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 October 13, 2006 – Dangerous E. coli Found On One Ranch Fast Testing For Pathogens Necessary Lobbying For Better Refrigeration Pundit’s Mailbag – Population Inured By Recalls? Botulism And Carrot Juice Summary III Pundit Rewind XIII: Spinach Crisis Summary
Dangerous E. coli Found On One Ranch The United Fresh Produce Association issued the statement we copy below related to the FDA and California Department of Health Services finding on one ranch that supplied Natural Selection Foods some cattle feces that match the strain of E. coli 0157:H7 that was implicated in the spinach recall. Although the whole world will leap to the conclusion that this proves the tainted spinach came from that ranch, it does nothing of the sort. Remember, the FDA and CDHS are not doing a random study of ranches in Salinas. They are bearing down on those they can associate with supplying Natural Selection Foods with product during the period in question. That means that we have no idea if they would have found that same strain of E. coli 0157:H7 on other ranches that they haven’t even looked at. I don’t see that it brings us any closer to a causal link. Here is United’s notice: The California Department of Health Services and the U.S. Food and Drug Administration announced this evening that three positive samples of E. coli 0157:H7 with the same genetic strain as that which caused the recent foodborne disease outbreak in spinach have been identified in cattle feces on one ranch that supplied spinach to Natural Selections Foods on the day of production in question. Dr. Kevin Reilly of CDHS reported that the investigators have now narrowed the investigation from nine to four ranches, now limited to two counties – San Benito and Monterey. The positive matches for the same DNA strain linked to the spinach outbreak were all found on one ranch, although investigation continues on all four. Reilly said that the three samples of cattle feces that tested positive were located between one-half and one mile from the actual field where spinach was grown, but that the cattle pasture was adjacent to the field. Reilly said that the land owner sublet a portion of the ranch for fresh produce production, and also maintained a cattle ranch on the property. Investigators emphasized that this is the first time a direct matching strain of E. coli 0157:H7 that was linked to foodborne disease has been identified in the environment in this area, in close proximity to the field where implicated spinach was grown. However, officials strongly advised that this does not prove cause-and-effect, but is a significant finding for further investigation. The agencies would not speculate as to how the contamination may have been transmitted to the spinach. Both California and FDA officials stressed tonight that there have been “significant improvements” and “a lot of progress” in implementing Good Agricultural Practices across this growing region and the industry in the past year. “We’re not 100% there yet, with 100% of the farms implementing GAPs 100% of the time, but that’s where we’re heading,” Reilly said. As an example, Reilly once again commended The Nunes Company for its precautionary recall of green leaf lettuce earlier this week, stating that this was evidence of commitment to GAPs taking hold throughout the industry. “We commend the staff at CDHS and FDA who have worked so hard to help narrow this investigation further,” said United Fresh President Tom Stenzel. “The finding of this matching strain is extremely helpful in learning exactly what went wrong in this case. There is more investigation to be done, but the public can certainly have confidence that we are narrowing this down to a specific cause that industry and government together can work to prevent in the future,” he said. Fast Testing For Pathogens Necessary The Nunes lettuce recall, which we dealt with here, points out the weakness of testing inputs and then seeing results after product has been shipped. First, it doesn’t guarantee safety because the product could have already been consumed. Second, it doesn’t stop the bad publicity related to recalls. My read of the regulatory agencies is that they really want product testing. As part of its own efforts to appease regulators and rebuild the confidence of consumers, Natural Selection Foods has created a product testing “firewall” for its facility: “Most important is what we are calling the “firewall.” We will be testing all of the freshly harvested greens — spinach and everything else — that are brought to our facility before they enter our production stream. If pathogens are detected, the lot will be discarded. This program is modeled on the program successfully implemented by the beef industry and approved by the International Commission on Microbiological Specifications for Food. This “firewall” will prevent anything like this E. coli-contaminated produce from ever entering our facilities.” This is one way of doing it, and if it keeps pathogens out of the plant, it may even be the best way. My sense, however, is that in the end the FDA really wants product testing after the product is