Food Safety News is reporting this week that the Food and Drug Administration has aimed an “unmistakable warning shot at the leafy greens industry.” FSN says the actual warning came in a column from Mike Taylor who co-chairs the board of the non-profit group “Stop Foodborne Illness” that represents foodborne illness victims and their families in efforts to keep people from getting sick.
Taylor has a long history with the industry. He served as FDA's Deputy Commissioner for Foods and Veterinary Medicine from 2010 to mid-2016 and later worked for USDA's Food Safety and Inspection Service, where he was acting under secretary for safety.
FSN reminds that Taylor was the official who, after the deadly 1992-93 Jack in the Box hamburger outbreak, ruled that the pathogen E. coli O157:H7 “is an adulterant in meat.”
Taylor says that he hopes the recent FDA warning will serve as a call to urgent action that gets to the root of the problem of the persistent dangerous E. coli in the growing environment for leafy greens and other fresh produce.
He says the warning cited the recurring nature of the E. coli hazard in the Salinas and Santa Maria growing areas and declared the recurring strain implicated in the 2020 outbreak to be a “reasonably foreseeable hazard,” which it attributed to the presence of cattle on land adjacent to growing fields.
This finding seems obvious and shouldn't be surprising, Taylor thinks, but noted that the surprise is that FDA used regulatory language to spell out implications: farms covered by the current produce safety rules “are required” to implement science and risk-based preventive measures to minimize the risk of serious illness or death from the E. coli hazard.
Make no mistake, he says, FDA's message is aimed not only at farms but at every entity involved in the commercial production, processing and sale of leafy greens coming from the California Central Coast Growing Region. The message is that, without effective preventive measures, important quantities of leafy greens will be in persistent violation of federal food safety regulatory standards.
He does not anticipate FDA taking extensive judicial action to enforce its April 6 finding, absent egregious practices or clear negligence in a particular leafy green growing situation. He does see, however, a heightened sense of urgency at FDA and frustration that efforts to date have not solved the leafy greens safety problem. He shares that frustration, he says.
Fifteen years ago, the disastrous spinach outbreak caused by E. coli O157:H7 was linked by the Centers for Disease Control and Prevention to run-off from nearby grazing land, he recalls. “Since then, we've had outbreak after outbreak associated with E. coli in leafy greens and other fresh produce. And the outbreaks are just the tip of the public health iceberg. The federal government estimates that 60% of all food-related E. coli O157:H7 illnesses are associated with fresh produce. The vast majority of these illnesses are not part of an identified outbreak,” he concludes.
Recent E. coli outbreaks and illnesses persist despite a lot of hard work by a lot of people in the leafy greens industry, researchers, the California Department of Food and Agriculture, the FDA and its federal partners, Taylor says. He mentions groups he works with and says he knows “serious people are at work on the problem.”
Then he asks what actions does public health demand?
At one level, the answer to these questions are the same he says--the leafy greens industry and all those across the leafy greens supply chain and in government should be doing everything they can to minimize the “now well-known risk posed by E. coli O157:H7.” Certainly, this includes preventative measures within the leafy greens production system, such as strict implementation of rigorous water quality and irrigation standards, improved compost management, sanitation of harvesting equipment, and pre-harvest test-and-hold programs.
He also thinks that modern food safety best practices dictate that prevention should begin at the root of the problem -- and that as long as leafy greens are grown outdoors in the vicinity of cattle operations, the food safety problem will persist. However, he notes that effective vaccines are available. Changed feeding practices have promise. Perhaps containment measures can reduce risk.
He adds that it is clear that “no responsible food manufacturer would today deem it acceptable to produce food in an environment in which dangerous bacteria are being released or are present on a sustained basis. The same principle should apply to leafy greens and other fresh produce grown outdoors.”
However, he notes that neither greens producers or cattle producers can exert “the necessary direct control over the source of the hazard, in many cases.” That is why FDA Deputy Commissioner Frank Yiannas calls for “industry leadership and collaboration among growers, processors, retailers, state partners and the broader agricultural community,” including cattle producers, Taylor argues.
He says he is “glad” the alarm has been sounded and that even though the kind of leadership needed is difficult in a “notoriously fragmented” sector, he thinks too much is at stake for all concerned to let such obstacles stand in the way. He says “now is the time for leaders from all across the commercial value chain and government to act together, with greater urgency, to get to the root of the problem.”
So, we will see. Clearly FSN and Taylor have strong voices throughout the industry and their ideas can be expected to attract attention. Whether or not this will be adequate to control this growing safety problem remains to be seen and should be watched closely by producers in the months ahead, Washington Insider believes.