Agriculture Reference
In-Depth Information
In view of continuing outbreaks associated with fresh and fresh-cut lettuce and
other leafy greens, particularly from California, we are issuing this second
letter to reiterate our concerns and to strongly encourage fi rms in your industry
to review their current operations in light of the agency's guidance for minimiz-
ing microbial food safety hazards in fresh fruits and vegetables, as well as other
available information regarding the reduction or elimination of pathogens on
fresh produce. We encourage fi rms to consider modifying their operations
accordingly to ensure that they are taking the appropriate measures to provide
a safe product to the consumer. We recommend that fi rms from the farm level
through the distribution level undertake these steps.
and
Foodborne illness investigations rarely pinpoint the point of origin of the con-
tamination. However, claims that “we cannot take action until we know the
cause” are unacceptable. We believe that there are actions that can and should
be undertaken immediately to address this issue. For example, at least some
outbreaks may be related to contamination that may have occurred in the pro-
duction environment. In June 2004, the California Department of Health
Services, Food and Drug Branch (CDHS-FDB) initiated multi-agency, collab-
orative research aimed at identifying the environmental reservoirs for
E. coli
O157:H7, and understanding how lettuce may become contaminated. In a pre-
liminary report presented at the August 2005 annual meeting of the International
Association for Food Protection,
E. coli
O157:H7 was isolated from sediment
in an irrigation canal bordering a ranch that had been identifi ed in three separate
outbreaks. The ranch is bowl-shaped; it sits upon a drained lake and is highly
susceptible to localized fl ooding. Expanded sampling in the Santa Rita Creek
and the Salinas Valley area indicate that creeks and rivers in the Salinas water-
shed are contaminated periodically with
E. coli
O157:H7. The specifi c source
of contamination that led to the outbreaks was not identifi ed. However, several
possible sources of contamination were identifi ed, both on the ranch initially
studied and upstream. Although it is unlikely that contamination in all 19 out-
breaks was caused by fl ooding from agricultural water sources, we would like
to take this opportunity to clarify that FDA considers ready to eat crops (such
as lettuce) that have been in contact with fl ood waters to be adulterated due to
potential exposure to sewage, animal waste, heavy metals, pathogenic microor-
ganisms, or other contaminants. FDA is not aware of any method of recondition-
ing these crops that will provide a reasonable assurance of safety for human
food use or otherwise bring them into compliance with the law. Therefore, FDA
recommends that such crops be excluded from the human food supply and
disposed of in a manner that ensures they do not contaminate unaffected crops
during harvesting, storage, or distribution. Adulterated food may be subject to
seizure under the Federal Food, Drug, and Cosmetic Act, and those responsible
for its introduction or delivery for introduction into interstate commerce may be
enjoined from continuing to do so or prosecuted for having done so.
For retail and foodservice establishments, the U.S. FDA 2005 Model Food Code
Section 3 - 302.15 specifi es: “Raw fruits and vegetables shall be thoroughly washed in