processed. The big cost to this is not the testing itself; it is that you really want a hold-and-ship system implemented, in which product is held until the test results come back “all clear”. (The test results take about 48 hours, so you are talking about the loss of two days of shelf life.) This is a big problem for certain prepared foods that only have seven or eight days of shelf life – but most fresh-cuts have 14 to 21 days, so a day or two delay shouldn’t be impossible to deal with. If the system was done properly, we could possibly even allow shipping to cross country destinations as long as the product isn’t released from the truck until the “all clear” was given. This would mean no reduction in shelf life to the East Coast, for example. Recalled product should be so infrequent that the cost of the truck on the occasional recall should be inconsequential. Still, if we could speed up test results, it would be better, so I turned to my friend Lou Cooperhouse, Director of the Rutgers Food Innovation Center, and asked him about the prospects for faster testing: As you know, most microbiological testing for food products done at food companies today occurs with Petri dishes or Petri film that typically takes 24-48 hours, or longer. However, for the perishable food industry, this is far too long a time period, as simply waiting for microbiological results can easily consume 25% to 100% of the total shelf life of a perishable food product. This is obviously not a realistic situation. As a result, many companies in the perishable food industry commonly ship products before finished product microbiological testing has been completed. They rely on “statistical process control” that occurs post-shipment, instead of microbiological testing that should occur (and be completed) pre-shipment for 100% of the lots that have been produced. Many companies don’t even test-finished products for pathogens like E. coli 0157:H7 and rely instead on environmental testing on a random and statistical basis. An interesting model in the food industry is the sprouts industry, as sprouts have a very short shelf life and have been implicated in a number of food safety recalls in the past as well. There is an interesting (but technical) PowerPoint on the FDA website — link to http://www.cfsan.fda.gov/~dms/sprfuto/sprfuto.ppt — about rapid methods for testing spent irrigation water as an indicator for the microbiological condition of sprouts. Rapid methods for testing sprouts for E. coli are currently being practiced in the industry, and FDA has supported and promoted these efforts. However, such methods are not utilized in other perishable foods industries. Another interesting rapid-testing model in our society is drug testing — which many of our companies utilize for evaluating prospective new employees. Drug screen results are given within minutes, and if an individual “fails” in the instant “presumptive” test, samples are sent to labs for confirmation. So such technology is used commonly in industry today In my opinion, we should learn from alfalfa sprout growers, and even the drug testing industry, and adopt a quick-testing system across the perishable food industry, and insist that manufactures adopt procedures for microbiological testing of all lots of finished products before shipping. Such test kits are now available, and presumptive testing can tell a food producer within minutes if harmful levels of E. coli or E. coli 0157:H7 are present. I believe that such kits are available for less than $5 per test. An organization called the AOAC is a not-for-profit scientific association that is the recognized clearinghouse for approved scientific methods used in analytical testing. They list such testing methods on their website at http://www.aoac.org/testkits/testedmethods.html#Microbiological This site also has links directly to the manufacturers of these products as well. So this is what we are looking for: “…a quick testing system across the perishable food industry, and insist that manufactures adopt procedures for microbiological testing of all lots of finished products before shipping.” Lou mentions the sprout industry and when I think sprouts, I think of my frequent correspondence with Bob Sanderson at Jonathan’s Sprouts in New England. I asked him if he thought that the experience of sprout growers might be helpful to spinach and lettuce growers. He was a little skeptical: FDA recommends that spent-irrigation water from all sprout-production batches be tested for Salmonella and E. Coli 0157:H7, and that results be back in house prior to shipment of the sprouts being tested. In some ways this seems analogous to the packaged salad situation, but it is different in some key respects. We can put collection cups at every drainage point on our growing systems, and so, in effect, get a water sample that has come into contact with every sprout in the batch. The sprouts sit there for another 48 hours after we take this sample, and so we can know exactly which sprouts are involved if we get a positive test result. The “rapid” tests, which are widely used, still take the better part of 48 hours. There are 24 hour-methods, but I don’t know of labs that offer them yet. I read about even faster methods; don’t know about their “limit of detection”, pre-enrichment, etc. I think the salad mixes present much greater challenges in terms of high-confidence sampling and testing. But people are clever... Bob is clever too and serious about sprouts and food safety. Take a look at this page from his website that details, with photos, the food safety regimen for sprouts. What is clear is this:
