June 15th, 2022 – Pre-Harvest Testing

Greg Komar, Pre-harvest Testing Working Group

The Pre-harvest Testing Working Group submitted comments to the Pre-Harvest Testing Issues in the LGMA-approved Metrics.

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Submitted Comments

Vicki Scott – Arizona LGMA

2022-07-08T15:45:12-07:00July 8th, 2022|

Arizona Technical Subcommittee Comments on Pre-Harvest Testing
July 6, 2022

The Arizona Technical Subcommittee (TSC) met on June 30, 2022. The agenda included a review and discussion of the proposed 18. Issue: Pre-Harvest Product Testing 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 Technical Subcommittee concurs with the statements regarding the potential benefits of a pre-harvest product testing program and insights into food safety system performance. As stated, the “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.
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 but not to compile and evaluate the substantial amounts of data needed to provide meaningful trend and/or risk analysis to inform future commodity specific best practices and guidance.
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 pre-harvest product testing research project, but to facilitate and encourage industry involvement. The completed research may be utilized to inform future metrics or standards.
The Arizona LGMA members of the metrics review work group previously provided comments on the proposed draft document to be considered in the upcoming webinar on July 13th. It is the Arizona Technical Subcommittee’s intent to have those comments shared within the webinar for the benefit of the attendees. We also offer the following for consideration (new comments):
1. AZ TSC asks that the audience be polled regarding whether a
hazard/risk assessment based sampling protocol or the prerequisite sampling protocol as proposed is preferred.

2. AZ TSC recommends a poll to assess attendee opinion on whether romaine should be the only commodity tested within the pilot.

3. 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.

4. Revert to the earlier requirements concerning target organisms that includes EHEC with a note that the LGMAs need to revisit other metrics sections with references to only STEC. Arizona work group members’ initial concern was regarding harmonization with the overall document requirements.

5. Clarify the intended status of WG Appendix I.

6. Clarify why the new Appendix L is being created rather than incorporating the content intended for Appendix L into the existing Appendix C.

The Arizona Technical Subcommittee advocates continuous improvement and the use of the most currently applicable research as a guide to inform that improvement process. The Arizona Technical Subcommittee appreciates Western Growers facilitation of the metrics review process and the association’s enlistment of subject matter experts to provide advice during the 2022 review.

Thank you,

Arizona Technical Subcommittee

Gurmail Mudahar – Tanimura & Antle Fresh foods

2022-07-08T15:43:00-07:00July 5th, 2022|

Comments on Pre Harvest Product Testing Pilot Program for Romaine.
Gurmail Mudahar Ph.D. Food Science
Vice President, R&D and Food Safety , Tanimura & Antle Inc.

After learning from several Pre-harvest working group and WGA members, that outcome of the pre-harvest test pilot study will be used to fill knowledge gaps such as determination of buffer distances from high risk environmental and animal holding areas, I agree with the work group that there is a need for a large scope study in collaboration with the industry to understand real environmental risk to leafy greens. However, in order to conduct this study accurately, scientifically and with maximum involvement of industry, I have following concerns and suggestions:
1. Since the proposed study will be conducted at grower level, ideally, a grower Association such as WGA or another independent organization should manage this study. This study should not be associated with LGMA metrics, until recommendations of the study are published. However, LGMA can help in facilitation of the study.

2. Overall objective of the Pilot study need to be defined. The design of study must outline following details related to its objectives:
a. Hypothesis and expected outcome of the study needs to be defined. identify growing areas where samples to be taken.
b. Study need to consider if products grown differently such as romaine hearts vs. open romaine show different levels of pathogen presence.
c. Study must explain on who and how data will review and publish findings of the study.
In order to understand environmental risk in various growing areas and type of romaine, following experimental design and data collection form is suggested:
Sampling region Type of romaine
Closed head romaine (hearts) Open head romaine
Total samples STEC (% positives)* Salmonella (% positive)* Total samples STEC (% positive)* Salmonella (% positive)*
Salinas Valley (N of Gnzalas)
Salinas Valley (S of Gnzalas)
Hollister area
Watsonville area
Santa Maria
Imperial Valley
Gila Valley
Yuma Valley
Bard
Dome. Welton,
Huron

*Note: Root cause Analysis of all positive samples must be submitted.
3. Proposed crop testing time line before harvesting is not realistic. Due to sudden changes in weather, customer demand and logistics, occasionally harvesting decision are made on the day of harvest. These situations may not allow taking pre-harvest samples from the field as described in the proposed pre-harvest testing plan. This study should consider Pre-shipping (instead of pre-harvesting) testing timeline options for such situations.

