Regardless of regulation, actually employing best practices matters

A lot of folks in the food system are concerned about the potential for FDA’s Food Safety Modernization Act (FSMA), and associated rules, to negatively impact businesses. There’s been a bunch of rhetoric and uncertainty around the final rules and what will be needed to comply. The majority of the content of the proposed Produce and Preventive Controls Rules summarizes the industry’s best practices and lists the references behind decisions.tomato_dump_tank

Not much in there that’s a surprise for folks who have been paying attention.

The focus of FSMA is on identifying hazards, putting steps in place to manage them and actually doing it. The best businesses are already doing this.

There are some specifics like manure incorporation and what a qualified individual is (who is supposed to be responsible for written plans) that need to be worked out. But employing practices and putting systems in place based on the best available science goes a long way in the absence of a regulation.

Back in the day when we were working with produce farmers and packers in Ontario (that’s in Canada) that’s what we tried to do – to stay ahead of the market requirements and regulation.

It’s not a unique approach – the almond industry took a similar path, so did Florida tomato growers and leafy greens producers in California and Arizona to some extent.

According to Lancaster Online, Pennsylvania farmers, through ag educators might be focusing on the uncertainty.

Ag educator Jeff Stoltzfus said he has learned a lot about food safety in the past five years.

But when it comes to the U.S. Food and Drug Administration’s efforts to overhaul food safety regulations, he’s still trying to figure out the impact it will have on the growers he works with.

“What we don’t know is more than what we do know,” he told a group of growers gathered recently at Yoder’s Restaurant for New Holland Vegetable Day.

Keeping good records, he said, could be the most important thing for growers to protect themselves in case a problem arises.

“Records are going to be very important and policies will be even more important, especially if you’re taking stuff from other growers.”

I disagree – actually employing the correct risk-reduction practices based would top my list. The documentation is nice and shows a regulator or a buyer that you know what you’re talking about – but doing it is more important.

Food safety culture and leafy green hacks

Ever since the E. coli O157:H7 outbreak linked to bagged spinach from California in 2006 killed four and sickened 200, the leafy green folks have begged for government inspection and flogged their apparent transparency.

Anyone who brags about having government inspection has nothing to brag lettuce_skull__e_coli__O145_1_story(1)about; see XL Foods in Canada from yesterday.

And why it took 29 outbreaks before something was publicly done to allegedly improve food safety conditions remains one of those unanswered mysteries.

But for their seven years of food safety investment – which has succeeded only in lowering the Sponge Bob cone of silence over any outbreak involving California leafy greens – the best these PR flunkies can do is respond to a week-old article about food safety culture by CNN’s Dr. Gupta with a link to their own website which shows … nothing.

The phrase food safety culture has certainly jumped the shark and is bandied about by people who have no idea. I’m fairly sure Chris Griffiths came up with the phrase in the early 2000s, I used it publicly at IAFP in Calgary in 2006, based on the cultural influence of my French professor wife, and Wal-Mart Frank wrote a book about it in 2009.

Now every hack uses it.

The leafy green folks claim the LGMA website “provides access to the food safety practices, the audit checklist and annual reports which provide inspection and citation data.”

No it doesn’t.

Not anything meaningful.

And these folks are now telling Washington that food safety programs should spongebob_oil_colbert_may3_10(3)(1)(1)(1)be based on what they’ve done.

Bullshit.

If the leafy Green Marketing Folks want to be truly transparent, they will make actual inspection data public for mere mortals to review, they will market microbial food safety at retail, and stop stonewalling every time there is an outbreak linked to leafy greens.

Like the E. coli O145 outbreak that sickened 30 people in New Brunswick (that’s in Canada) in 2012.

Or the E. coli O145 linked to Romaine lettuce that sickened some 50 people in Michigan and other states in 2010.

That lettuce was grown in Arizona, but they have also adopted the LGMA model.

And were silent during the outbreak.

A table of leafy green related outbreaks is available at http://bites.ksu.edu/leafy-greens-related-outbreaks.

