Pundit Interviews

Pundit Letters





Perishable Pundit
P.O. Box 810425
Boca Raton FL 33481

Ph: 561-994-1118
Fax: 561-994-1610


email:
info@PerishablePundit.com

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Produce Business

Deli Business

American Food & Ag Exporter

Cheese Connoisseur



SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

FDA Pattern of Shame:
In Order To Seem Relevant,
It Acts After The Outbreaks Are Over

Hopefully all of us in the industry would put food safety over profit and so if warning people not to eat something would save a life or avoid a serious illness, few would object to the FDA issuing such a warning.

However, as has become its practice, it appears the FDA was a day late and a dollar short — as such, its warnings have reduced consumer confidence in the food supply, destroyed businesses, led to the needless destruction of food — without helping to avoid illness in any way.

The current CDC update is very clear. Nobody has reported an onset of illness later than May 27, 2008. This date has remained constant even as the number of people interviewed has risen to 73.

Just to be clear, the FDA actually issued its recommendation extending its warning not to consume certain tomatoes nationwide on June 7, 2008. Salmonella has an incubation period of 12 to 72 hours after infection. This means that by the time the FDA imposed its warning, the outbreak was finished.

As we carefully discussed, this is the exact pattern that the FDA followed in its imposition of an “import alert” regarding cantaloupes produced in Honduras by Agropecuaria Montelibano. In that outbreak, the last person to become ill did so on March 5, 2008. The FDA imposed an Import Alert on March 22, 2008. As a result, the unemployment, the destruction of food, the crushing of businesses… all this was done for absolutely no purpose.

We see the same pattern here. The CDC/FDA/State Health Department/Local Health Department combo is too slow in its epidemiology. This was pointed out in an important letter we published under the title, Tomato/Salmonella Situation Cries For Improved Epidemiology, by James R. Gorny, Ph.D., Executive Director of the Postharvest Technology Research & Information Center, University of California, Davis.

As Dr. Gorny asked:

Why did it take upwards of 6 weeks for public health officials to identify this cluster of illnesses… and then only due to the diligence of state public health officials in New Mexico?

Obviously one issue is how to improve the public health system so that it can intervene while it can still do some good.

Another issue is how the produce industry can improve so that such intervention will not be necessary.

Yet another, and perhaps the most proximate issue, is how to change the standard operating procedure at FDA so that food is not needlessly destroyed and business not needlessly disrupted.

Shortening a bit, the FDA press release should have been written in this manner:

There has been a salmonella outbreak which our epidemiology has traced back to certain types of tomatoes. The last person to get sick as a result of the outbreak got sick on May 27, 2008. As such, the outbreak is over; any tomatoes currently in the market would not be affected by this outbreak. We regret that the epidemiology did not proceed quickly enough for us to identify this outbreak while we could have acted to prevent people from getting ill.

As a precaution, we are issuing a Consumer Advisory urging consumers to destroy any tomatoes or uncooked products — such as a fresh salsa — made with round red, red Roma or red plum tomatoes that had been purchased or may have been purchased on May 27, 2008 or earlier.

We will, of course, continue our full trace back procedure in an attempt to identify what the cause of this outbreak was with the goal of preventing such outbreaks in the future.

The FDA did not issue such a release — and never does — because it wants to appear to be acting to enhance public health. An honest release such as the one above might have FDA officials testifying before congressional committees as to why FDA couldn’t act sooner.

This is understandable, as this instinct might be as a survival mechanism of FDA officials, but it simply causes too much waste and destruction to allow this mode of operation to continue.

Right now the problem is simple. The incentive is 100% on FDA officials to restrict commerce or advise against consumption. If they did not do this and one person got seriously ill or died, these FDA officials will be hung out to dry.

On the other hand, if they crush an industry, deprive the world of a needed food, cause unemployment… that is not something they will be held accountable for.

This is the same problem we have on the drug side where people with terminal illnesses plead for FDA approval of drugs. Once again, the FDA officials have little personal upside in speedy action.

In perishables, FDA should adopt — - and if it does not, Congress should require it to adopt — a policy that when it wishes to restrict commerce — as with an Import Alert — or restrict consumer behavior — as with a Consumer Warning — FDA shall be obliged to issue a Public Finding that the outbreak is ongoing. Such a finding will have to be signed by each member of a relevant committee set up for this purpose.

This way the judgments of those individuals can be subjected to scrutiny. If it turns out that they are consistently incorrect, they can be terminated.

As it is now, perfectly healthy produce that could feed people gets destroyed because FDA officials have an incentive to appear relevant to safeguarding public health — even when they are not.




SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

CDC’s Lack of Transparency

Despite the fact that, according to the Centers for Disease Control and Prevention’s latest update, the last person to become sick as a result of the salmonella/tomatoes situation became sick on May 27, 2008, scarcely anyone has objected to the FDA warning that consumers nationwide should not eat raw red Roma, raw red plum, raw red round tomatoes, or products that contain these types of raw red tomatoes unless the tomatoes are from sources it has identified in a list.

