Food safety guidelines for tomatoes

By some quirk known only to the computer gods, a news release I was looking for from the United Fresh Produce Association was assigned to my Outlook spam folder. I retrieved the document and publish an excerpt below. The most important sentence is the last:

"The California Tomato Farmers and Florida Tomato Exchange have indicated that they support the Commodity Specific Food Safety Guidelines for the Fresh Tomatoes Supply Chain, 2^nd Edition as the basis for mandatory national food safety standards for the fresh tomato industry."

From the release:

United Fresh Produce Association (United Fresh) and the North American Tomato Trade Work Group (NATTWG) have published the second edition of the Commodity Specific Food Safety Guidelines for the Fresh Tomatoes Supply Chain for use throughout the fresh tomato industry. This document provides the latest food safety guidelines related to water, workers and soil factors, and it includes components for all companies along the supply chain, including retailers and foodservice distributors.

United Fresh and NATTWG initiated the year-long effort to revise the first edition guidance document in order to incorporate new scientific learnings and to include the perspectives of a broader scope of contributors than was included in the first edition.

Over the past 12 months, more than 40 scientists and industry experts from academia, government and the fresh tomato industry have reviewed the latest food safety research findings and industry practices in order to revise the first edition of the guidance document, which was published in 2006 by NATTWG.

“Significant efforts were made to involve as many associations, agencies, companies and individuals with expertise in food safety practices for one or more steps in the fresh tomato supply chain as possible,” said Dr. David Gombas, senior vice president of food safety and technology at United Fresh. “We wanted everyone’s input on this so we could be as thorough as possible.”

“In the two years since the first document, we’ve learned more about potential risks and control measures at all points in the fresh tomato supply chain,” said Reggie Brown, chairman of NATTWG. “The second edition of the guidelines represents current understanding of conditions and controls that should be considered by every company in the tomato supply chain.” NATTWG is a consortium consisting of fresh field and greenhouse tomato organizations within the United States, Canada and Mexico.

The California Tomato Farmers and Florida Tomato Exchange have indicated that they support the Commodity Specific Food Safety Guidelines for the Fresh Tomatoes Supply Chain, 2^nd Edition as the basis for mandatory national food safety standards for the fresh tomato industry.

A message from Stenzel

TK: This across the inbox this afternoon, United Fresh president Tom Stenzel previews not only next week's hearings but the continuing debate over government interaction with the trade:


A Message from President Tom Stenzel


Dear United Fresh Members,

Last week, Chairman of the Board Tom Lovelace wrote to tell you of our association’s commitment to driving change in the way government addresses foodborne disease outbreaks, and to seek compensation for those unfairly harmed by this investigation. There’s been so much going on in these areas, let me update you on our progress.

Consumer Warnings/Investigation
First, we’re continuing daily to push government authorities to narrow the current investigation and bring it to a close as quickly as possible. The finding of a sample of jalapeño peppers in a distribution facility in McAllen, TX with the identical DNA fingerprint as the outbreak is an important step toward closure. Yet, the government’s warning not to consume any peppers is destroying markets for hundreds of jalapeño growers and suppliers unrelated to the outbreak, and we’re urging government to lift this total supply chain warning.

Congressional Hearings
Next week three separate Congressional hearings are scheduled to look at this outbreak investigation, what went wrong, and what lessons we can learn for the future. Robert Guenther and Dr. Dave Gombas on our staff have worked hard to brief each committee’s staff in advance of each hearing, providing detailed background on where we see things went wrong and what needs to be done in the future. I’m pleased with the strong slate of industry experts called to testify, along with government officials, academics, consumer groups and others. I’ll be focusing on overall lessons learned in my testimony at two of the hearings, and others will focus on everything from damages to the tomato industry to the loss of consumer confidence in food safety and government.

Legislation to Compensate Tomato Industry
There’s good news here with the introduction of legislation by Rep. Tim Mahoney of Florida to provide up to $100 million in compensation to the tomato industry for losses incurred through the misidentification of tomatoes and blanket consumer warnings. Congressman Mahoney gets it, and we’re working with him and Congressional allies to build the case, despite what are frankly some pretty big odds. Even with an uphill fight, we need to drive home the message that government warnings have huge impact, with major financial consequences on those totally unassociated with the outbreak. There simply must be greater recognition of the damage these broad brush actions have. The entire tomato industry suffered here, and we’ve got to make sure that growers, shippers, repackers and fresh-cut tomato processors are fairly compensated. A number of us will advocate strongly in support of this effort in next week’s hearings.

FDA/CDC/HHS Actions
We’re also continuing direct dialogue with FDA about clearing all tomato production regions for the future, as well as broader questions of what went wrong in this investigation, and ways that the system must change in the future. You’ll remember that our association and PMA have asked the Secretary of Health and Human Services for a top-level meeting and ongoing dialogue about these issues, and government staff members are now working to set that up.

