Could it be that the Jensen Farms LM outbreak will be traced to contaminated irrigation water?

Looks like the Arkansas river is the irrigation source for this entire farming region through a series of diversion canals and ditches. We also have to remember that pesticides are also applied using surface water sources in some regions.

For some great pictures of water usage in this region see:

I offer this theory because the low flow rates of the river due to the drought conditions in this region, and the access of the water source to all sorts of animal vectors is a very likely exposure pathway for LM.

For a look at  NOAA drought conditions reporting in this region see:

The growing region is in Prowers County, in extreme southeastern Colorado.

Given the wide spread of cases over time, this points to pre-harvest contamination, as opposed to post-harvest contamination. Although its been reported that LM was found in the production areas of the packing operation, such may have been introduced through contaminated incoming products.

For the latest from CDC and the report on LM findings from the facility see:

I hope we get the details of this investigation. If drip irrigation is used, and there is little exposure to irrigation water except through the roots, then my theory is less plausible. 

In spite of what some people have said about the Del Monte Salmonella cantaloupe outbreak, knowing the cause of outbreaks does help prevention efforts in the future.

We have heard the retail industry insist that more must be done by the growers to prevent these events.

If we are to do more, we need to know what.


Being an avid reader and researcher of all things food safe, I cannot help but notice a trend. The pattern of reported large scale multi-state outbreaks every few weeks or months seems to be changing to a pattern of small scale but almost daily outbreaks at the local level.

Coincidentally there seems to be a shift from large scale processing and manufacturing contamination to retail and food service handling mistakes as the key factors. If you do not read Bill Marler’s blog or Doug Powell’s or stay focused on the current events you will not see this trend. But it is getting very difficult to stay current. I spend 2 hours a day reading news and analyzing new research, it’s getting tough to keep up even with Bills and Doug’s help.

As some may know, I have been offering HACCP classes at the FS/retail level for 13 years beginning when I conducted the first training for inspectors in Florida in 1998 with my Applying HACCP Principles course. Last week, I certified another 17 FS professionals and sanitarians. I am going on about 250 persons trained/certified under NEHA HACCP and about 1500 under my own International HACCP Alliance accreditation. I am at about 2000 trained in on line programs. These students represent food service, hospital, catering, retail industry professionals, small processors, and a few sanitarians. I have certified about 300 in accredited Produce HACCP, but I have not even scratched the surface of what needs to be done in the way of training in any of these more or less forgotten sectors.

Just look at the recent news and you will see that that most of the problem right now is surfacing at the local level, although the big nationwide fiascoes make most of the news (and there are all sorts of epidemiological reasons for that trend).

So where are food safety management systems at retail? Nowhere, almost.

Apathy regarding food safety is a huge problem at the food service level, and so is waiting around for the health inspector to tell you what to do. And still, the retail industry fights developing food safety management systems, even when it is required, what is wrong here?

I think I know, but I would like to hear someone else besides I address the lack of motivation on the part of 90% of the food service sector.

OK, the obligatory caveat, the national restaurant chains have a type of HACCP, and they do better, sometimes much better, but they represent about 10% of the one million food services in this country. I am tired of hearing how food safety management is too big a burden on the “average Joe” food service operator, or that they just are too backward to handle a scientific approach. This is just not so in my experience.

If a restaurateur can figure out how to make money in this economy and stay afloat, then they are not too stupid for HACCP, so ignorance is an excuse. I am also tired of the excuses that come out of CFP, and actually from FDA itself about the voluntary nature of HACCP at retail.

Listen…food safety is not voluntary; it’s an implied warranty, and should be the one and only criteria for maintaining a permit or license AND an operator should be able to prove it. Its more than just passing an unannounced inspection, its 24/7 365 food safety and its achievable.

How many people have to die from stupid mistakes, lethargy and plain negligence before operators such as the ones below take food safety seriously?

I don’t expect people to come flocking to me for HACCP training, but really people, my numbers at the retail level of HACCP training are pitiful, but I am not giving up.

Thanks as always to Doug Powell at BITES, always a fantastic resource. Please see the donation button. Each of us chipping in $25.00 a year is not too much to ask for this work and more if you can afford it.

