Meeting the Challenges of Produce Supply Chain Safety
By An interview with Edith Garrett
For more than 20 years, Edith Garrett has been a fresh produce industry insider, leading efforts to meet the challenges of food safety and quality assurance at all links in the supply chain. Currently president of Edith Garrett & Associates, Inc. (www.edithgarrett.com), a consulting firm with expertise in the fresh fruit and vegetable industry focused on developing tools and processes to assist companies with food safety and quality issues, supplier certification, regulatory requirements, crisis management, strategic planning and research and development, Garrett previously served nine years as president of the International Fresh-cut Produce Association (IFPA). In her role at IFPA, she was the industry spokesperson; organized a world-class technical department; and directed educational programming, strategic development, operations management and market trends analysis for the association.
Prior to joining IFPA, Garrett gained extensive industry experience from eight years serving as the director of environment and quality assurance for South Bay Growers, Inc., a Florida lettuce and celery grower/shipper/processor, where she developed, from the ground up, the company’s quality assurance monitoring program for the fresh-cut produce processing facility, built and operated the microbiology and shelf life laboratory, and worked extensively with foodservice customers, including McDonald’s and Burger King. She also served on the U.S. Department of Agriculture’s Agricultural Technical Advisory Committee for Trade in Fruits and Vegetables from 2001-2003 and numerous other industry committees.
Recently, Food Safety Magazine tapped into Garrett’s produce category expertise to discuss state-of-the-industry issues and challenges in assuring food safety.
Food Safety Magazine: With a recent spate of produce-related recalls that affect the whole supply chain—from field and packinghouse, to processing, distribution and retail/foodservice—the category as a whole has come under scrutiny about how food safety is assured by produce industry growers and producers. In your opinion, why the confluence of these “wake-up” calls?
Edith Garrett: I think that there are many factors that have come together to put the safety of fresh and fresh-cut produce on the radar screen. The trend toward globalization of the food supply chain and the import of produce commodities into the U.S. at higher volumes have captured the public’s attention and consumers are actively seeking to understand more about where their foods come from, especially in light of the fact that a large percentage of imported products go uninspected in terms of food safety. The “buy local” trend has come out of this consumer perception that we are importing too much food with little food safety oversight. There is more attention by the media and more follow-though by news oulets when there is an outbreak associated with produce.
Another factor, in my opinion, is that the state departments of health are getting better at investigating outbreaks and so there is more data available about potential food contamination situations. State inspectors and and public health professionals are seeing some unexpected foods popping up with food safety issues more often and so they are adding those unconventional foods to their checklists when conducting investigations. Some states have honed their talents and techniques and become trend-setters, if you will, in identifying outbreaks that are associated with produce, such as Minnesota, Wisconsin, Florida, Washington, California, and New York.
New research is also being conducted, which is generating more data and information with regard to produce and how pathogens are related to them. All of these factors, or new information sources, whether state or federal health agencies, the media or the general public, are leading to more focus on produce.
Food Safety Magazine: What are some of the initiatives in progress that may help the produce supply chain to be proactive with regard to food safety?
Garrett: As the size of the Salinas County E. coli O157:H7 outbreak associated with fresh spinach attests, there is an information gap within this large and complex commodity chain that is due to a lack of a comprehensive traceability system. This is an inherent weakness in the produce industry that we don’t see in processed food or other organized food supply chains. Prior to the 2006 spinach case, we’d never had an FDA outbreak announcement associated with an entire category of a product; the agency has historically announced recalls by naming a specific product with a specific SKU produced by a specific company. This recall marked the first time FDA has ever identified one commodity group in its entirety as the subject of a recall, and they had to name the entire commodity because the traceability information was lacking.
So one of the more proactive initiatives just announced by some of the leading produce trade associations—Produce Marketing Association (PMA), Canadian Produce Marketing Association (CPMA), and United Fresh Produce Assocation (UFPA)—is a joint effort to implement traceability standards within the industry (see “Joint Produce Traceability Initiative Launches,”).
There was a document introduced several years ago that resulted from a combined effort between PMA and CPMA to identify basic guidelines for traceability, but now all three associations are working to get the word out and motivate the industry to implement these guidelines. I think the industry is doing a good job going one step up toward the consumer, but it is the one step back component of a traceability system that needs better guidelines and better tracking. The guidelines identify basic tools such as tags on the product containers as they come out of the field and describe how to monitor that product once it begins to be pooled together in packing and cooling operations. The guide ties together the tagged product with the paperwork that also contains the appropriate traceability lot code identifiers.