National News Media
Media coverage continues to be frustrating, but we’re breaking through here and there. From the Wall Street Journal and Washington Post to USA Today, CNN, ABC, etc., our communications VP Amy Philpott is getting our views in every story we possibly can. Our general assessment is that most media have realized that tomatoes are highly unlikely to have caused any illness whatsoever.

Media stories are now turning to follow-up coverage, focused a lot on what happens next. Many in the consumer advocacy community and Congress are using this outbreak as a means to drive food safety legislation, or prescriptive traceability schemes. Ironically, the major problem in this outbreak investigation was identifying the wrong cause and chasing ghosts far longer than needed. You know that United Fresh supports commodity-specific, risk based regulation that is fair and equitable across an entire commodity. And, we’re working hard to increase efficiencies across our supply chain in traceability. But neither of those topics has anything to do with the failures in this outbreak. Drawing those distinctions for the news media is a challenge, though.

Industry Traceability
Finally, let me add a word about industry traceability, a topic likely to dominate next week’s Congressional hearings. We believe the vast majority of produce companies and their supply chain partners are in compliance with the Bioterrorism Act and its “one-step-up; one-step back” requirements. Industry members take that responsibility seriously. While produce often changes hands between farm and table, industry members are able to track a majority of produce from retail back to farm source. While FDA continues to report major problems in doing tracebacks, others such as Minnesota health officials have said it takes “a few phone calls and you can work it fairly quickly back to the grower.” That is the experience that I hear as well from many of our members across the industry. We believe that when FDA tracks produce, it is more dependent upon a legal trail of paperwork, seeking to make sure that all the details correlate exactly on invoices, bills of lading, etc. This can lead to bogging down in understanding the different ways companies use to track produce within their own operations. It may be confusing to an outsider who is examining hundreds of pages of records in an unfamiliar business, but to most industry members, each part in the distribution chain can effectively determine where it received produce, and keep tracking back to the farm.

Nevertheless, the produce industry understands better than anyone that we need the most efficient and quickest traceability systems possible. We have the most to gain from isolating produce that may be part of a problem as quickly as possible, and a similar incentive to rule out concerns about produce that is clearly not related to a problem. That’s why United Fresh joined with PMA and CPMA last year to launch an initiative to build better transparency, a common framework and nomenclature for case labeling, and streamlined connectivity across the supply chain. That initiative is guided by a Steering Committee of more than 50 produce retailers, wholesalers, distributors, packer-shippers and growers. The committee has met four times this year and is now finalizing action plans and timelines for industry adoption. That’s the best example I know of an industry committed to constant improvement in traceability, not one that requires more government regulation to get the job done.

As you can tell, there’s a lot going on. We’re getting lots of member questions, so I wanted to answer as many of them here as I could. Let’s look forward to clearer days ahead.

Tom Stenzel
President
United Fresh Produce Association

Crisis management

The tomatoes/salmonella outbreak/investigation has presented the industry with one of its toughest challenges ever, creating dynamics of outrage with the FDA's performance and defensiveness about produce traceability. Here is a July 1 communication from United Fresh, which touches on both realities.

Dear Produce Industry Members,

Given the heavy media pick up over the past few days, I wanted to send you a brief update on the Salmonella saintpaul outbreak, even though there is no new information to report specifically on the outbreak investigation itself.

Last Friday, on June 27th, CDC and FDA held a joint media briefing to provide an update on the Salmonella saintpaul outbreak. As you know from the media reports over the weekend, during this briefing CDC indicated that tomatoes may not be the source of the outbreak, although CDC also said that there was still a very strong correlation with tomatoes. In addition, FDA stated that the source of the outbreak may still be in the marketplace; this was based on a June 15 onset of illness date.

Today, CDC and FDA held another joint media briefing, and health authorities reported that June 20 is now the latest onset of illness date related to the Salmonella saintpaul outbreak, and this is still an ongoing outbreak. During the call, CDC and FDA both reiterated that although "other items commonly consumed with tomatoes" are now also being investigated, the strongest correlation is still with tomatoes.

It is important to note that CDC and FDA did not change their advice to consumers, retailers and restaurateurs. The FDA advice is: "July1, 2008: At this time, FDA recommends consuming raw red plum, raw red Roma, or raw red round tomatoes only if grown and harvested from the… areas that HAVE NOT BEEN ASSOCIATED WITH THE OUTBREAK." In addition, "types of tomatoes not linked to any illnesses are cherry tomatoes, grape tomatoes, and tomatoes with the vine still attached."

A replay of today's media call is available until Friday, July 4, 2008 by dialing 1-800-462-2082; international callers can dial 1-402-344-6820.

FDA is continuing its outbreak investigations in both Florida and Mexico to determine the source of the outbreak. FDA is sampling both domestic and imported product, and continuing to pursue new traceback investigations.