4. Proposed sampling plan is very confusing, complicated and does not differentiate between smaller and large growing lots (10-40 acres). Sampling plan based on 90 percent of confidence may not generate realistic outcome of the study. To avoid sampling confusion, having higher level of confidence (95%) and be reasonable to smaller and commodity growers, a sampling plan similar to United Fresh White Paper recommendations should be considered as following:

If Lot sizes <10 acres or <10,000 cartons (24 ct equivalent): 1 set of 375 g each
If Lot size 10-20 acres or 10,000-20,000 cartons (24 ct equivalent): 2 sets of 375 g each
If Lot size 20+ acres or more than 20,000 cartons (24 ct equivalent): 3 sets of 375 g each

Gurmail Mudahar
July 4, 2022

Amanda Brooks – Yuma Safe Produce Council

2022-07-08T15:43:38-07:00July 1st, 2022|

Thank you for the opportunity to comment on the Pre-harvest Testing Working Group’s submission. The Yuma Safe Produce Council (YSPC) supports pre-harvest testing when risk assessments deem it is necessary. For cause testing applying to all leafy greens should be implemented to prevent potentially contaminated produce from being harvested. Identifying hazards and assessing risk are the primary role of the food safety professional and thus, they should have adequate training. All producers should have pre-harvest testing SOPs for when hazards present a risk. Data derived from pre-harvest testing can provide valuable information to industry and we encourage sharing of such data however this should be voluntary.
Historically, the LGMAs have leaned on academia to help fill knowledge gaps. Research is a key component to the continual improvement of industry prevention efforts and LGMAs should support efforts to learn about industry practices, contamination, and risk factors. The Work Group’s submission falls short in meeting all the pilot programs objectives because it does not provide a plan for how data will be aggregated and analyzed. Instead of breaking course, the LGMAs should rely on academia to collect, analyze, and provide the data necessary to inform the metrics.
The work group’s submission will add significant costs and logistical challenges for signatories. The YSPC does not support a mandatory romaine testing program or pilot program and would like the LGMAs to consider a risk-based approach to pre-harvest testing that covers all leafy greens while supporting and potentially funding research projects that will aid in the continual improvement of prevention efforts.
Yuma Safe Produce Council

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June 14th, 2022 – Pre-Harvest Testing

Aaron Anderson, Pacific International Marketing

The Pacific International Marketing submitted comments to the Pre-Harvest Testing Issues in the LGMA-approved Metrics.

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Submitted Comments

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May 31st, 2022 – Pre-Harvest Testing

Amanda Brooks, Yuma Safe Produce Council

The Yuma Safe Produce Council submitted comments to the Pre-Harvest Testing Issues in the LGMA-approved Metrics.

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May 27th, 2021 – Adjacent Land Use/Production Locations

Amanda Brooks, Yuma Safe Produce Council

The Yuma Safe Produce Council submitted comments to the Adjacent Land Use/Production Location Issues in the LGMA-approved Metrics.

Cover Letter

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May 27th, 2021 – Adjacent Land Use/Production Locations

Kay Pricola, IVVGA

This submission provides comments from the IVVGA regarding Adjacent Land Use/Production Location Issues in the LGMA-approved Metrics.

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Submitted Comments

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May 27th, 2021 – Adjacent Land Use/Production Locations

Teressa Lopez, AZ LGMA

This submission supports the CA LGMA and the Adjacent Land Use Subcommittee comments.

Cover Letter

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May 26th, 2021 – Adjacent Land Use/Production Locations

Greg Komar, CA LGMA

This submission proposes updates to the glossary, acronyms, appendix list, Issue 5, Issue 15, and Table 7 of the LGMA-approved metrics.

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Submitted Comments

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April 27th, 2021 – Soil Amendments/Non-Synthetic Crop Treatments

Don Stoeckel, private citizen

This document suggests edits, clarifications, and changes to the Soil Amendments / Non-Synthetic Crop Treatments section of the LGMA-approved metrics.

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Submitted Comments

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April 27th, 2021 – Soil Amendments/Non-Synthetic Crop Treatments

Bill Hsu, Taco Bell

This document, submitted on behalf of the Leafy Greens Safety Coalition (LGSC), suggests changes to the Soil Amendments / Non-Synthetic Crop Treatments section of the LGMA-approved metrics.

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Submitted Comments

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April 27th, 2021 – Soil Amendments/Non-Synthetic Crop Treatments

Teressa Lopez, AZ LGMA

This submission represents a review of the proposed CA LGMA Soil Amendments / Non-Synthetic Crop Treatments revisions by the AZ LGMA Technical Subcommittee.

Sources Used:

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April 26th, 2021 – Soil Amendments/Non-Synthetic Crop Treatments

Greg Komar, CA LGMA

In this submission, the CA LGMA provides suggested revisions to the Soil Amendments/Non-Synthetic Crop Treatments and Glossary sections of the LGMA approved metrics.

Sources Used: Fate of Coliform Bacteria in Composite Beef Cattle Feedlot Manure

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April 26th, 2021 – Soil Amendments/Non-Synthetic Crop Treatments

Amanda Brooks, Yuma Safe Produce Council

The Yuma Safe Produce Council provided comments and suggestions for the Soil Amendments/Non-Synthetic Crop Treatments section of the LGMA-approved metrics.

