The verification of supplier food safety has emerged as a critical component of a retail operation’s Food Safety Management System (FSMS), but we continue to see Subway stress supplier safety while poor management of its own operations results in outbreaks of foodborne illness.

See Bill Marler’s Food Safety News to learn how a Subway contributed to a community wide outbreak of norovirus gastroenteritis.

http://www.foodsafetynews.com/2012/07/sick-subway-employees-went-to-work-during-norovirus-outbreak/

In light of the costs borne by the supply chain to satisfy retail industries’ high standards for prevention, it is unfair for a firm as influential as Subway to have lax control over its own operations.  

It’s critical to have safe lettuce coming in the backdoor, but if an infected employee handles it, it negates all the costly prevention done upstream by suppliers. The revelation that this was allowed to happen creates animosity on the part of suppliers and undermines Subway’s own efforts at supplier control.

Subways’ food safety management system failed as the result of poor decision making; what we see here is the failure of food safety culture. Subway has an obligation to consumers who expect the company to be a supplier of safe wholesome food. Subway has an obligation to its suppliers to maintain the same vigilance over food safety they expect from them. By failing its obligations, Subway risks the reputation it has built, and the value of its brand.

As consumers, we should expect MUCH more of Subway. As food safety professionals, we should ask “what is the root cause of this failure” and “how best can Subway’s management solve the problem”.

I am for a more fair system when it comes to inspections and grading. The grading numbers may not mean much, and this is because inspections are snap shots of events and there are all sorts of bias and human elements. However, when the facility maintains its records of food safety efforts, its more like seeing a moving picture. When inspections or audits make an evaluation based on what they see, and what they determine to be required in the firm’s food safety program, now you have something that has the ability to be meaningful. Its the firm’s daily practices that will make or break a sanitation program. Lets start evaluating that. 

But wait, that means a food service operation has to have an internal food safety program to evaluate! 

Too bad restaurants don’t have to do have one, its not required, they "just follow the code". 

That mentality doesn’t work and all this controversy about grading being a poor measure is true; but it is just a subterfuge for the fact that the FS industry as a whole will not agree to a mandatory self-control program that would allow checks and balances. Fortunately, most of the rest of the supply chain has. 

Here is what the FRA has to say about grading in 2005,

http://www.wftv.com/news/news/no-state-issued-letter-grades-for-restaurant-inspe/nJwwH/

and thier stance has not changed, in aspite of the fact that reports from agencies with letter grading support risk reduction has occurred. 

If this is to catch on we have to overcome some of the problems that are rightly recognized. Its just we have not understood what food safety management is and applied it to Food Service and this means we have no real measurement we can rely on. 

The latest pushback from NYC. 

NEW YORK: City Council throws rotten tomatoes at restaurant grades
11.mar.12
New York Daily News
http://www.nydailynews.com/opinion/city-council-throws-rotten-tomatoes-restaurant-grades-article-1.1036545?localLinksEnabled=false
It is but a slight exaggeration to say that everyone who eats in a restaurant in New York City — which means essentially everyone who lives, works or visits — loves the A, B and C placards posted in eatery windows.
Those grades, based on Health Department inspections, have had powerful effects. They have improved restaurant sanitation, reduced food-borne illnesses like salmonella and boosted business at restaurants that have earned the top mark.
What’s not to like?
Ask the City Council and Speaker Christine Quinn.
The industry has fought letter grading from the moment the Bloomberg administration floated the idea. Restaurateurs have griped repeatedly that inspections are too tough, fines are too high and the marks are based on poorly chosen criteria.
Now, Quinn & Co. have produced a survey purporting to find that the program desperately needs reform. A questionnaire asked restaurateurs their opinions about the grading. Of the city’s 24,000 restaurants, 1,297 responded.
Based on the survey, Quinn is calling for a reevaluation of the violation system, an ombudsman to adjust inspection results before hearings are held and an “early warning system” to weed out supposed inconsistencies in inspections.
She needs to get specific and prove her proposals will not undermine the most important consumer protection in recent New York memory.

 

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 Reusable Harvesting Container Rinse 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.

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.

Fix the mess first with regulations and guidance, then maybe there is some justification that Jensen and the rest of us should have known better.

Passing the hot potato is only going to burn more consumers.