CALIFORNIA: Documents show history of problems at Fernbridge Cafe; investigation continues, DA weighing charges
Contra Costa Times
Thadeus Greenson
As the Humboldt County District Attorney’s Office continues to mull filing charges against the operator of the Fernbridge Café, environmental health division documents outline a long history of problems at the restaurant.
Deputy District Attorney Krista McKimmy said Thursday that her office is continuing to investigate the case, but that she expects to make a decision on charging operator Steve Sterbeck by Monday.
Sterbeck was arrested on suspicion of operating a food facility without a valid permit on March 31 due to what the DA’s Office deemed “a continued refusal to comply with the Health and Safety Code” that put the public at risk of illness. The arrest came after Sterbeck was asked to close the business temporarily on the heels of water tests showing high levels of E. coli bacteria, officials said.
According to a case file in the Humboldt County Department of Health and Human Services Division of Environmental Health, tests on the cafe’s water conducted on March 17 and 18 showed high levels of E. coli — bacteria found in the lower intestine of warm blooded animals — and coliform bacteria. Further, the tests showed high levels of turbidity — cloudiness — and that chlorine levels in the water were four times below the state minimum and 30 times below the recommended level for treating unfiltered surface water.

Vac-paking pizzas also not for amateurs; Indiana Pizza King cited
Doug Powell
Pizza King has been cited by the Delaware County Health Department for nine violations of sanitation requirements related to its vacuum-packed pizzas.
Two of the violations relate to the lack of a hazard analysis and critical control point (HACCP) food safety plan, which is required to prevent contamination that can lead to the growth of botulism and listeria bacteria in such packaging.
The violations occurred March 15 at 109 E. McGalliard Road, the only Pizza King site that ships vaccum-packed pizzas, which are partially baked and then frozen, to customers around the country and to other Pizza Kings, where they are sold as take-and-bake products.
Pizza King also was cited by the health department during an inspection nearly six months ago for the lack of a HACCP plan.
"They did in fact cite us in October (for the same violation)," said Pizza King official Jerry Riley. "They were going to, from our understanding, get back with us and show us how to do a HACCP plan, and they never did. So when we got this last one (violation), we got lined up with the federal people who inspect our commissary, and they are in the process of helping us put together the HACCP plan. So we will have it in no time at all. Keep in mind, all of the product we receive has a HACCP plan at the commissary."
Terry Troxell, food safety coordinator for the health department, said Pizza King needs a HACCP plan not only at its commissary in Anderson but also at the store in Muncie where the vacuum-packaging, also known as "reduced oxygen packaging," actually occurs.
"I told them I can help answer questions, but we are not in the business of making HACCP plans," Troxell said. "That’s not something we do. They need to do that. We are a regulatory agency. We do inspections. They never approached me with any questions or request for assistance."

Se Bill Marler’s blog, where one of his clients in the DeFusco Bakery Salmonella crises in Rhode Island tells it like it is on TV.

Thankfully, we have a functioning tort system in the US. It stands in the gap for the decrepit and often ineffective regulation of facilities by our disconnected health authorities. While this operation had a legal obligation to control the risk of Salmonella in its foods, an obvious defect like using egg containers for storage of pastry shells should have been caught. We may learn of other factors that led to this massive outbreak.

As a public health consultant and food safety auditor, I make frequent audits of bakeries and develop HACCP systems for them. I am often shocked at the lax attitude that the authorities have in bakeries-they are obviously viewed as a low priority. Most bakers when properly educated and given the tools can and will gladly do their jobs safely, but when they do not, there are plenty of hazards that reach the public. I am often telling bakers for the first time about the risks of Salmonella from eggs, and time and temperature abuse, and inadequate cooking.

As a public health professional that spent 20 + years fighting the “system” to try to improve conditions for consumers, I say it’s high time we make both industry and our government agencies responsible for the damage that lax agency enforcement and industry ignorance causes-like in China. Although I am not in favor at this time of the firing squad, I am advocating proper funding, education, and empowerment of our inspectors so can they protect us better.

Agencies and the food industry, including the forgotten bakery segment, should be all about prevention in the interest of public health. Unfortunately, there is a mean-spirited group of legislators who are more than willing to take apart our public health agencies- to "make it easier for the industry". These are the same ones who say we should limit damages against businesses that cause injury to the consumer, when in fact, civil lawsuits are about the only means for justice the people have.

Right now, plaintiff lawyers stand in the gap for the consumer and we are glad they do. These injured people deserve their day in court. But most importantly, we need to stop these totally preventable, stupid and tragic events, and we frequently fail to do it. 

