Is there a statistical bias against Salinas in the food safety numbers?
The underlying question surrounding this E. coli outbreak on spinach is whether there is a specific problem in the Salinas Valley. Known as the “Salad Bowl of the World”, Salinas is both headquarters and source for much of the product that gets hit with these types of outbreaks.
On November 4, 2005, the Center for Food Safety and Applied Nutrition of the U.S. Food and Drug Administration sent a “Letter to California Firms that Grow, Pack, Process, or Ship Fresh and Fresh-cut Lettuce”, which basically “encouraged” the California industry to work on issues such as eliminating the environmental reservoirs for E. coli 0157:H7, to follow “Good Agricultural Practices” and “Good Manufacturing Practices” and to fully implement the FDA’s 2004 Produce Safety Action Plan — all to reduce the frequency and severity of food safety outbreaks.
Why send a specific letter to California lettuce growers? Why not just establish good procedures for all lettuce growers? The justification is in the letter:
FDA is aware of 18 outbreaks of foodborne illness since 1995 caused by Escherichia coli O157:H7 for which fresh or fresh-cut lettuce was implicated as the outbreak vehicle. In one additional case, fresh-cut spinach was implicated. These 19 outbreaks account for approximately 409 reported cases of illness and two deaths. Although tracebacks to growers were not completed in all 19 outbreak investigations, completed traceback investigations of eight of the outbreaks associated with lettuce and spinach, including the most recent lettuce outbreak in Minnesota, were traced back to Salinas, California.
But the letter is odd in that it doesn’t relate the number of cases to production quantity. In other words, it doesn’t establish that California, in general, or the Salinas Valley, in particular, has had disproportionate numbers of food safety outbreaks.
In addition, the nature of food safety outbreaks is that larger producers are always more likely to get caught. Why? Well first, only a tiny percentage of those affected by an outbreak ever go to doctors. As of 1:00 PM Monday, September 25, 2006, the FDA was reporting 175 cases of illness due to E. coli 0157:H7 infection — which implies thousands, maybe tens of thousands or more were sickened in this outbreak. But healthy people generally just get sick and then get better. They don’t go to doctors.
So, on this major outbreak, with worldwide publicity, we only have 175 people who we know were affected.
If another growing area grows, say 5% of the volume of spinach grown in Salinas and had an outbreak of the exact same severity, we would only expect 8 to 9 people to be known to be sick. If the spinach was distributed in, say, the New York Metro area — so three people were sick in New York State, two in New Jersey, two in Connecticut and, say, one in Pennsylvania and one in Vermont. — the odds are the connection would never be made. The numbers are too small.
And how many of the 175 reported in the current outbreak only went to their doctors because of the national news? Perhaps normally only half that number would have gone.
And, Salinas is not only disproportionately large in total production but the companies that ship are disproportionately large with the best known brand names in the business. Meaning they are far more likely to be identified in food safety outbreaks.
Remember, the way spinach was tied to this initially was through a survey. The governmental agencies asked people to fill out a form and check off what they ate. The government noticed a statistical discrepancy between the forms filled out by a “control group” and the people coming in with the current case of E. coli 0157:H7. If you don’t have enough people who are sick to fill out the survey, you can’t do the survey and get any useful information.
There is talk that the government of California is going to try to help rebuild the reputation of the Salinas Valley. This is probably needed and a good idea for the state to protect such a valuable resource. But Salinas may be getting a bum rap. The statistics the FDA has published do not persuade me that Salinas has any more food safety outbreaks than other places. And the focus on Salinas may be giving other areas a false sense of security. If so, the FDA’s pursuit of Salinas may improve food safety statistics more than food safety.
Sally Squires, who writes the “Lean Plate Club” column for WashingtonPost.com, writes a column for consumers in which she points out:
Today, the odds of getting sick from tainted food “are overall about a third less than they were in 1998,” says Richard Raymond, undersecretary for food safety at the U.S. Department of Agriculture (USDA).
Though she warns:
All that may come as little comfort to the 76 million people that the federal Centers for Disease Control and Prevention estimate suffer upset stomachs, gut-wrenching diarrhea, vomiting and other symptoms annually from various food-borne illness. Up to 5,000 deaths, including one so far from the recent E. coli outbreak in spinach, are also blamed on tainted food and drink each year.
On the positive side:
Improvements in the food supply — including establishment of “good growing” practices for lettuce established by the Food and Drug Administration (FDA) — seem to have helped reduce outbreaks. (Following the recent E. coli outbreak, those growing practices have just been expanded to include spinach.)
