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.