(Betcha anything the eggs carried Salmonella into this baked good, betcha anything DeCoster had something to do with the eggs)

Cantaloupes are again the vehicle for Salmonella. Such instances should be closely investigated to determine the root cause. Typical contamination sources in growing cantaloupes would include irrigation, run off, human waste, animal intrusion and infected workers.

The problem of contamination and potential growth of bacteria on melons is a difficult one. Normally, with a product that can both harbor and grow bacteria we would require that the items containing it be kept under temperature control; the FDA retail food code does require cut melons to be held at 41 degrees until service, for example.

Prior to cutting (processing), there are no current regulations for limiting growth of bacteria on melons. There are no requirements for shipping or storage temperatures for whole intact melon. Food safety efforts with melons, and most raw agricultural products is primarily a matter of contamination control. Melons may or may not be washed in the packinghouse to remove contamination before shipping to retailers. Again, no mandatory provisions exist for any type of post-harvest treatment with melons. Thus, the final processing of the product is the final opportunity for prevention and also the step with the highest risks.

The challenges for the fresh produce industry are in identifying the risks in the growing, harvesting, packing and shipping of these items, and then taking a combination of preventive measures that reduces those risks to the next user to some measurable level. The new research pointed out in Bill Marler’s blog found below, is useful, but the industry response will take some time, given the nature of the industry and what it has traditionally seen as risk.

Farmers know that wild animals are a major concern in melon operations; they consume and destroy a significant amount of crops. Deer, pigs, raccoons, as well as birds are attracted to these growing and harvesting areas. While growers may not have absolute control over access to the growing areas, harvesting methods must account for contamination found. Operations under third party standards are required to monitor for these hazards and not harvest areas with obvious signs of animal intrusion. That procedure if rigorously done limits the wide scale fecal contamination problem but does not eliminate it. Handling thereafter must be sanitary. Packers that do not wash melons can do little to remove contamination. Buyers drive this model, and many will accept raw agricultural products that have not had a washing step, leaving the consumer hard pressed to defend themselves.

However, washing in a large packinghouse is itself hazardous. During washing, if antimicrobial quality of wash water is not maintained, water becomes a vehicle to further spread contamination between lots. Diligent control of wash water quality is often a critical control in a food safety program for this reason.

We may not be able to eliminate the pathogens in melons at any one stage of the production system, thus calling for a coordinated effort between growers, handlers, shippers and end users. We need to strengthen the weak links in this chain to the extent we can, and combine that effort with effective microbiological testing, recall procedures and oversight.

The regulation of the supply chain for agricultural products in general is very weak at present, but we expect this situation to change soon. Efforts to properly guide the fresh produce industry and enforce necessary public health controls will improve as the new federal policies and procedures come into effect. An expansion of the regulatory controls and industry led efforts will eventually reduce the risk of contamination in raw agricultural products overall, but don’t expect immediate resolution of the fundamental problems of melons, and perhaps, other high risk produce items.

We thank Dr. Doug Powell and attorney Bill Marler for keeping us informed about safe handling, as the produce industry continues to make progress in reducing risks to end users.

See Marler Blog

The hazaelnut outbreak may spur FDA to move in its new powers.

Here we see the packinghouse that packed the hazelnuts refusing to cooperate with officials after nuts it shipped sickend several people with E coli O157:H7. (Note the very soiled hands in this picture this would not be an acceptable level of cleanliness for a harvester).

Schools are skipping out on thier responsibility to prepare food safety plans.

Under the Richard B. Russell School Lunch Act of 2004, all schools were to have HACCP plans in place years ago.…Policy…/2005-01-10.pdf

Here below is a perfect example of why. Schools that do not have a monitoring system in place are in default of federal guidelines. Whether the temperature abuse problem that led to this outbreak was wholly caused or partially caused by the school, the lack of temperature controls for 4 hours and failure to test incoming product temperature is what HACCP was meant to correct.

While retailers demand food safety management systems for suppliers, the food service, institutions and retail firms at the vulnerable end of the supply chain have resisted developing food safety systems.

The Richard B Russell act was supposed to fix this in schools, but there are few if any schools who have heeded this requirement. The political protection that schools enjoy (being part of the county, just like the health departments) is partially to blame, as is lack of funding for health departments at the county level. It’s a Federal Program! An “unfunded mandate”, or so say the health departments. The insulation that retailers and food service firms enjoy from the political action campaigns of the National Restaurant Association is also wrong.