I think we need to stop chattering and just make it happen. Wal-Mart, Costco, Safeway, Kroger, Supervalu — call in your suppliers and ask them for a schedule of how quickly it can be implemented. Resistance is futile – and foolish. Some great news from The Nunes Company. Independent lab tests of the product have come back negative: Green
Leaf Lettuce Update Nunes Company President Tom Nunes announced this afternoon that results received by the Company from an independent lab, testing multiple samples of recalled Green Leaf, and water taken Sunday, October 8th, were negative for pathogenic E. coli 0157:H7. He explained that the Company undertook the recall based on tests of irrigation water. “At the time we ordered the recall, we only had an indication that there might be the potential that people could become sick. We thought it better to be safe, and to protect the health of our consumers. On Sunday, we pulled Green Leaf and water samples. We had all of the samples, tested for E. coli O157:H7. We are relieved that all results were negative, and we are confident our product is safe.” On Monday, October 9th, the FDA also collected water samples, and they are now being tested. This was a nervous week, so the decision was probably the right one. But the long-term question is this: Does it make sense to recall product because the water supply tests positive for generic E. coli? If we were doing product testing, we wouldn’t have to ask the question. Lobbying For Better Refrigeration We’ve been dealing a lot with the Bolthouse botulism problem on 100% carrot juice. You can see our coverage right here. Sometimes our industry lobbyists can do the trade the best service by working on issues outside the specific purview of our industry. In light of all the publicity that has been tied to the botulism problem on 100% carrot juice and the need on many fresh-cuts and other products to sustain a cold chain, how about lobbying for a law that requires new home refrigerators to have built-in thermometers and the ability to set the actual temperature as opposed to just a wheel that you can spin to get “colder” or “warmer”? Consumers are the last link in the food safety chain. They should have the tools needed to do a good job. Going along with this, merely saying “keep refrigerated” on a label is insufficient. Labels should be required to give specific temperatures: “Keep refrigerated at or below 35 degrees”… or whatever is required. We ran it yesterday and it so upsets me that I am going to run it again. Did everybody notice that PulseNet, which is supposed to be protecting our food safety and food security, CLOSES ON THE WEEKEND? Wisconsin public health officials knew they had a serious problem. They also had a responsibility to alert health officials in other states in case the outbreak was larger than they knew. So on Friday, Sept. 8, microbiologist Linda Machmueller sat at her computer in the Wisconsin State Laboratory of Hygiene in Madison and posted a terse message on PulseNet, a federal Web board run by the Centers for Disease Control and Prevention that allows scientists around the country to communicate about possible disease outbreaks. “Wisconsin has a cluster of 8 E. coli O157:H7,” she typed, including seven local cases and one from Illinois. They all appeared to “match the pattern” for a strain of the organism that the U.S. Department of Agriculture had isolated earlier in hamburger patties from Texas. The microbiologist attached a copy of the deadly organism’s DNA fingerprint. She had no idea what would happen next. “You never know when you post these things if it’s going to amount to anything,” she said. The Wisconsin posting landed on PulseNet at 5:14 p.m. EDT, after everyone at the Web board’s Atlanta headquarters had gone home for the weekend. So it wasn’t until Monday, Sept. 11, that database manager Molly Joyner read the brief note, checked the DNA fingerprint and began trying to figure out what was going on. pulseNet, as Wisconsin’s Davis puts it, is a little “like a dating service for bacteria.” It allows public health labs throughout the country to compare the organisms they’re seeing with those being found in other states. The bacterium isolated in the Wisconsin outbreaks was not a highly unusual strain. Two or three cases a week are commonly posted on PulseNet. But by the end of the day on Sept. 11, Joyner had discovered that nine states had posted single matching E. coli samples to PulseNet in the weeks leading up to the Wisconsin cluster, although it was unclear if they were connected. And Minnesota e-mailed that afternoon with yet another match. You can read the whole article here. I think the Centers for Disease Control needs to change this policy, immediately.
