Teressa Lopez – Arizona Leafy Greens Marketing Agreement (LGMA)

Shoon Phyo2023-02-15T08:11:33-08:00February 15th, 2023|

February 14, 2023
Arizona Leafy Greens Technical Subcommittee Comments on Pre-Harvest Product Testing

The Arizona Leafy Greens Technical Subcommittee (TSC) met on February 14th 2023, the meeting agenda included a review and discussion of the proposed document, 18. Issue: Pre-Harvest Product Testing (PHT) Pilot Program for Romaine. After careful consideration, the Arizona Technical Subcommittee supports a research approach based on environmental hazard and risk assessment rather than a LGMA metrics pilot program concept to accomplish the goals outlined in the introductory paragraph of section 18.

The Arizona TSC concurs with the statements regarding the potential benefits of a pre-harvest product testing program and insights into food safety system performance. As stated, “pre-harvest testing program’s objective is to increase the understanding of how practices may affect contamination, contamination prevalence over time, risk factors, and to inform the continual improvement of industry prevention efforts.” In an effort to reinforce this work the Arizona LGMA did adopt standards that require shippers that are conducting PHT to have standard operating procedures (SOP’s) to guide their programs. Additionally, the Commodity Specific Food Safety Guidelines for the production and harvest of lettuce and leafy greens (Metrics) require that PHT be completed if the environmental assessments deem it necessary.

The Arizona TSC believes if we are to aid the industry in the understanding of risk potential and prevention strategies, a research study should be designed and conducted based on a standardized sampling protocol, assessment of field and adjacent land hazards and risk factors, mitigation strategies, differences in product characteristics, and evaluation of sampling plan designs at a minimum.

The LGMAs are structured to verify metrics compliance and train to those findings. The Arizona TSC believes there is a substantial amount of data that needs to be compiled and evaluated to provide meaningful trend and/or risk analysis to inform future commodity specific best practices and guidance. The Arizona LGMA has the ability to fund this type of research if it improves the Metrics. Broad industry support and participation will be needed to conduct such a research project. The LGMAs are positioned to not only provide input into the scope of a PHT research project, but to facilitate and encourage industry involvement and standardization. The completed research may be utilized to inform future metrics.

The Arizona LGMA and the Arizona Attorney General’s Office is currently evaluating the ability and legality of implementing the proposed 18. Issue: Pre-Harvest Product Testing Pilot Program for Romaine. This evaluation will include a review of disclosure statements and conflicts of interest.

With that said the AZ TSC would like the following clarifications and considerations:

1. Provide a clearer definition of monocultured romaine with respect to mini/midi or petite varieties of romaine that includes these types of romaine in the description or offers a days-to-maturity clarifier.
2. Provide a clearer definition of regionality.
3. AZ TSC asks for clarification on expectations of pooling sample.
4. AZ TSC asks for an overview of expectations and capabilities for laboratories on the proposed method.
5. AZ TSC asks for clarification on why STEC and Salmonella were removed from the original draft.
6. AZ TSC supports the removal of Appendix I until there is scientific research to support the outlined distances. Additionally, Arizona and California LGMA are about to pilot an Environmental Assessment Tool that will help standardize the evaluation of risks and the mitigations strategies utilized to minimize those risks that will be helpful in overall risk evaluation.

The Arizona TSC advocates continuous improvement and the use of the most currently applicable research as a guide to inform that improvement process. We recognize that participating in the Western Growers review process helps to achieve these goals and appreciate being a part of the first review of PHT. We would like to point out that we were not invited to participate in the most recent discussion on PHT and therefore seek a better understanding of some of the recent changes.

The Arizona TSC appreciates Western Growers facilitation of the metrics review process but would like to ask why the calendar for annual public comment timeline was changed and why industry was not given the same historical timeframe of 30 days for public comment as listed as the process on the leafygreensguidence.com website. Additionally, going forward the AZ TSC would like for there to be a way to submit the inline tracked changes document to the submissions page.

