Food Safety White Paper February 2009

Food safety is of paramount importance to the berry industry and the food industry in general.  Although the Food and Drug Administration (FDA) reports that from 1996 to 2006 less than 1% of all reported outbreaks of foodborne illnesses were associated with fresh produce,  the impacts of an outbreak can be catastrophic both to those affected and to an entire industry.

Recommendation

The berry industry is committed to providing safe and nutritious food and offers the following recommendations.

  1. Government should support research to assess the real microbiological risk of each berry crop.  This assessment should consider, within each crop, risk incident history, regional differences, and risks associated with growing, harvesting, handling and transportation.  Understanding those significant factors that actually could contribute to a food safety problem represents the best opportunity to mitigate risk.

  2. Produce safety standards issued by the federal government must be commodity specific and region specific (where necessary), as well as scientific and risk-based. Such standards should take into consideration the uniqueness of each crop type with respect to the assessed real microbiological risk, growing location, and the uniqueness of each crop’s specific agricultural and handling practices.

  3. Food safety standards should strongly discourage the proliferation of multiple audit systems and purchase requirements that result from independent requirements of governments, non-governmental organizations and from independent corporations.

  4. Good Agricultural Practices (GAPs) and GAP audits should be developed and standardized for each type of berry crop. These audits should include self-audits as well as some type of federal system for audit verification.

  5. Crisis management plans suitable for the risks associated with each crop should be developed.

  6. GAPs and GAP audits should not be financially devastating to growers.  If necessary, the government should provide financial assistance to those growers who otherwise could not afford to comply.  Financial assistance will be particularly important for small growers.  Food safety should be supported through the Farm Bill.

  1. Microbiological testing methods should be standardized and validated so that they are relative to each other and represent real risk.  Testing methods should be quick and low in cost.  Testing should not hinder time-to-market.

  2. Eat-safe guidelines should be readily available to consumers.  The importance of proper handling of food by the end-user cannot be over-emphasized.  Grower and handler food safety practices cannot eliminate all pathogens.  Further, food-borne pathogens can be introduced at the point of food preparation and consumption.

Berry Crop Diversity

Berry crops represent a wide range of phenotypically unique crops including strawberry, caneberries (raspberry, blackberry, others), blueberry, cranberry (including lingonberry) and Ribes (currant and gooseberry).  Not only are they diverse in the size, shape and colors of their fruits, they are also diverse horticulturally, from low growing berries (e.g. strawberries and cranberries) to tall shrubs (e.g. blackcurrant and gooseberry). All are perennial but some are cultivated as annuals (e.g. strawberry); most are cultivated while others are collected from the wild (e.g. wild blueberries).  Many berry crops (e.g. strawberries) are often eaten raw or minimally processed, while others (e.g. cranberries, currants) are usually processed. In developing food safety programs, it is important to recognize both the the differences and similarities among the berry crops and with other crops.

Developing Standards

Good Agricultural Practices (GAPs) play an important role in helping farmers integrate a multiplicity of codes, standards and regulations devised by governments and non-governmental organizations; and help to address a variety of environmental, economic, social sustainability, food quality, and food safety goals.  At times, the diversity of standards imposed by buyers or regulators can be confusing, costly, and conflicting.  Science must be used as the foundation to ensure that these diverse practices address real risk.

The government often searches for a generalized approach.  Sometimes a generalized approach creates a “level playing field” so that all affected parties compete under the same regulatory conditions.  However, at other times, a generalized approach creates inequities among affected parties and/or fails to achieve the goals for which the regulatory action was intended. A one-size-fits-all approach may also misdirect limited resources and create a false sense of risk reduction.

For example, a simple factor such as water testing could be easily generalized into a generic guideline for fruit and vegetable production.  However, a generalized approach would fail to account for different risk profiles by commodity and region.  More specifically, the risk associated with contamination from the water can vary depending on regional conditions such as reliance of surface water or groundwater or on commodity-specific conditions such as application via overhead sprinkler irrigation or drip irrigation.  In addition, the inherent properties of some crops (fruit surface characteristics, handler processing methods, consumer post-harvest handling, etc.), as substantiated by their low risk-incident profile, reduce the need for equally burdensome irrigation standards on all crops.  These different risks associated with something as simple as water quality testing demonstrate the need for mitigation measures that are commodity, region, and risk specific.

This example also illustrates how buyers can mis-apply a commodity-specific guideline by imposing it on other commodities.  For example, if a guideline metric required monthly water quality testing for a row crop using surface water and sprinkler irrigation, a buyer might assume that weekly testing is even better and impose a new “Super Metric” for all commodities.  However, such a “Super Metric” would be a false assumption and only cause limited resources to be directed toward less relevant factors.