Pundit’s
Mailbag — We mentioned the Nunes green leaf lettuce recall here and heard a lot of praise for the proactive attitude The Nunes Company took in initiating a voluntary recall when nothing had been found on the product: The Nunes Company could not have done a better job with the green leaf. Their response was evocative of the way the Tylenol and Odwala Juice crises were handled, and those two incidents are normally held out as the best examples of what to do. I agree that we will have a rash of recalls as new and more stringent tests, such as this water check, are now in place, and a hyper-sensitive news media is looking for all related stories on food safety. While this would seem to be a negative in the short term, it could be a positive in the long term. The more recalls and warnings occur with no one getting ill, the less sensitive the public will be to the announcements. Also, the more commonplace these warnings, the less interested the media will be. The overall numbing affects of overexposure will occur. Also, with each of these incidents, we see a faster, more specific response, again, with no illness or death reported. This will eventually bolster consumer confidence. Finally, the next wave of “in depth” stories on safety in our perishable food chain should, and if history proves correct, will stress the health benefits of fresh food and especially produce consumption weighed against the infinitesimal risk of infection as borne out by data. All in all, more responses like Nunes without subsequent infections will do more to restore the public confidence in Salinas produce, fresh produce in general and food safety. Richard Kaiser The Richard Kaiser Company Richard is reacting to my take that constant recalls will be bad for the industry. Richard is basically saying that if we have a lot of recalls, people will become used to them and see them as background noise, the way lions in Africa that are raised in game reserves don’t object to the vehicles going by; they see them as part of nature. But open the door and break the profile of the vehicle and you can get eaten pretty easily. It is a reasonable point. But I think it would be better if we didn’t have to announce recalls at all. Botulism And Carrot Juice Summary III We’ve been asked to make available in one place our coverage of the recall by Wm. Bolthouse Farms of certain 100% carrot juice products and the broader implications of this issue for food safety. This piece is updated regularly and will be re-run to include new coverage of this outbreak and issue. We initiated our coverage on October 2, 1006, by publishing the FDA notice to consumers warning them not to drink the product, and we inquired as to the margin of safety on the product. You can find the piece, entitled Oh No! Another Outbreak, right here. On October 4, 2006, we published Bolthouse And Juice Refrigeration, which analyzed the proper standard of refrigeration for vulnerable products and the ability of both the trade and consumers to maintain that cold chain. Read it here. October 5, 2006, we ran Botulism III, which detailed the 12 steps in the distribution chain that the industry needs functioning properly in order to maintain the cold chain. The piece challenged retailers to evaluate the integrity of their own cold chain. You can find the piece here. In The Botulism And E. coli Connection, which we ran on October 6, 2006, we noted similarities between the botulism outbreak on certain Bolthouse carrot juice and the spinach/E. coli outbreak. The piece is right here. On October 10, 2006, we noted, in Bolthouse Botulism Case Hits Canada, that two Canadians were now victims of this botulism case and noted that it was an unusual cluster to occur at one time if the problem was solely temperature abuse by customers. You can catch it here. October 11, 2006 we ran Carrot Juice Still On Canadian Shelves, we noted that Canadians were getting upset over the inability of Canada’s public health authorities to execute a simple product recall and that the frequency of recalls was raising questions over the safety of California produce. Read it right here. On October 13, 2006 we ran Lobbying For Better Refrigeration urging industry lobbyists to work on legislation to make sure consumers have the tools they need to keep product safe at home. The article is here. The Pundit originally ran this piece on September 21, 2006. We continuously update it in order to keep everyone organized with respect to reference material on this subject, we have updated it with new items and run it again today. Spinach Crisis Summary With so much having been written in so short a time, thought it would be helpful to publish a sort of round-up of available material to help people understand the whole situation regarding spinach and this E. coli breakout: The Perishable Pundit itself has dealt extensively with the subject in several major pieces. On September 15, 2006, we published Spinach Recall Reveals Serious Industry Problems, which addressed the implications of this crisis for the fresh-cut industry. You can read the piece here. On September 18, 2006, we published Organic Dodges a Bullet, which deals with the implications of the outbreak for the future of organic farming. You can find this piece here. Also on September 18, 2006, we ran a piece called Ramifications and Reflections on the Spinach Recall, which provided our first 10-point analysis of the situation. You can read it here. September 19, 2006, we asked Is FDA’s Concern Now an Obsession? — a piece in which we assessed whether a national recommendation to not eat spinach made any sense. You can review this here. On September 20, 2006, we noted 10 Peculiarities about the E. coli Outbreak and reviewed why certain aspects of the situation are unlike past food-safety challenges and other unanswered questions regarding the outbreak. Read this one right here. Also on September 20, 2006, we did our third 10-point list, calling this one “Spinach Recall Begs for Solutions”, where we