Why? The CDC has hoarded the information necessary to make a fair evaluation of the FDA policy possible.

Although CDC is saying that 73 people have been interviewed and that the date at which illnesses onset range from April 16 to May 27, 2008, it is refusing to release the data points for each person.

The key question is this: Do the date of onsets form a bell curve? Is there any reason to think that May 27, 2008 is not on the tail end, if not the actual end of the outbreak?

CDC should not allow itself to be used to facilitate FDA’s cover-up of its irrelevancy to the protection of public health in this matter. CDC should adopt as a policy the release of all non-privacy-related information at the earliest possible date.

The point, very specifically, is that FDA is not the only organization capable of interpreting the data CDC has collected. We will get better results if the data is publically available and thus subject to public scrutiny.

If CDC continues to play “control” games, hoarding the data so that neither CDC nor decisions FDA makes based on CDC data can be critiqued, then Congress has to legislate a more comprehensive transparency on the part of CDC.




SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

FDA’s Lack Of Logic
And Awkward Use Of Language
Lead To Consumer Confusion

When the FDA initially announced that people in New Mexico and Texas should not eat certain types of tomatoes, we pointed out that this simply made no sense:

Now the only reason to stop anyone from eating anything would be if the FDA believed there was a continuing risk to public health. But if there was a continuing risk to public health from the producer or region that has been supplying New Mexico and Texas, how does warning consumers in those two states not to eat something increase public safety?

The “dangerous” production is not banned from sale; it just will be diverted from sale in New Mexico or Texas to New York or Michigan. The net effect on public health? Zero.

Even before FDA made a further announcement, we were getting inquiries from around the country as, quite evidently, if a policy was necessary to protect public health, this irrational policy wasn’t going to fit the bill.

Unfortunately, when the FDA went national with its warning, saying that consumers across the country shouldn’t eat certain types of tomatoes, it made this awkward negative use of language:

FDA recommends that consumers not eat raw red Roma, raw red plum, raw red round tomatoes, or products that contain these types of raw red tomatoes unless the tomatoes are from the sources listed below. If unsure of where tomatoes are grown or harvested, consumers are encouraged to contact the store where the tomato purchase was made. Consumers should continue to eat cherry tomatoes, grape tomatoes, and tomatoes sold with the vine still attached, or tomatoes grown at home.

This referred to another page, that in its updated version, goes like this:

FDA traceback review, in addition to production and distribution pattern information, has indicated that tomatoes from the following sources are not associated with the outbreak:

Arkansas
California
Georgia
Hawaii
North Carolina
South Carolina
Tennessee
Texas
Belgium
Canada
Dominican Republic
Guatemala
Israel
Netherlands
Puerto Rico

FDA recommends that retailers, restaurateurs, and food service operators offer only fresh and fresh cut red Roma, red plum, and round red tomatoes and food products made from these tomatoes for sale or service from the sources listed above.

FDA further recommends that retailers, restaurateurs, and food service operators continue to offer cherry tomatoes, grape tomatoes, and tomatoes sold with the vine still attached, from any source.

Let us all understand, the FDA knows nothing about the tomatoes from these states and countries except for that they have learned that such regions either were not producing at the time in question or, if they were, they were not being imported to the region or the US at the time.

But the list — which has been updated with additions such as Hawaii and Arkansas from the original — seems to depend on those industry geographies that have a lobbyist to bring their cause to the attention of the FDA.

We are sure there were no New Jersey tomatoes or French tomatoes in the market either. Why aren’t they on the list?

Based on the time of year and the geography, this long list basically says that FDA has ruled out every place but Florida and Mexico.

How much less confusion there would be if in speaking about round red tomatoes, red Roma and red plum tomatoes, FDA simply said that everything in the whole world is cleared except we are still investigating both Mexico and Florida as the source of this particular outbreak.




SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

FDA Undercuts Buyer-Aligned
Risk-Based Systems

It is becoming increasingly clear that the FDA is indifferent to the real life food safety impacts of its decisions. In our discussion of the foolishness of FDA’s actions in restricting the sale of cantaloupes from Agropecuaria Montelibano, we pointed out that this company is well respected, third-party-audited, does business in the UK and thus meets the requirements of many British retailers. For example, it has a Certificate of Conformity with Tesco’s Nature’s Choice Standard — universally recognized for rigor as a food safety standard.

Yet in imposing an Import Alert, the FDA has banned imports into the US from this company. The irony here, of course, is that the company right next door — unaudited, not able to sell anyone in the UK, not recognized for excellent food safety practices — can keep shipping all it wants. In other words, the ban leads Americans to consume less safe food — not safer food.

Now the FDA’s way of operating is creating a similar dynamic on tomatoes.

In the midst of the spinach crisis, we published a great deal of copy on the Buyer-led Food Safety Initiative. Yet if the FDA is going to interfere with procurement choices, how can buyers build and be responsible for a supply chain aligned along the values of food safety?