Here we see the convergence of hazards from the retail level and the school coming together to make pedople ill. All of them should thank God it was not E coli O157:H7. In any event this outbreak was easily preventable.

When will the consumer become the focus of food safety?

Well it seems only when the restaurants and schools who cause these outbreaks are sued, and so let the lawsuits fly.

Wake up people!

ILLINOIS: Merle’s owner decries ‘reckless’ health report
Evanston Review
Karen Berkowitz,ev-merles-criticizes-health-report-030411-s1.article

Thanks to

The owner of Merle’s BBQ Restaurant in Evanston Friday decried the Evanston Health Department’s "rush to judgment" in blaming the restaurant for the outbreak of foodborne illness after an event Feb. 16 at Haven Middle School.

Merle’s owner Larry Huber said the restaurant had no control over how the food was served after it dropped off the food order.

"The event was not a fully catered event, but a drop-and-go delivery," said Huber. "If it had been a fully catered event, we would have had the appropriate staff and equipment to maintain the presentation and quality."

One of the 30 people who reportedly became ill after eating the food, served "buffet style" during parent-teacher conference night, filed a lawsuit Tuesday against the eatery.

The lawsuit quoted the findings of the Evanston Health Department, as summarized in a Feb. 24 press release that was posted on the city’s website and reported on in the media.

(This is an excellent study on Clostridium perfringens and worth reading)

The Health Department identified unsafe food handling and temperature storage at both Merle’s and Haven Middle School as possible causes and concluded "that it’s unlikely the exact cause of the outbreak will be determined."

The food was prepared at Merle’s, 1727 Benson Ave., and delivered to Haven Middle School, 2417 Prairie Ave., where it was served without a heating source between 3 p.m. and 7 p.m., according to the Health Department.

Huber said he was told by a Health Department manager that none of the samples taken from Merle’s tested positive for “Clostridium perfringens”, which was determined to be the cause of the outbreak.

Huber was informed the restaurant did not take hourly time and temperature logs, but he contends the practice is not required by the health codes of either the state of Illinois or the city of Evanston.

According to Huber, the restaurant was in full compliance of the requirement that foods prepared and then cooled for later serving be labeled with the time and date they are made.

Eric Palmer, communications director for the city of Evanston, said Friday the city has no comment and stands behind the statement issued last week.

While tomatoes were identified early as an outbreak vehicle, subsequent investigation revealed Serrano and jalapeno peppers as the common food item in later outbreaks. I agree with Dr. Acheson that the epidemiological association is only an approximation and there will be a potential for things to occur by chance alone and confounders, but the relationships here are difficult to dismiss without some kind of explanation.

The short list includes cross contamination during repacking, common growing or harvesting methods, in common contaminated water supplies and irrigation, maybe even run-off.

We really do not know exactly what went wrong at the various production stages with these commodities and there is something important to learn from this either way.

2008 Outbreak of Salmonella Saintpaul infections associated with raw produce
New England Journal of Medicine
Casey Barton Behravesh, D.V.M., Dr.P.H., Rajal K. Mody, M.D., M.P.H., Jessica Jungk, M.P.H., Linda Gaul, Ph.D., M.P.H., John T. Redd, M.D., M.P.H., Sanny Chen, Ph.D., M.H.S., Shaun Cosgrove, B.A., Erin Hedican, M.P.H., David Sweat, M.P.H., Lina Chávez-Hauser, M.A., Sandra L. Snow, M.D., Heather Hanson, M.P.H., Thai-An Nguyen, M.P.H., Samir V. Sodha, M.D., M.P.H., Amy L. Boore, Ph.D., M.P.H., Elizabeth Russo, M.D., Matthew Mikoleit, M.A.S.C.P., Lisa Theobald, B.S., Peter Gerner-Smidt, M.D., D.M.S., Robert M. Hoekstra, Ph.D., Frederick J. Angulo, D.V.M., Ph.D., David L. Swerdlow, M.D., Robert V. Tauxe, M.D., M.P.H., Patricia M. Griffin, M.D., and Ian T. Williams, Ph.D. for the Salmonella Saintpaul Outbreak Investigation Team

Raw produce is an increasingly recognized vehicle for salmonellosis. We investigated a nationwide outbreak that occurred in the United States in 2008.

We defined a case as diarrhea in a person with laboratory-confirmed infection with the outbreak strain of Salmonella enterica serotype Saintpaul. Epidemiologic, traceback, and environmental studies were conducted.

