HANK GICLAS | SR. VICE PRESIDENT, STRATEGIC PLANNING, SCIENCE & TECHNOLOGY SCIENCE & TECHNOLOGY
Food Safety Efforts Underway to Create NewWater Paradigm
Between 2009 and 2017, FDA and their partners at the Centers for Disease Control and Prevention (CDC) identified 28 foodborne illness outbreaks of Shiga-toxin producing E. coli (STEC) in the United States with a confirmed or suspected link to leafy greens—an average of more than three outbreaks per year. This eight-year period came on the heels of the 2006 E. coli
policies, and best practices to enhance leafy green safety. FDA specifically highlighted the importance of assuring that the agricultural water (ag water is defined as water that directly contacts the harvestable portion of the crop) used in production and harvest is “safe and adequate for its intended use.” After assessing the need, industry groups have determined that change is necessary. United Fresh and the Produce Marketing Association have organized a task force to further review and assess issues associated with recent outbreaks while actively working to develop resources, which might manifest as white papers, guidance, recommendations, or other deliverables in several areas including preventive practices, labeling, traceability, investigation, and outbreak response. The task force includes many fresh produce supply chain members and is progressing as rapidly as their large structure allows them to deliver results. Western Growers, recognizing that the Leafy Greens Marketing Agreements in Arizona and California are the quickest path to any implementation of new preventive controls, has been facilitating a process to develop new food safety practices and standards for adoption and implementation by industry. The facilitative process includes WG working directly with a small drafting committee to develop initial language and then asking broad industry for feedback on the drafts. As industry provides commentary and suggestions, WG works to incorporate that feedback and take it back to the drafting committee for its input. After cycling through this iterative process often enough to feel comfortable with a stable final draft, Western Growers will then hold an industry-wide webinar to explain the draft and take further input. Upon conclusion of those steps, Western Growers will take the proposed revisions to the Arizona and California LGMA Technical Committees that, in turn, will review the changes and, when comfortable, recommend adoption to their respective boards. If adopted by LGMA boards, the work will become the controlling language for all leafy green handlers engaged in the Arizona and California LGMA (the vast majority of the fresh romaine supply). Because both FDA and industry have prioritized water as an issue that needs to be addressed, the current effort is to develop a new paradigm for water quality relating to food safety. In food safety programs commonly deployed by industry, water that is “safe and
O157:H7 spinach outbreak followed by the industry’s development and implementation of the initial leafy greens marketing agreement. Then in 2018, as the industry prepared for Food Safety Modernization Act (FSMA) compliance and inspections, additional E. coli O157:H7 outbreaks occurred that were linked by the FDA’s traceback investigations to Arizona and California’s desert growing region and California’s Central Coast. In each of these outbreaks, FDA deployed investigators to the regions and found the outbreak strains in the leafy green production environment. During the FDA’s environmental assessment conducted in response to the early 2018 outbreak associated with desert-grown romaine, three samples of irrigation canal water analyzed by whole genome sequencing were found to contain an E. coli O157:H7 strain with the same rare molecular fingerprint as the strain that produced human illnesses (the outbreak strain). These samples were collected from an approximate 3.5-mile stretch of an irrigation canal in the Wellton area of Yuma County that delivers water to several of the farms identified in the traceback investigation as potential shippers of contaminated product. Later in the year, another foodborne illness outbreak sent FDA investigators to California’s Central Coast where an irrigation reservoir was found to contain E. coli O157:H7 with a molecular match to the outbreak strain. What links these two outbreaks, other than they are both associated with romaine, is that in each instance FDA found the same strain as the outbreak pathogen in water and sediment in the area of investigation. It cannot be said with certainty that the water contaminated leafy green crops. And we do not know how the water and/or sediment itself may have become contaminated. But these findings, coupled with a high potential for water of unknown quality to transfer pathogens if applied to a crop, have prompted both the FDA and industry to re-examine the preventive controls associated with water used in fresh produce operations. It is well understood that water, if it contains fecal material and contacts edible portions of the crop, may contaminate leafy greens during production and harvest operations. Contamination may also occur by means of water-to-soil followed by soil-to-leafy greens contact. In its November 2018 letter to industry, FDA requested that we assess the need for updating and developing additional commodity-specific procedures,
28 Western Grower & Shipper | www.wga.com MARCH | APRIL 2019
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