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Submitted Comments

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June 12th, 2020 – Field Sanitation

Greg Komar, CA LGMA

This document contains the CA LGMA’s proposals and comments to the Field Sanitation section.

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May 27th, 2020 – Field Sanitation

Teressa Lopez, AZ LGMA

In this document, the AZ LGMA proposes consolidating similar bullet points, transferring best practice bullet points into SOP’s, and created new suggested language to different areas of emphasis. The key areas of modification are Harvest Equipment and Tools SOP, Harvest Containers, and Food Packaging Materials.

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May 4th, 2020 – Water Amendment

Greg Komar, CA LGMA

In the accompanying document, you will find suggested changes to be made to the LGMA-accepted food safety practices in the area of agricultural water (specifically related to drip and furrow irrigation and application of chemicals). The document includes new best practice language, enhancements to sampling requirements for system-based water use, enhancements to the post-harvest water section, and a new section for chemical water application water.

*This document is a revised version of the April 7, 2020 submission from Greg Komar with the CA LGMA.

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May 4th, 2020 – Water Amendment

Teressa Lopez, AZ LGMA

The accompanying document includes comments and suggestions on chemical compatibility, physical disinfection, on farm practices regarding harvest and post-harvest contact, and more.

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May 4th, 2020 – Water Amendment

Amanda Brooks, Yuma Safe Produce Council

This proposal provides notes and suggestions on chemical compatibility, agricultural water treatment, document consistency, and root cause analysis.

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May 4th, 2020 – Water Amendment

Paul Monadragon, Ag Partners SW

The document suggests including additional components within the metrics that make clear (more clear) that UV is an equally acceptable approach to be used.

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May 4th, 2020 – Water Amendment

Lacy Litten, Innovation Produce
The focus of this proposal is on agricultural water systems, sourced mainly from Type A wells commonly found in the Santa Maria and Salinas Valleys. While Type A well water likely carries the lowest risk, the most recent metrics revision only gives a snapshot of water quality through initial and routine testing. The proposal suggests allowing monthly water sampling to verify water quality throughout the entire growing season. There are no proposed changes to Type B water nor B->A water.

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May 4th, 2020 – Water Amendment

Jeremy Vanderzyl, Duncan Family Farms
This proposal includes a request to change the current treatment and sampling metrics to remove the rigidity of compliance and instead focus water sampling as a tool to developing risk assessments and allow for flexibility in the treatment process.

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April 7th, 2020 – Water Amendment

Greg Komar, CA LGMA
In the accompanying document, you will find suggested changes to be made to the LGMA-accepted food safety practices in the area of agricultural water (specifically related to drip and furrow irrigation and application of chemicals). The document includes new best practice language, enhancements to sampling requirements for system-based water use, enhancements to the post-harvest water section, and a new section for chemical water application water.

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Submitted Comments

Mark Shakespeare – Walmart Inc.

2020-04-23T09:14:54-07:00April 23rd, 2020|

a) Furrow irrigation – require an addition to irrigation records that notes that furrow irrigation water did not come into contact with the edible portion of the crop if applied < 21 days before harvest.
b) Furrow irrigation – if furrow irrigation water does contact edible portion of the crop < 21 days before harvest, then this would trigger corrective actions (irrespective of the water quality microbiological test results).

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The 2022 Calendar

Western Growers supports the continuous improvement of the LGMA-approved leafy green food safety guidelines and facilitates a yearly systematic amendment process.

Starting in 2022, the “Priority Setting Committee,” established by the LGMAs, is responsible for assessing annual priorities. At the beginning of each year, the Priority-Setting Committee sets the topic(s) for the remainder of the year.

Important Documents

View all current proposed changes and comments on the Submissions page.

Notable Dates:

Pre-harvest Testing Comment Period: May 2 – July 6, 2022

Pre-harvest Testing Submission Period (Proposed revisions): May 2 – June 15, 2022

Pre-harvest Testing Comment Period Webinar – July 13, 2022

Participate in the Process

If you are interested in proposing changes to the LGMA-approved metrics, follow these submission guidelines:

1. Download either the CA or AZ working draft excerpts for the corresponding comment period.

2. Use the Word function “Track Changes” to outline your revisions throughout the document. (If you are new to tracking changes, click here to review a guide.)

3. Use the Word function “New Comment” to provide details on how the proposed change will enhance food safety, along with the rationale behind the change.

To view an example of steps 2 and 3, click here. In this example, revisions are tracked within the document and a statement on how the proposed revision enhances food safety along with the rationale for the change are provided through the Word function “Comments” in the right-hand panel.

4. When you are ready to submit your document, click on “Propose a Change”.

Note: We are only accepting proposals that follow the above steps. If you have any questions about this process, please contact us at WGScience@wga.com.

Propose Change

Please send comments, questions and feedback about this website and/or the WGA’s amendment process to the WGA’s Science Team.

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