Prepare For The Year Of Food Safety [Opinion]

Prepare For The Year Of Food Safety [Opinion]

Frank GilesIt only took four years, but the FDA released the Food Safety Modernization Act (FSMA) final rule on produce safety in November. So, now the work begins to decipher what it all means and the steps you need to take toward compliance.


Food safety is in the news again following the foodborne illness outbreak affecting Chipotle Mexican Grill. More on that later.

According to FDA, the rule for the first time has established science-based minimum standards for the safe growing, harvesting, packing, and holding of fruits and vegetables grown for human consumption.

There is a large emphasis on agricultural water in the new rules. It sets two criteria for microbial water quality both of which are based on the presence of generic E. coli.

No detectable generic E. coli are allowed for certain uses of agricultural water in which it is reasonably likely that potentially dangerous microbes, if present, would be transferred to produce through direct or indirect contact.

The second set of numerical criteria is for agricultural water that is directly applied to growing produce (other than sprouts).

For untreated groundwater that is used in a manner where no detectable E. coli is allowed, FDA will require farms to initially test the water at least four times during the growing season over a one-year period to determine if the water can be used for that purpose.

If the four samples show no detectable signs of E. coli, the farm is then only required to test water once annually. But, if any of the tests show detectable E. coli, the farm must continue or resume testing four times per year.

There is no requirement for testing water from public water systems that are certified or for water treated in compliance with the rule’s treatment requirements.

As these rules roll out over the next few years, will they improve the food safety of American grown produce? And, will they hold imported produce to the same standard as our growers here? Let’s hope so on both counts.

During our recent Florida Ag Expo grower panel, Del Monte’s Elvie Engle made a statement that stuck with me. He said he is bothered by the fact that his company and many others are already meeting and exceeding these very intensive requirements for food safety, yet these outbreaks continue to happen.

So, after all this time and investment in FSMA happens and with growers already following stringent rules set by retailers and foodservice, what happens if there is no discernible reduction in produce-related foodborne illness outbreaks? Do we double down with more government regulation? Or, do we focus science more on how these things spread in our system?

Back to Chipotle. One of its big marketing ploys has been “process, not processed,” meaning they prepare a lot of their produce on location at their roughly 2,000 outlets.

During the panel, Taylor Farms’ Leonard Batti noted Chipotle made a decision to move away from fresh-cut products to cutting at their chain locations. Suddenly, you have roughly 2,000 new vegetable processors pop up across the country. At the end of the day, Batti noted, it is a fast food restaurant and by its nature can’t ensure the food safety protocols like those in place in large, fresh-cut processors.
In the end, this may or may not have anything to do with Chipotle’s outbreak, but it is a cautionary tale for companies that build their reputation on a food elitist platform that sought to demonize “evil corporate agriculture.”

Turns out those big corporate farms have been working on food safety for a lot of years and should be recognized for it, not held out as the wrong way to farm as Chipotle chose to.

Leave a Reply

Chris Robb says:

Interesting article, what concerns me is the water rule, as you may recall there was an article in this journal on the work Koike and Suslow did in Salinas with e-coli, they couldn’t infect the lettuce seedlings with e-coli even though they planted it in the soil prior to seeding the crop. Even residual e-coli didn’t infect the next crop. This was real world non laboratory research. We overhead irrigate with agriculture ditch water collected in the mountains of Kohala, Hawaii. There are low levels of e-coli in this water, so what constitutes detectable? I have used drip but for a short 6 week crop cycle it is cumbersome to use drip, for small farmers to buy all the equipment to do it right it is very expensive. So are we the typical 20 to 40 acre farmer to just disappear from the scene, leaving it to imports to continue this unsustainable practice of importing all of our food? I got food safety certified 5 years ago but didn’t recertify because the rule keep changing and its hard to keep up with these changes.
Are small local farmers more of a threat to food safety or is the large central food processing facility with a large distribution network a bigger threat? The fear is this new rule will put all small and organic farmers out of business, can corporate America really feed the country? As it currently exists 80% of the food in this country is produced on family farms, if we are forced out by this new legislation where will the food come from? The worst part is the animal industry agreed 5 years ago to reduce the overuse of antibiotics but actually have increased the use by 30%. They are the source of these more virulent strains of e-coli and salmonella, what is being done about this more imminent threat?

April Ward says:

Chris – I believe that the requirement for no detectable e coli would be for water used on harvested product, not water used on irrigated crops.

FDA will be hosting several meetings and webinars to help growers understand how to comply with requirements. If you are a grower of leafy greens (like lettuce or spinach) you can also use our organization as a resource. The LGMA is a farm food safety program that has been operating since 2007. Our requirements are almost identical to what is required by FSMA Produce Rule.

Food safety measures have long been in place at most U.S. produce farms. This new law will formalize the system and provide additional government oversight to make sure the laws are being followed. And that’s a good thing for us all – Not just because it’s now the law, but because it’s the right thing to do.

keithsrv says:

Ohio Department of Agriculture seems to think it can happen with Ohio wineries. They want to regulate us as hazardous food processors, but the same is not necessary for imported wine. Wine has no history of food safety issues and wine kill all these known pathogens.