Food Safety and Environmental Health Blog : Disease Prevention, Public Health, Sanitation Information & Analysis : Environ Health Associates

As an environmental health professional, I have enjoyed a successful career in hands-on food protection from farm to table. My success in this wide array of conditions has come through the effective application of environmental health principles.

Nowhere in food safety today is environmental health needed more than down on the farm, where the environmental health risks factors are becoming better understood. As a sanitarian and independent food safety auditor, there are some key areas of environmental health in my work on the farm; water quality, animal control, and worker hygienic standards. Private food safety auditors have started calling these the "Three W’s" for Workers-Water-and Wildlife.

 Typical tomato wash water used to rinse picking buckets 

Downstream effects of the environmental health problems originating on produce farms are huge. The  problems reverberate through the the rest of the controls we have in place. Because the risks are not well controlled, we need more and more robust surveillance, traceability and product recall ability, testing; and of course, redress for victims in court. These unfortunate individuals and their families hold the bag at the end of the system without much control.  The cost burden on the food industry due to outbreaks is remarkable. The Listeria problem in cantaloupe may cost industry $150 million in legal fees, alone. All of this has happened because we have not effectively established in the produce industry a relatively few environmental health protections that should have been there years ago.

Thinking optimistically, we can fix most of the produce contamination problem during growing and harvesting of produce by effective controls over workers; water supplies and usage in all its forms; and wildlife. We can ease the pressure on the supply chain, and minimize the downstream effects on consumers and society at large.

Agriculture has been side by side with animal husbandry and wild animal populations forever, so we cannot expect to remove the zoonotic reservoirs for pathogens completely in farm environments. Therefore, there will always be some risk in fresh produce; but the residual risks passed on in the supply chain will be better managed during packing, processing and handling downstream, if the microbial burden is low.

Vaccination maybe an option to protect against E coli infection in cattle, since we have one with efficacy; but granted, this protection has had poor discussion and vaccines have not been applied. If we had an effective vaccine and farmers would use it, one would start there. Ideally, we would reduce the incidence of pathogenic E coli in cattle (the reservoir) through vaccination, and then move on to exclude the wild animal populations and clean up water sources.

It is likely that adequate fences and other animal barriers, adequate setbacks (still don’t know what this means in every case), water treatment (when needed), strict adherence to personal hygiene, self-inspection and maintenance will solve most of the E. coli and Salmonella problem in growing areas.

We can do this, but a coordinated national efforts is not so simple, and everything has a cost. Somebody must pay, then somebody must make sure it gets done, and financial resources are not necessarily there.

The farms I see would need about $10,000 to $50,000 (could be higher for some) of initial investment, and probably at least 10% of that for yearly maintenance, to implement effective wild animal exclusion measures. The cost would be borne by the farmer in addition to the many other costs of Good Agricultural Practices(GAP), like personal hygiene, training, use of antimicrobials and water treatment, liquid and solid waste controls, that he currently pays for.

Not all farms need the same intensity of controls; I see irrigation water coming out of deep wells as clean as tap water (Total Coliform < 1 cfu), and often the crops see no foliar applications. I see other situations where the foliar application of water is sourced from the surface, and must be treated.

Animal intrusion risks vary widely also; there are some farms in the Southeast where I see only isolated dogs, cats, or bird exposures with an occasional rodent or ground animal.

On some other occasions, I see systematic deer, pig and other wildlife intrusion and extensive droppings. Sometimes we find feces to the extent where harvesting must be halted, and/or production stopped.

In the western US, I see the cattle operations butted right up to produce production; the Salinas Valley in California has much different space requirements, resource needs, and land use issues then Immokalee in the Florida Everglades. As an aside, during our private investigation of the 2006 spinach E coli matter, I sampled one cow patty from a Salinas area hillside pasture and recovered an E. coli: O157:H7 isolate (but not the outbreak strain). One lucky random sample? Or is this bug seriously rampant in this area?