But there is a negative side too:
But as USDA’s Raymond notes, “The bad news is that we still don’t have the science to declare that raw meat or poultry products or even cooked products are pathogen-free. The FDA can’t guarantee that either for fruit and vegetables. We’re both doing a better job, but we’re both still struggling.”
So, in the US, 76 million people get foodborne illness and 5,000 die each year. The food supply is getting safer but still is not perfect.
Seems like this a perspective in which it is useful to view the spinach/E. coli outbreak.
The newly established Produce Marketing Association Education Foundation will have its inaugural meeting in October during the PMA convention and exhibition in San Diego.
Recently Cindy Seel, a popular executive when she worked at PMA from 1997 to 2002 and a minor celebrity as she was the pioneer in a PMA experiment that led to certain employees being allowed to operate from remote locations, was appointed as the executive director of the new foundation.
PMA Education Foundation leaders at Wegmans —
(left to right) Silbermann, Seel and Erickson
Now the new Board of Directors has been announced. Stephen Barnard, President of Mission Produce, Inc., has been named chairman. In another context, we’ve spoken previously about Steve here.
Additional officers will include: (insert links for each company and organization)
Vice Chairman William M. Schuler, president and chief executive officer, Castellini Company, Wilder, Kentucky, and Secretary/Treasurer Jay Pack, chief executive officer, The Pack Group, Dallas, Texas, and Immediate Past Chair, Janet Erickson, executive vice president, purchasing and quality assurance, Del Taco, Inc., Lake Forest, California.
Additional members of the Educational Foundation Board include:
John Anderson, chairman, president and chief executive officer, The Oppenheimer Group, Coquitlam, BC, Canada
Roberta Cook, cooperative extension specialist, University of California, Davis, California
Margaret D’Arrigo-Martin, executive vice president of sales and marketing, D’Arrigo Brothers of California, Salinas, California
Duane Eaton, senior vice president of association services, Produce Marketing Association, Newark, Delaware
Bud Floyd, vice president, C.H. Robinson Worldwide, Inc., Eden Prairie, Minnesota
Don Harris, vice president of produce and floral, Wild Oats Markets, Inc., Boulder, Colorado
Gene Harris, senior purchasing manager, Denny’s Corporation, Spartanburg, South Carolina
Peter Goulet, president, Pinnacle Sales & Marketing, Inc., Saco, Maine
Robert Gray, chief executive officer, Duda Farm Fresh Foods, Inc., Salinas, California
Edward W. McLaughlin, educator, Cornell University, Ithaca, New York
Lisa McNeece, vice president, foodservice and industrial sales, Grimmway Farms, Bakersfield, California
Bryan Silbermann, president, Produce Marketing Association, Newark, Delaware
Bruce Taylor, chief executive officer, Taylor Farms California, Inc., Salinas, California
Particularly important is the presence of Roberta Cook of U.C. Davis and Ed McLoughlin of Cornell on the new board. These are the types of people very difficult to get to serve on an association board of directors but whom are more open to serving on the board of a non-profit. Both of these academics have had extensive connection with the produce trade but, over time, we can expect the board to attract leaders who have expertise in other areas such as education.
A lot of dissertation writing services prefer to put profit over the quality.
Although industry members could give money to PMA and deduct it as a business expense, those not in the produce industry would have difficulty doing so. So the Foundation opens the door for many new donors, including various governmental agencies and private and corporate foundations that can only give money to a 501 c3 non-profit organization.
The Pundit wishes the new staff, the new board and new foundation a hearty send-off in San Diego. There is important work to be done, and the Foundation is just the way to get it going.
First we welcomed the new United Fresh Produce Association here. Then we discussed the challenges related to conducting government relations for an association that is both vertically integrated and horizontally diverse here.
We have dealt with immigration reform before, both here and here, but the situation is now coming to a head. We would be remiss if we didn’t discuss today’s legislative situation with regard to immigration, which was the real focus of United’s Washington Public Policy Conference.
The Pundit’s reading of the political tea leaves, though, is that United and others in its coalition are very possibly going to lose and that there will be either no law or none with a guest worker program included.
Most of this is unavoidable. Here is Prevor’s Law on the matter: To the extent an issue becomes a matter of general public interest and concern, the ability of special interests to influence the legislative outcome on that issue is constrained.