In fact, it was Mark Munger of Andrew & Williamson Fresh Produce who — in a piece entitled, Pundit’s Mailbag — Insights From A Conscientious Grower, which focused on what Andrew & Williamson had accomplished by working with Darden Restaurants — told us this:

Darden takes food safety very seriously. They have empowered a food safety team that must approve each and every supplier. They have inspectors in the field who make weekly random inspections of growing operations, picking and packing programs. When problem issues are identified, they work closely with our food safety team to help educate our team and to ensure that collectively we fix the problem. The knowledge that an inspector can be in any field or packing shed at anytime has forced us to treat every day as an inspection day.

Additionally, Darden’s food safety team is separate from their buying team. If a farm is not up to par, they have the authority to stop all transactions until the problems are fixed. They truly put their money where their mouth is and have helped us become a markedly better company. I cannot think of a better example of the power of collective thinking between suppliers and customers. I think the industry would be well served to learn more about their programs and create similar models.

In other words, top buyers work closely with producers to ensure food safety. Yet the FDA, in defacto banning product from Florida or Mexico, will lead high quality buyers with vigorous food safety programs to abandon the vendors certified under such programs and improvise by buying product from vendors they have had no contact with until yesterday.

In other words, let us assume that the epidemiology showed that there had been some salmonella somewhere in Mexico — hardly earth-shattering news. Is the FDA actually prepared to say that the mere fact that somewhere in the country of Mexico there was some salmonella means that McDonald’s, Darden and Jack in the Box should just abandon their carefully vetted vendors and go buy tomatoes off a terminal market or at an Amish auction — and that this will enhance food safety?

We need a risk-based food safety system. Not one run off hysteria.




SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

Chains Could Give A Little
Support And Frankness

Many on the buying end of the produce industry are being a little less frank than they could be and thus making the situation regarding salmonella and tomatoes worse than it need be.

Many of the chains, especially in foodservice, that have withdrawn tomatoes from their menus have issued statements or made comments, typically something such as this quote from McDonald’s:

“The safety and well-being of our customers is a top priority,” McDonald’s said in the statement. “We apologize for any inconvenience this may cause, but food safety and quality at McDonald’s will not be compromised.”

Maybe it is asking too much to hope that operators might give a little support in their hour of need; say something like McDonald’s praising and defending its vendors — noting that they all share McDonald’s deep cultural commitment to food safety.

But at very least, we could have a little frankness. The real reason most of these chains are pulling tomatoes is that, despite the long list of states and countries the FDA is saying are not implicated in this outbreak, very few are producing many tomatoes right now. Many of the rest are distant and euro-based, and air-freighting their product is likely to be too expensive anyway.

No chain is going to run the legal liability of selling tomatoes the FDA recommends not selling, so that leaves everyone scrambling for very limited supply of the restricted varieties. Most big chains are pulling tomatoes because they can’t get their volume requirements at all or at a reasonable price.

Not sure why that is such a terrible thing to say.




SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

Retail And Foodservice
Buyers Share Their Experiences

The press releases may fly, but how are retailers and foodservice operators actually experiencing this tomato/salmonella outbreak? We asked Pundit Investigator and Special Projects Editor Mira Slott to speak with an industry leader in each segment to find out more:

Mike O’Brien
Schnuck Markets
St. Louis, Missouri

Q: We’re looking to get a pulse on the market of how the tomato outbreak has been affecting retail business and your customers.

A: Since we’re in Missouri, we weren’t one of the states affected until Saturday [June 7] evening, when all the e-mail alerts starting coming in from PMA, United, FDA and others. I called my tomato buyer and we met Sunday morning, evaluated where we were and pulled any tomatoes not approved at that point by FDA. We followed the FDA list.

At that time, we just had four SKUs of Florida tomatoes. We carry so many varieties. We don’t have any Roma tomatoes for sale at this point. They’re in the back room, and we’re no longer putting them on the shelves. Along with the Roma’s that we pulled, we had some Florida organic tomatoes, and wonderful ugly ripe tomatoes from Florida and we had to pull those too.

Q: Did you communicate with consumers through in-store signage or by other means?

A: We put a small sign up. It mentioned to consumers, ‘Due to health concerns we had to remove certain tomatoes, but be assured all tomatoes on the shelves are safe to eat.’ I’m always concerned about putting a sign up drawing more attention to a problem that’s already been blown out of proportion. But then we want to inform consumers. It’s a slippery slope.

As usual, this outbreak has turned into a whole debacle, and the media has gotten half its information wrong. I feel so bad for the affected growers

Q: What were you thinking when that first FDA alert had come out?

A: That first warning only focused on Texas and New Mexico, but they had illnesses in other states, including Illinois and Indiana. I just had a bad feeling about it at that time. Now with produce-related outbreaks, when you get the first alert, things tend to grow.