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

The noted microbiologist Mansour Samadpour has recently suggested to Bloomberg’s Stephanie Armour that (See Bill Marler’s blog) 

“You can make these audits useful by writing them on toilet paper. Then someone would at least use them,” said Mansour Samadpour, president of Lake Forest Park, Washington-based IEH Laboratories and Consulting Group, a food-safety consulting firm, in an interview. “They’re worthless. They give a false sense of security.”

 

http://www.marlerblog.com/legal-cases/the-best-quote-ever/?utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+MarlerBlog+(Marler+Blog

 

Are third party audits currently useless to buyers and to the supplier who pays for them?

 

I think we need to clarify how the buyers can best use these reports, and how to improve the reporting process rather than throwing stones at one another…no one is shatterproof.

 

Understand that assuring food safety in the fresh produce supply chain is very different in many ways from assuring the safety of the meat, poultry, dairy or other food industries, most of which are highly regulated.

 

Currently, there are some alternatives to the independent third party risk assessment on farms, but those solutions are a ways off. Some state regulators are focusing in on the agricultural sector, but today the regulation and enforcement of food safety standards is left to the industry.

 

The “food safety industry” is quite competitive and diverse; private labs compete for market share against auditing firms with labs, auditing firms compete with other auditing firms, standard setting and certification bodies compete, pest control services also compete with chemical suppliers who also own auditing firms.

 

Therefore, understanding what is being said by firms like IEH Laboratories and Consulting Group about its competitors requires some retrospection.

 

The testing of agricultural products for safety by labs today is not routine. However, as this trend grows we may eventually see a produce firm that "has passed a Lab test" involved in an outbreak just as we have seen raw meat facilities that have passed government inspection and laboratory analysis involved.

 

I would like to ask Mr. Mansour if he would be just as critical of labs for giving a "false sense of security" when the products they test cause outbreaks? Is USDA inspection worthless if inspected products cause outbreaks?

 

It is clear to me that third party audits are needed in the absence of any other outside controls of primary producers at this time. The produce industry, together with the food safety industry that supports it, should consider the following soft spots in this process: 

  • Audits are routinely announced, meaning that the time of the audit is known ahead of time by all parties. An auditing firm that conducts both announced and unannounced audits reports that the differences in the score between the two measures can be 10 percentage points or more. Risk based inspections do not necessarily require unannounced visits as the risk in a process can usually be determined from operations, but at least some announced audits are a good idea. 
  • Buyers currently are empowered by their customers to go outside the recognized certified sellers if product is needed. The pool of unregulated and unsupervised facilities is still large. It is not uncommon to have an audited, certified and even inspected produce operation, operating beside an unregulated unaudited firm. Inconsistencies like that cause animosity and dysfunction.  

·         The pressure on buyers, especially brokers and other middlemen to buy from anyone, results in placing some operations in a competitive disadvantage. There is no clear answer to this as some operations just simply ignore the requirements that others must follow and can still sell their products. 

  • The standards the third parties use are written by the buyers. These are also the entities that evaluate the findings, and make buying decisions supposedly based on conformance to their standard. Buyers cannot raise the bar so high as to eliminate a large share of the supply chain and thus develop those standards so as to be inclusive of the current levels of sanitation and safety in the industry- which can be less than perfect. I have not seen yet where a low score on an audit has caused an operation to go out of business. An outbreak will do this, but not a low or even failing score. In today’s market, if the supplier has needed product, the volume and the physical quality, he will be able to sell it to a customer somewhere with our without a passing grade, even with or without an audit of any type. 
  • Retailers and their own culture effect food safety audit systems in produce.

I was in a well-known market the other day and saw next to the open bin of cracked and otherwise damaged mixed tree nuts (with no traceability), bags of packed nuts, clean and unbroken with source codes. The bagged nuts were about 50% more expensive.

Rather than using audit reports for toilet paper, buyers should instead be using them to make decisions and all involved in the private assurance of produce food safety systems should read the writing on their own wall.

We are now seeing huge gaps in the food safety net.  We also see the effect of the serious pathogens like E coli that have become entrenched in our food animals, thus in our food supply, and in our environment. The failure of agriculture to control E. coli has contaminated the entire food supply, our water and soil.

