1. 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

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

3. 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

4. 1998 – 2006 Produce Outbreaks 30% 17% 13% 11% 24% 5% Top 5 produce items make up 76% of outbreaks

5. Produce Outbreaks 1973-97 (190) 54% pathogens identified From presentation to produce associations, January 2004, Lynch and Tauxe, CDC

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

8. 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

9. Tomatoes Washed with Chlorinated Water S. montevideo Log CFU/cm 2 0 1 2 3 4 5 060110210320 Chlorine (ppm) Zhuang et al, 1995

10. 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

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

12. 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

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

14. 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

15. 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

16. Is testing product effective?

17. 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

18. 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

19. 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

20. QUESTIONS? Devon Zagory, Ph.D. Senior Vice President Food Safety & Quality Programs NSF Davis Fresh dzagory@nsf.org 530-219-7489