reviewed how the trade can deal with this issue for the future, including looking at the meat industry, the prospect of universal testing and the use of RFID and GTIN. You can read all this here. On September 21, 2006, we asked Is FDA Causing Long-term Damage? Here we posed the question of whether punishing the innocent and the guilty alike doesn’t reduce incentives to invest in food safety. You can read this piece right here. The September 25, 2006 edition of the Pundit includes our fourth 10-point list entitled Though Not ‘All-Clear’, Consumers Can Eat Spinach Again, which reviewed many issues facing the industry as spinach begins to reenter the market, including the FDA’s announcement, PMA consumer research, the behavior of industry association, battles over fresh-cuts and organics, the reintroduction of Salinas Valley production, the FDA’s capabilities, and more. You can read this piece here. Also on September 25, 2006, we reviewed The Role of Retailers And The Future Of Food Safety, which pointed out that buyers have an important role in insuring food safety. Catch this piece here. Additionally, on September 25, 2006, we ran the Pundit’s Pulse Of The Industry in which a panel of retail pundits gave us insight into the way the spinach issue played in store and with consumers. You can read it here. The Pundit on September 26, 2006, included an articled entitled The California Department of Health Services Owes People An Explanation in which the question was raised whether certain parties received preferential treatment in the current spinach/E. coli outbreak. Read it right here. Also on September 26, 2006, we did a piece questioning the efficacy of our trace-back systems. The piece was titled More Recalls Trickle In, and you can read it here. On September 27, 2006, the Pundit analyzed the bad publicity that the Salinas Valley has received and asked Is Salinas Getting A Bum Rap On Food Safety? The piece can be read right here. September 28, 2006, the Pundit included a piece entitled Call For Stronger FDA that analyzed the demand of some in the food industry for beefing up the FDA and its budget within the context of the spinach/E. coli situation. You can read it here. On September 29, 2006 we did a piece called Lies, Damned Lies And Statistics that explored the contradiction of modern life that has led things to seem less safe, even as they are actually safer. Read the piece here. October 2, 2006 we ran The FDA Needs to Reexamine Its Methodology, inquiring why it was necessary to shut down a whole industry when, as far as we know, it was only Dole brand bagged spinach that was implicated? Read it here. Also on October 2, 2006, in a piece called Needless Recalls, we examined how even if many of the recalls were unnecessary, the recalls revealed big flaws in the trade’s traceback systems. You can find the piece here. Another piece October 2, 2006, entitled Deconstructing FDA, analyzed the FDA’s statement regarding the end of the spinach crisis. The piece is right here.The Pundit also ran a piece entitled Action Plan to Regain Consumer Confidence that both discussed the industry plan and proposed an alternative plan. Read about it here. Also on October 2, 2006, we did a piece called Collateral Damage vs. Assumption of the Risk, which analyzed some of the liability issues surrounding the outbreak. You can find the piece here. Additionally, on October 2, 2006, we published the second in our series of Pundit’s Pulse Of The Industry. This one including insight from Bob Edgell of Balls Foods and Ron McCormick of Wal-Mart, regarding reaction at retail as spinach outside California became available. Read it here. On October 4, 2006, the Pundit ran a piece entitled In Defense of Salinas, in which, based on a discussion with a Salinas farmer, we outlined five points you need to understand about the relationship between the Salinas Valley and this outbreak. You can find it here. Also on October 4, 2006, we published Notes On Natural Selection: It Could Happen To You, which discussed the new food safety plan revealed by Natural Selection Foods and discussed the necessity of product testing. Read it here. October 5, 2006, we analyzed the implications of the FBI raid in Salinas with Just when you thought it was safe to go back in the water… You can read the piece here. We also explained on October 5, 2006, the involvement of Growers Express in the FBI raid in a piece entitled Bailando Juntos (Dancing Together), which you can find right here. What’s more, we discussed on October 5, 2006, why Canada is still banning U.S. spinach and what that implies about relations between the FDA and CFIA. The piece is called U.S. Spinach Still Banned in Canada, and you can read it here. On October 6, 2006, the Pundit pointed out the importance of considering the human costs of our actions in A Look At The Faces, which you can read here. Also on October 6, 2006, we analyzed how increased use of a federal network was bound to mean the recording of more frequent food safety outlets in a piece entitled PulseNet Ups Ante In Food Safety Battle, which can be read right here. Although not strictly speaking spinach-related, when one company voluntarily recalled certain green leaf lettuce, it was a decision affected by the overall environment caused by the spinach/E. coli situation. In Nunes Recall Reveals Testing Dilemma, published on October 10, 2006, we analyzed how stricter standards may lead to more frequent recalls. Catch the piece here. October 11, 2006 we pointed out that the Center for Disease Control was beginning to see fresh-cut in a whole new light. You can read CDC’s Aha! Moment right here. Also on October 11, 2006, we offered Heads Up – Political Posturing On Spinach Begins, pointing out that the a State Senator in California was going to start some hearings. Read the piece here. On October 12, 2006, in PulseNet Asleep At The Wheel, we detailed that the nation’s food safety bulletin board likes to take off on weekends. Read this astounding piece here.