Put another way, as long as something is “inside baseball” — meaning the produce industry cares about it but nobody else does — the industry can usually carry the day. Even if it is produce versus some other trade group, it is a situation where we can have a lot of influence.
But immigration reform is on the front page of every newspaper. It strikes at the very essence of our nationhood, the kind of country we wish to have, our national security.
In this kind of context, regardless of the strength of our arguments or the quality of our lobbying effort, it is very hard to have a big impact on the outcome of the final vote. If the majority of the population feels that what is at stake is the security of the nation or the type of country we are going to be, the impact on the produce industry unfortunately isn’t likely to play a big factor in the debate.
This particular issue is especially difficult because normal compromises won’t likely be reached because the government has no credibility on this matter. Typically you would have people on one side in favor of very limited immigration, and on the other side you would have those who say economic growth requires workers.
The perfect compromise would normally be a guest worker program. One side achieves its goals of keeping the citizenry as is; the other achieves its goal of getting workers. But it doesn’t work in this situation. Why?
Pick any affluent community in America and you can find thousands of housekeepers, nannies, etc., who are all illegal. Not one of them arrived in the country illegally. All came on a legal visa and didn’t leave when they were supposed to.
The US government does nothing about this flaunting of the law. As much as anything else, it is this fact that makes many unwilling to vote for a guest-worker program, since they have no reason to believe that these guest workers won’t overstay their visas and no reason to think that the government will do anything about it when they do.
If we really want to pass a guest-worker program, I think we need to add two elements to the current proposals:
- We have to break this credibility gap. The only way to do this would be to assess a fee per guest worker to be used to set up a special force within the Department of Homeland Security, whose only two purposes are A) To maintain a registry of exactly where all these guest workers are living at any time, and B) To act immediately if someone fails to exit the country on schedule. If a guest worker is scheduled to leave on September 18th and doesn’t show up at a border checkpoint; then at 12:01 AM on the 19th, there needs to be an APB out looking for that person.
- We have to make any guest-worker program temporary. There are many problems with guest-worker programs, and we’ve pointed them out here. It is not clear that everyone understands how extraordinary the produce industry request really is. After all, merely increasing the amount of legal immigration, for example, would not satisfy the produce industry. Why? Because legal immigrants could work in any chosen field and would, likely, find other opportunities than harvesting produce. What we are asking for is a class of immigrant whose opportunities are constricted so they won’t go open a produce retail operation or work in a produce wholesaling operation, much less be a lawyer, doctor or engineer. Instead, the only thing that these people are to be allowed to do is harvest produce.
A guest-worker program such as this is so alien to the American way and so offensive to the way many people think about America and the opportunities it offers that it seems unlikely to last indefinitely. The industry should take the bull by the horns and propose a guest-worker program as a temporary measure while we invest in mechanized harvesting. Whatever number we want to start with, we should agree now to a 2.5% phase out in the number of guest workers each year. In other words, the industry should make a promise to America that we will reorganize our domestic agriculture over the next 40 years so that we will no longer require guest workers.
These two proposals might break the logjam caused by the lack of governmental credibility on immigration issues. Maybe, maybe, this could pass.
Of course, there are reasons why these things haven’t been proposed. Growers don’t particularly want to pay a tax to fund a police function, and they are uncertain if they can ever operate without illegal immigrants or guest workers.
But the problem is right now. We are getting many reports that the Border Control’s current “catch and release” program is significantly reducing the current availability of farm labor, so crops are not being harvested as a result but left in the fields.
From an industry perspective, fighting for a guest-worker program without these two provisions may be a case of allowing the best to stand in the way of the good.
With so much having been written in so short a time, thought it would be helpful to publish a sort of round-up of available material to help people understand the whole situation regarding spinach and this E. coli breakout:
The Perishable Pundit itself has dealt extensively with the subject in several major pieces. On September 15, 2006, we published Spinach Recall Reveals Serious Industry Problems, which addressed the implications of this crisis for the fresh-cut industry. You can read the piece here.
On September 18, 2006, we published Organic Dodges a Bullet, which deals with the implications of the outbreak for the future of organic farming. You can find this piece here. Also on September 18, 2006, we ran a piece called Ramifications and Reflections on the Spinach Recall, which provided our first 10-point analysis of the situation. You can read it here.
September 19, 2006, we asked Is FDA’s Concern Now an Obsession? — a piece in which we assessed whether a national recommendation to not eat spinach made any sense. You can review this here.