In addition, there are areas with water diversion and flooding problems (due to drought conditions we have not seen much of this factor in outbreaks) and several other environmental health risks we can point out across the board in agriculture.

This is all manageable, and makes it more manageable for us to put into place all of the other safeguards we now need.

On the farm we have “in your face" environmental health problems similar to those that are already addressed by the existing environmental health profession.

We need environmental health professionals to fix environmental health down on the farm, and they can do it, its as simple as that.

Nothing affects everyday people every day more than the food they eat. So stories about food generate lots of interest. Of course, we all want our meals to be safe, and the industry takes precautions to try to ensure that happens, but in produce safety, there are a lot of misunderstandings and wrong things being said today that have the potential to do more harm than good.

The produce industry has accepted that it has a hazardous group of products, which include melons, berries, leafy green vegetables, cucumbers, papaya and tomatoes, among others. Industry has attempted hazard control since the early 1990’s when produce-borne outbreaks became widespread. At that time, there were few if any requirements for microbial food safety down on the farm. Such efforts now include testing of irrigation water, safe use of fertilizers, exclusion of farm animals, personal hygiene, and the sanitation of the on-farm operations (such as the packing shed at Jensen Farms), but we are not moving fast enough. Keep in mind the demand for fresh fruits and vegetables has increased exponentially in the last 20 years.

We are still waiting after 20 years, for a coordinated effort by government, industry and academia to right the wrongs of the past.  What we see in this long drawn out scenario is the basic collapse of our public health infrastructure and our inability to address the shear magnitude on farm environmental health. Years of neglect and political interference have marginalized FDA and public health programs across the board, and it is anybody’s guess what if anything can be done now to improve produce safety. We should probably expect from FDA no more than expanded produce guidance documents and the investigation of third party failures, at least for the foreseeable future.

Guidance is OK (although not completely thought out, or so it appears) and we have a good supply of reports, but FDA admits that application of its guidance documents is not universal; in fact FDA does not know to what extent the industry has adopted these self-stated voluntary programs, or their effectiveness.

Within such a vacuum, industry to protect its vital interests has developed numerous food safety schemes and programs with food safety auditing being one important tool in the tool box. An on-farm food safety tool kit contains science- based standards, lab support, traceability systems and educational programs. All of these programs have spun off businesses that have evolved in the vacuum of regulation.

To expect business interests not to affect a private food safety system is totally naive. To expect auditors to become experts in all the different schemes and guidance may be reasonable from the point of view of FDA, but the reality is that the auditor workforce suffers from the same sorts of deficiencies as many government agencies in terms of knowledge and experience. It is important to point out that new skills are needed in a new discipline such as environmental health down on the farm. That not all risks and not all controls are known on the farm, is a given.  To expect auditing companies to mandate and enforce a plethora of rules and demand strict adherence when even our government cannot do this and the science is not strong is ludicrous.

Criticism does come with the territory. Auditors like their close cousin’s “regulators”, are attacked whenever food safety problems come to light in their jurisdiction or sphere of influence. We must grant however, that overlooked gross deficiencies should not have occurred in any proactive and effective system. There should not have been dozens of dead rats on the floor of PCA.  Jensen Farms should not have had water dripping from overhead areas on to products.  Con Agra should not have operated a peanut butter plant with a wall down and raccoon tracks on the floor of production areas. These obvious problems should have been caught by the auditor or inspector, if not by the firms themselves. These firms should have been proactive, instead some forms just wait around for an auditor to correct deficiencies. This is actually another story that needs be told, and probably a more important one for the advancement of the cause then the constant bashing of auditors and such firms.

In the case of the auditor, what follows negative findings? The auditor writes a report and it gets submitted to a buyer, buying decisions are made, and the auditor moves on. There is no mechanism to enforce anything, or re-inspection, which only exists for his inspector cousins.

