Vicki Scott – Arizona LGMA

Kendra Clark2022-07-08T15:45:12-07:00July 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

Kendra Clark2022-07-08T15:43:00-07:00July 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

Kendra Clark2022-07-08T15:43:38-07:00July 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

Mark Shakespeare – Walmart Inc.

Scott Nichols2020-04-23T09:14:54-07:00April 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).