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Making Leafy Greens Safer by Reducing the Opportunity for Pathogen Contamination

11 May 2021

There has been a move by two major institutions, the Controlled Environment Agriculture Food Safety Coalition (CEA) and the California Leafy Greens Marketing Agreement (LGMA), prompted by the Food and Drug Administration (FDA), to ensure that the production of leafy greens is both safe and compliant.

In April 2021, recurring contamination of leafy greens in the Salinas with a strain of E-coli resulted in the FDA declaring said contamination to be ‘a reasonably foreseeable hazard’.  As a direct result, there is now the potential that the FDA will consider that the commodity group will be in violation of food safety legislation unless mitigating steps are taken.

Within the legislation, growers/processors are required to implement science and risk-based analysis to reduce the incidence of harm to health from pathogens, in this case, resistant E-coli.  Without a doubt, the requirement will be implemented throughout a much wider based production area since producing food contaminated with E-coli is in breach of federal food safety legislation.

The statute has been around for several years and, in some cases, contamination has been severe with many deaths, systemic illnesses, product recall, and loss of market share.  Now, surely, things must change. 

To meet the statutory requirement, these two institutions have made substantial recommendations and requirements to reduce the incidence of contamination with E-coli and, of course, other possible pathogens.

The CEA, for example, has a product safety module that is science-based and risk assessed.  It must be completed to show compliance with certification indicating that the product has been produced indoors to minimize contamination from several sources.  This enables producers and processes that use controlled environment agriculture to label products, avoiding product withdrawal and recalls which are frequently linked to environmental/animal contamination, poor water quality, and inadequate irrigation.  This method of controlled environment agriculture, where crops are not affected by external sources, uses technology without chemical treatments such as pesticides and is considered to be less problematic. 

The LGMA requires members to be audited for compliance and has now also taken a further step mandating that members are now required to be audited, annually, including pre-harvest testing.  Although pre-harvest testing is nothing new, the take-up was poor.  The methodology used for pre-harvest testing incorporates methods approved by the FDA. 

The picture is clear: now the FDA has declared E-coli contamination to be ‘a reasonably foreseeable hazard’ and since most legislation is now based on risk assessment, action is required to prevent contraventions taking place.

Security Exchange food safety experts will be happy to provide interested parties with information on how to achieve the Gold Standard which will lead clients through the requirements to achieve compliance.  

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