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Inspection Agencies Could
Assist In Traceability

Jim Prevor’s Perishable Pundit, September 25, 2007

Public health authorities have been critical of the industry for failing to maintain suitable traceability systems. As a result, millions have been spent and countless efforts are underway to enhance traceability. But the public health authorities could assist the effort.

Turns out that the Canadian Food Inspection Agency does its tests on blends in such a way that the source of the pathogen cannot be ascertained and that traceback thus becomes a massive and probably fruitless exercise involving field investigations of three states (at least in the recent case of the Dole recall).

Concerned with the source of the outbreak, in our first report on the Dole recall, we asked about the source of the product used. Here is what Eric Schwartz, President of Dole Fresh Vegetables, explained:

Q: I understand this product was a blend. Could you delineate the raw ingredients, and where they were grown and processed?

A: There were three raw ingredients. The primary ingredient was Romaine. Most Romaine came from California. A little bit of the Romaine from Colorado. Butter Lettuce came from Ohio and the green leaf came from California.

Yet it turns out that the way the CFIA set up its test will not allow the agency to have any hope of identifying exactly which ingredient may have been carrying the E. coli 0157:H7.

Instead of separating the three types of leaves — butter, romaine, and green leaf — and testing them separately, CFIA simply took 40 bags and then broke them into 8 samples of 5 bags each.

There was no attempt to segregate by product, thus there is no possibility that CFIA will ever be able to tell which leaf from which growing area caused the problem.

Now testing individual components of a blend may not prove anything — but it may. The logical thing to do would be to pluck out romaine — test that, butter lettuce — test that, and green leaf — and test that.

Everything might show up with pathogens — after all, it is all blended together in one bag.

It is also possible that all the, say, butter lettuce will show up with pathogens, and the other items will not or will do so much less frequently. It might give us a lead on where the likely source of the contamination is.

CFIA, FDA, state agencies, private companies — everyone needs to be looking at separate testing protocols for blends that maintain component integrity through testing. Everyone should be thinking about what would help traceability of a pathogen if it was found.

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