Thank you,
Arizona Technical Subcommittee

Greg Komar – CA LGMA

Shoon Phyo2023-02-13T12:03:58-08:00February 13th, 2023|

California region recommendations:
o Salinas Valley (North of Gonzales)
o Gilroy, Hollister and San Juan Batista area
o Santa Maria
o Imperial Valley
o Bard
o Salinas Valley (South of Gonzales)
o Watsonville area (Santa Cruz county)
o Oxnard
o Huron (Central Valley)

Will the program include “What is a Positive”? Will each Handler use their own definition of “Positive”? Some handlers may declare a positive based on a presumptive test result. Some handlers may send their presumptive sample to a lab to be cultured out. Some handlers may send their presumptive to be molecularly confirmed. If the program provides instruction on how the conclusion of “Positive” is reached, then all Handlers should use the same process. If the program does not want to provide a defined process for a conclusion of “Positive”, perhaps Handlers should report their method for determining “positive”, whether it based on presumptive, cultured or molecular method, and the lab associated with each result.

Dr. Gurmail Mudahar – Tanimura & Antle Fresh foods

Shoon Phyo2023-02-13T12:03:46-08:00February 13th, 2023|

Pre harvest testing Comments AZ

Gurmail Mudahar Ph.D. Food Science
VP R&D and Food Safety Tanimura & Antle

LGMA’s Proposed Appendix C for Pre harvest crop sampling and testing is based on the following assumptions:
1. Contamination is present at >1 CFU per pound, ie; in 30,000 heads (1.5 lbs each), there must be more than 45000 CFU of pathogens present per acre of romaine. To achieve 95% confidence, 5% of romaine heads (>1500 heads/ per acre) must be contaminated.
2. Contamination is randomly distributed throughout the lot
3. Maximum lot area is 40 acres. Nominal sample lot area is <5 acres increments in the lot.
4. Sample number is N60 and sample specimen size of 2.5 g to 25 g each.
5. Outer edible leaves of romaine are representative of contamination in a head.
This plan has serious technical errors and unrealistic assumptions as following:
1. When all GAP and LGMA requirements are implemented and verified by CDFA/ AZ inspectors, chances of very high level contamination (5% heads) in a normal field of romaine is extremely rare. This situation can happen only if there is any risk situation such as storm, floods, contaminated irrigation water or close proximity to a CAFO. There must be a pre requisite crop Assessment that should help to identify if the crop in a specific lot is exposed to very high levels of contamination and thus qualify for pre harvest testing. There should not be any need of testing of those lots that do not qualify for testing based on risk assessment
2. In order to achieve consistent and valid microbial results, all testing parameters should be fixed. Using same numbers of N for various size sampling lots (i.e.; 1, 5 or 40 acres) do not provide consistent and same results. There are 40 times more chances that pathogens will be detected from 1 acres than 40 acres using 60n sampling plan. For detecting random contamination, N should be proportional to the sampling lot area or there should be only one fix sampling size.
3. In order to achieve consistency in results, sample preparation and specimen size must be same at all the time. Considering average weight of edible outer leaves of romaine hearts is 25+5 g and open romaine is 35+5 g, suggested specimen weights of 2.5-25 g are not realistic. Moreover, one full or partial leaf (as suggested) is not representative of the entire head. Ideally, sample specimen should be representative of the entire edible portion of a head i.e.; cross section slice from middle area of the head that should include inner as well as outer leaves.
Considering very low level and sporadic type of contamination, routine testing of fruits and vegetables is not recommended by ICMSF (International Commission on Microbiology Specifications of Foods), United Fresh Produce Association and many more experts including Mr. Devon Zagory (a well-known expert on produce safety).
Food Safety is extremely important for our industry, however, proposed pre-harvest testing plan will not help in improving food safety but will provide a false sense of security and mislead customers and consumers.
References:
1. Would my sampling plan have detected contamination levels that resulted in outbreak? 2020 United Fresh Work group white paper.
2. Microbiological testing of fresh produce, A white paper of United Fresh Association 2010.
3. Microorganisms in Foods 2: Sampling for Microbiological analysis: Principles and specific applications. Pg. 198.
4. Microbiology testing of Fresh produce: Where is Value by Devon Zagory.

Jan 10, 2023