These events will continue and escalate due to our inability to create a nationwide food safety system form farm to fork and the propensity of these pathogens to proliferate. Glaring deficiencies exist; most notably, flaws in basic sanitation and related practices found at the farm, in restaurants, and in the transportation sector are going without effective controls. These correctable conditions if left uncorrected allow for the persistence of deadly infectious agents in food.

While we  as an industry concentrate our prevention efforts in the supply chain, remember that not addressing the starting and ending points of this chain thwarts all other purposes.

A comprehensive approach to the problem must involve a strong response by FDA to both on farm and consumer safety.  Without adequate resources, FDA cannot do this job. Without industry support for proper funding the Food Safety Modernization Act will fail. This Act crafted by industry working alongside government addresses concerns in the food supply in the most comprehensive approach yet attempted,

A double standard is evident in the lack of industry support for FDA and FSMA. This is clearly seen in a letter to congress from the American Meat Institute and its signatories.

As long as powerful political interests put political power and influence over public health, food safety in this country will continue to deteriorate. The effect on industry has already been devastating for certain groups, especially for growers of tomatoes, spinach, peanuts; and now the entire melon industry is tainted with the problem of Listeria monocytogenes in cantaloupes.

The many millions of dollars defending lawsuits and untold millions lost in sales, as well as the loss of confidence of the American consumer, and the huge burden for those with resulting health care costs are compelling reasons for industry to support FDA.

Industry paying its fair share is something we should expect. Just "not wanting to pay" to ensure that there is a strong regulatory framework for food safety is not acceptable.

As the result of the release of the FDA environmental assessment at Jensen Farms, the roles of all food safety persons involved at Jensen Farms-Frontera have rightfully come under fire.  Once again the the nature of industry led food safety regulation itself (food safety auditing) is in question. 

That all involved maintain some degree of responsibility for this disaster is without question. When a disaster like this occurs, one must ask who is responsible, but also why did it occur and how can it be prevented in the future.

The produce industry is unregulated and has been since the founding of this country, and this is the primary problem. In the recent past, we have become painfully aware of the inadequacies of our industry led prevention efforts at the farm level. In defense of the effort, while much has been done, it has been a short time to change the nature of agriculture This is what we are doing by implementing food safety strategies in open air and on- farm environments. We must also change the culture; animals on farms, for example, have been a given for centuries.

Food safety auditors executing a buyer driven auditing model rely upon the certification body to develop and manage the standard that guides their work in the field. The standard is not a public health law and it is not developed like one. The auditor has no legal authority to demand records, embargo products, or close an operation, for example.

Enforcement, if you will, has been in the hands of the "buyers". They rely on third party audits, their own second party audits, letters of guarantee and the like, before make buying decisions. Buying decisions should take into account food safety, but supply and demand pressures might induce buyers to purchase from sources without a clear safety margin. However wrong this is, there is nothing illegal about this practice.

Auditors currently are not required to inform FDA of violations, but auditors are currently required to know what regulatory violations have been cited in the records of the firm, and if they were corrected. Auditors are also expected to follow the guidelines of the audit and make an accurate assessment of findings. When this is not done we must ask why.

So there is a connection between the two independent systems of food safety "regulation", but a relationship that is way underutilized.

Auditors conduct prearranged audits to evaluate the conditions of the environment, equipment, water supply, personnel, waste removal, use of chemicals, vector control, general sanitation, equipment hygiene, and structure maintenance, within a sometimes narrow scope of the audit. Regulators should be approving plants and operations in advance, then making frequent unannounced visits to determine compliance with laws and rules. They also have free range to demand any required document and inspect any licensed area. While both touch on the same items, the perspectives and powers are vastly different. The legal process should occur in cases where violations are not corrected or immediate threat to the public is found, and buyers should not purchase from unsafe sources. Auditors cannot perform these vital public health functions, nor can they the directly affect buying decisions.

Generally, FDA guidance and the available research form the basis for the audit criteria. However, issues like severity can be difficult to interpret. For example, in cantaloupes the commodity has not had the type of industry oversight we have in leafy greens or tomatoes (under market orders).  But FDA has provided guidance to the melon industry. We should mention this reference below: 

  • Using single pass (or one use) cooling water of sufficient quality for this intended purpose also may be used to cool product.

