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Perishable Pundit
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Did Wal-Mart Have A Role In Ballantine’s Fall?

We’ve written many pieces about the challenges facing the California tree fruit industry, including these:

Although we had no reason to think it was going to fail, we can’t say that the collapse of Ballantine Produce was a shock. We had heard they were slow on paying growers and that led to a loss of volume. When a few big growers decided to leave, that led to a collapse.

Although, of course, the failure of a company is always related to its own situation and its financial strength, one of the key factors that many in the industry feel led to this collapse was the way Wal-Mart has been dealing with the California tree fruit industry. Here is how one insider put it:

Ballantine’s crown jewel was that it had 10 Wal-Mart DC’s. There may be a short-term scramble, but the supplies will get filled by others.

However, the way Wal-Mart is comporting itself toward the tree fruit industry may have been a major reason for the decision of the ownership to pull the plug.

First, Wal-Mart opened the 2009 pre-season bidding for tree fruit to ‘everyone’. Those outsiders, who would do ANYTHING to get in, including some vertically integrated companies, gave Wal-Mart what most concede were unnecessarily low season-long prices. Then, Wal-Mart used the ‘outside prices’ to leverage its traditional suppliers, including Ballantine, to lower their prices to match, then essentially gave all DC assignments back to its traditional suppliers.

Finally, the ‘last straw’ may have been a decision by Wal-Mart to ‘turn the screw’ and demand suppliers supply only 60s and larger on both peaches and nectarines during a traditional contract period where 70-size were permissible — at the same price — a huge price concession in a traditionally high priced harvest period!

There was quiet outrage among Wal-Mart suppliers and their partners, but all industry suppliers acquiesced to meet the new standard.

Put another way, if one’s biggest customer won’t let you make any money, what is the point of struggling to continue?

Some, of course, believe in a “last man standing” theory, whereby if the Ballantine’s of the world go out of business, they hope to stand, at the end, as one of very few suppliers — maybe the only supplier able to meet Wal-Mart’s volume needs. They hope to profit at that time.

It is a theory, but not one we have really seen work in practice.

It is not unethical for Wal-Mart to pursue low prices or to consider alternative vendors. Though trying to demand things not called for in the contract after the deal is made would be unethical.

The problem is that one would hope that the biggest buyer in the industry would be selecting vendors via other criteria. Perhaps it could restrict its purchases to the vendors who are furthest along in pursuing traceability or those that have invested most heavily in preparation for Global Food Safety Alliance certification, or maybe those whose efforts most closely match Wal-Mart’s publicly proclaimed priority of sustainability.

Obviously Wal-Mart did not cause the Ballantine collapse. Wal-Mart treated others the same way and the others were sufficiently capitalized not to collapse — at least for now. Still, the fact that Wal-Mart went back to its traditional vendors is telling. It meant it was satisfied, thought it had the best vendors and, yet, elected to make these “best” vendors compete on price with those it thought less desirable.

This is the habit that is inching through the industry, in which our best producers who take supply chain obligations most seriously are put in a position of competing with secondary producers on price. As long as this continues, industry progress will be most difficult to obtain.

Ballantine’s future and the future of the fruit it marketed is uncertain. It is reported that some key employees were trying to hold together a ‘surviving company’ that might have perhaps 1.4 million boxes — a very rough guess — from Ballantine-owned orchards and some key growers who would like to stay together.

What is clear is that the industry needs fewer handlers and sellers, not more.

Although industry orchard pullouts are far above recent experience, and estimates are for 12-13% fewer peaches and nectarines, that doesn’t actually tell us enough.

The time frame of the volumes — still heavily clustered — the volumes for the eastern crops — projected to be above average — and the fragmentation of the marketing effort — still quite fragmented — all will impact on grower returns.

So what happens to the plans for the 1.4 million boxes really matters. If it winds up in weak hands, cuffing stuff in the markets, there could be a big impact on returns.

Plum supplies seem more in line with demand, maybe even a bit short, but the estimating program does not include pluots — and these often get sold as plums.

We had the opportunity to chat with a number of growers late March when we gave a talk on sustainability for The California Grape and Tree Fruit League. For the most part, despite its problems, the industry is hopeful. However, industry weakness persists, Ballantine being the latest and most shocking example. It will take a lot of discipline to manage profitable sales during the whole of the California tree fruit season. We wish the growers and handlers good fortune.