Here at United Fresh, Dr. David Gombas and I have both been giving print and on-camera media interviews. Our general messaging is focused on the industry’s commitment to food safety both in preventing and responding to problems, our sincere hope that CDC has not led any of us down the wrong path, both because of the losses incurred by the industry, but also because, if the outbreak was not caused by tomatoes, everything done over the past five weeks will have done little to actually protect public health, and, finally, the unacceptable management of this outbreak and our request for industry and government health officials to work together on an ongoing basis, not just when a problem occurs. The media has also asked about traceability and country of origin labeling. If you have been contacted by the media and would like to discuss these lines of questioning, or if you would like to refer these calls to us, please feel free to provide my number to reporters.

Obviously, the most important thing to do is still to stop the outbreak, which would be signaled by going 2-3 consecutive weeks with no new illness occurring. To this end, United Fresh has been working with industry scientists and supply chain experts to provide FDA and CDC as much industry input as possible. We are also receiving calls from congressional offices asking what the industry is doing in the areas of traceability and food safety, so we have been answering these questions as well.

As always, we will keep you updated as new information becomes available. If you have any questions, feel free to contact me at: Amy Philpott, Vice President, Communications, 202-303-3400 ext. 425.

Regards,

Amy

United Fresh Produce Association
1901 Pennsylvania Avenue NW, Ste 1100
Washington, DC 20006

Tomatoes and salmonella: avoiding ambiguity

I talked to a distributor of Mexican tomatoes in Nogales today who said they were now selling about 60% of their production from Sonora at depressed prices, leaving 40% behind in Mexico.

No word yet about the FDA investigative team in Mexican, other than the fact they are apparently traveling with their Mexican counterparts and super secretive about where they are going and what they are looking for.

The distributor's biggest concern is that the FDA will come up with an ambiguous result, with no certainty of where the contamination occurred and what caused it. He also chafed at the idea that the FDA's David Acheson is using the occasion to ask for more authority for the agency. "We have all been 100% cooperative."

Meanwhile, the FDA said they may have another conference call this afternoon. A little illumination, gentlemen?

At this point, can we call the FDA's management of the salmonella investigation incompetent, as some have said? Certainly, the FDA's advice to consumers has been confusing. Many loads of good tomatoes have been thrown away. Yet the contention by some critics that the outbreak is over doesn't seem to be supported by facts. The CDC today pushed the number of victims of salmonella saintpaul higher again, to 707.

I think the industry should tread lightly in respect to damning the agency's efforts. I don't think you will hear PMA or United describing the FDA investigation with the term "incompetence."
Frankly, I would be shocked if they ever did. Until I hear United's David Gombas and PMA's Bob Whitaker call the FDA incompetent, I tend to discount any such talk by anyone else.

Don't forget that one of the big hurdles the agency faced in their traceback investigation was the apparent absence of an effective industry traceability/record keeping system for fresh tomatoes.

The most unsatisfying result for the FDA's traceback investigation would be ambiguity. If that is the result of these weeks of travail, perhaps "incompetence" may not be too strong a characterization.

Traceability: A lost industry initiative?

Has the salmonella outbreak linked to tomatoes torpedoed hopes of an industry-led solution to traceability? I don't know the political dynamics of produce safety legislation on Capitol Hill, but I perceive the reality of a government imposed solution is closer than ever after the turmoil associated with the salmonella outbreak.

Take, for example, the House Energy and Commerce Oversight Investigation subcommittee hearing today. A couple of themes were country of origin labeling and traceability. Importantly, committee vice chair Rep. Diana DeGette, D-Colo., engaged FDA food safety official David Acheson repeatedly on the traceability issue. The net of the exchanges was that Acheson agreed that the salmonella outbreak has moved traceability to the front burner at the agency.

That gives me the sense that FDA might not be averse to a legislative, mandated solution.

DeGette, for her part has been getting press for her legislative push for traceability. The Denver Post writes about DeGette:

(DeGette) said that what is needed is a tracing system that would allow federal inspectors to almost instantly find where food produce was contaminated. She has proposed such a tracing system in her bill H.R. 3485, the TRACE ACT.

On its editorial page today, The Washington Post backed passage of DeGette's bill.

The Washington Post editorial said that nestled within the Food Safety Act of 2007, under consideration in the House, is DeGette's provision that would give the Agriculture Department and the FDA power to issue a mandatory recall of contaminated food.

"This is more than reasonable," said The Post editorial, "since the federal government can and did recall lead-tainted toys imported from China last year. Besides, the hammer of potential government action would be a powerful incentive for growers and packers to conform to safety standards."

Packer coverage from May 12 about the traceability steering committee:

David Gombas, senior vice president of food safety and technology for Washington, D.C.-based United Fresh, said the steering committee of the traceability initiative met Jan. 9, Feb. 22 and April 11 and is scheduled to meet again June 12. The initiative is sponsored by the Newark, Del.-based Produce Marketing Association, the Canadian Produce Marketing Association and United Fresh. Forty-one companies are participating, with nine foodservice operators/distributors, 13 retailers and 19 grower-shippers.