On September 20, 2006, we noted 10 Peculiarities about the E. coli Outbreak and reviewed why certain aspects of the situation are unlike past food-safety challenges and other unanswered questions regarding the outbreak. Read this one right here. Also on September 20, 2006, we did our third 10-point list, calling this one “Spinach Recall Begs for Solutions”, where we reviewed how the trade can deal with this issue for the future, including looking at the meat industry, the prospect of universal testing and the use of RFID and GTIN. You can read all this here.
On September 21, 2006, we asked Is FDA Causing Long-term Damage? Here we posed the question of whether punishing the innocent and the guilty alike doesn’t reduce incentives to invest in food safety. You can read this piece right here.
The September 25, 2006 edition of the Pundit includes our fourth 10-point list entitled Though Not ‘All-Clear’, Consumers Can Eat Spinach Again, which reviewed many issues facing the industry as spinach begins to reenter the market, including the FDA’s announcement, PMA consumer research, the behavior of industry association, battles over fresh-cuts and organics, the reintroduction of Salinas Valley production, the FDA’s capabilities, and more. You can read this piece here. Also on September 25, 2006, we reviewed The Role of Retailers And The Future Of Food Safety, which pointed out that buyers have an important role in insuring food safety. Catch this piece here.
Additionally, on September 25, 2006, we ran the Pundit’s Pulse Of The Industryin which a panel of retail pundits gave us insight into the way the spinach issue played in store and with consumers. You can read it here.
The Pundit on September 26, 2006, included an articled entitled The California Department of Health Services Owes People An Explanation in which the question was raised whether certain parties received preferential treatment in the current spinach/E. coli outbreak. Read it right here. Also on September 26, 2006, we did a piece questioning the efficacy of our trace-back systems. The piece was titled More Recalls Trickle In, and you can read it here.
In addition, the Pundit did several smaller pieces that touched on various aspects of this crisis. On September 18, 2006, we raised the issue of whether food safety outbreaks such as this raise long-term issues about the viability of cartoon character tie-ins in Who Has Marketing Fortitude? You can read about it here. Also on September 18, 2006, we dealt with the way some companies have little sense of decency when it comes to marketing their products in the midst of a crisis. You can read this one right here.
Additionally on September 18, 2006, our Pundit’s Mailbag focused on letters received by United President/CEO Tom Stenzel and incoming Chairman Emanuel Lazopoulos of Del Monte Fresh, which dealt with the confluence of United’s Board Meeting and the spinach crisis as well as issues of industry leadership. You can find this one here.
On September 19, 2006, we noted that there might be a Greenhouse Opportunity in all this. Read this here. Also on September 19, 2006, we noted that, though fruits and vegetables are healthy, fresh produce is not necessarily the best choice for those with a compromised immune system. The piece is called Marketing Nightmare and you can find it right here.
On September 21, 2006, we did a piece called Wal-Mart Deli/Bakery Has Crisis Of Its Own that draws a link between the difficulty of preventing a Salmonella outbreak at one store with the difficulty of preventing an E. coli outbreak on an industry-wide basis. You can read this piece here.
On September 25, 2006, the Pundit noted Another Oddity In Spinach Crisis and raised the question whether some or all of the product being marketed as conventional might not be organic. Read it right here. Also on September 25, 2006, we ran a Pundit’s Mailbag which dealt both with the utility of loyalty card programs and with the nature of large, multi-line fresh-cut packing facilities. You can read this one right here. Also we did a short piece on what change was actually necessary if consumers were to be reassured of the safety of spinach. Read it here.
On September 26, 2006, we discussed the issue of recalls and how insurance plays into that. You can read this here. Also had an unrelated piece on Wegmans that included a video clip on how consumer media is dealing with the reintroduction of spinach. You can catch it here.
Additionally on September 26, 2006, we ran a Pundit’s Mailbag exploring the causes of the outbreak. You can read this piece here.
Several additional pieces appear in the Perishable Pundit on September 27, 2006, and they will be incorporated into future iterations of this Spinach Crisis Summary.
In addition to our own work, there are many excellent sources of information out there that do not require payment, membership or registration. Three of the Pundit’s favorites:
The U.S. Food and Drug Administration has offered daily information on the crisis right here.
The Centers for Disease Control and Prevention deal with the outbreak here.
The Produce Marketing Association has maintained an excellent industry resource on the subject right here.
Please feel free to write or call if you are looking for specific information not included here. Note that many of the articles and websites have links to other resources.