Security Exchange News

Study finds gap in food safety as possible legacy of Tester amendment

23 December 2020

This article makes it clear that there is an unmet need for additional food safety training, a need identified directly from research statistics.  In this reply, Security Exchange’s food specialists have made a number of points for the reader to consider:

  1. Many small growers are not members of professional associations such as United Fresh Produce Association and Leafy Greens Management Agreement, to name but a few. Such associations and institutions have codes of practice, training, internal and external audit schedules, and recognised sampling protocols to limit contamination of the product in question. Under the ‘Tester Amendment’, they are exempted from the food safety requirements of The Food Safety Modernisation Act and the third-party recognition which provides comfort that those holding membership do have an audited robust food safety system in place.  
  2. The lack of food safety knowledge outlined in the survey, reduces the chances that these companies and their employees will nurture a much needed ‘food safety culture’, a process which is considered paramount and is in fact required in companies to achieve third party recognition. Food safety culture is the product of individual and group values, attitudes, perceptions, competencies, and patterns of behaviour that determine the commitment to, and the style and proficiency of, an organisation’s food safety management system.
  3. Personnel, predominantly pickers who support the smaller growers, often move location and companies in the search for continuous employment in the active growing and picking season. Many will move several times and whilst the move to the new company may incorporate food safety precautions, experience has found that personnel may not fully embrace such, since the requirement may seem ad-hoc.
  4. The article by Dan Flynn, also notes that even though more than 51 percent of participants use bare hands for harvesting, 39 percent of growers do not provide hand-washing facilities for workers and 46 percent of the growers do not provide toilet facilities. With statistics such as these we can see how E-coli contamination, for example, is likely to cause illness and result in product recall, from a ready to eat product which receives little or no further process to eliminate the classic pathogen.
  5. To further quote Dan Flynn, 34 percent of growers use manure and 51 percent have domestic animals on their farm premises. This is a classic environment in which contamination of product is so easily achieved. Trained individuals can show by simple practical microbiology, how easily contamination takes place resulting in growth of pathogens to dangerous levels. Without such training the risks of contamination may go unnoticed and uncontrolled.
  6. Insufficient or complete lack of testing of irrigation water has resulted in several food borne disease outbreaks and product recalls in the past. E-coli is the main pathogen of concern and no facility should use irrigation water, from any source, without some form of benchmarking/testing the quality and yet in this study, it is reported that 87% of those surveyed fail to address this major factor to control and negate the risks.
  7. Many smaller growers, such as those represented in the article, sell their produce direct to retail outlets, farm shops and market stalls. If the exemption from food safety legislation, such as testing, training and lack of facilities remains as it is, then it is highly likely that contamination, leading to sickness, and product recalls will result. 

Security Exchange specialists applaud the work completed in the survey and the points highlighted in the article and hope that the recommendations made by the authors are available to all concerned soon. For access to our food safety services or to speak with one of our specialists, send a message to