Overlooked sanitation issues are troubling to the auditing community because most auditors do catch such obvious defects. Third party assessments are mostly effective; but how effective, none can tell. As in any prevention program, there are no data to show how many outbreaks would have occurred in the absence of such audits. Nevertheless, we have had 2 terrible audits linked to 2 massive outbreaks. This does point to problems in the system, and more discussion will assuredly produce more questions. In essence, what we are seeing is the marginalizing of public health protection by the business model; the model the industry has had to rely on since there are few other public health protections available in farming today.

The media feeding frenzy over this topic will continue until the bare bleached bones of these hapless auditors are exposed for all to see. But just remember that these systems were developed by the buyers to assure a continuing supply of safe fresh fruits and vegetables, not as a defacto regulation of the industry, and auditors are not regulators.

And to my media friends, please also check your facts, stop repeating mistakes like the “Primus auditor should have required the melon wash water to be chlorinated” when the 2009 FDA melon guidance does not require it.

In your frenzy, remember that third party standards are all the public has to protect them, right now.

So OK USA Today, fire away.

http://www.usatoday.com/news/opinion/story/2012-01-24/produce-marketing-association/52780194/1?csp=34news&utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+News-Opinion+%28News+-+Opinion%29

Looks like we will not see then end of the Jensen/Frontera/ Primus Auditor issue for some time. While there is plenty of room for criticism of Jensen, Fonterra, and Primus there are also problems with FDA, and this tragic incident has become a hot potato being passed to and fro by congress.

http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/ProduceandPlanProducts/ucm174171.htm

I keep reading FDA's take on this as if they had an actual law in place that people had to follow, and actual inspectors in the field for enforcement, and an educational arm. FDA still has no muscle on the farm, just a law now on the books that is lagging behind. Until they get thier ACT together, it’s not fair to blame the industry for not getting it together when they themselves cannot.

I am not defending anyone, but if I were, I could look at the 2009 FDA Guidance for melon and wonder where it says that Jensen should have used a chlorinated hydro cooler to cool melons. FDA says it’s safe to use flowing water of satisfactory quality without an antimicrobial to cool melons. Nowhere does it say melons had to be pre-cooled, anywhere. In fact according to FDA, melons can be field packed and placed directly into a cooler. A hydro cooler (this is a refrigerated, circulated water bath, tank or drench that may also contain ice) is recommended, but the flowing water method is allowable, according to the guidance. Any auditor who would read the Melon Guidance of 2009 would have said FDA has no requirement to use an antimicrobial IN SINGLE PASS WASH WATER.

And here we have more from Leavitt and Partners, a DC consulting firm, taking shots at the auditing company from left field and just repeating the double talk while not really understanding what they are saying. But of course, this is business.

This whole discussion is beginning to smell and is turning into a witch hunt and a diversion for the fact that we have next to no currently enforced laws in produce safety. As result, we see systematic failure of the food safety protection they would afford us. And so industry has taken on itself this huge challenge of agricultural food safety and failures are occurring, and will continue. Third party audits are not designed for public health protection, and even if strengthened they will not their place.

And when and how does FDA propose to notify the industry about the minimum requirements under the FSMA? Most folks I speak to don't have a clue what to do.

This sad scene points not just to failure of audits, but reveals food safety at the primary production level of our food supply has been neglected. It’s going to take decades to educate farmers and to fix the problems spread over millions of acres of land and thousands of farming operations. The failures include FDA not being able to enforce rules or educate the industry, and if I sound like I am repeating myself, I am.

The third party food safety audit system was never intended to stand in the place of regulation. If we as auditors were supposed to enforce FDA Guidance, and now Laws, just how is that supposed to work? There is no mechanism for that.

Where are the thousands of competent people to do this job, the army who understand agriculture and how to do a produce risk assessment, commodity by commodity? How are small producers like the Jensen brothers supposed to cope with the detailed scientific risk assessment he and now thousands like him must by law perform?

This situation has got to be solved by industry and FDA working together, and proper funding and research.

http://leavittpartnersblog.com/2012/01/investigation-of-cantaloupe-listeria-outbreak-has-congress-asking-serious-questions-around-third-party-audits/?