FDA has the responsibility for protecting consumers, and when they can’t pin down the problem, a lot of growers get hurt. Even if the problem ends up being narrowed to a particular region, it’s still not the entire growing community; it’s just one person. It’s all about prevention.

Q: The reports from CDC indicate that the most recent onset of illness was May 27. With the time that has elapsed, does it protect your customers any more by stopping the sale of tomatoes starting Sunday June 8 moving forward?

A: When FDA and CDC do the trace back investigation and interview people who got ill, they look at commonalities… what kinds of tomatoes, where they bought them, and it can be a long, drawn-out process.

The same thing happened during the spinach crisis. By the time retailers stop selling tomatoes, the tomatoes related to the outbreak already washed through the system. At the same time, whoever made an error, nobody knows if it has been fixed. It’s a bad situation.

A lot of innocent people are getting hurt, consumers and companies all the way down the supply chain. Retailers will be affected. We’ll lose sales, but if I’m a grower of tomatoes, this can be devastating and put me out of business. If anything, because of supply issues, costs will go up for non-affected regions.

Q: What feedback have you received from your customers?

A: Up until this FDA alert warning all consumers across the nation not to eat tomatoes, we hadn’t had many comments at all; not a lot of customers asking questions about it. Concerns have increased. One elderly customer called today, worried that the tomatoes she gave her relatives last week were OK, and I assured her they were.

Mike is one of the really great guys in the industry who genuinely care about suppliers, and he has an ownership team prepared to back him up. Unfortunately, in a situation such as this, there is little he can do.

Like so many in the industry, Mike’s experience leads him to think this way:

As usual, this outbreak has turned into a whole debacle, and the media has gotten half its information wrong. I feel so bad for the affected growers…

And to recognize that the whole exercise is typically pointless:

The same thing happened during the spinach crisis. By the time retailers stop selling tomatoes, the tomatoes related to the outbreak already washed through the system. At the same time, whoever made an error, nobody knows if it has been fixed.

But Mike has a decent person’s understanding of his role in the whole situation:

A lot of innocent people are getting hurt, consumers and companies all the way down the supply chain. Retailers will be affected. We’ll lose sales, but if I’m a grower of tomatoes, this can be devastating and put me out of business.

With that kind of perspective, at least vendors know they can count on some support when the crisis passes.

Maurice Totty
Director of Procurement
Foodbuy
Charlotte, North Carolina
purchasing arm for the UK-based
Compass Group.

Q: What actions have you taken regarding the tomato/salmonella outbreak?

A: The direction we’re taking is in conjunction with our quality assurance team. We have put the use of tomatoes on hold with the exception of the states approved by FDA. The only issue is that most of those regions are not producing tomatoes or a very limited supply. It will be at least a few weeks until there are enough tomatoes to fill the gaps; mid-June to late-June before the supplies start to be produced to meet our needs.

Q: How does the food safety vetting process work in terms of your ability to bring in new suppliers to make up shortages? How complicated is it for a large chain to go outside its set supply system in cases like this?

A: The level of food safety protection that a McDonald’s or Compass utilizes in sourcing product creates little flexibility in this case. The approval process to bring on a new supplier is quite lengthy and detailed. This is more a supply/demand situation. If we haven’t been dealing with a producer, and that supplier has other customers, when supply is tight, they won’t have any additional volume to sell to anyone else, including us.

Compass is the largest food service management company in the world. We service a range of organizations from healthcare to schools, higher education, business institutions, corrections and the list goes on.

Q: What feedback have you received from your broad range of customers?

A: Internal communication is working with Quality Assurance; getting communication out to chefs not to use any raw red Roma, red plum or round red tomatoes from unapproved sources, and interacting closely with distributors insuring none are being shipped to our accounts until further updates from FDA.

Everyone is waiting right now for FDA to issue another update on what the situation is. Florida tomatoes at this point haven’t been approved for use in the marketplace. These growers are major suppliers. A lot of people are waiting for the OK on that from FDA. That would have an impact on the market. California production hasn’t really started to any degree.

Q: Different retailers and foodservice operators are taking varied actions, some choosing to pull all raw red Romas, plum and red round tomatoes nationwide, some pulling selectively, some not at all. How does one determine the right approach?

A: FDA’s warnings have created some confusion. FDA first advised that just consumers in Texas and New Mexico not eat certain tomatoes, but it was OK for everyone else. This didn’t seem to make sense. Many people had the same questions; if you couldn’t eat certain tomatoes in Texas, but went over the state line to Oklahoma and ate those same tomatoes, couldn’t they make you sick?

I can’t speak for the FDA, but it seems they were going on where the largest number of food borne illnesses had broken out. From a supply-chain point of view, it makes it very challenging and difficult to understand the logistics — It is not OK in Texas and New Mexico, but perfectly fine in neighboring states?

Without knowing the source of where product came from, it’s very difficult to pinpoint — tomatoes from this supplier are affected, so don’t use them. It can take weeks to identify the source of the problem, and oftentimes, it is never definitively determined, or by the time it is, it’s too late.

