Dan Okenu, Ph.D., Food Safety Manager, H-E-B
Retail Food Safety Forum

Benchmarking Produce Safety in the New FSMA Regulatory Climate

By Dan Okenu, Ph.D.
No Comments
Dan Okenu, Ph.D., Food Safety Manager, H-E-B

Produce safety featured prominently in the recently concluded Food Safety Consortium in Chicago November 17-18, 2014 for two reasons: First, produce remains the largest source of foodborne illness outbreaks in the United States, and second, the recent supplemental notice by FDA calling for another round of public comments on the proposed rule for “ Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption .”

Produce safety featured prominently in the recently concluded Food Safety Consortium in Chicago November 17-18, 2014 for two reasons: First, produce remains the largest source of foodborne illness outbreaks in the United States, and second, the recent supplemental notice by FDA calling for another round of public comments on the proposed rule for “Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption.”

Thus, a consortium of growers, processors, packers, suppliers, retailers, buyers, innovators, regulatory officials and food industry consultants came together in the retail foodservice track to discuss “Benchmarking Produce Safety from Farm to Fork.”

The central question revolved around compliance with FSMA provisions to continue supporting the availability of safe quality food in a cost-effective manner. Issues surrounding the provisions of foreign supplier verification and how to engage with FSMA-exempt small local growers and suppliers on produce safety were discussed. The thorny problem of a quick and reliable traceability system for produce was also addressed. Other issues that were discussed include: how to ensure and verify good agricultural practices in the farms; introducing a safe and effective kill step in both cut and whole produce; and how to avoid cross-contamination on washed ready-to eat (RTE) fruits and vegetables. We also deliberated on how to close the gap in-between FDA audits to ensure that proper food safety practices are in place all year round.

The consortium brainstormed on how to take the current produce safety industry practices to the next level, towards a science and risk-based preventive approach as provided for in FSMA. To adequately address the issue of auditing gaps and the FSMA foreign supplier verification provision, it was suggested that it could be cost-effective for large scale buyers to embed their employee on site with large scale growers, processors and suppliers, especially for those located in foreign countries. This will support a real time status update on the food safety practices in place at such foreign facilities by your corporate employees, and in fact reduce the need for expensive frequent and auditing visits that don’t really capture everything. It can also be a conduit for training and maintenance of corporate food safety and quality standard to enhance the delivery of safe quality products, especially if your company is doing business in developing countries where food safety policies and regulatory enforcement are still in rudimentary stages.

Alternatively, make it a corporate policy to do business with only GFSI-certified facilities and increase the frequency and duration of unannounced audit visits for a more representative assessment and documentation of the prevailing food safety practices in place.

In addition, some private-label food programs involve ownership of farms, manufacturing plants and processing facilities. Thus, some retailers operate their own farms and plants both here in the United States and in foreign countries, and that may enhance active managerial control on produce safety from farm to fork. Engaging small local growers who are FSMA-exempt through an organized Agricultural Extension Services will enable resource sharing for implementing standard food safety practices and support integration in the local market. It will not only bring down cost but will also increase the availability of fresh fruits and vegetables without the need of a long distance temperature-controlled distribution network.

Both government and the private sector can support the running of these extension services in a more robust manner that builds upon the current USDA Cooperative Extension System which provides useful, practical research-based information to agricultural producers. A safety gateway could be established for produce from local growers through innovation on an effective pathogen kill step that can achieve up to 5-log reduction using effective consumer-friendly sanitizers.

GRAS classified sanitizers like electrolyte water, Ozone, hydrogen peroxide, chlorine dioxide and sodium hypochlorite are under various stages of R&D and some have been found to extend produce shelf life as well. Since the absence of a microbial risk does not preclude chemical contamination; continuous testing and monitoring for chemical residues that may result from the use of pesticides, contaminated soil or manure is recommended. A reliable produce traceability system will facilitate the investigation of foodborne illness outbreaks and timely corrective actions.Current R&D innovations in this area include the use of DNA tagging to assist in identifying both cut and whole produce even when out of the box. It was also stressed that behavior change is as important as the technology-driven interventions, and as such should be encouraged among retail and foodservice workers to embrace best practices and avoid actions that may lead to cross-contamination of RTE foods. Washing and rinsing of produce singly in running cold water is not only recommended for removing dirt and foreign matter but also for eliminating potential cross-contamination that may result from soaking fruits and vegetables.

Overall, it was a lively discussion that was spiced with practical real world examples by highly experienced industry leaders and decision makers.

About The Author

Dan Okenu, Ph.D., Food Safety Manager, H-E-B

Leave a Reply

Your email address will not be published. Required fields are marked *