IMPLICATIONS OF THE CRISIS Additionally on September 18, 2006, our Pundit’s Mailbag focused on letters received by United President/CEO Tom Stenzel and incoming Chairman Emanuel Lazopoulos of Del Monte Fresh, which dealt with the confluence of United’s Board Meeting and the spinach crisis as well as issues of industry leadership. You can find this one here. On September 19, 2006, we noted that there might be a Greenhouse Opportunity in all this. Read this here. Also on September 19, 2006, we noted that, though fruits and vegetables are healthy, fresh produce is not necessarily the best choice for those with a compromised immune system. The piece is called Marketing Nightmare and you can find it right here. On September 21, 2006, we did a piece called Wal-Mart Deli/Bakery Has Crisis Of Its Own that draws a link between the difficulty of preventing a Salmonella outbreak at one store with the difficulty of preventing an E. coli outbreak on an industry-wide basis. You can read this piece here. On September 25, 2006, the Pundit noted Another Oddity In Spinach Crisis and raised the question whether some or all of the product being marketed as conventional might not be organic. Read it right here. Also on September 25, 2006, we ran a Pundit’s Mailbag which dealt both with the utility of loyalty card programs and with the nature of large, multi-line fresh-cut packing facilities. You can read this one right here. Also we did a short piece on what change was actually necessary if consumers were to be reassured of the safety of spinach. Read it here. On September 26, 2006, we discussed the issue of recalls and how insurance plays into that. You can read this here. Also had an unrelated piece on Wegmans that included a video clip on how consumer media is dealing with the reintroduction of spinach. You can catch it here. Additionally on September 26, 2006, we ran a Pundit’s Mailbag exploring the causes of the outbreak. You can read this piece here. September 27, 2006, we focused on a piece in the Washington Post that helps us in Putting Things In Perspective. How does the Spinach/E. coli outbreak relate to the total numbers that get sick and die each year from foodborne illness? You can read it right here. On September 28, 2006, we published a terrific Pundit’s Mailbag exploring the frustration the buy side felt in dealing with the spinach/E. coli situation. Read it here. October 2, 2006, we had some Questions For Western Growers that asked how far the WGA was willing to go to make sure foreign growers meet the same standards as Salinas area farmers. Read about it here. We also asked How Committed Is The Produce Industry To Broad/National Food Safety Program. You can read the piece here. In addition, on October 2, we ran pundit’s Mailbag: Another Despicable Marketing Attempt that pointed out how a seed company was taking advantage of the situation and, possibly, leading to harm, by pushing its products. Read about it here. On October 4, 2006, we ran a piece entitled Primary And Secondary Suppliers, which details how this food safety crisis has to impact retail vendor selection. Catch it right here. Also on October 4, 2006, we discussed how to help innocent spinach farmers who were victimized by this crisis in Everyone Needs to Do A Little Bit. The Pundit pledged to do its own bit. Read it right here. October 5, 2006, we ran a piece focused on another outbreak of foodborne illness -- in this case, botulism in carrot juice. The focus, however, was on the necessity to change attitudes as the produce industry becomes less a packing industry and more a processing industry. It is called Botulism III, and you can read it here. On October 6, 2006 we pointed out The Botulism And E. coli Connection where we explained that our focus on pathogens at the product source, though important, is insufficient. Read it here. Also on October 6, 2006 we ran Pundit’s Mailbag: What Are The feds Up To? This answered a reader’s letter inquiring as to whether the FBI being in Salinas implied industry members weren’t cooperating. You can find this item |