This is the source of info that indicates single pass water of sufficient quality may be used for washing melons. There is no mention of antimicrobial in this application. For dump tank or flume water, or where direct melon to melon contact occurs in common water, then treatment is indicated. Standards vary greatly as to disinfection of water, and for sanitizing various fruits and vegetables.

The risk assessments are still developing (and so are the politics involved with any industry led effort.) It is telling that according to "commodity thinking" cantaloupes fall into the class of fruits and vegetables with "inedible peels". This narrow definition ignores the other routes of disease transmission with this product. Microbial testing of products and the production environments is not a given. This is telling because in other Listeria susceptible products FDA and USDA demand stringent testing programs for the environment.

Water used in packing operations is required by the third parties to be potable. FDA has not published specifics about how to determine potability in a packinghouse environment, the references simply being for the use of potable water at the start of a washing process. Potability has come to mean that coliform bacteria are not present in a 100 ml sample. There are no guidelines for chemical parameters for safety in the potable supply and no requirements for the wells themselves to be treated or permitted before construction. No FDA requirement I know of demands that the local health departments permit, inspect, and require a certified operator to maintain the water quality.

At Jensen Farms, washwater for cantaloupes was apparently not reused, being simply a single pass wash of cantaloupe without treatment. There is nothing prohibiting washing cantaloupes or any produce in this fashion in the standard as long as the source is potable. This is room for improvement in the third party standard, but until the industry as a whole agrees on water treatment standards for these melons it is unclear how to develop them. This is now apparently a glaring deficiency, and just one amongst a myriad of things not addressed in food safety at the packinghouse level by FDA. 

In light of these problems in our food safety systems, auditors and auditing companies have stood in the gap for regulators. I appreciate FDA and its remarks concerning the training of auditors and any classes they could offer would be much appreciated. To date, however, I know of know such training program for industry auditors sponsored by the FDA that is available today. One day that might change.

We also have to thank the FDA for such a well developed theory on causation and it is perfectly clear that the focus should be on the packing environment.

Problems that existed in this plant in this situation are accurately described by FDA in its report. The evidence is clear for the propagation and spread of Listeria monocytogenes through water and surfaces, and "improper cooling" of cantaloupe. Pre cooling to remove field heat as a route of causation makes perfect sense, but pre-cooling is by no means a standard practice on farms or packinghouses in general as pointed out by FDA in its guidance.

The nature of equipment in packinghouses is subject to contamination and often hard to clean; moving heavy crates of products will deteriorate floors; draining is often a problem especially where washing flumes and spray systems are used. Some structures and waste disposal systems are better developed than others for this type of "dirty" packing work; however, there are no standards for construction of a packinghouse.

Currently, there are no regulations for the construction and maintenance of packing equipment; its design, layout or even fundamental function have no legal basis. Regulatory agencies normally have the functions of approving the designs, equipment and plumbing schedules, lighting, finish of walls and floors in a plant. Auditors rate these items according to the dictates of the standard within the scope of the audit. Of course FDA has the authority over such, and it would be best to have regulations of these items, but FDA has not exercised that authority and has only written guidance for general requirements. I appreciate what FDA has done in ferreting out the causation at Jensen/ Frontera, but it would have been much better for them to have published packinghouse rules, and been there before the outbreak to enforce the requirements they address as violations now.

Therefore, in light of these ongoing and serious gaps in food safety, the industry itself has required what it finds to be the best practices to protect itself to the extent it can. That these industry requirements are suited to the needs of the buyer is self-evident and expected. More importantly, things need to change as we understand risks better; but what a tragic way to learn.

Its sad that the farmer in this case did not recognize the difference between his potato line and a "cantaloupe line" nor the distinction between a potentially hazardous product like cantaloupes and a non potentially hazardous raw potato. In crops like potatoes, bulb onions, carrots, beets, there is dirt, the distinctions between risks of different crops do not generally drive standards. However, with melons the risks should have been identified, and the best practices possible followed, and they were not.

In a risk assessment we develop such preventive measures for a variety of crop types and information like this often comes out if properly done. But then, HACCP is not "required" in produce; but training in risk assessments should be mandatory for operators of high risk facilities and especially for auditors.