From a regulatory standpoint, FDA has been working to understand the scope of the produce issue within their own ranks. But it is an enormous industry and has many levels of handling and distribution, so this has not been an easy task. In early October, the agency issued a statement on one of its leading initiatives, the Leafy Greens Safety Initiative, which is now in its second year of implementation. A multi-year collaborative effort of FDA and the State of California’s Departments of Public Health and Food and Agriculture that began in 2004 focuses on risk assessment and preventive food safety efforts for high risk fresh and fresh-cut produce products, first focused on lettuce in response to the E. coli O157:H7 outbreaks of 2006. The FDA and state inspectors have just begun to visit farms in California to evaluate factors in and near the field environment which may contribute to potential contamination of leafy greens with E. coli O157:H7 and the extent to which Good Agricultural Practices (GAPs) and other preventive controls are being implemented. To further focus this risk-based approach, collaborators have been reviewing data to identify areas where co-existing environmental risk factors are present. Data analyses and GIS mapping will be followed by preliminary assessments to confirm the data analyses and to finalize site selection for the field assessment. The agency noted that the findings of the 2007 Leafy Greens Safety Initiative will be shared publicly upon completion of the effort, to allow state officials and members of the industry to maximize their food safety efforts.
In the academic arena, produce industry expert Devon Zagary is taking the reins of a new Center for Food Safety, University of California-Davis, which is being funded by PMA, Taylor Foods and the university. According to the October press release, they have $4.5 million to get this new center off the ground and it will be a clearinghouse for all research related to food safety and produce, acting as a gathering point for information. In general, we’re also seeing a lot more research papers being published on the interactions of specific pathogens and produce, as well as studies on soil or other agricultural practices and how they may affect the pathogenic survival rate or actual contamination rates.
Food Safety Magazine: Does risk assessment offer solutions for produce companies that want to enhance their food safety compliance rates?
Garrett: For this industry, risk assessment is a powerful tool. We need to identify the commodities that pose more risk than others, whether microbiological, chemical or physical hazards, so that we can focus attention on areas where we can make the most progress in assuring food safety and deliver the most benefit to the public. To do that, we must have quantifiable data to measure the risk associated with each commodity. A good way to begin the process of risk assessment is to look at the available foodborne illness outbreak data and analyze that information to understand how each commodity is or has been historically associated with various outbreaks in the U.S. The FDA has conducted many specific studies on pathogenic contamination of imports and domestic produce products and commodities that can provide valuable information in this regard. From a food safety standpoint, a produce company will need to concern itself not only with evaluating the risks posed by microbiological contaminants but also chemical and physical adulterants. There are still some concerns about produce contamination by pesticides or other chemicals used on produce in the field or even those that are naturally occurring, such as mycotoxins in mushrooms or patulin in apples. Companies can review market basket studies that are conducted year after year on specific foods to zero in on the produce items that have been tested and identify trends within commodity groups. We are interested in those commodities that have tested postive for pesticide residues, either because they are out of tolerance or for those where there is no tolerance established.
Beyond that, there is a category we use in doing a risk assessment that is considered “industry knowledge,” which can be used to identify potential threats, as well. In cases where there may not be specific science-based trending data available there is often an oral history from long-time experts in the industry or within the company, or data that can be culled from your own company’s external complaint records. Are you getting complaints about rocks or metal inclusions, or are customer complaints centered on general quality issues? Finding out what your consumers are calling in about is a good way to spot risk trends. In other words, look at whether you can quantify within your own company’s history the incidence levels of physical, microbial or chemical contaminants. Gathering industry knowledge may also include networking with industry colleagues at other companies who are in the same line of work to find out what their trending is showing. In other words, use your industry knowledge to identify commodities for which there are indications that they pose a higher food safety risk for some reason.
I recommend this approach to risk assessment because we don’t have much government or research related information to fall back on. The message is that when you are doing a risk assessment you want to be sure that you are using real, measurable data that is quantifiable so that you can back up your findings and focus your resources to be proactive and really mitigate your risks. An example is FDA’s focus on five commodities that consistently show the highest incidence rates of pathogen contamination as a result of the agency’s own outbreak data (Table 1). They have released specific guidelines for these commodities, as well as for fresh-cut produce.
