The recent Romaine lettuce recall—two in the last year—has turned the leafy green industry upside down. Flashbacks of the 2006 spinach recall in California’s Salinas Valley haunt the area’s farmers, the same farmers who after the 2006 outbreak implemented stringent practices through the California Leafy Green Marketing Agreement aimed at stopping the next outbreak.

But it happened again. Why?

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Training for on-farm fruit and vegetable operations in the Produce Safety Rule is proceeding. The FDA and state departments of agriculture are offering on-farm educational inspections prior to regulatory inspections in their “educate before we regulate” approach. With the emphasis placed on worker hygiene, soil amendments, wildlife & domestic animal intrusion and irrigation water testing; I wonder if we may be missing an important aspect in post-harvest handling. Sanitation of harvest and packing shed equipment is critical to ensure pathogens don’t become established in the equipment and serve as a source of contamination.

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In a previous blog post, I explained that the new produce safety regulations released as part of the Food Safety Modernization Act (FSMA) do not address the cause of past foodborne illness outbreaks, leaving the produce industry in limbo. It also leaves consumers unprotected because they view most produce items as being “ready-to-eat” (RTE), meaning that they are able to be consumed without any additional washing or cooking. Regardless of where a farm or packing shed falls within the regulations, this perception by consumers raises significant concerns for public health, which then fall to the grower or packer to address. Continue Reading

Currently, the first stages of FSMA are being implemented, and the FDA is beginning to inspect facilities according to the new rules. In anticipation, companies in all sectors of the food industry are adjusting their food safety plans to meet the new requirements and pass inspections. Certain segments of the food industry, such as farms growing and harvesting fresh fruits and vegetables, are adjusting to new federal regulatory oversight that they have not experienced before. In particular, the processed fruit and vegetable segments are struggling with consumers treating their products as ready-to-eat, instead of their traditional use as raw agricultural commodities. This, coupled with the fact that the new regulations do not address the cause of past outbreaks, leaves the produce industry in limbo and the consumer unprotected. Continue Reading

The Food Safety Modernization Act has introduced many new food safety requirements to the food industry. In particular, FSMA places a focus on performing a hazard analysis and using preventive measures in food manufacturing. The requirement to develop and implement supplier preventive controls for raw materials and ingredients to address hazards has renewed interest in methods for sampling and testing raw materials. In order for sampling and testing to be used to address pathogen concerns identified in the hazard analysis of raw materials, a valid sampling plan must be in place. Continue Reading

As the Food and Drug Administration (FDA) moves forward with Food Safety Modernization Act (FSMA) implementation, food companies are beginning to realize the need for effective environmental monitoring procedures to minimize microbial cross-contamination and allergen cross-contact. In developing the Preventive Controls Rule for Human Food, the FDA revised the antiquated Good Manufacturing Practices (GMPs) once contained in 21 CFR Part 110 and now published in 21 CFR Part 117. In doing so, the FDA has been very specific in addressing environmental contamination in the revised GMPs and in the new Preventive Control regulations.  Continue Reading

For over 20 years, the food industry has been steadfast in our view of the role of sanitation in classical Hazard Analysis Critical Control Point (HACCP) programs. Our experience with meat and poultry HACCP by way of the International HACCP Alliance and what came later with Global Food Safety Initiative (GFSI) HACCP requirements solidified the supportive role of sanitation as a food safety prerequisite program. We have managed sanitation as a separate prerequisite program, and then used these programs to eliminate the need for sanitation critical control points. However, compliance with the Preventive Controls Rule for Human Food (PCHF) as part of the Food Safety Modernization Act requires a different approach in how we manage sanitation procedures that directly addresses a food safety hazard identified in the hazard analysis. Continue Reading

Thirty two years ago, regular discussion about the field of food safety did not exist. Back then, information on food safety came from a limited number of sources. This included the ICMSF (International Commission for the Microbiological Specification for Foods) organized in 1962, the International Association for Food Protection (then called the International Association of Milk, Food and Environmental Sanitarians) organized in 1911, and a few loosely organized regional associations consisting primarily of academicians and state health departments. Sourcing information proved to be difficult, and books on the subject were limited and costly. Continue Reading