While there is quite a bit of controversy concerning what happened at Jenson Farms, there is no denying that the fresh produce industry has been forced to reevaluate its food safety efforts.
The Buyer Driven Food Safety Model
Third party food safety audits are still what they have always been, an industry led method to determine conformance with a set of voluntary standards. As third party auditors, we have no control over the operations we audit. The only real control lies with the customers of the operation. The customer can choose not to purchase from a supplier, work with the supplier to correct problems uncovered in the audit processes, or ignore the audit findings. Increasingly however, customers are becoming more selective and looking much more closely at audits before making buying decisions. Unfortunately, the dictates of supply and demand still apply, and if a customer needs product and the price is right, buyers will purchase from suppliers with questionable records, or even those without any oversight at all. In the end, audit findings are still just one of the criteria that a prospective customer uses to make a buying decision.
Traceability and Recall
Traceability is improving, with some firms investing considerable resources in advanced electronic record keeping and coding of unit packaging. Still, recent outbreaks show that traceability is a difficult matter. The recent outbreak of cyclosporiasis in leafy greens this year illustrates the difficulty with traceability. Even with over 600 cases of illness affecting numerous states, investigators did not conclusively link the outbreak cases to a supplier. The final report by CDC indicated that both cilantro and bagged salad items were involved, without pointing to a single source of the contamination of both products. Products might be coded when they are packaged, but processors do not always maintain the needed batch coding records to tie inputs to outputs, and there is plenty of comingling going on throughout the supply chain. While traceability systems such as PTI, Harvest Mark and ScoringAg are available, the industry has not come to a consensus as to what it wants, leaving suppliers with uncertainty as to what system to choose.
Packers and processors are using a variety of antimicrobial treatments such as ozone, chlorine dioxide, chlorine and peracetic acid; however, we lack clear scientific evidence for the sanitizing effect of these treatments on fresh produce. Treating the water used to wash produce is a wise idea, especially if the wash water is reused (recycled), and we can reliably determine the effectiveness of that type of treatment. The problem with sanitizing produce is that each product has its own world of microbial issues, such as surface area characteristics and vulnerability to microbial colonization, and each antimicrobial treatment process has its own set of variables, e.g., concentration, contact time, and coverage. Determining the precise methods needed to inactivate a wide range of microbes in such diverse products and processes remains elusive. Currently, the USDA does not recognize any microbial treatment for whole fruits and vegetables as capable of sanitizing and therefore no antimicrobial product has a registration for reduction of human pathogens on whole fruits and vegetables. Much more research is needed in this particular area of produce safety.
The Food Safety Knowledge Gap
The produce industry is moving forward with the education and training of its personnel, but currently there is no approved or recognized program of instruction in food safety in the produce industry. Unlike training programs at the restaurant level, very little has been done to identify the core curriculum needs of the produce industry. For example, operators of complicated antimicrobial addition systems are usually recruited from existing production staff having no training in chemistry or microbiology. Such operators often do not fully appreciate the complexities of sanitizing processes and concepts such as free chlorine, oxidation-reduction-potential (ORP), and pH. While microbial treatment of process water and surfaces are becoming standard operating procedures, the industry lacks the expertise to perform tests or interpret results. Findings often get filed without an evaluation by a knowledgeable person. The use of ATP as a verification tool is required by most third party standards (and FSMA), yet few firms have the skills needed to effectively establish such programs and/or benefit from this type of monitoring.
While a HACCP program is often required (by buyers) the understanding of the concept by the produce industry is marginal. Without a grasp of epidemiology, microbiology and science in general, this concept is nothing more than window dressing in many firms.
Equipment Design and Construction Standards
There is no formal registration process for equipment used in the produce industry. Unlike the dairy industry where processors have very successfully applied the 3-A standards, there is no set of criteria for the finish of surfaces, or even the types of equipment used to pack or process fruits and vegetables. We see everything from cast iron to stainless steel construction of various grades, with rubber, plastics and even cloth and wood used as food contact surfaces.
Control of Wastewater
There are several commodities that are not typically washed before packing, such as berries and watermelons, but many produce items are washed, generating a substantial amount of wastewater. The systems for collection and discharge of wastewater from washing- flumes dump tanks and spray bars are often poorly designed, resulting in water flooding production areas. Wherever there is water collecting, these is a substantial risk of microbial contamination; workers splash through wastewater pooling on floors, and forklifts splash such water onto packaging and products . Poorly designed and located floor drains and floors that are not properly sloped to drain are common problems throughout the industry.
Facility Construction and Design
Just as there are no recognized industry standards for equipment, there is no national industry standard for design of produce facilities. Facilities can be open sheds with no walls and bare concrete floors while other are enclosed production facilities with a variety of layouts and construction types. Facilities in the produce industry are often viewed as part of farming operations and resemble farm buildings (pole barns), as opposed to the processing facilities one might find in fisheries or meatpacking. Attempting to control contamination, (physical, chemical and microbiological) in such facilities can be frustrating to those tasked with sanitation.
Probably the best deterrent to an outbreak in high risk commodities is a robust microbial sampling program for products and surfaces. There is some controversy as what constitutes a high risk commodity, but those fresh produce commodities with an edible peel and those that are in a ready to eat form (no cooking required) might be targeted, along with those produce items with a history of causing outbreaks. It is reasonable that since outbreak investigations can often isolate the pathogen on incriminated produce that such contamination could be spotted ahead of time before such products cause harm. The problems remain as to what to sample, what analysis methods to use, what microbial indicator organism to use, or pathogen to look for, and how much and how often to sample; and then there are the problems of how to interpret the results, and when to initiate a recall. The produce industry is by and large poorly prepared to employ microbial testing to its advantage.
FDA rules under FSMA are still not clear. After years of waiting, the produce industry is still uncertain as to what the impact of the new requirements will be, and FDA itself appears to be groping for answers. It will be years before the FDA can effectively enforce its rules, and the industry must move forward on its own, now.
While the produce industry is frightened by what happened to the Jensen brothers, the industry remains perplexed as to what to do, and the reality is this same scenario could play itself out again at any number of firms. What is clear is that in spite of the progress that has been made in food safety, the fresh produce industry has a long way to go to prevent another Jensen Farms type of incident.