Q: Couldn’t the damage be significantly lessened if the industry’s traceback systems were stronger?

A: Traceability continues to be the missing link. The amount of time it takes to identify the source is just too long. Simply, most of the product is destroyed or out of the supply chain by then. This situation has a rippling effect. Growers have product in the field they can’t sell, re-packers have hundreds of thousands of tomatoes just sitting there, distributors have pallets they can’t ship to accounts. Warehouses are holding restricted product.

Retailers and foodservice operators can’t use cases in the back room — it’s an ongoing, perpetuating problem. The industry has all these tomatoes in the system and FDA has put out a directive not to consume the products.

The big difference between retail and foodservice right now is flexibility.

On the merchandising side, retailers can sell more SKUs or larger displays of cherry tomatoes, grape tomatoes or tomatoes on the vine.

Restaurants that use slicers for sandwiches have few options.

On the procurement side, those foodservice operators with aligned supply chains have to decide whether to go outside those loops or simply not carry the product.

Maurice is a sharp guy, and he caught on the absurdity of the FDA’s initial approach quickly:

Many people had the same questions; if you couldn’t eat certain tomatoes in Texas, but went over the state line to Oklahoma and ate those same tomatoes, couldn’t they make you sick?

Traceability remains crucial, but this particular outbreak reminds us that, as Dr. James Gorny explained, you can’t start doing trace back until FDA has done the epidemiology that tells us where the product was purchased. In this case, that took six weeks — just for New Mexico.

Just looking at the geography. It is hard to imagine this outbreak could be sourced anywhere but Mexico, but FDA has not yet been willing to take Florida off the hook.

Many thanks to both Mike O’Brien of Schnuck Markets, Maurice Totty of Foodbuy and the Compass Group for sharing their experience during this tumultuous time with the whole industry. They truly perform a generous and much needed service during challenging times.




SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

Pundit’s Mailbag — Producers Do Not Operate In A Vacuum

Our initial piece, Salmonella And Tomatoes Linked In New Mexico, and our SPECIAL REPORT: Tomato/Salmonella Outbreak…Insights and Analysis brought many letters, including this poignant one from a man who sees that the future of the produce industry is likely to be different from the past:

As an industry, we do a terrible job of taking care of the people in the industry who do the right thing all of the time.

What is my point?

As a company we spend a small fortune on food safety, HACCP, audits and everything else that goes along with caring about the consumer and the integrity of the industry.

However, we have no standards that we all have to maintain and live by.

Then we let the FDA throw everyone under the bus because we cannot quickly identify where the problem is originating.

In Europe, the retailers hold all of their vendors accountable for Food Safety.

In the U.S., price is more important than Food Safety until there is a problem.

Until everyone abides by the same set of rules, the system will be flawed and many of us will not make the cut because we cared.

I have been doing this for 40 years and I love this industry, but today I am glad I am 65.

— James H Hannigan
President/CEO
J&J Distributing
St. Paul, Minnesota

This is a short letter but when you get a letter from a man who, with his wife, Deborah, started a company in 1978 with 300 square feet and now operates out of 125,000 square feet, it pays to read carefully.

He brings us back to first principles. In the case of food safety outbreaks, this is always a matter of preventing the problem to begin with.

These pages may be critical of the CDC or FDA but whatever their faults, it remains the responsibility of the producer to deliver safe food.

Yet as Mr. Hannigan reminds us, producers do not operate in a vacuum. At the PMA convention, in the aftermath of the spinach crisis, we released a piece in Pundit sister publication PRODUCE BUSINESS, entitled Food Safety Is A Retail Issue.

The key point: Suppliers cannot deliver more food safety than buyers are willing to pay for.

In the months since, there has been some progress but mostly the progress, as with the establishment of the California Leafy Greens Handler Advisory Board, focuses on raising minimum standards but not changing the culture of procurement organizations.

In fact, the reason it was so important to have everyone sign up for the Leafy Greens Board is precisely because there was so little faith that buyers would insist on only buying from producers who met the standard, few doubted that cheaper product would find a ready market.

So we thank Mr. Hannigan for reminding us we have important work to do on food safety.

We also note this line with more than a little interest: Then we let the FDA throw everyone under the bus because we cannot quickly identify where the problem is originating.

There is a real problem and it is that the FDA has so much discretion that everyone is afraid to point out their incompetence and irrationality.

Yet, increasingly, it is clear that simply being nice is not solving the problem — it is just leading to small outbreaks being made into disasters by the FDA.

We are going to have to move in the direction of standing up for ourselves and the industry.

We talk about attracting new talent to the business, yet here we have one of the most successful people in the trade reminding us that if we want to keep this industry a fulfilling place to build a career, we need to make sure that those who do the right thing are the one’s who get rewarded — not those who look to cut corners.

An important reminder at an important time… Many thanks to James H Hannigan for sharing four decades of perspective with the broader industry. That itself is a kindness worthy of praise.




SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

Pundit’s Mailbag — Too Quick
To Blame Mexico?

We started with Salmonella And Tomatoes Linked In New Mexico and then ran our SPECIAL REPORT: Tomato/Salmonella Outbreak…Insights and Analysis and received this thoughtful critique:

I have a huge amount of respect for your up-front assertion of this industry’s faults and respectively its positive aspects.

But I am a bit perplexed by this particular column on the salmonella contamination of tomatoes in the South West regions of the USA.

In your piece, Outbreak Alert: FDA Clears Some States And Countries But Not Others, which was part of the Pundit’sSPECIAL REPORT: Tomato/Salmonella Outbreak…Insights and Analysis, you make a statement :

“We have to applaud the FDA for working to minimize the extent and impact of its restrictions. For all practical purposes, this really just leaves Mexico as the source of tainted tomatoes, since Florida production is finished.”

This statement somewhat suggests that the problem is a Mexican problem, although the proper reading of the statement suggests “minimize the extent of impact” you follow up with “Mexico as the source of tainted tomatoes.”

There is no doubt at this point that the other named regions have been eliminated, but Florida has not been eliminated.

Yet your column is suggestive to eliminate Florida from the possibilities of being the source.

Florida was in big production of tomatoes for the time of the contamination and Florida is still in fair production of tomatoes this past week.

The facts remain that it may even be tomatoes of any origin (excluding those mentioned I would hope) that have been repacked and handled by a repacker.

Mexico could be the source, and by the odds of regions sold, and tomato types mentioned, the likelihood is very high.

Yet I find it not your normal self to assess the guilty party with so much missing information.

This spin on elimination of Florida as the possible source is a Bill O’Reilly thing.

It is absolutely a speculative shot at probabilities and it is an opinion that will be considered by many as fact in the way that it is presented by you.

Our company, Red Zoo Marketing, was the first greenhouse marketer in Ontario to have a 3rd-party audited food safety program.

We have worked very diligently to maintain an AIB SUPERIOR rating for 7 years in a row

All of our investments into such traceability is washed away in value with your making assumptions rather than factual conclusions

I remain respectful of your industry opinions, however, I think this particular area of evaluation may be bit too American-minded, no insult intended.

— Jay Colasanti
Red Zoo Marketing
Ruthven, Ontario, Canada

Many thanks to Jay for his kind letter and threes swipes with a wet noodle to the Pundit for inadvertently shutting Florida down too early.

The FDA has clearly not foreclosed the possibility that the tomatoes implicated in the outbreak could be from Florida, and so we will keep that possibility open.

When we look at the CDC map of the outbreak, it does seem to us that it is highly likely that Mexican tomatoes would be implicated:

Since mid-April, 145 persons infected with Salmonella Saintpaul with the same genetic fingerprint have been identified in 16 states: Arizona (12 persons), California (1), Colorado (1), Connecticut (1), Idaho (2), Illinois (17), Indiana (1), Kansas (3), New Mexico (39), Oklahoma (3), Oregon (2), Texas (56 persons), Utah (1), Virginia (2), Washington (1), and Wisconsin (3).

These were identified because clinical laboratories in all states send Salmonella strains from ill persons to their State public health laboratory for characterization. Among the 73 persons who have been interviewed, illnesses began between April 16 and May 27, 2008. Patients range in age from 1 to 82 years; 49% are female. At least 23 persons were hospitalized. No deaths have been reported.

Although it is not definitive, please note that beside one person in Connecticut and two in Virginia — who all may be found to be travelers when this is all done — there is a small cluster in the Midwest and the vast majority of the cases from Texas west.

Nothing is impossible, but this would be an odd geographic dispersion pattern for a Florida-based outbreak, but would make perfect sense for a Mexico-based outbreak.

Jay is in an interesting position with his production bookending the US. After receiving Jay’s letter, we asked if he was still involved in Mexico, which we recalled from some years ago, and received this quick response:

Yes we are very involved in the greenhouse industry in Mexico. Red Zoo has ownership interests in nearly 40 acres in Veracruz, and independently controls and operates an additional 21 acres in the state of Jalisco.

As well as relationships where Red Zoo does the commercialization for other greenhouse growers in different regions in Mexico.

Our production is focused fully on unique specialty products: Baby Eggplant, Baby Seedless Cucumbers, and many, many specialty cherry & cocktail-sized tomatoes

We thank Jay for catching our mistake and trust we’ve clarified our position. We appreciate him keeping us on our toes.




SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

Pundit’s Mailbag — Look At Lot Size

Salmonella And Tomatoes Linked In New Mexico was our kick-off. Then we ran our SPECIAL REPORT: Tomato/Salmonella Outbreak…Insights and Analysis, and that brought this note from an industry luminary:

I spent a couple of years in the traceability space, and regarding your tomato article, the real issue, I think, is one of “lot size management”.