Gombas said the January meeting brought is consensus on four key points:

* the GS1 standard is to be used achieve whole chain traceability;

* a timeline is needed achieve whole chain traceability;

* a public declaration is needed by each company; and

* start at the case level, with strong provision to move to item level.

Gombas said the June 12 meeting will establish timelines for each milestone on the path of supply chain traceability. In comments after the session, Proctor said the steering committee might set a timetable for implementation in a range from 18 months to five years.

TK: I don't know if the steering committee's work was postponed by the salmonella outbreak, but the urgency for industry led action on traceability has never been greater. Without an ambitious timeline for industry adoption of "whole chain traceability," the government will mandate a solution. Whether that solution will make sense for the industry will be secondary to the urge by Congress to act. In fact, the events of the past month or so may have made the work of the steering committee only a footnote in what will be a government imposed solution.

United relelase: June 11

From the United Fresh Produce Association:

FDA has expanded its list of areas NOT ASSOCIATED WITH THE OUTBREAK to include counties in Florida that were not in production at the time of the first illness onset associated with the recent Salmonella saintpaul outbreak. According to FDA, "shipments of tomatoes harvested in these counties are acceptable with a certificate issued by the Florida Department of Agriculture and Consumer Services."

Florida Department of Agriculture and Consumer Services (FDACS) will verify that tomatoes from the designated Florida counties were harvested after May 1 - after the outbreak began. The specific shipment criteria can be found on the Florida Tomato Committee's website at www.floridatomatoes.org.

For more information about the FDACS certificates, please contact FDACS, Division of Fruits and Vegetables at 863-291-5820, or Florida Tomato Committee at 407-660-1949.

Tomatoes from all other states and countries on the FDA list do not need to be verified or accompanied by a certificate.

FDA is still investigating the outbreak and United Fresh will keep you updated as we receive new information. United Fresh is taking calls from the media and yesterday we spoke to several reporters about misinformation in some of the news reports. We will continue to work to provide new information to reporters and correct any misinformation in the media. Please contact us, if you have questions.

Amy Philpott, aphilpott@unitedfresh.org, 202-303-3400 ext. 425

Dr. David Gombas, dgombas@unitedfresh.org

Helpful Links:

Florida Department of Agriculture and Consumer Services: http://doacs.state.fl.us/

Florida Tomato Committee: http://www.floridatomatoes.org/

Shipment criteria found on the Florida Tomato Committees website http://www.floridatomatoes.org/tomatoshipmentcriteria.pdf

United Fresh Produce Association, Home Page www.unitedfresh.org

United Fresh Produce Association, special page on Salmonella saintpaul outbreak http://www.unitedfresh.org/newsviews/food_safety_resource_center/salmonella_saintpaul_outbreak

U.S. Food & Drug Administration http://www.fda.gov/oc/opacom/hottopics/tomatoes.html

Jay Martini - How to recoup losses?

Here is the the letter from Jay Martini to David Mitchell of The Packer - lead writer on the salmonella coverage - and copied to me. Jay said it was fine to publish on the blog, save one passage dealing with a rumor. Here is the letter, save that one paragraph:

8:00 AM, Sunday, June 8, 2008

David---

As a tomato broker for the last 28 years, I've seen a handful of food safety scares regarding produce come & go. But this instance hits home, and hits it hard. The difference with this one, other than it involves the commodity in which I make my living, is that the process this time smacks of politics, without any regard for the U.S. farmers or distributors with domestic tomatoes presently in the pipeline.

The headline of your online article below said that Mexican tomatoes were implicated in this outbreak. A more accurate headline should have been that any tomato-producing area not listed by the FDA (a ridiculous, self-serving list of areas that aren't even in season) is suspect. And that includes Florida, whose tomato shippers are left twisting in the wind at this point, along with all of us down the line with Florida product. David Gombas of the UFPA telling industry people 'not to read too much into the list' is an idiotic statement. Of course, everyone's looking at the list---it's our business!

Why doesn't the FDA state in their press release that no grower/shipper in Florida, to my knowledge, has to date been contacted by the FDA? (deleted passage)

The spokesperson for the New Mexico Department of Health has herself said that that time of year (beginning April 23), most if not all tomatoes in New Mexico are sourced from Mexico. If this is the case, why is the Florida tomato industry publicly being held hostage?

I was at a graduation party last night when I got a text message with the sickening news that the FDA had gone nationwide with their release, and also that Subway had had an emergency meeting, eventually deciding pull all tomatoes from their sandwiches.

If it is found, as I imagine it will, that Mexican tomatoes are the one and only source of this rare strain of salmonella, how do the shippers, distributors & handlers of Florida tomatoes recoup their losses? Multiple millions of dollars are being lost with every day that this farce continues.