Multistate outbreak of Escherichia coli O145 infections associated with Romaine lettuce consumption, 2010

03.jun.13

Journal of Food Protection, Number 6, June 2013, pp. 928-1108 , pp. 939-944(6)

Taylor, E.V.; Nguyen, T.A.; Machesky, K.D.; Koch, E.; Sotir, M.J.; Bohm, S.R.; Folster, J.P.; Bokanyi, R.; Kupper, A.; Bidol, S.A.; Emanuel, A.; Arends, K.D.; Johnson, S.A.; Dunn, J.; Stroika, S.; Patel, M.K.; Williams, I.

Non-O157 Shiga toxin-producing Escherichia coli (STEC) can cause severe illness, including hemolytic uremic syndrome (HUS). STEC O145 is the sixth most commonly reported non-O157 STEC in the United States, although outbreaks have been infrequent. In April and May 2010, we investigated a multistate outbreak of STEC O145 infection. Confirmed cases were STEC O145 infections with isolate pulsed-field gel electrophoresis patterns
indistinguishable from those of the outbreak strain. Probable cases were STEC O145 infections or HUS in persons who were epidemiologically linked. Case-control studies were conducted in Michigan and Ohio; food exposures were analyzed at the restaurant, menu, and ingredient level. Environmental inspections were conducted in implicated food establishments, and food samples were collected and tested. To characterize clinical findings associated with infections, we conducted a chart review for case patients who sought medical care. We identified 27 confirmed and 4 probable cases from five states. Of these, 14 (45%) were hospitalized, 3 (10%) developed HUS, and

none died. Among two case-control studies conducted, illness was significantly associated with consumption of shredded romaine lettuce in Michigan (odds ratio [OR] = undefined; 95% confidence interval [CI] = 1.6 to undefined) and Ohio (OR = 10.9; 95% CI = 3.1 to 40.5). Samples from an unopened bag of shredded romaine lettuce yielded the predominant outbreak strain. Of 15 case patients included in the chart review, 14 (93%) had diarrhea and abdominal cramps and 11 (73%) developed bloody diarrhea. This report documents the first foodborne outbreak of STEC O145 infections in the United States. Current surveillance efforts focus primarily on E. coli O157 infections; however, non-O157 STEC can cause similar disease and outbreaks, and efforts should be made to identify both O157 and non-O157 STEC infections. Providers should test all patients with bloody diarrhea for both non-O157 and O157 STEC.

foodsafetyinfosheet-5-6-10

Lettuce sickens, hacks hack; ‘leafy green marketing agreements set a bar, but it’s still too low’

Last week, Western Growers released food safety guidelines for the production, harvest and processing of fresh culinary herbs.

According to The Packer, in April 2011, the Food and Drug Administration urged the industry to take action to improve the safety of fresh cilantro. In response, Western Growers lettucestarted an initiative to develop commodity-specific guidelines for all fresh herbs as opposed to cilantro only.

Good.

But in the wake of the U.S. Centers for Disease Control study fingering produce as the biggest source of foodborne illness amongst known outbreaks, several groups decided this was an ideal moment to lecture consumers rather than explain the food safety challenges of fresh.

And none of them mentioned cantaloupe.

Bad.

ConAgra Foods, purveyors of peanut butter and pot pies that have poisoned hundreds of Americans, teamed with the Academy of Nutrition and Dietetics to tell Americans, rather than avoid certain foods, practice safe food handling at home instead.

My Food Safety Network apparently lives on at the University of Guelph, dispensing advice I never would have provided, because there is little evidence consumers can do much when it comes to fresh produce.

And then there’s the blandness of FightBac, which used the study to remind people, “Any day is a good day to share a reminder about the importance of checking food safety steps at home!”

I’m not even sure that’s a sentence.

Much better and more realistic is the effort by Matt McClure of the Calgary Herald, who wrote the faraway fields of California were the source last year of lettuce tainted with a potentially-fatal bacteria that sickened scores of Canadians in at least three outbreaks.