About the future of third party audits, I think we need the FDA to be conducting their own risk assessments and allow us third parties to simply be the eyes and ears of industry, and not the enforcers of public health protection in this nation.

This is not the role of the third party auditor.

 

 

In Bill Marler’s blog below, he quotes Bill Bagby of Tiny Greens, who sickened scores of people for 4 months with his contaminated sprouts.

http://www.marlerblog.com/legal-cases/bill-bagby-and-tiny-greens-sprout-farm-are-full-of-well-a-fecal-bacteria-salmonella—sprouts-are-ki/

Mr. Bagby says,

"Sprouts are kind of a magical thing," says Bagby, owner of Tiny Greens, a sprout farm in Urbana, Ill. "In terms of vitamins they’re just off the charts compared to normal produce."

If this is magic, it is Black Magic of the worst kind. It is not really magic though…its make-believe. And the motive is as always… money. I wonder if Mr. Bagby believes his own statements about the health benefits vs. risk of sprouts? Does he feel eating raw sprouts is worth the risk of losing one’s kidneys?

 

This is the same ploy we hear from the raw milk industry. If Mr. Bagby was doing all he could to make a safe product, I might have some sympathy for him, but he operated an unsafe and unsanitary operation according to FDA. There is no excuse for the use of unsafe compost.

 

No responsible grower of any produce item I have ever met would do such a thing.

Mr. Bagby continues to mislead the public, he gives no evidence that his products are safer today than they were yesterday; having an "audit" once a year is not a food safety program. The changes he should have made were likely obvious and likely were put off, that is until he sickened consumers.

 

FDA’s public stand on sprouts is saddening. These officials know full well that this commodity is too risky to consume, they do not eat them, themselves. Yet, they avoid confronting the issues. After the terrible tragedy in Europe, it is now time for a shot across the bow to the entire sprout industry. We need FDA to say "get rid of the unsafe operations in your industry, make your product safely or we will put you out of business" and not, "it’s an individual decision ". When unsafe cars or tires kill people, we don’t hear Washington folks saying "buying these unsafe cars and tires is an individual decision". Its not a matter of "tastes good", or "good for you", these products are too difficult to make safely, even under the best of conditions, and they pose a continuing public health threat.

 

No respectable, conscientious retailer should ever offer sprouts for sale. A firm like Jimmy Johns seems to me, totally reckless. Even after several illnesses from their sandwiches, they continue to offer sprouts. So I must conclude it’s a popular item and thus the firm is willing to take the risk.

 

Tiny Greens constituted a public health hazard for at least 4 months when it caused the last outbreak and so my feeling is the operator cannot be relied on in the future. Does he expect his auditor to stop him the next time he takes a short cut with food safety? The next time it could be devastating, knowing what we know now about the ability of the most severe strains of E. coli to contaminate these products.

 

I am sure FDA is hoping that the sprout industry will "kill itself off", which I believe will eventually happen, but how many consumers will have to die before our public health folks will tell the American public the plain truth, "raw sprouts are too dangerous to eat".

Lets stop all the make-believe.

Hemorrhaging to death is not worth the nutritional benefits of anything…period.

The Chicago Tribune asks, What should Consumers Do About Sprouts?

The answer is easy, "don;t eat them".

 

http://www.chicagotribune.com/health/ct-met-sprouts-safety-consumers-20110611,0,4296792.story

 

The Chicago Tribune tried to portray Mr. Bagby and company in a balanced way, but I do not think he deserves a favorable spotlight for his "magical" views.

Third party audits of produce are relatively new phenomena. Fueled primarily by the retail sector’s demands for safe year-round supplies of fresh fruits and vegetables, there is a serious industry-led effort underway to evaluate primary production and the resulting supply chain.

While the third party audit model has some similarities with regulatory inspections, there are major differences; Third party audits are buyer driven and may contain some unscientific provisions (one insect in a package, even an intermittent mosquito or ant) fails the audit. Another automatic failure often found in third party assessments is the provision for a blood and body fluid policy. It is universally agreed that the risk of HIV transmission is zero through food, and other bloodborne risks are very remote. Yet, the failure to have a policy on bloodborne pathogens is totally unacceptable to buyers.

 

There is no sound scientific reasoning behind provisions like these, yet since it is a buyer-driven risk assessment, these “hazards” to the retailer and his “business” are very real.