Recommendation For An ‘Appropriate’ Seed-screening Program Shows FDA Unwilling To Take Responsibility For Its Recommendations

On April 28, 2009, the Perishable Pundit published a piece titled, Insights On The Alfalfa Sprout Advisory, which included an interview with Bob Sanderson of Jonathan’s Sprouts. The interview revealed an insight into a fundamental food safety problem regarding alfalfa sprouts:Alfalfa seeds are not typically grown for human consumption.So all the food safety burden is put on the sprouter. We suggested the following:

Most alfalfa is raised for animal feed, so they make no effort to avoid animals or animal excrement in the growing fields. Later on, when a sprouting facility buys the seed it suddenly becomes food for human consumption. Yet it was not grown under any procedures designed to keep it clean and free of pathogens.

Any buyers out there who want to make a productive contribution, here is an opportunity: Make a policy that next year you will only buy alfalfa sprouts that are grown from seed certified to have been raised on a third-party audited, GAP-compliant farm. This should also be added to the FDA’s Guidance Document.

We seem to have hit a nerve, as three days later the FDA sent out a letter to the sprout industry, which included these lines:

As you are aware, seeds are considered the most likely source of contamination in most sprout-associated outbreaks. Therefore, it is important that sprout growers source their seeds from suppliers with an appropriate program to screen their seeds for potential contamination with pathogens.

This kind of communication illustrates clearly the enormous frustration of dealing with the FDA and the enormous obstacles the incentives of the FDA pose for food safety.

The questions are obvious: Why use vague language such as saying that seed producers ought to have “an appropriate program” — what does that mean? How would a farmer know if he had one, and what would make a sprouter agree with the farmer on that point?

And is the goal solely to “screen” for pathogens or is the goal also to grow seeds in an environment where they are less likely to become contaminated with a pathogen?

If someone managed to somehow discern what the FDA was talking about in terms of an “appropriate program,” where would a sprouter find seed that was grown under such conditions? Would it be labeled in some special way? Inspected in some way? Audited in some fashion?

Does the FDA communicate in this way because it has no idea of what the “appropriate program” might be or does it communicate this way because the very last thing the FDA wants is to be held responsible for something?

As long as it merely urges an “appropriate program” as the criteria, FDA is fully protected. If there ever is a food safety problem, it will use that food safety problem as ipso facto proof that the suppliers did not have an “appropriate program” in place.

If FDA says anything useful, say that in an “appropriate program,” fields must be fenced with a fence going from 12 inches below ground to six feet over the ground level, and if a burrowing animal digs under the fence or a leaping animal leaps over the fence and this causes a food safety problem, then this failure will be on FDA’s hands.

And the Number One most important priority at FDA is not enhancing safety, of food or medicine; it is, instead, making sure that no FDA executive can ever be blamed for a death or illness related to food or medicine.

There are many efforts afoot to reorganize our government’s effort in the food safety arena. Many of the plans, such as proposals to create one food safety agency focused on logistics, organizational charts, developing clearer lines of authority, etc., may help or hurt or not make a difference.

To make a big difference, we need to focus in on changing the incentives of individuals… in this case the executives at FDA.

Alfalfa Seed Company, FDA, USDA And Supporting Cast Comment On Seed Withdrawal

The alfalfa sprout industry is operating under an FDA recommendation not to consume since April 26, 2009. We discussed this issue in a piece titled Insights On The Alfalfa Sprout Advisory.

Then the FDA issued as “Alert,” identifying an epidemiological link between a specific seed supplier and the outbreak. We asked Pundit Investigator and Special Projects Editor Mira Slott to find out more:

Lyle Orwig
Caudill Seed Company
Louisville, Kentucky

Q: FDA says the preliminary epidemiology ties the alfalfa salmonella outbreak to Caudill seeds. What can you tell us?

A: The seeds have been implicated but there is no proof. While the seeds are said to be epidemiologically linked, FDA hasn’t been able to conclusively tie the source of the salmonella in the sprouts back to where it actually occurred. FDA would need an exact fingerprint serotype match, but it has no confirmed test.

From the seed company perspective, we encourage all sprouters to follow FDA food safety guidance. Back in ’99, they did all that work to establish best practices. If the seeds are treated with recommended soaking chemical and the sprouters do that and test and hold, we wouldn’t be talking about this problem now. Not everyone tests and holds.

Q: Are food safety measures conducted at the seed level? Does the seed company hold some responsibility here? On your website, it says all of the alfalfa sprouting seed provided by Caudill has been tested for germination, purity and absence of salmonella and E coli. How does that work?

A: We sell a raw agricultural product. What that means is that the alfalfa seed is either put into the ground to grow, or the sprouter will use it to produce edible product. It can be the same seed. Part of the seed industry law, in and of itself, is that when we sell, there’s a seed tag that shows what the germination is of that bag of seed, as well as the purity and process it has gone through. This is part of the federal law we follow that has to go on every bag we send out. When we buy seed, it’s sorted, tested and bagged and when it’s bagged and the tag goes on it, we’ve followed our legal duty. Then it’s the sprouter’s responsibility.