Media attention has focused on a recent surge of 30 illnesses in the eastern half of the country linked to E. coli-tainted iceberg lettuce distributed to fast-food restaurants, and another outbreak last spring
lettuce.tomato.skullinvolving 23 patients in New Brunswick and Quebec who ate bagged romaine lettuce that was laden with the bacteria.

But federal documents — not made public until now — also show a Calgary senior was one of at least three patients who fell sick in a separate outbreak last summer that was also linked to tainted lettuce.

The 84-year-old woman — whom the Herald has agreed not to identify — died last month after being in and out of hospital for months following a severe infection from a strain of E.coli O157: H7 that was a genetic match to the bacteria found in a package of Tanimura and Antle brand lettuce.

“You assume the companies providing a product have all the controls in place to make sure it’s safe,” the woman’s daughter said.

“For our family, that assumption proved deadly.”

The leafy greens marketing types remain under the Sponge Bob cone of silence.

Mansour Samadpour, a microbiologist and lab executive based in Washington, said illness statistics show that programs like California’s Leafy Green Marketing Agreement are failing to make salads safer.

More than 1,200 people around North America have fallen sick after eating the product in the half decade since the program was introduced, twice the number who became ill in the previous five-year period.

“The size and number of lettuce outbreaks in Canada during the last year suggest a serious situation, one that’s arguably worse than the recall of tainted beef from XL Foods,” Samadpour said.

“The leafy green marketing agreements set a bar, but it’s still too low.”

While some retailers like Costco require testing of their suppliers, Samadpour said some in the produce industry balk at the additional cost of about four cents a bag.

“The industry says we triple wash with chlorine but we know that’s not effective in killing bacteria if they are present in large numbers,” Michael Doyle said.

“I think we need to require a reliable regimen of testing of these bagged products, but the problem is it costs money.”

He said one large manufacturer had confessed to him recently it was cheaper to recall product found to be tainted than to have advanced food safety interventions at their processing plants.

Tanimura and Antle did not respond to a request for an interview about its food safety program and how its tainted shipment of lettuce to Canada last summer was only detected when a CFIA official took a random swab at an import facility in Winnipeg.

Leafy greens cone of slience.

A table of leafy green outbreaks is available at http://bites.ksu.edu/leafy-greens-related-outbreaks.

The abstract of the CDC report is below:

Each year, >9 million foodborne illnesses are estimated to be caused by major pathogens acquired in the United States. Preventing these illnesses is challenging because resources are limited and linking individual illnesses to a particular food is rarely possible except during an outbreak. We developed a method of attributing illnesses to food commodities that uses data from outbreaks associated with both simple and complex foods. Using data from outbreak-associated illnesses for 1998–2008, we estimated annual US foodborne illnesses, hospitalizations, and deaths attributable to each of 17 food commodities. We attributed 46% of illnesses to produce and found that more deaths were attributed to poultry than to any other commodity. To the extent that these estimates reflect the commodities causing all foodborne illness, they indicate that efforts are particularly needed to prevent contamination of produce and poultry. Methods to incorporate data from other sources are needed to improve attribution estimates for some commodities and agents.

http://wwwnc.cdc.gov/eid/article/19/3/11-1866_article.htm

Produce primary source of US foodborne illness

The folks who grow lettuce and spinach in California would make a great comedy act: if only so many people didn’t get severely sick.

The U.S. Centers for Disease Control has confirmed what some of us have been saying for 15 years: fresh produce is the biggest source of lettuce.tomato.skullfoodborne illness in the U.S.

This isn’t surprising: produce is fresh, not cooked, so there is ample opportunity for cross-contamination and pathogen transfer, such as norovirus.

This is nothing new, and nothing to be scared of.

It means that food safety starts on the farm, and goes all the way through to the fork.

I don’t know what it is about moral outrage in the U.S. but it was rampant when we were there for the past two months and it seems like every group out there feels a higher duty to dictate to the masses.

So it was predictable when the California Leafy Greens Marketing Agreement  said with a straight face today, that produce food safety is a “shared responsibility” and that “we believe this program is the best model for producing safe food because it establishes a culture of food safety on the farm.”