 

The standards set by retailers are mostly reasonable, but are often defined in minutia. There may be numerous questions that are so closely related that details become burdensome. For example, there are often a half dozen questions or more on rodent traps alone that must be evaluated independently, such as; are they positioned correctly, numbered, secured, clean, marked as monitored, kept on a schematic, with wall markings, in sufficient number, in sound condition, etc., etc. The intention is to cover every possible threat that a rodent will enter a building without being trapped or poisoned.

 

The detailed nature of audits sometimes lasting several days, with up to 500 individual questions, and often occurring multiple times in a year can be vexing, counterproductive and exhausting to all involved. Add to this that third parties often demand scientific programs and science-based risk assessments from operators unprepared through education or experience to provide such reasoning, and you have a problematic and sometimes dysfunctional system.

 

A huge gap emerges between the food safety expert-auditor and his “bible of standards”, and those just now becoming familiar with basic food safety concepts.

 

Auditors are often the first and primary source of scientific information for produce-facility operators unfamiliar with concepts such as Free Chlorine, Oxidation-Reduction Potential, microbial sampling plans, and interpretation of microbial testing results, ATP bioluminescence technology and other sanitation assessments and controls. Auditors often find themselves as much educating the operator as evaluating their performance. The auditor on the other hand often finds the produce-production manager assigned to food safety educating him on what things really work.

 

There is a notable lack of food safety knowledge at the primary producer level but there may also be a lack of traditional agricultural knowledge on the part of the auditor. Few auditors have the wide range of experience in public health protection, food safety, environmental health, water, chemistry, vector control, and the life sciences to truly provide an expert evaluation of safety in the agricultural world. Furthermore, it takes years of experience in the field for even qualified auditors to begin to understand the wide range agricultural and facility environments they must work in.

 

While food safety experts, production managers, and business owners struggle with these issues in produce safety, we should keep in mind that the findings of audits will not necessarily always be indicative of risks, and food safety programs no matter how well intentioned will not always prove effective given the robust exposures often encountered in farming environments. We are yet to stop the harvesting of foods where migratory birds have zeroed in, controlled floods, shot every wild pig, or figured out how to keep deer from jumping 8 foot fences to get to crops.

 

In light of all the obstacles, it’s encouraging to see contamination events caught quickly, and exposures kept small. More and more the contaminated produce that comes to light is recalled and/or production is stopped before a wide-scale outbreak occurs. This speaks to the food safety efforts of industry as we try to limit the inevitable exposures through testing and intensive traceability systems. Re-call systems are developed with computerized tracking of lot code information, and they recently have proven effective at preventing grand exposures through contaminated produce common just 2 or 3 years ago.

 

The produce sector is unique perhaps in its willingness to accept strict third party oversight, government regulation, and also to adopt and embrace food safety systems. Given enough time, the safety of produce will be assured. In the meantime, many of us have a lot of work to do.

As a  person ages, one tends to think about how their life’s work will be evaluated by future generations. Most people would want to be remembered for some accomplishment and hope that in the future, mistakes they made along the way will be forgotten.

For some, however, whatever they may have accomplished in life will be overshadowed by some spectacular moral failure. This is the unfortunate legacy of Jack DeCoster, self-made multi-billionaire farmer and US egg baron, par excellence .

By most accounts, Mr. DeCoster is the person behind the bulk of the eggs produced in this country. Through his subsidiaries and deals too entangled to entwine, Mr DeCoster and his cohorts control your egg supply, and have for many years.

Monopolies are not a good thing in any industry, but what makes this situation so incredibly bad for consumers is that the egg supply in this country is so seriously contaminated with Salmonella.

One only has to look at recent events and the history of DeCoster’s fiasco’s,  environmental, occupational, and public health to see that he is personally responsible for what has happened to the egg supply. It appears that most of the contaminated (and non contaminated) eggs in the US pass through him and his assorted businesses.

It didn’t have to be this way, but this is the way DeCoster apparently wants it.  So will he be remembered- not as the self-made successful business man- but: "The Notorious Egg Man Who Made America Ill".

For DeCoster’s latest assault on America’s public health, see:

http://www.desmoinesregister.com/fdcp/?unique=1301439874140