After you’ve identified your risk, now what? Well, let’s say you are a carrot producer and your product doesn’t show up as a high risk commodity for microbiological contamination; however, it does show up as a higher risk item when looking at chemical contamination data. If, for example, the product testing occasionally shows pesticide residues that shouldn’t be there, then you will need to focus your food safety action plan on the chemical risk. You don’t want to forget entirely about microbiological or physical contaminants but you’d likely want to address your activities and put more funding towards monitoring, reducing and addressing the risk category into which your commodity falls and keep producing test results according to GAP guidelines. Monitoring might include testing irrigation water, looking at employee hygiene and how well field or processing plant workders are following the rules to operate a clean or sanitary way. Our fictional company will need to look more closely at how pesticides are being applied and by whom, and how they are handling their record keeping for traceability purposes. Ultimately, the approach you take to assessing risk for your operation is dependent on the risk and the commodity. If you are a company producing more than one commodity, then you would want to have a risk assessment focused on the commodities first followed by a risk ranking.
Food Safety Magazine: How can food companies ensure that their supplier certification programs are effective?
Garrett: Today, most produce buyers want to know, ‘Where are my risks as they specifically relate to the list of produce commodities that I buy on a daily/weekly/monthly basis?’ Risk assessment is a tool that makes sense for more and more produce buyers and provides the best foundation to ensure that the supplier certification program is effective. Buyers should look at the suppliers of high risk commodities and focus attention there, making sure that those suppliers’ food safety programs are up to date and include critical components that are required by law and meet industry standards. From a supplier certification standpoint, it is important to look at what would be the critical or key components of a food safety program that will reduce risk from microbiological, physical or chemical hazards. Once high risk commodities have been identified, the buyer can then look at the supply group and make sure those key elements are present. If not, the company or their consultants can help the supplier develop or modify their food safety programs to meet buyer’s specified standards.
The supplier certification program applies upstream in the supply chain. When McDonald’s is buying fresh-cut produce, their program should drill down further, not only requiring the fresh-cut processor to document that they have met the food safety specifications but also that the processor’s supply chain partners—the growers and distributors—can prove the efficacy of their food safety practices, as well. Every processor should be looking at their own supply sources, and even growers—it is inherent in this business that growers may have one name but they may be buying produce from many smaller growers. So, even at the growing level, the companies should be looking at who their suppliers are from a standpoint of risk and certification.
One of the food safety programs that we see as being a critical key element within an overall food safety system and the supplier certification program is the third party audit. In the produce industry third party audits are frequently required in contracts, but the buyers’ follow-up to assure that suppliers meet certification program requirements is maybe not as good as it could have been on the buyer’s part. So as a buyer, follow up on the audit to make sure there is action taken for those critical areas that were deficient. Be more observant about how the audit is conducted, what are their processes, and make sure that you are familiar with that auditing company, laboratory or government agency This is an area that needs a lot of discussion within our industry. I think that there has been a blanket statement by a buying group that you need a third party audit or a specific audit by a specific company without regard to the third party audits already in place and it causes a lot of confusion and adds cost to the system.
Food Safety Magazine: What is the primary take-home message for the produce industry at this point in time?
Garrett: Know your products and conduct risk assessments to identify weaknesses in your food safety programs. For instance, salsa shows up a lot in outbreak data as a source of pathogens, and when you look at the ingredients it shows that a lot of produce is going into an acid-based product—you’ve got the tomato which FDA says is a high risk commodity and you’ve got cilantro which is a high risk herb, so you really have to be aware of the ingredients in the final product you are producing. Salsa can be made safer by assuring it has a finished pH of 4.2 or lower so there are proper steps to be taken. We’re getting into so many new, fresh and fresh-processed foods that are available to the public to buy that you have to be clear about the characteristics of the food, their ingredients and where they are coming from, identifying the high risk ingredients, and the appropriate shelf life and handling instructions for the consumer.
In general, I think that produce is becoming more readily identified with outbreaks and contamination, but it is also in more demand by consumers. I think anyone handling produce needs to understand what the risk factors are and understand the finished product they are selling so they know they are handling a safe product. We’re going through so many changes in the way food is produced and sold nowadays that it may be happening faster than we can keep up with. Make sure you are able to identify risk categories, best auditing practices, proper handling procedures and good traceback systems.