No evidence was offered to substantiate such a claim; but they got all the groovy words in their PR.

For the number of outbreaks, for the number of severely ill and dead, for the decade of inaction, you don’t get to lecture Americans about how it’s a shared responsibility.

Take care of your own stuff, admit when California leafy greens are involved in outbreaks instead of stalling and obstructing, and if you’re program is so great, publish all test results and market food safety at retail.

Otherwise, save the morality lectures and go back to growing crops, making money, and try not to make people barf.

A table of leafy green outbreaks is available at http://bites.ksu.edu/leafy-greens-related-outbreaks.

The abstract of the CDC report is below:

Each year, >9 million foodborne illnesses are estimated to be caused by major pathogens acquired in the United States. Preventing these illnesses is challenging because resources are limited and linking TheMasterOscarPageindividual illnesses to a particular food is rarely possible except during an outbreak. We developed a method of attributing illnesses to food commodities that uses data from outbreaks associated with both simple and complex foods. Using data from outbreak-associated illnesses for 1998–2008, we estimated annual US foodborne illnesses, hospitalizations, and deaths attributable to each of 17 food commodities. We attributed 46% of illnesses to produce and found that more deaths were attributed to poultry than to any other commodity. To the extent that these estimates reflect the commodities causing all foodborne illness, they indicate that efforts are particularly needed to prevent contamination of produce and poultry. Methods to incorporate data from other sources are needed to improve attribution estimates for some commodities and agents.

26 sick; leafy green cone of silence descends again

On Jan. 4, 2013, the California leafy greens folks were quickly out with a press release praising the passage of proposed rules regarding produce food safety under the Food Safety Modernization Act (FSMA) spongebob.oil.colbert.may3.10and how California growers were way ahead of the government.

Yesterday, the Public Health Agency of Canada said the most probable cause of 26 confirmed E. coli O157:H7 illnesses in the Maritimes and Ontario was shredded lettuce grown in California and distributed by FreshPoint Inc. primarily to some KFC and KFC-Taco Bell restaurants.

The silence from the California Greens Marketing Agreement has been deafening.

A table of leafy green outbreaks is available at http://bites.ksu.edu/leafy-greens-related-outbreaks.

California lettuce linked to E. coli outbreaks in NB, Quebec and Calif.

When California lettuce growers were courting Canadian hacks on a paid junket, they probably didn’t talk too much about the possible links between several E. coli O157:H7 outbreaks and California Romaine lettuce that were being uncovered at the same time.

Or the sick people.

The Sponge-Bob-Colbert leafy greens cone of silence was once again deployed.

Phyllis Entis of eFoodAlert confirms tonight that Romaine lettuce grown on a
California farm is the probable source of E. coli O157:H7 illnesses that were reported in April and May in California,
New Brunswick and Quebec.

The binational outbreak sickened at least 18 people in New Brunswick (Canada) and nine residents of California. At least one resident of Quebec also was infected with the same outbreak strain.

The New Brunswick outbreak victims ate at Jungle Jim’s, a restaurant in Miramichi, between April 23rd and April 26th, and had consumed romaine lettuce, either in a salad, as part of a wrap, or as a garnish on hamburger. Most of the nine California victims had eaten at a single (unnamed) restaurant in April 2012, according to information provided by Ronald Owens (Office of Public Affairs, California Department of Public Health). A case control study implicated lettuce as the source of the California outbreak. No information has been released on the Quebec cases(s).

California was notified in May by the US Centers for Disease Control and Prevention (CDC) that CDC had learned of an outbreak in Canada, caused by the same strain of E. coli O157:H7 as the California illnesses. Traceback investigations carried out by Canada and California both led to a single California farm that supplied lettuce to the California restaurant and to Jungle Jim’s in New Brunswick. Lettuce from the implicated fields was also supplied to Quebec.

At the same time, Marie-Andree Guimont wrote a lovely puff piece in divine.ca after her educational – and funded – trip to Monterey, California, to see how leafy greens are grown.

