The new “metrics” for members of the Arizona Leafy Greens Marketing Agreement are effective immediately. Officials with the grower consortium said inspections are set to begin in November. Arizona growers plant romaine at this time of year, with their harvest season usually running from November through mid-March.
The revised requirements in Arizona involve:
Daily cleaning of equipment;
More extensive review of crop impact after weather events such as flooding or high winds;
Mandatory traceability measures; and
A 1,200-foot minimum buffer zone between growing fields and feed lots with 1,000 or more animals. Previously the buffer requirement was 400 feet.
“Arizona farms take these food safety practices very seriously and are committed to doing everything possible to prevent future outbreaks,” said Arizona LGMA Food Safety Committee Administrator Teressa Lopez.
Another new provision deals with treatment of water used for overhead irrigation, said Scott Horsfall, CEO of the California LGMA organization.
Together California and Arizona produce 90 percent of the leafy greens consumed in the United States, according to LGMA statistics. The members-only LGMA grower consortiums are non-profit entities that operate under the administration of state agriculture departments.
Horsfall told Food Safety News the California group expects to approve new metrics by the end of September. He said the proposed requirements are virtually identical to the new Arizona rules. California romaine growers usually start planting in November for their harvest season, which generally begins in late March.
A wake-up call
In early April this year, outbreak investigators pinpointed romaine from the Yuma, AZ, growing area as a common denominator for victims in the E. coli O157:H7 outbreak. At least 210 people in 36 states were eventually confirmed infected, with at least 96 requiring hospitalization. Five patients died.
In mid-May federal officials reported they had found the outbreak strain of the bacteria in water from open canals. Those canals run through and adjacent to romaine growing fields and concentrated animal feeding operations (CAFOs or feedlots). At least one of the feedlots in the Yuma area can house 100,000 cattle at a time.
Many in the food safety arena describe this year’s outbreak as a game changer.
“Everyone realizes it can’t be business as usual,” Horsfall said.
Top leaders in government and industry agree.
Bob Whitaker, chief science and technology officer for the national Produce Marketing Association, describes this year’s romaine-related E. coli outbreak as a seminal moment for everyone in the fresh produce supply chain. His Ph.D in biology and his resume give him a perspective different from most people in the country.
Before joining the Produce Marketing Association (PMA) in 2008, Whitaker worked in food safety and product development for 10 years at NewStar Fresh Foods and its subsidiary, MissionStar Processing, where he was vice president of process operations. He also helped found LGMA following a deadly 2006 E. coli outbreak that was traced to fresh spinach. That outbreak sickened 199 people, killing three.
“A change in awareness and recognition that (contamination) is an issue is more powerful than any other factor,” Whitaker said of this year’s outbreak. “We need to pay attention to the research very closely.”
Stephen Ostroff, deputy administrator of the Food and Drug Administration, compared the E. coli outbreak this year to a canary test in a coal mine. He said enforcement of the produce rule mandated by Congress as part of the Food Safety Modernization Act is a good place to start. But regulators can’t, and don’t want to, do it alone.
“It’s a very strong signal (this spring’s outbreak). It’s time for industry to get serious and comply with FSMA,” Ostroff said during an interview with Food Safety News at the annual meeting of the International Association for Food Protection in July.
“We don’t want to go in for a ‘gotcha’ deal, though. … This is a very teachable moment.”
Viewpoints and visions
The diagram of this year’s romaine-related E. coli outbreak is not yet completely drawn, and likely won’t be for several more months at the least. As academia, industry and government continue to search for the root source of the bacteria and how best to avoid future contamination, key players on all fronts have distinct views.
Some in industry are frustrated with government. Some in government are frustrated with industry. Academics are frustrated by non-existent data. Consumers are frustrated by vague answers they see as less than helpful.
Consumers want safer food, and they want it yesterday
Some in the consumers’ corner believe there should be a shorter route to stronger food safety measures. Individuals, advocacy groups and some elected representatives would preferred to travel as the crow flies. They say government and industry should have picked up the pace this year.
Entities such as Consumers Union contend the 2006 spinach outbreak should have blazed a trail leading to quicker detection and containment of this year’s romaine outbreak. The organization’s affiliated publication, Consumer Reports, aggravated the leafy greens industry this year with a blanket warning urging the public to avoid all romaine instead of just that from the Yuma, AZ, area.
