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Pundit’s Mailbag —
Kill Steps And Irradiation

Jim Prevor’s Perishable Pundit, November 16, 2006

It is said that generals are always fighting the last war. So, with all the attention being paid to the fields, it is wise to remember that the next foodborne illness outbreak may take place somewhere else, such as the processing plant. An executive at a major processor sent these thoughts:

I returned from Western Growers where they had a spinach meeting and discussed the marketing order and the research dollars. Most of the discussion was around GAPS, which are important, but Tommy Russell at [Pacific International Marketing] rightly pointed out that without a kill step in our processing plants, a fence around a reservoir (that pigs can break through, birds can fly over) will do us no good and I agree.

Pollan writes about the centralization of the food supply in The Omnivore’s Dilemma: A Natural History of Four Meals and he has a point. If FDA is frustrated with our industry’s inability to do faster trace backs, then how will we be able to bring in carrots grown on a ranch in Holtville, broccoli from Soledad and cauliflower from Salinas and bring them all into a central facility, run them on the same belts and then divvy them back out? You cannot deny the fact that we are multiplying the risk of an outbreak when we bring product in from different ranches to a central facility. Perhaps one ranch had a problem, now they all do.

I think the FDA could say you need to run this in batches and stop and clean your belts in between, which would greatly increase cost and reduce efficiencies. Or they could say no more blends (the higher margin items we all love to pack).

Unless we have a kill step and we aren’t going to get one without research.

Tommy pointed out all of our luggage was x-rayed on the way to Vegas and we all still used the toothpaste that was in our bag. Is the industry and the consumer willing to pay more or be more open to new technologies to ensure safer product? Is the organic industry going to accept a system or product that may go against their current standards?

A lot more questions than answers right now, but even more stringent GAPS will not eliminate the processing challenges. If we have to reconfigure plants for more through-put or change the way we run things, it could get even more expensive

A lot of good questions here. The importance of finding an acceptable kill step can’t be overstated, but the fence around the reservoir, although certainly imperfect, can still be an enhancement to current practices.

And, even if we find an acceptable kill step, food safety protocols still require us to take steps to have “clean” product when it gets to the kill step.

Hamburger meat, for example, has a whole E. coli testing protocol, despite the fact that it has a kill step when the food is cooked.

Also, philosophically, we, as an industry, clearly want to provide as “clean” a product as possible — regardless of whether we have a kill step later in the process.

Blends are a major problem. If you have a spinach field that is 100% contaminated and you do a blend with a 5% spinach mix, you have just increased the number of contaminated bags twenty-fold.

But it is not centralization — Pollan is incorrect. The blending would have exactly the same effect if done in 50 local markets.

The difference: 50 small outbreaks pass unnoticed by CDC. Remember in this giant spinach situation, only 200 were known to be sick. Breaking 200 people into 50 small outbreaks, you’ll get 4 people sick per outbreak — it will never be counted.

A kill step done in the production/packing of the product, not by consumers, is, however, the only 100% effective way to avoid foodborne illness outbreaks.

The million dollars that PMA has appropriated for research related to food safety might be applied to trying to identify a new kill step. But, maybe, we should do some tests on consumer acceptance of irradiation — which is the only known process that will solve the problem.

In the midst of the spinach crisis, we received a brief note from Michael J. Adams of Sadex Corporation.

Has anyone explored irradiation as a part of their food safety program? If not, why not?

The Pundit answered and asked a few questions:

My understanding is that besides consumer acceptance issues, irradiation was problematic because of the need for fixed facilities. So, if a Salinas-based processor, for example, wanted to irradiate, it would currently have to truck everything to Sioux City, Iowa. Is this correct?

Have you ever done any salad bags?

And Mike Adams came back:

While the product does have to come to our facility, we normally have a truck back on the road in 2-3 hours from when we open the doors. Most of our customers treat their product enroute so if spinach is going from California to say Wisconsin, it is just a 2-3 hour delay in trucking. We have treated some spinach bags and achieved a 5 log reduction. This is definitely enough to ensure no one gets sick from eating this product straight out of the bag.

We are continuing to experiment with different samples using Midwest Labs to verify our results. I will say this: We have treated some spinach product at a very low dose (.75 — 1 kgy), and it has been sitting in our warehouse for 2 weeks and looks like the day we received it. So it appears we are also extending shelf life.

Currently our biggest stumbling block is the FDA. Are they going to allow us to treat bagged produce at these low levels? They have a 1 kgy maximum dose for infestation. Although E. coli is technically a bug, we need their blessing and as yet have not received it. In the wake of this last spinach catastrophe, I don’t understand why.

Tom Stenzel of the United Fresh Produce Association and the Pundit had a spirited exchange that partially centered on how “scientific” the FDA’s decisions are as opposed to the extent that the activities of the agency are colored by politics.

Here is another political issue: The FDA has been sitting on the petition to allow irradiation on bagged produce for over half a decade.

There is no scientific dispute on this issue. It is just the FDA feeling that an approval will get the luddites protesting and a disapproval can’t be supported scientifically, so they just do nothing. It really is shameful.

We spoke with the owner of the company. He was interested in building a plant in Salinas if the demand was there. The cost to treat spinach and bagged lettuce is about 1.5 cents per pound.

Now our original correspondent just back from the WGA asked:

Is the industry and the consumer willing to pay more or be more open to new technologies to ensure safer product? Is the organic industry going to accept a system or product that may go against their current standards?

Fair questions, however:

  1. It is not clear that irradiation will cost more — all these stringent GAP and GMA protocols will cost a lot. If we can get a little flexibility on these because we have a “kill step,” the total cost may go down.
  2. It is not clear that consumers have not always been open to new technologies. The few consumer tests retailers had on fresh produce in Chicago and Miami went fine. Most spices are irradiated and a fair amount of hamburger is irradiated. All without any great consumer outcry.

    Is it possible that supermarkets are scared of protestors more than consumers are scared of irradiation?
  3. Odwalla was all opposed to pasteurized juice, right up to the day someone died and then they started pasteurizing. Organic will probably object… unless circumstances compel a change.

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