“Awareness of food safety has allowed us to change the culture among producers, said Scott Horsfall, CEO of California LGMA, with a straight face. “They are proud of their training, and it therefore becomes their badge of honor.”

The Leafy Greens Marketing Agreement would be a lot more credible if they’d come clean about outbreaks and data, instead of ole’ timey public relations crap, buying off would-be journalists, one at a time. And governments. Canadian regulators will only accept leafy greens entering the country that are LGMA-certified. No idea why.

Health types may want to figure out a policy for going public about outbreaks. Finding out later just further erodes any remaining credibility.

A table of leafy green related outbreaks is available at http://bites.ksu.edu/leafy-greens-related-outbreaks.

30 sickened: Miramichi E. coli outbreak linked to Romaine lettuce

The Sponge-Bob-Colbert leafy greens cone of silence has been partially peeled back after investigators in New Brunswick (that’s in Canada) determined an outbreak of E. coli O157 in April was linked to Romaine lettuce.

CBC News reports the Department of Health released results of a case control study on Friday that examined 55 people, including 18 individuals who were sick and 37 people who were not sick.

Dr. Eilish Cleary, the chief medical officer of health, said all of those in the study who were sick with E. coli appear to have consumed romaine lettuce.

"The lettuce was used in salads, as an ingredient in wraps and hamburgers and as a garnish. These results indicate a strong likelihood that contaminated lettuce was served at the restaurant,” Cleary said in a statement.

The Public Health Agency of Canada helped the province’s health department on the control study. The experts focused on the food items eaten by those who ate at Jungle Jim’s in Miramichi between April 23 and 26, 2012.

The federal agency became aware that cases matching the E. coli strain involved in the Miramichi outbreak had also been identified in Quebec and California, according to the province’s statement.

Now that would be something to follow up on. So while the Leafy Greens Marketing Agreement folks were wining and dining Canadian journalists last month (not so much journalists, more like hacks) , I wonder how many asked about the Romaine-related outbreaks? There was also the Schnucks salad bar outbreak that sickened 58 people in the U.S. Midwest last fall.

A table of leafy green related outbreaks is available at http://bites.ksu.edu/leafy-greens-related-outbreaks.

Canadian PR program seeks to educate consumers on US greens

When all else fails, resort to posture: the rock-star pose with Townsend-inspired exaggerated guitar, sexual imagery in TV sitcoms, public relations rather than public information.

I can’t wait to be plied by the PR types at Argyle Communications about the safety of California leafy greens.

The California Leafy Greens Marketing Association, rather than address a rapidly accumulating number of outbreaks associated with their lettuce and spinach and leafy product that have never been made public – has chosen to boost consumption by educating Canadians on the safety of U.S. greens; with that focus, they’ve already lost.

Data, transparency and creativity are what count. Mad Men is an entertaining television show set in the 1960s and they figured out these basics. So did Aristotle about 2,350 years ago, when he wrote any successful rhetoric includes an appeal to logic, an appeal to authority and an appeal to emotion.

“With funding from a California Specialty Crop Block Grant, the LGMA is launching a comprehensive public relations program designed to directly reach Canadian consumers through magazines, newspapers, television and the Internet to make sure they know all California leafy greens sold in Canadian must be certified by the LGMA.

"Consumer media outlets are the primary target of the campaign which seeks to raise awareness among Canadian consumers about the safety of leafy greens from California. Shortly after the LGMA was established, the Canadian government issued a mandate that all California leafy greens imported into the country must be certified by the LGMA.

"To make Canadian consumers aware of the measures being taken to ensure the safety of California leafy greens, Argyle Communications, a Canadian-based public relations firm has been retained to conduct a year-long communications campaign. The planned program includes two separate outreach efforts targeted at food and health reporters from Canadian media outlets and blog sites. The first of these will be mailed in the next few weeks and includes a presentation packet with basic facts and information about the LGMA along with featured recipes developed specifically for this effort. For a select target list, the packets will be hand delivered and will include product in the form of one of the featured recipes. For the first delivery, the featured recipe is Kale Chips. Later in the summer this same type of activity will be repeated with a different theme. A food safety spokesperson will also be pitched to Canadian television and radio outlets in an additional effort to communicate with consumers about the safety of California leafy greens.