Influencing Food Safety Practices in the Field

Recent outbreaks of food-borne illnesses associated with produce have generated a public policy discussion about mechanisms to improve food safety practices on the farm.  One issue is mandatory versus voluntary food safety standards and enforcement. Current mandatory programs include the requirements by many buyers that their suppliers participate in GAPs programs. The Leafy Greens Marketing Agreement in California has demonstrated that a voluntary approach can achieve near 100% compliance with a commodity-specific food safety standard.

If a farmer causes an outbreak of foodborne illness, not only does he put his own farm at financial risk, but he also puts the entire industry at risk.  This creates a significant amount of peer pressure for maximum compliance with food safety GAPs. In short, the impact of a foodborne outbreak is so significant that it compels maximum participation in voluntary programs.

How can mandatory or voluntary programs ensure that food safety practices are being followed in the field?  Audits have emerged as the leading mechanism to ensure compliance.  Audits are an important component, but are limited to a paper review at a single point in time.  Another alternative is continuing education and training for farmers, supervisors, and handlers.  Combining audits and training can create the optimum balance of written procedures and employee behaviors.

The Role of Recalls and Need to Educate the Consumer

In the past, Food and Drug Administration (FDA) recalls have been a blunt instrument, implicating an entire industry and bringing harm to innocent farmers. FDA frequently issues recalls based on epidemiological analysis, without conclusive evidence such as biological testing and “fingerprinting”. The Salmonella Saintpaul outbreak in summer 2008 illustrates both the progress made by FDA as well as one of its biggest failures.  In the Salmonella Saintpaul outbreak, FDA issued a recall of tomatoes.  As FDA reviewed more information about which states were harvesting at the time of the outbreak, they were able to rule out areas and remove them from the recall.  While this represents significant progress in how FDA has managed recalls, the investigation finally concluded that imported peppers from Mexico, not tomatoes, were the source of the outbreak.  Improvement in how FDA conducts its investigation, the threshold upon which it determines to issue a recall, and greater communication to consumers about the comparative risk of the recall would both improve public health and reduce grower economic damage.

A related aspect of recalls is traceback. Traceback is an important tool.  While many farmers are able to trace back to the specific block where the produce was harvested, that information is often lost when the produce is distributed at the retail level.  The “Produce Traceability Initiative” by the Produce Marketing Association, United Fresh Fruit and Vegetable Association, and Canadian Produce Marketing Association is one alternative that would improve current traceback ability.

Finally, the majority of foodborne outbreaks are associated with mis-handling by end-users.  End-user education should be a major component of any effort to improve produce food safety.

References

Cornell University.  “Food Safety Begins on the Farm – A Growers Guide”. Cornell Good Agricultural Practices Program. Department of Horticulture 134 A Plant Sciences Bldg., Ithaca, NY  14853-5904.  http://www.vegetables.cornell.edu/issues/foodsafe.html

Food and Drug Administration.  “FDA Advises Consumers About Fresh Produce Safety”. U.S. Department of Health and Human Services. Public Health Service 5600 Fishers Lane Rockville, MD  20857.  http://vm.cfsan.fda.gov/~lrd/tpproduc.html

Food and Drug Administration.  “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables: Draft Final guidance Contains Non-Binding Recommendations”, U.S. Department of Health and Human Services, Center for Food Safety and Applied Nutrition. March 2007.  http://vm.cfsan.fda.gov/~dms/prodguid.html

Penn State University.  “Good Agricultural Practices for Pennsylvania Fruit and Vegetable Growers”.  Luke F. LaBorde, Department of Food Science, University Park, PA 16802.  http://foodsafety.psu.edu/gaps/PSU_USDA_GAPs_1.3_2007.pdf

The Partnership for Food Safety Education (PFSE).  Food safety and safe food handling campaign information.  http://www.fightbac.org/

United Fresh Fruit and Vegetable Association (UFFVA)  “Food Safety Auditing Guidelines: Core Elements of Good Agricultural Practices for Fresh Fruits and Vegetables”  727 North Washington Street, Alexandria, VA 22314. http://www.uffva.org/food_safety_docs.htm

University of California, Agriculture and Natural Resources.  UC Good Agriculture Practices.  “Good Agricultural Practices: a Self-Audit for Grower and Handlers”  http://groups.ucanr.org/UC_GAPs/GAP_Self-Audits/

University of Wisconsin. A3701 “Producer’s Guide to Reducing Microbial Contamination of Fresh Produce”.  University of Wisconsin Cooperative Extension, Cooperative Extension Publishing, Rm. 170, 630 W. Mifflin St. Ma1dison, WI 53703.
http://www.hort.wisc.edu/freshnews/2007/A3701.pdf

USDA. “USDA Good Agricultural Practices & Good Handling Practices Audit Verification Checklist.  AMS, FVP, Fresh Products Branch. May 11, 2007 version.
http://www.umaine.edu/umext/potatoprogram/Fact%20Sheets/GAP%20&%20GHP%20Checklist%20April%2007.pdf