Jay Martini
Sales
Art Kramer's Produce Buying Service, Inc.
Skokie, IL

United update on tomatoes/salmonella

From United Fresh this afternoon:


June 7, 2008
Dear Produce Industry Members,
This is an update concerning the Salmonella saintpaul outbreak. U.S. Food & Drug Administration (FDA) updated its consumer advisory at 6pm eastern time this evening .
FDA is still recommending retailers, restaurateurs, and food service operators continue to offer cherry tomatoes, grape tomatoes, and tomatoes sold with the vine still attached, from any source. In its update this evening, FDA also advises consumers to limit their consumption of tomatoes to these types of tomatoes and to tomatoes from the areas listed below.
FDA also recommends that all retailers, restaurateurs, and foodservice operators offer raw red plum, raw red Roma, or raw red round tomatoes only if grown and harvested from the areas that are listed below.
The list below was compiled by FDA based on both traceback information and shipping dates. That is, the list includes production areas that have been eliminated as a possible source based on traceback information and it also includes growing regions that were not shipping tomatoes when the first illness related to this outbreak was reported.
FDA has indicated that red Roma, red plum, and round red tomatoes from the following sources are NOT ASSOCIATED WITH THE OUTBREAK:
Arkansas
California
Georgia
North
Carolina
South Carolina
Tennessee
Texas
Belgium
Canada
Dominican
Republic
Guatemala
Israel
Netherlands
Puerto Rico
According to Centers for Disease Control and Prevention (CDC), illnesses related to this outbreak began April 23 and the last onset of illness related to this outbreak is currently May 27. There is roughly a two week period between when someone becomes ill and when the health authorities can determine whether or not they are actually linked to the outbreak. This means that even though the CDC is reporting an increase in illnesses, the cases reported today are people who became ill between April 23 and May 27. This also means that health officials are unlikely to declare the outbreak officially over until they have seen at least two weeks with no new illness onsets.
The FDA's national consumer advisory will likely generate even more media than we've already seen. If you would like, feel free to forward media calls about the outbreak to me or Dr. David Gombas, or contact me if you would like general media messaging points. United Fresh has also established a dedicated webpage to provide the latest information about the Salmonella saintpaul outbreak.
We’ll keep you updated as new information becomes available.
Amy Philpott, Vice President, Communications, 202-303-3400 ext. 425
Dr. David Gombas, Senior Vice President of Food Safety & Technology

Coming on

Had some visits today with David Gombas of United, Michelle Smith of FDA and sat in on a little bit of a labor hearing, where Reggie Brown of the Florida Tomato Committee was testifying. I missed the farm bill conference hearing, but I've heard that not a lot happened.

From a Capitol Hill staffer, I heard there there will be a Putnam-Cardoza produce safety bill introduced in the not too distant future.

Will the WIC food packages be reopened? Juice and fresh potato interests (United also favors including potatoes) wants to revise the packages, and others want to gain back the $2 per month lost in rulemaking. I have an interview with John Keeling on Thursday and I'm sure the topic will come up....

Tomorrow I'll spend some time at the USDA and try to catch some more or the farm bill conference.

What - or more accurately, where - is the future venue of United's shows? Haven't seen Tom Stenzel this week to ask him, and no one else on United staff is spilling the beans. When I see Tom, I'll see if he has any news....

Have your people call my people

Talking to Dave Gombas of United earlier in the week, he indicated there has not yet been a meeting between suppliers/association leaders with members of the Food Safety Leadership Council. The purpose of the clutch, of course is to talk about the merits of the council's on-farm food safety standards. Gombas was hopeful for a meeting before the end of the month. There appears to be, in my view, a little trepidation from all parties over what to expect from the process. Is this a technical discussion only or will it delve into marketing issues? In any case, there should be no reason that the council and suppliers should not agree to meet at least one time. If nothing comes of it except the perfunctory "agree to disagree" spin, it would be better than if the meeting never happened.

How big should the steering committee of the Produce Traceability Initiative be? The question appears to be open for at least now, as some favor adding a few more members to fill out the supply chain, while others would prefer a committee size that is more manageable.

I'm afraid they may have already breached the ideal committee size. From the Web site Solutions that endure.

Seven is the Ideal

Seven is the ideal number of members for a group to problem solve, find creative solutions, build a strategic plan or grapple with complex challenges. If groups are formed for other purposes such as building consensus, representing diverse communities or governing, these concepts may not apply.

Too Large

As a group gets too large in the 9-12 region group dynamics deteriorate. Meetings get longer and each person has less time to contribute. This leads to many potential pitfalls; boring meetings, members not paying full attention, noisy meetings and ultimately lack of attendance. In large groups many participants will feel not enough “attention” is given to their opinions and input. Aggressive personalities will feel the need to assert themselves to get their share of limited time. Passive personalities will hold back and not contribute equally as the meeting becomes time constrained. Dissatisfaction of members with the group dynamics, output or effectiveness will lead to a downward spiral of diminished group performance.

Balance

The closer the group size is to seven the easier it will be to achieve the balance needed to create a highly effective group. Creative synergy is the goal. This happens when group members throw their ideas on the table and others are stimulated and react to that idea, spawning another idea or view. The goal is to create a positive feedback loop of contribution of each member so that the individual members feel energized about their contribution. When this cycle occurs each individual contribution is a building block to a bigger and better final product built by the entire group.