“Consumer Reports’ food safety experts are advising that consumers stop eating romaine lettuce until the cause of the outbreak is identified and the offending product is removed from store shelves,” the advocacy group recommended on April 16.
Three days later a U.S. Representative chastised top administrators at the CDC and the FDA in a letter about the federal government’s response to the outbreak. She specifically criticized the agencies’ recommendations to consumers.
“I am alarmed by the inconsistent advice that your Agencies’ have given to consumers,” wrote Rep. Rosa DeLauro, D-CT. “Consumers … across the county, are confused as to whether they should avoid all romaine lettuce or just romaine lettuce that was grown in the Yuma, AZ, region. For an outbreak of this size and severity, that kind of confusion is simply unacceptable.”
More from FDA’s Ostroff
As the agency’s deputy commissioner, Ostroff is in the position of protecting the public from unsafe food while balancing the realities of science and industry.
“Yuma is a very large growing area,” Ostroff told Food Safety News at IAFP. “You just can’t go in and test everything. It’s too big. … To put resources and testing out there you need to have some kind of idea where to begin.”
Ostroff openly admits there are questions remaining, some of which may never be fully answered. By the time the outbreak was identified by public health officials, the romaine harvest in Arizona was finished and fields had been tilled. Soil samples would have been useless by then. The short shelf life of romaine meant product samples were virtually impossible to find or test.
Even with the finding that the outbreak strain of E. coli was in the canal water, Ostroff describes the situation as an enigma.
“How could the water contaminate such a large area” is a key question, Ostroff said. Another he, says, is how did the water itself become contaminated. “I hope to get actionable information. That’s what we all want.”
Leafy greens and CAFOs
Even though a concrete connection hasn’t been documented between the feedlot operation near the Yuma romaine fields and the E. coli outbreak, the proximity of huge herds of cattle in dirt pens is not something that can be ignored.
Leafy greens growers have previously acknowledged the importance of buffer zones, requiring members of the LGMA organizations to provide acreage for them. Increasing the minimum buffer distance from 400 to 1,200 feet in the new requirements reflects some research findings and some best guesses, according to government, academic and industry sources.
“It’s a complex issue,” PMA’s Whitaker said. “One thing the industry wants to do is use science.”
Whitaker referenced a study led by Elaine D. Berry at a USDA research station in Nebraska that looked at E. coli O157:H7 drift from a feedlot to adjacent plots of land she planted with spinach. The two-year research project showed the virulent bacteria found in the feedlot dirt was blown on to leafy greens 600 feet away and possibly further. Limited land availability did not allow for testing of longer distances.
Berry reported the study suggested that buffer guidelines of 400 feet may not be adequate to limit the occurrence of E. coli O157:H7 in crops planted near concentrated animal feeding operations. Whitaker said the new LGMA requirements err on the side of caution partly because of Berry’s research.
“At the end of the day we thought, we know what goes on at 600, not beyond. We decided we should double it to 1,200,” said Whitaker, who was tapped to be on a special leafy greens task force formed this year to develop new guidelines.
The CEO of the California LGMA has a similar opinion on increased buffer distance. But, Horsfall doesn’t see it as all the responsibility of the leafy greens growers.
For feedlot operations that are already in place, there’s not a lot that can be done to require them to bear the burden of idle land. That means fresh produce growers have to cut into their money-making acreage to provide adequate separation. That doesn’t have to be carried forward, though.
“We are starting to talk more with the cattle people and the USDA, which has jurisdiction,” Horsfall said.
New research projects set to begin in the next year or so and data that is still being collected and analyzed from this year’s outbreak investigation is expected to inform those conversations between the two factions of American agriculture.
The non-profit Center for Produce Safety has helped fund previous research on feedlots and produce fields and additional projects are anticipated. The California-based center just issued its annual call for research proposals. But, Executive Director Bonnie Fernandez-Fenaroli said the center and its board are moving forward cautiously.
“We have to reach out beyond the produce industry to the animal ag industry and work together,” Fernandez-Fenaroli said this past week.
“We’re holding off on CAFO (projects) until we drill down on what we don’t know. We want to do it right.”
