Who’s Minding the Store - The Current State of Food Safety and How It Can Be Improved Devon Zagory, Ph.D. Senior Vice President Food Safety & Quality Programs NSF Davis Fresh University of Seattle School of Law April 11-12, 2008

What Is The Problem With Produce? More outbreaks Bigger outbreaks More media attention Less confidence on the part of buyers and consumers

Why the increase? Increased consumption –More raw, less cooked Larger scale production, widespread distribution –Increasing size of outbreaks and ability to detect them Increase in public and scientific awareness –More severe illness Greatly improved methodology More aggressive investigation

1998 – 2006 Produce Outbreaks 30% 17% 13% 11% 24% 5% Top 5 produce items make up 76% of outbreaks

Produce Outbreaks (190) 54% pathogens identified From presentation to produce associations, January 2004, Lynch and Tauxe, CDC

Routes of Contamination Beuchat, 1996 ANIMALS, BIRDS PRODUCE HUMANS water feces insects sewage soil meat, milk, eggssilage, feedplants (cross contamination) harvesting, handling, processing environments

Washing Doesn’t Eliminate Pathogens At best 1-3 log (1 to 1000-fold) reductions can be expected under commercial conditions regardless of antimicrobial used Issues –Complexity –Stem scar area –Hydrophobic niches –Internalization of pathogens

Tomatoes Washed with Chlorinated Water S. montevideo Log CFU/cm Chlorine (ppm) Zhuang et al, 1995

Good Agricultural Practices FDA, 1998 guidance document –“Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables” Not a regulation - guidelines onlyNot a regulation - guidelines only –Focus on prevention of contamination and redundant reductions –Commodity-specific guidance increasingly available –Lettuce and Leafy Greens Marketing Agreement Provides metrics for key factorsProvides metrics for key factors

Commodity Specific Guidelines Melons Sprouts Lettuce and Leafy Greens Tomatoes Strawberries Fresh-cut Food Safety Guidelines

California Leafy Greens Marketing Agreement Initiated by Western Growers Assoc. Signatories are “handlers”, not growers Nearly 100% of CA handlers have voluntarily signed Once signed, terms are obligatory Must buy only from suppliers meeting the terms “Metrics” were developed by a committee of experts Suppliers and handlers are audited by the CA Dept. of Food and Agriculture

Lots of Audits! Internal self-audits Customer audits Third party audits Regulatory audits USDA AMS CA Dept. Food and Ag. Organic audits Sustainability audits

Micro Testing Testing of irrigation water for generic E. coli required by CA LGMA Environmental testing in facilities validates cleaning and sanitation Product testing required by many buyers –Raw product testing –Finished product testing

Is Testing Product Effective? Negative Tests Don’t Prove AbsenceNegative Tests Don’t Prove Absence What will you test for?What will you test for? –Coliforms (Inaccurate Indicators) –Viruses –Pathogens No Government StandardsNo Government Standards Quality Assurance & SanitationQuality Assurance & Sanitation Validate HACCP SystemValidate HACCP System

Is testing product effective?

Lawyers and Risk Aversion Large buyers are driving food safety requirements and programs Judgments can be very large in food borne illness cases Damage to brand identity can be even greater Prominent retailers and food service companies are very risk averse about food safety In the absence of scientific data about risks, buyers are asking their suppliers to eliminate anything that COULD present a risk This sometimes leads to wasted resources, and environmental costs

Where is the FDA? Historically FDA has been little involved with fresh produce FDA is reluctant to issue regulations –Produce is extremely diverse –There is a lack of knowledge and data What should the regulations be? What steps would insure safety? There are lots of unknowns –There is a lack of resources

How Can We Fix It? More and better data Level the playing field - Regulation Make the producer/handler responsible for the process, not just the result Base actions on analysis of hazards Improve knowledge of food safety throughout the system Reduce regulatory ambiguity

QUESTIONS? Devon Zagory, Ph.D. Senior Vice President Food Safety & Quality Programs NSF Davis Fresh