Another objective of the balanced group is making fewer mistakes. This happens because the diversity of opinion allows more facets of a problem and proposed solution to be seen and vetted. There is a high value in diversity of life experiences. Just when the group feels they have solved the problem or found the ideal solution, one lone member will catch the flaw that others missed in their excitement.

Characteristics of a Team

A balanced group size has all members actively participating and sharing their questions, observations and ideas. An effective group evolves when members see themselves as a team, and value the output of the group and identify with the group with pride.

One Reason it Matters

Problems are created when people insist on designing and empowering very large groups to solve problems. The confusion comes from the focus on having all interest groups or stakeholders represented which is a laudable goal. After a very large council, commission or committee is formed it becomes evident the “work” cannot get done efficiently. At that point a methodology has to be constructed to work around the dysfunctionality of the 25 member group.

TK: At least we can hope for 7-member subcommittees after the Jan. 9 meeting in Atlanta.

Wanted: silver bullet

Here is the link to the final report of the International Lettuce and Leafy Greens Food Safety Research Conference, presented recently by United's Dave Gombas to the USDA’s Cooperative State Research, Education and Extension Service.

From the report's general recommendations:

Research Scaled to Real World. All participants felt that research should be conducted on a pilot-scale or field operational basis and that we must get beyond the classical laboratory research of the past. It was noted that research on microbial ecology and field interventions should focus on actual field conditions and what the pathogens are doing, not what they can be made to do.
Access to Private Sector Data. Critical information exists in both industry-conducted data collection and industry-funded research. These private sector operational data must be mined in such a way as to allow access with confidentiality. Collaborative partnerships between industry, academia and government must be facilitated to ensure research is focused on solutions for real world practices and data gaps.

Kill Step Technology. While there is a crucial need for a pasteurization process for lettuce and leafy greens, it is recognized that no current technology has a significant potential to accomplish this in the near future. Therefore, significant expenditure of research funds here is unlikely to result in a meaningful intervention until an innovative approach is found.

TK: Does irradiation offer "significant potential to accomplish" a kill step for lettuce and leafy greens in the near future? Apparently not, say the authors of this report. However, even if irradiation were a kill step, would it be used? Here is an excerpt from commentary by Michael Osterholm is director of the Center for Infectious Disease Research and Policy and professor in the School of Public Health at the University of Minnesota.

"In the end, there is only one absolute measure to address this issue: food irradiation. This process, which primarily uses an electron gun -- just like the one in your TV, except at higher power -- that turns electricity into an energy that safely and cost-effectively kills bacteria like E. coli. It does so without significantly changing the flavor, color or nutrient content of the food. Routine irradiation of meat and poultry would do for those food commodities what pasteurization did for milk: make them safe. In the end, that's all that matters, particularly for those who have lost loved ones needlessly to E.coli infection."

Another produce code

Luis of the Fresh Produce Industry Discussion Group provides this story from the Nov. 16 edition of www.InsideHealthPolicy.com.From the story cited by Luis:

The organization representing state food and drug regulators is working with the food industry and a consumer group to draft by early next year a model produce code that state and local regulators could adopt. The Association of Food and Drug Officials and the food industry have not yet endorsed mandatory, federal good agricultural practices but concede they will likely be the next step. "There would be value in some mandatory programs," says Craig Henry, chief operating officer and senior vice-president for scientific and regulatory affairs at the Grocery Manufacturers Association. "Whether it is part of the federal food code remains to be seen." The model code will set out basic good agricultural practices. The agricultural standards will likely address worker hygiene, field equipment, fertilizers, land use, water testing, pest control programs, and produce tracking. The groups are building on the 1998 FDA guidance on preventing microbial hazards in fresh fruits and vegetables, another industry source says. After the draft code is released, commodity-specific standards will likely be issued, says David Gombas, senior vice president for food safety and technology at the United Fresh Produce Association. He says there are already GAPs being developed for melons, leafy greens and tomatoes by different states and commodity groups the produce code will draw upon. The Center for Science in the Public Interest, while working on the produce code, is also drawing up a separate petition to FDA, with some industry groups, that asks FDA to regulate farms.

A common response

At 4:42 PM CST yesterday, from the email address of Amy Philpott of the United Fresh Produce Association, came this note addressed to the produce industry trade press:

“We want to provide you with a copy of a letter that is being sent this afternoon to the Food Safety Leadership Council on behalf of a wide cross-section of produce industry associations. This letter expresses the shared concerns of our organizations about recent communications received by many industry members requiring compliance with a new set of on-farm standards apparently developed by this group. While we are clear in stating our concerns, we are also committed to a positive dialogue with these industry partners. Food safety is a shared commitment and a shared responsibility across our total supply chain, and we look forward to working with all of our partners to ensure that together we are putting consumer safety first based on the best science and expert judgment available.”