With the spinach outbreak, the lot size was the entire industry, this time with the love apples, it is different… the industry is getting better…

— James D Still (Banana Jim)
Consulting Director of Cold Chain
Moraitis Group of Companies
Homebush Bay, NSW
Australia

Banana Jim is well known as the founder of Thermal Tech, and inventor of TarpLess ripening. He then did many projects with Chiquita-Asia Pacific, which was a joint venture with the DeNadai’s and is now a joint venture with Unifrutti.

For the most part, he worked with the very well respected and liked Jeff Jackson, who we mentioned here.

Now working on a ripening facility in Queensland, it is nice to have him weigh in on our industry crisis.

He is 100% correct that the key to traceability is lot size. Many people think of traceability as something you do after you produce the product to keep track of it, but that kind of traceability is almost useless.

As Michael McCartney explained during an interview we entitled, Getting A Better Grasp on Traceability:

You can’t do traceability if you don’t have a unique product identity already established.

Once product arrives, how do you separate each lot or bin or farm? The only way to do this is to create a time gap. If three farmers supplying the same product each have a unique identity, all bets are off once the food processor dumps the product in bins and it’s all blended together. It can happen like this now. If there isn’t a gap between your produce and mine, we lose our identity. We lose our ability to trace back. If an inquiry comes in, we have to look at a three-farm recall instead of a single farm, and what comes before and what comes after.

Now that the CDC, FDA and State Health Departments are presumably coming to the end of their epidemiological investigation, it will be interesting to see how far the industry has come. Will we be able to quickly identify the precise source of these tomatoes and thus liberate the FDA to focus its ire on a particular producer or particular farm?

Let us keep our fingers crossed. Many thanks to Banana Jim for reminding us of the crucial role that lot size plays in traceability.




SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

Pundit’s Mailbag — PMA And Others
Part Of Alliance For Stronger FDA

Salmonella And Tomatoes Linked In New Mexico was our first piece on the salmonella/tomato incident but hardly our last. It was quickly followed up with our SPECIAL REPORT: Tomato/Salmonella Outbreak…Insights and Analysis and that led to a brief note from PMA:

Just wanted to be sure you’re aware that PMA and others are part of the Alliance for a Stronger FDA and we are working to increase resources for the agency.

— Kathy Means
Vice President of Government Relations and Public Affairs
Produce Marketing Association
Newark, Delaware

Kathy was specifically responding to our piece, Tomato./Salmonella Situation Cries For Improved Epidemiology, which was part of our Special Edition and featured an important letter by James R. Gorny, Ph.D., Executive Director of the Postharvest Technology Research & Information Center, University of California, Davis, California, which pointed out:

Public health agencies are currently fragmented and under-resourced to effectively monitor and respond rapidly to developing public health issues.

We also commented on the letter by saying this:

Can the Center for Produce Safety look to develop better tools for epidemiology in produce? Can the government relations pros at PMA, United, WGA, FFVA, etc., get budget allocations to beef up staffing and pay people in a way likely to increase competency?

And PMA has supported efforts to increase FDA staff and funding:

Statement: PMA supports FDA hiring plans

In light of today’s FDA announcement (available at http://www.fda.gov/bbs/topics/NEWS/2008/
NEW01829.html
) on adding new staff to assure the safety of drugs, medical devices, food, and other products, Produce Marketing Association (PMA) is pleased to see the agency undertake such an ambitious hiring program to further bolster its capacity to protect public health.

PMA continues to advocate for increased funding for the agency during Hill visits. We urge FDA to allocate additional resources for the Center for Food Safety and Applied Nutrition (CFSAN) in order for CFSAN to better fulfill its important produce food safety mission.

On balance we support all this but do have some thoughts:

First, we are a little concerned that more money without institutional reform may not achieve much. What we need is a move to a proactive risk-based food safety assessment system, not this hysterical reaction whenever something goes wrong.

Second, we are concerned about the ability of the public sector to attract and retain top scientists. Putting more money in without changing salary parameters means the FDA will have a few highly dedicated public servants and many people less competent than those in the private sector.

Third, with all our work on different food safety outbreaks — the spinach crisis, botulism, the Honduran cantaloupe situation and many others, including the current salmonella Saintpaul situation, we find that the FDA and CDC get all the attention but it is often the state laboratories and public health departments that do the work. And these vary wildly in quality. We suspect a mechanism to do something on the state level may be very important.

This current outbreak was discovered due to the energy of the team in New Mexico.

Many thanks to Kathy Means and to PMA for keeping us abreast of the association’s activities.




SPECIAL EDITION II:
As Tomato/Salmonella Outbreak
Expands, Government Agencies
Require More Scrutiny

Pundit’s Mailbag — Assume Product Delivered ‘Dirty’???

In the midst of the spinach crisis, we received a piece we ran under the title, Pundit’s Mailbag — Framers Are Not The Cause Of Food Safety Problems. The thesis was simple: farmers were expected to deliver dirty product and it was the job of processing plants in the fresh-cut industry to clean it up.

