company, titled Alfalfa Seed Company, FDA, USDA And Supporting Cast Comment On Seed Withdrawal. This interview was very hindered because Caudill, instead of having a principal keep the industry apprised on its doings, insisted on having an outside PR agency do its talking, and that agency, though trying to be helpful, was simply not an expert on alfalfa seed, Caudill Seed Company, nor seed in general, making several claims that were simply incorrect. We have nothing against the principals at Caudill Seed Company and can’t speak to their concern about food safety. We can only say that we gave them an opportunity to speak directly to the industry and they declined to do so.

The basic science behind the FDA Guidance is based on work developed by The Sholl Group/Green Giant Fresh and Brassica Protection Products with Dr. Art Davis directing the effort. We have been a constant supporter of the guidance in its entirety. Our Food Safety Program is based on the FDA guidances and includes an audit to ensure compliance with all the guidances. Unlike Bob Sanderson, whom I have a great deal of respect for, we believe in seed sanitation with the 20,000 ppm of calcium hypochlorite and insist it be followed. It may not be the best or the only method of seed sanitation, but right now, it is the only one that FDA explicitly supports.

What is interesting about this is we have spoken with some of BPP’s licensees and they told us that they are, in fact, not using calcium hypochlorite as they have other chemicals they believe are more effective. So it does not seem that use of calcium hypochlorite is a “hard” standard for BPP. And, in fact, as it came out in our interview with Bob Sanderson, which you can read here, the FDA Guidance uses calcium hypochlorite solely as an example, specifically leaving the door open for other options.

Now, we found Bob Sanderson’s interview enlightening but we think that Bob may be interpreting the FDA guidance too broadly. Although the FDA clearly uses calcium hypochlorite as an example only, it seems that those sprouters who wish to not use it do have a burden of obligation to prove that their use of an alternative is substantially similar or superior to calcium hypochlorite if the sprouter wishes to claim to be in compliance with FDA guidance.

The FDA wants all sprout growers to adhere strictly to all the guidance (including using 20,000 ppm chlorine), not just the parts they are comfortable with. FDA has noted in its investigations that there are many failures in following the guidances properly and that these have resulted in problems for the industry.

This strikes us as a little unfair. FDA knows perfectly well how to change its guidance to say that it wishes to see the use of calcium hypochlorite and nothing is a suitable substitute. FDA chooses not to do so, which means FDA is OK with the use of alternatives.

We also would be a little careful about claiming that following the FDA Guidance is the be all and end all of food safety in sprouting. Yes, most of the food safety outbreaks come from those not following the FDA Guidance but post hoc ergo proctor hoc is still a logical fallacy.

Most of the companies following the guidance are the big players in the industry. As Earl mentions in his letter, his 14 domestic US licensees produce 50 to 60% of the green sprouts. These folks have the most capital, and access to food safety staff. They are subjected to the most rigorous oversight from large buyers. It is very possible, even likely, that if FDA never came out with its guidance, these larger organizations would have safer practices anyway.

With regard to seed, it is completely untrue that all the outbreaks have come from Caudill Seed Company and that none have come from Bob Rust’s ISS. By my reckoning, of the 11 recalls/market withdrawals of alfalfa sprouts in 2008 and so far in 2009, seed from Caudill was implicated in only 5, seed from others, primarily ISS, was implicated in 5 and 1 was facility-related. If Caudill sells 75% of the alfalfa seed in the US, and their seed is responsible for less than 50% of the outbreaks, then that’s a pretty good indicator of the care he takes with his seed. Any outbreak is one too many, but to say that Caudill seed is responsible for all the outbreaks as some have said, is simply not true.

We have had several writers that have expressed doubts about Caudill seed and they may well have been unfair, expressing broad generalities based on anecdote. Though we do note that those who wrote in skeptically about Caudill, as you can see here and here, were speaking about long term historical experience, not the 2008/2009 record that Earl is referencing. It is, of course, imperative to consider market share in interpreting these numbers.

While we endorse the idea of your challenge to the sprout industry to have alfalfa seed grown for sprouting with particular attention to not getting farm animal contamination, I know Caudill’s seed contracts specify that seed cannot be grown within ½ mile of any animal feed lot and cannot be grown on land that was grazed by animals in the previous 6 months. I am sure that Bob Rust/ISS has a similar policy in place.

The test we are organizing is designed to produce alfalfa seed for sprouters that has been grown specifically for human consumption, which is a significantly higher standard than simply trying to avoid farm animal contamination. We are aware of the clauses in seed company contracts and simply point out that a contractual clause merely gives the seed company a breech-of-contract claim against a grower who doesn’t observe the clause. It is dramatically different than requiring a third-party auditor to certify that the standard is being followed. Our interview with Caudill made it clear that no such audit was required.

I think the sprout industry faces many challenges right now and the industry needs to band together to ensure that sprouts are grown as safely as possible, before other outbreaks destroy the industry. Right now it only seems prudent to follow all the FDA guidances strictly. We support the industry in finding other superior methods that can be demonstrated to be supported by real science on the lab bench and in practice at sprouting facilities.

Here we are on common ground. The sprout industry faces significant challenges. Safety must be made a top priority if the sprout industry is to grow beyond core consumers. Large markets in foodservice simply won’t carry the items.

The FDA Guidance is all we have right now, so it is going to be the focus of these efforts.

Yet, this is somewhat problematic. The FDA has no procedure set up to regularly revise and update this Guidance. So as Earl’s producers are calling us to say they have alternatives that they believe are superior, the FDA sits on its hands. Indeed the FDA Guidance can lead to atrophy in industry food safety efforts as buyers, wanting to be safe, demand adherence to a decade-old guidance.

This means that newer ideas are frozen out. Buyers dare not deviate from FDA Guidance, which means sprouters won’t dare deviate, which means food safety innovators have a battle to find markets.

Thus the road to food safety for sprouts has to involve a way to make innovation attractive to buyers and sprouters alike.

Many thanks to Earl Hauserman and Brassica Protection Products LLC for helping to broaden the industry debate.

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