Here is the letter:

November 14, 2007
Mr. Larry Kohl
Walt Disney World Co.
Food Safety & Health
PO Box 10000
Lake Buena Vista FL 32830-1000
Dear Mr. Kohl,
We understand that you help coordinate a group of company representatives that has prepared the attached Food Safety Leadership Council On-Farm Produce Standards. On behalf of the organizations shown below representing a wide cross section of the produce industry, we write to express our strongest concern about this document and its potential implementation, and ask that you share these concerns with all relevant parties. In recent days, many produce suppliers have received letters from Publix, Avendra LLC, and possibly others which state that their companies are members of the Food Safety Leadership Council FSLC) and go on to require suppliers to comply with the set of practices outlined in this ocument. It is unclear from this document exactly which companies are part of this effort, what legal and/or organizational structure exists for the FSLC, and what specific expectations may exist for your produce supply networks. The demands outlined in these individual companies’ letters and the content of the FSLC document present neither a scientific approach to enhance food safety nor a respect for the produce, retail and foodservice industries’ mutual commitment to deliver the safest possible fresh fruits and vegetables to our consumers everyday. As you know, we all share a commitment to providing consumers the safest possible foods, and we ask that you step back from this unilateral and unfounded direction to engage in a real scientific and professional dialogue with your produce suppliers, technical representatives from our industry’s trade associations, academia and government. Together, we should be engaged in mutual efforts to ensure an approach to food safety that can truly make a difference for our consumers, rather than focusing more concern on liability placement than actual sound,scientific and achievable food safety practices. Let us list several specific concerns with the FSLC document and approach.
1. Produce food safety demands a commodity-specific approach. While broad principles of risk prevention apply and are embodied in FDA’s Good Agricultural Practices (GAPs) for on-farm production, the specific standards and practices that should be employed for different commodities vary greatly. The FDA has directed industry to pursue commodity-specific GAPs as the best way to enhance produce safety overall, and huge strides have been made in addressing best practices for those commodities which have had recent linksto foodborne disease outbreaks. The FSLC document’s “one-size-fits-all” approach contains specifications that clearly should not apply to many commodities, and in fact, could be counter-productive in requiring growers to focus on the wrong things.
2. It appears that the FSLC document is based largely upon the approach industry has taken in preparation of Commodity Specific Food Safety Guidelines for the Production and Harvest of Lettuce and Leafy Greens, which were subsequently adopted as the metrics for compliance measurement under the California Leafy Greens Marketing Agreement. These standards have been developed and revised over several years with intense analysis of scientific issues, current research understanding, and production practices; and vetted extensively with industry, academic and government scientists. We believe this represents the current best practice standard for production of leafy greens. Both the National Restaurant Association and the Food Marketing Institute recognize the validity of these leafy greens food safety guidelines and support producers complying with these standards. Also,the Food and Drug Administration has reviewed these metrics, and never advised of any areas where they believe these are inadequate. Given that wide state of support for these best practices, FSLC members must be careful not to imply in any way that your approach would provide any higher level of safety than compliance with these industry standards. Our industry is committed to continuous improvement in food safety, and certainly expects to frequently revise best practices to incorporate the latest science and understanding of risk prevention strategies. We would be xtremely interested in discussing with you both the current best practice standards for leafy greens and the suggestions for production and testing that you have outlined in the FSLC document. But this must be a scientific discussion committed to mutual industry efforts to develop and agree on best practices to serve our consumers, not to create a bifurcated food safety system with different groups setting separate and unilateral
requirements.
3. On a practical level, you must know that some standards such as the water requirements outlined in the FSLC document cannot physically be achieved in many cases, even by world class producers. Perhaps you were thinking of a target for producers to strive for, but wthout further discussion, our best scientists just don’t understand what you have in mind. Similarly, some of the recommendations in your document are inherently based on opinion and judgment where science is insufficient, such as distance of production from animal grazing. Science today cannot tell us an exact distance, and we would therefore argue that expert consensus among industry, academia and government is the best way to address such unknown scientific questions until research can provide better evidence for risk-based decision-making. Otherwise, we are faced with an escalating, unscientific approach – if a 100-foot buffer is good; a 1,000-foot buffer must be better. Or why not 1,000 yards; or perhaps a mile, or two, or three. This is indeed a slippery slope without real science to guide these judgments. In conclusion, we respectfully urge FSLC members to reconsider your approach seeking to enforce the practices outlined in your document. We believe enforcing these practices would be inappropriate for many commodities, add unscientific and needless requirements to already existing best practice standards widely endorsed in the scientific community; could be counterproductive to produce safety in diverting attention from real issues; and would create an “us-against-them” food safety split in the produce supply chain. Perhaps that last point is our greatest risk, but one we should be able to avoid by working together. We know your companies well as industry leaders, and respect the fact that you want to do the very best for your customers in providing safe foods. Your produce suppliers share that unequivocal goal, and believe that we must work together as a total supply chain in order to fulfill our mutual objective of the safest possible produce. This issue cannot descend into an “us-against-them” fight or we all lose – we simply must work together to
bring wise, consistent, scientific and industrywide best practices to on-farm production, post-harvest handling and processing, distribution, retail and foodservice operations. No sector is exempt, and no one sector has all the answers. Mr. Kohl, please convey to your group our strong desire to engage in the earliest possible meeting to discuss these issues and ways we can work together for food safety. We will bring together scientific, technical and business representatives of our organizations and your produce suppliers to engage in dialogue to hopefully find a better course ahead that meets our shared goals for food safety. Please respond to Dr. David Gombas, senior vice president for food safety and technology, United Fresh Produce Association, as your primary contact in setting up a meeting and moving forward. Please also let David know if you have any questions or comments in the meantime. Thank you.
Sincerely,
American Mushroom Institute
California Avocado Commission
California Citrus Mutual
California Grape & Tree Fruit League
California Strawberry Commission
California Table Grape Commission
California Tomato Farmers
California Tree Fruit Agreement
Florida Fruit & Vegetable Association
Florida Tomato Exchange
Georgia Fruit and Vegetable Growers Association
Grower Shipper Association of Central California
National Potato Council
National Watermelon Association
New York Apple Association, Inc
Northwest Horticultural Council
Produce Marketing Association
Texas Citrus Mutual
Texas Produce Association
Texas Vegetable Association
United Fresh Produce Association
U.S. Apple Association
Western Growers