Now, following our pieces, Salmonella And Tomatoes Linked In New Mexico, and our SPECIAL REPORT: Tomato/Salmonella Outbreak…Insights and Analysis, the same writer weighs in trying to extend his argument to tomatoes:

“It’s not about the tomatoes…” Here we are again. Should anyone be surprised? I certainly hope not.

It’s not about will we have another food contamination outbreak, but when — who said that? While I could be quick to criticize government, academic and association efforts or lack thereof, to do their part in this recent or any contamination issue, the blame clearly falls on the stewards of the supply chain.

Who cares and what impact does it have to find an academic moment or a food safety person of the year? When was the farmer, immigrant or a humble but tough inspector ever nominated or even listened to when it comes to what is important for food safety? After the spinach crisis and the government’s inability to respond, fix blame or improve their system, are we still naive in thinking we could depend on them for anything?

It’s not the farmer — the farmer is expected to bring the product to the next node in the supply chain, dirty. So take this hearty soul out of the picture for now. And remove the pig, cow and bird that unfortunately share the same habitat as the farmer. So those critics who have to say it had to come from somewhere, yes the pathogen did come from these sources, and I say, “…this is where it naturally comes from along with all of our fresh produce — should we move to thousands of acres of hydroponics?” Ludicrous! Do we move to regional or farmers markets for our produce — unrealistic.

A few weeks ago, I sat in my lofty perch chomping down some fresh green onions from my favorite supplier thinking, “…hum, what is next and when?” Remember, it’s not will, but when.

What, am I crazy? I thought we fixed food safety years ago? Imagine the surprise and horror in the pillars of academia, the halls of government and the bars of the trade associations.

Let us look at some facts:

Like Leafy Green, the FDA tomato guidance is fairly clear about preventative measures, essentially more guidance and regulation on top of more guidance and regulation,

Leafy Green exists with continuing issues and recalls, real or not, (just for the record, I think the Leafy Green effort is one good and great example for the industry),The FDA and other regulators have not changed the way they do business,

The trade associations and pundits find value in naming significant persons of the year,

Farmers are still blamed,

Processors and those up and down the supply chain are still being inspected with faulty standards and by weak third parties,

Processors and those up and down the supply chain are still operating without adequate surveillance,

We are still pumping the public on “Ready to Eat” (how about a “Wash Before You Eat” campaign),

The Pundit fell off of making food safety an issue and is more interested in what Tesco is doing,

Organics, well, still not more than changing the color of your hair,

And, not much has changed except we cite slow technology, point fingers a little better and talk about how much we really need to embrace new technology.

So what do you say? Here’s the ticket my friend. It comes down to this:

  • Do your due diligence at your node or point in the supply chain and do it well. All food contamination issues started because someone was asleep at the switch.

  • Do not make any assumptions about your suppliers. Check them well and check them (unannounced) often — don’t be afraid to cut them off if they can’t do it right. The same goes for your customers; see what they are doing.

  • Have a simple but effective trace-back system. Ensure you understand your supplier’s trace-back system. Ensure your customer understands yours and complements it. Test it often.

  • Be inspected often, internally and externally. Have a couple third-party certifiers and ask your customers to visit often.

  • Find a good and tough food safety advisor and give this person the authority to take the necessary actions to make your system work — let them close you down until your facility gets it right.

Despite what some may think or what you gather from this article — the food safety program at the grass roots level is getting better. My hat’s off to those like the Leafy Green board that keep trying, and my condolences to those like CAFF who think they are something special and don’t need the oversight.

Farmer Jones, Jose and Maria, keep up the great work! You are my persons of the year!

By the way, eat your tomatoes.

— Karl Kolb Ph.D.
President and CEO
The High Sierra Group and the American Food Safety Institute, International

Although we consider ourselves second to no one in our support for farmers, we question if telling farmers that it is ok to deliver “dirty” product is actually helping them.

If by “dirty,” one means laced with dangerous pathogens, then the answer is that this is not correct as a matter of law and is a highly dangerous attitude if one is looking for commercial success.

Perhaps, to some extent, one could understand this view if delivering to high-tech food processing facilities such as fresh-cut plants. Whatever the strength of the argument, though, it falls apart completely when one is simply delivering to a packingshed. Not to mention that an awful lot of crops are never delivered anywhere, but are packed in the field.

It is easy to say that as an industry, we should abandon “ready to eat” but it is also true that this is where the market is and if we can’t serve it, others will.

Certainly the suggestions about knowing one’s suppliers and inspecting, etc., are prudent but often not enough.

Many of the issues regarding food safety also revolve around cleanliness. One reason many oppose irradiation is they feel that without food safety as a concern some would care less for the purity of their product.

Remember, most of the food safety concerns seem to revolve around excrement. Many would say that they don’t want to eat irradiated excrement — even if it is safe, they want a purer, cleaner product.

The industry is selling a consumer good. The only rights we have are those that consumers give us, and there is little indication they will like this “dirty product” idea.

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