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From: Food Quality & Safety magazine, December/January 2007

Guidance and Stricter Enforcement, NOW

by Steve Sayer

The present unraveling of the virulent E. coli O157:H7 outbreak-involving scallions and green onions at Taco Bell have at least 42 confirmed cases of E. coli O157:H7 illness with at least five hospitalized. Just prior to Taco Bell’s present snafu was the E. coli O157:H7 outbreak involving packaged spinach, which resulted with three deaths and 204 illnesses. Preceding those outbreaks there have been numerous food poisons caused by fresh produce, including a cornucopia of imported products that has also gone largely unnoticed by the public.

The continuum of farm-to-the-table food safety prevention needs to be addressed once again. The training of workers, putting into place good manufacturing practices, sanitation standards of operations, HACCP and specific microbiological testing that are daisy chained to hold and release programs will indelibly truncate substantially these ongoing outbreaks. Most importantly, governmental inspectors need to have the clout to cite and close up processors who do not follow science based preventive programs.

The culprits for these outbreaks are the same as they were in meat and poultry sectors with the remedies even tougher to solve. The main problem is the irresponsible growers and processors who should be held fully accountable for outbreaks as well as the warehouses where the products are processed and stored. The majority of growers and processors are busy watching their bottom lines rather than acting in a responsible manner concerning food safety prevention. Present local and state requirements concerning food safety of fresh produce are too lenient and are largely ignored by the produce industry as a whole while concurrently not being enforced by any local governmental inspectors, which includes the FDA.

These most recent outbreaks involving tainted produce may collectively prove to be the same type of defining moment that the beef industry experienced with the Jack in the Box outbreak in 1993.

The Jack in the Box outbreak involved E. coli O157:H7 tainted hamburger meat. In due course, 700 people became ill with four children dying. The federal government responded with what is known today, as the Mega Reg. E. coli O157:H7 was defined as an adulterant by the FSIS of the USDA as the meat and poultry industry experienced monumental and seemingly draconian regulatory changes in the guise of mandatory HACCP and SSOP Programs.

Risk prevention, detection and control measures must be put into place at every step of fresh produce production in order to minimize food safety risks. Present voluntary guidelines are not an effective public health response to address the food safety problems that keep appearing in fruits and vegetables. States must pass legislation for mandatory food safety programs similar to the USDA’s HACCP systems. HACCP systems coupled with the before mentioned test and hold programs have proven very effective in truncating the number of E. coli O157:H7 and other pathogen outbreaks linked to beef and poultry.

In addition, the following preventive measures would be a good starting point:

Water Supply: Produce growers should ensure and verify that the water supply used for irrigation and in processing plants is suitable for its intended use.

Manure: The application of manure on produce should be prohibited during the growing season. See 5 CFR Part 205.203(c) for manure application requirements under the National Organic Program.

Personal Hygiene and Training: Growers and processors should ensure that employees have close access to bathrooms and that hand washing facilities are visible to supervisors. Employees with direct and indirect access to the production areas should be trained in preventive controls that will help to eliminate or minimize contamination of produce.

Sanitation: Processors should establish mandatory sanitation standard operating procedures, including cleaning procedures for equipment, storage areas, air system and water storage areas.

Processing: The penultimate step to the consumer, processing and storage is where pro-active preventive measures should be in place and verified.

Transportation: Clean transportation and temperature control for fresh and processed produce is essential.

Safe Handling Labeling: Generic safe handling labeling/instructions should be mandatory on all packaged fruits and vegetables as well as signs depicting safe handling at the home that are posted at all supermarkets and other produce outlets.

Trace-back Accountability: Processors should mark packaging to ensure easy trace back when fruits and vegetables are implicated in an outbreak. Information gained from a trace back investigation can limit the impact of an outbreak of foodborne illness and help to identify and eliminate conditions that may have contributed to product contamination.

Another big factor is that the majority of farm workers are immigrants who have had very little if any training with regards to hygiene and food safety. Add in the high seasonal turnover rates that affects this segment of the food industry as well. Also in the formula is the exposure of the product that is derived from the soil compounded with pesticide spraying, (chemical hazards), and free roaming vectors in the guise of mammals and flying birds, which connotes to biological hazards involving E. coli O157:H7 and Salmonella to name a few.

Every microbiologist that I have talked to over the years have always emphasized to me that if you want to find pathogens forget about the meat and go to your local salad bar. How many E. coli incidences involving hamburgers may have been from the lettuce or tomatoes rather than the meat? Restaurants and retail outlets employ untrained workers who handle such products with zero training, knowledge or skills involving food safety.

This area of the food safety continuum is ripe for mishandling and cross-contamination.

The end user, the consumer, needs to be better educated and made aware of the dangers of fresh produce. Consumers certainly have a responsibility to handle these products in a responsible manner. It is not uncommon for cross-contamination to occur at home. In addition, there is a prevailing false assumption by consumers that the fresh produce that they buy has been properly cleaned. Unless cooking is involved, the consumer is presently vulnerable to pathogens in their produce. Again, pathogen outbreaks involving fresh produce will only continue until there is established enforceable state and federal laws that are verified by assigned governmental inspectors who have invested in them the authority to close violators of food safety regulations. All imports of produce must also abide to the same food safety regulations of domestic growers. The USDA considers E. coli O157:H7 as an adulterant in meat and poultry products with the attached label of, Zero Tolerance. The same should apply to fresh produce.

Steve Sayer is a 25-year- veteran of the beef industry and food safety for S and R Consulting (Aliso Viejo, Calif.). Reach him at



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