TK: One of the questions I submitted to Dwaine Stevens, the public relations contact at Publix, is whether Publix heard any direct response from individual suppliers on this issue. It wouldn't surprise me if they haven't. Certainly, Western Growers was helpful to their members and to the entire trade with its very public handling of supplier concerns about the FSLC on-farm standards. I don't think this follow up letter happens if WG hadn't started the ball rolling.

Meanwhile, we wonder who will be the voice of the FSLC. Will it be Publix, Disney, Wal-Mart or no one? Certainly it is disappointing to have the deafening silence from the group on these industry issues so far. How can the FSLC produce a document so strong without mounting a spirited defense?

More than the on-farm standards themselves - and there are very real technical concerns with those standards pointed out in the joint association letter - suppliers may feel put out about the FSLC "taking that tone" with them. For example, if I was writing the FSLC letter, I would have started it something like this:

Dear valued produce supplier,

We trust that produce safety and the well-being of consumers is your number one concern and we share that passion with you. As you know, we place great value on appropriate food safety standards at the farm level. We ask every supplier to detail their on farm food safety procedures they have in place. We conduct independent audits to check on compliance with stated standards.

In addition, now we are seeking your input on risk-based on farm food safety standards we have developed in conjunction with a group called the Food Safety Leadership Council.....

The Publix letter to suppliers can be seen here. Below are excerpts from the text of that letter. From the letter:

Please review these standards, together with the food safety procedures used by your firm, to ensure that you meet the standards required by Publix.

TK: As if that is as easy as a walk in the park....,Back to the letter:

It is our intention to utilize these FSLC On-Farm Produce Standards to evaluate vendor farms that provide produce to Publix. As a vendor, you agree by signing below to adhere to the standards.

TK: "And as a buyer, we agree to purchase only from FSLC approved farms". No, just kidding, those are my words. But if those words were in the letter, there may be no controversy here. Asking suppliers to conform to these "enhanced" standards without any reciprocal obligation by FSLC members may be galling to some suppliers. Again, back to the letter:

To assist us in maintaining the FSLC On-Farm Produce Standards, we request our supplier’s farms be inspected and audited for conformance to these standards by representatives of member companies of the FSLC, or designated inspection agencies that have been certified by the FSLC to conduct food safety audits. As a supplier to Publix, this standard will be verified through Primus and their good agricultural practice auditing program. This is not a new audit, but rather a standard to be verified by the auditing company.
By signing below, you acknowledge and agree to conduct and pay for an audit by an FSLC
certified auditor at least once per growing season. The results of any such inspection or audit will be shared among all members of the FSLC as a means to enhance consistent safety standards.

TK: By what authority do members of the FSLC share the results of any inspection or audit with all members of the FSLC? It is authority they appropriate themselves or does it exist in a formal organizational bond between members of the FSLC?

You further acknowledge that, regardless of the results of any audit, each FSLC member company will make its own independent purchasing decisions based on multiple factors which may be important to each such company in its sole discretion. Participation in the auditing process does not commit any FSLC member company to purchase products from your firm, and no such purchases may in fact occur.

TK: "Regardless of the results of any audit." Truly, "regardless"? What's the point of standards if they can be ignored for whatever reason? In fact, suppliers who are indeed committed to food safety will have on farm standards in place, "regardless" of the FSLC. The FSLC should be credited for appreciating the value of on farm food safety standards, but their blunt, if not heavy handed, approach has not been helpful. Perhaps the long term solution is a federal requirement for risk-based GAP standards at the farm level or common industry use of the GlobalGAP standard for suppliers.