"In early June, a tour of California leafy greens operations is scheduled to give Canadian media representatives a first-hand look at the comprehensive food safety program for leafy greens from California. In addition, the LGMA micro-site at www.safeleafygreens.com is being revised to serve a consumer audience with recipes and important handling information being added."

My milkshake is better than yours; will government make spinach and lettuce safer?

The folks that produce fresh spinach and lettuce are channeling their inner Milkshake, dialing back to late 2003 when weblogs or blogs began to emerge in force, and launched their own blog – last week.

The awkwardly named Leafy Greens Marketing Agreement – LGMA for funksters – is starting a “new dialogue on leafy greens food safety” with at least two blog posts a month.

Lowered expectations is good, especially when LGMA is eight years late to the blogshpere and about 10 years late to the food-safety-in-produce thing. The worst is to start a web page or a blog and then not follow through. Listeria-stricken Maple Leaf Foods hasn’t posted anything new on its Journey-inspired Our Journey to Food Safety Leadership, since Nov. 2010. Maybe they are on other journeys, looking for that small town girl.

LGMA chairman Jamie Strachan wrote in the inaugural blog on April 14, 2011, that it’s been four years since this “first-of-its-kind program began. It hasn’t been easy, but the very fact that the LGMA exists today is proof that the challenges of implementing a comprehensive food safety system for an entire commodity can be overcome.”

LGMA didn’t invent it. Lots of groups have marketing orders. We did the whole food safety thing with the Ontario Greenhouse Vegetable Marketing Board – as it was called back then – in 2000.

Chairman Strachan also writes, “I’m often asked, ‘How do you know the LGMA is working?’

“The answer to that question is simple — the LGMA is working to establish a culture of food safety on leafy greens farms. Most farmers will tell you that leafy greens were safe before the LGMA came along, but what is changed today is the high level of attention food safety on the farm now receives. Everyone involved in operations, from the farmer to the harvesters, know and understand that food safety considerations are ALWAYS top of mind.”

That’s not verification. And people who write in all caps are YELLING to get attention, maybe because their writing sucks.

They’ve got the rhetoric; where’s the reality?

There have been many reinterpretations of history regarding fresh produce and microbial food safety. We have argued the tipping point was 1996, involving both the Odwalla E. coli O157:H7 outbreak in unpasteurized juice, coupled with the cyclospora outbreak which was initially and erroneously linked to California strawberries (it was Guatemalan raspberries). This led to the first attempts at comprehensive on-farm food safety programs for fresh produce because, these bugs ain’t going to be washed off; they have to be prevented, as much as possible, from getting on or in fresh produce on the farm.

For the growers of leafy greens, things apparently didn’t tip until the 2006 E. coli O157:H7 outbreak in bagged spinach from California that sickened 200 and killed four, despite 29 previous outbreaks and years of warning from the U.S. Food and Drug Administration.

A table of leafy green foodborne illness outbreaks is available at:
http://bites.ksu.edu/Outbreaks%20related%20to%20leafy%20greens%201993-2010

Yesterday, the U.S. Department of Agriculture decided proposed to take LGMA national.

“The U.S. Department of Agriculture’s (USDA) Agricultural Marketing Service (AMS) is requesting comment on the creation of a voluntary National Leafy Green Marketing Agreement (NLGMA) that would assist all segments of the leafy green industry in meeting commercial food quality and safety requirements.”

Full justification for the proposed rule is available at http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5077207

When we were hanging out with greenhouse tomato growers, the joke we got familiar with was:

“What’s the worst thing you can say to a farmer?”

“Hi, I’m from the government, I’m here to help.”

If the government needs to be involved, things have really gone bad.

Should a federal food safety program be based on LGMA, a group that was dragged to the food safety party and is always behind?

 

Stop waiting for government. And stop channeling Kelis. Make test results public, market food safety at retail so consumers can choose, and if people get sick from your product, be the first to tell the public.