Among the 1500 case subjects, 21% were hospitalized, and 2 died. In three case–control studies of cases not linked to restaurant clusters, illness was significantly associated with eating raw tomatoes (matched odds ratio, 5.6; 95% confidence interval [CI], 1.6 to 30.3); eating at a Mexican-style restaurant (matched odds ratio, 4.6; 95% CI, 2.1 to ∞) and eating pico de gallo salsa (matched odds ratio, 4.0; 95% CI, 1.5 to 17.8), corn tortillas (matched odds ratio, 2.3; 95% CI, 1.2 to 5.0), or salsa (matched odds ratio, 2.1; 95% CI, 1.1 to 3.9); and having a raw jalapeño pepper in the household (matched odds ratio, 2.9; 95% CI, 1.2 to 7.6). In nine analyses of clusters associated with restaurants or events, jalapeño peppers were implicated in all three clusters with implicated ingredients, and jalapeño or serrano peppers were an ingredient in an implicated item in the other three clusters. Raw tomatoes were an ingredient in an implicated item in three clusters. The outbreak strain was identified in jalapeño peppers collected in Texas and in agricultural water and serrano peppers on a Mexican farm. Tomato tracebacks did not converge on a source.

Although an epidemiologic association with raw tomatoes was identified early in this investigation, subsequent epidemiologic and microbiologic evidence implicated jalapeño and serrano peppers. This outbreak highlights the importance of preventing raw-produce contamination.


I have now been involved in over 60 investigations of foodborne illness as an expert, on the sides of both plaintiffs and defendents, some reflections:

1. Most outbreaks that result in lawsuits have evidence of multiple major sanitation deficiencies

2. Most have pest problems as part of the documentation

3. Many have serious time and temperature issues

4. Many have personal hygiene issues

It seems like to have an outbreak that results in a lawsuit requires a lot of negligence. It is usually not some failure at a CCP, or an invalid HACCP plan due to some error in thinking. Its gross sanitation issues that put people in this spot more often than not. Those that have at least a semi scientific program with oversight of any type and are managing basic sanitation adequately seem less likely to get into deep trouble with litigation, and if they do, there is less likely to be a smoking gun.

Doug Powell below writes in his Barfblog about the delay in CDC notifying the public about the source of the current SE outbreak in eggs. The CDC went public in mid August when apparently sufficent information existed in late July to implicate Iowa’s Wright Egg Farms.

Other outbreaks in the recent past had the same scenario, a delay between identifying the likely source of outbreaks and public disclosure.

There might be a couple of explanations for the delay in the naming of names as a result of epidemiological findings. The strength of the epidemiological data sometimes is not strong enough to make confirmation completely bullet proof, remember we are dealing with relative risk.
Second, when an agency goes public they can be wrong and end up with well…egg on their faces, and much worse.

On the other hand, when there is a strong likelihood of a public health threat there might be good reason to go public even if all data crunching is not complete, a common supplier is certainly suspicious. I agree with Doug, the key is the strength of the data.

The FDA is investigating a nationwide outbreak of Salmonella in  shell eggs.

While many believe that contaminated water and feed and rodents are to blame, if you go further back into the causation you will find that the egg is contaminated because of the absence of salmonella pullorum in the gut of the chicken.

Programs to combat the one disease of chickens in the 1980’s some believe led inadvertently to the colonization of the gastrointestinal tract and reproductive organs of chicks by the human pathogen, SE. It doesn’t necessarily mean that the first event caused the other, but there is biological plausibility to this argument and the temporal association I think is striking. Especially, given this disease occurred in several parts of the world almost simultaneously. So the rodent that has been in the hen house for millennia causing limited human disease (through contaminated egg shells) becomes now a vector for a widespread invasive disease of poultry and humans and spreads to other food animals. Not to minimize the rodent’s infectious properties and need for control, but human meddling with bacteria doesn’t always turn out for the best for mankind. Interestingly, Salmonella pullorum is not treated with antibiotics, culling the bird is the intervention. 
Denmark has been successful in control of SE in broiler chickens, layer hens, and pigs through careful surveillance, culling, farm sanitation, pasteurization, and sanitary slaughter.
Denmark has now has the safest eggs in the world. And they achieved this only by an effective industry-government partnership, something we should take special note of, given the positive political climate in the US right now. See the paper from CDC below for a review of the Danish approach.