How safe is your salad? A response from Devon

The question was asked "How safe is your salad?" The mid-December San Francisco Chronicle article in which the question appeared is found at this link.
But in fact, the question was not, "How safe is your salad?" It is now "How environmentally appropriate are safe salad standards?"
The KSU Food Safety Networks sends this link to a letter to the editor in response to the article from Devon Zagory, executive director for the Center for Produce Safety at UC Davis.

Before we look at at Devon said, let's go back to the original article. One excerpt:

The consequences of the crisis fell heavily on California's Central Coast farmers, who are now being pressed by buyers to comply with a con{fllig}icting array of new food-safety measures, some of which, according to the Environmental Protection Agency and other regulatory agencies, are costly, scientifically unproven and environmentally harmful. Some violate state regulations, and may even be counterproductive to food safety. But the growers must follow these measures in order to market their crops to the larger contractors or handlers.

The new set of rules is jeopardizing the future of sustainable agriculture and of the habitat and clean water it supports, according to the Nature Conservancy's Monterey Project Director Chris Fischer: "Farmers and conservationists in California have been working together for more than 20 years to develop practices that help protect water quality and wildlife habitat, but since last fall, farmers have been under enormous pressure from their buyers to go the other direction. To stay in business, they are being forced to build miles of fences along streams, cut down trees and bulldoze ponds. Some actions, like creating bare-earth buffers along waterways, may actually increase the risk of contamination downstream."

TK: The wide ranging article focuses primarily on the perceived shortcomings of the leafy greens marketing agreement and other industry created standards relative to environmental and sustainability considerations. Here is Devon's letter:

I commend you on the fine article by Carl Nagin, "How Safe Is Your Salad?" (Dec. 16). It seeks to provide a complete and balanced view of a complex subject. There are a few additional things I would like to point out. First, though it may seem that contamination of lettuce or other leafy greens has become common, and that there is a crisis in food safety, that is actually not the case. While it is small comfort to those who have been made sick or otherwise affected by food-borne illness, 200 illnesses out of billions of portions of spinach consumed last year hardly indicate a system out of control. Of course, no illnesses are to be tolerated and the Leafy Greens Marketing Agreement is one manifestation of the unacceptability of any contaminated leafy greens reaching consumers.

The California Leafy Greens Marketing Agreement does not require fencing of fields, destruction of riparian habitat or tearing up of buffer strips or other water-quality measures. That this may be happening has more to do with a general attitude of risk aversion on the part of growers, handlers and buyers, and a lack of adequate research on the presence and magnitude of various hazards. We know that cattle represent the major reservoir of E. coli O157:H7, and managing farms to reduce exposure to cattle and their feces has become central in the production of leafy greens on the Central Coast and elsewhere. But the pathogen has also been found in deer, pigs, birds, rodents and garden slugs. What we don't know nearly enough about is the impact and actual risk associated with these other potential vectors. In the absence of such information, buyers are uncomfortable with any risk, and farmers are compelled to do their best to reduce or eliminate any possible risk - real or imagined.

In the current environment of risk aversion, and the absence of adequate scientific data about the impact of various animals, wind, organic composts and other factors, many in the buying community are requiring their suppliers to institute every more draconian measures to address risks. The solution is to provide the research needed to perform quantitative risk assessments, to prioritize the actual risks and to devote the necessary resources to minimize or eliminate them. The Center for Produce Safety at UC Davis was recently formed with industry and government money to better understand what is and is not known about actual risks. Where insufficient information is available, the center will sponsor, fund or otherwise facilitate research to enhance the safety of fresh fruits and vegetables, using money provided primarily by private companies that have a compelling interest in their resolution and are willing to donate money to the effort. This will resolve some of the potential food safety and environmental conflicts that have been outlined in the article.

TK: Devon makes a strong assertion in this letter out of the gate: "First, though it may seem that contamination of lettuce or other leafy greens has become common, and that there is a crisis in food safety, that is actually not the case." The rest of his letter makes a strong case for more research, and notes the valuable function of the Center for Produce Safety to fund and facilitate such research.

But consider his first assertion. If, in fact, contamination of lettuce and leafy greens has not become common - and that there is no crisis in food safety - why is the industry not saying so with a bigger voice? The time is overdue for a proactive consumer messaging campaign about the safety of produce, particularly the safety of leafy greens. There is no reason to wait any longer. Uniform national produce safety standards may take years to implement, and when they come they will not be without critics.

Consider the study by Paul Patterson and Tim Richards, "The Economic Value of Public Relations Expenditures; Food safety and the strawberry case."
From that paper's conclusion, the authors report that "defensive media efforts" by the California Strawberry Commission benefited strawberry growers to the tune of tens of millions of dollars following that industry's pr hit following two incidents of foodborne illness in 1996-97. Patterson and Richards were prophetic in the 1999 study in their observation that commodity boards may want to expand their efforts to include food safety standards for growers.

There is no generic board to promote leafy greens, so the strawberry case differs in that respect. But surely California growers - and indeed the entire produce industry - would gain from more aggressive investments in mass media outreach to consumers still cautious about consuming spinach and other leafy greens.