Q: What percentage of the alfalfa sprouting seeds is actually tested? Is the testing you’re doing statistically adequate to ascertain whether salmonella is in these seeds?

A: When we buy alfalfa sprouting seed, we take samples for a control lot, we grow alfalfa sprouting seed for 48 hours, but instead of following FDA guidance — say 25 million parts of chlorine to kill pathogens — we don’t do that, we just use water because if there is a pathogen we want to find it. If the seed is contaminated we don’t use it for commerce.

There is no such thing as pathogen-free anything. It’s like saying I washed my hands so why did I get a cold? Like growers that are doing things correctly, we’re testing the water, so if a pathogen is in that seed lot, it should come out in the irrigation water, tested and found, but there is no perfection in seeds or in finding salmonella in testing.

It’s a fact of life; you’ll never have the certainty of 100 percent pathogen-free seeds.

A sprouter would grow in a different medium than feed for animals where the seed goes in the ground to grow as hay to feed to cows. If I’m a sprouter, I’m sprouting in a medium to get the sprouts, washing that medium away and keeping the sprouts. These are two completely different processes.

The problem is you grow sprouts in a water-based media, usually a cold water base, which is the same grade for growing bacteria. That is why you need chlorine washing. At the same time you have to be careful because you’re dealing with a delicate product, and food safety measures can negatively impact the quality.

Q: If the salmonella contamination was isolated to an individual sprouter, the source of salmonella could have come from the plant, or from not following proper guidelines and testing. The reason FDA got involved was because there were different sprouters in various parts of the country connected to the outbreak, with the common link traced back to an Italian seed lot.

A: Look at the hundreds and hundreds of tests we did when FDA found this. FDA came to the Caudill property and went through seed lots, took thousands of samples, going through all the equipment, and couldn’t find Salmonella Saintpaul in any of our facilities, product, or seed — nowhere.

Q: If numerous sprouters in different states weren’t able to kill the pathogen through their food safety measures, what does this signify?

A: There were different sprout processors involved, but only three different ones where the sicknesses were connected, and they all used the same seed that came from us and traced back to that one lot. There were also many, many other processors that received seeds from that same lot that had no illnesses.

Q: Do you concentrate your buying with particular growers? How complex is it to trace back a problem?

A: We buy seeds from around the world, we bring them in, clean them, test them and distribute and sell them to sprouters or other seed companies or farmers wanting to grow alfalfa. We’re a major supplier to the sprouting industry.

We purchase primarily from Italy and Canada. These seeds in lot 032 come from Italy. When we sell that lot to any sprouting company, we know who got that seed, so when they sell those seeds to a retailer or foodservice company they know where the lot came from. The people that ate sprouts and got ill in various states told investigators where they purchased them. Each of those batches at the different places had certain numbers, and the common denominator was that they all came from lot 032, which is our coding for Italy.

Q: Did all the seeds in lot 032 come from one particular grower, or several? Could a grower blend seeds? Do you ever mix seeds from different lots, or growers?

How does this affect traceback capabilities? Do you have a way to narrow down with lot 032 what farm the seeds in question came from, what row?

A: I was able to get in touch with my technical guy. We can trace the seed back to the individual farmers and fields in Italy. There are six digits in the lot numbers. Everything with 032 comes from Italy, and the next numbers say which farms and which fields. What we’re looking at is all seeds from Italy.

As far as blending of seed, in order to get a full container of product, some times the production of two or more fields or producers will be combined. But that doesn’t alter our ability to trace back to those two or three farms.

Q: To what degree, if any, do you have control over the growers and the conditions under which product will be grown? Are you using any preventive measures to insure good agricultural practices are being followed? Do you test specific fields and conduct regular audits?

A: We do inspections, but I can’t tell you how often. We don’t do audits.

Q: Have you conducted inspections of the farms connected to this seed lot in Italy?

A: We have not yet visited the production area in Italy associated with this problem; that was planned for this month, but will not happen now because of the time commitment to this issue. However, since our supplier is a well known alfalfa sprout seed grower for the European market, we know they have a good understanding of our criteria for seed production

Q: Has the Italian equivalent of FDA gotten involved?

A: Yes. The Italian authorities have been contacted and are working with our supplier and the FDA.

There are different regulations in every country, but our standards are the same no matter where we buy the seed. We have good relations with all growers that grow alfalfa sprouting seed because it’s such a unique need, and yes there are specific guidelines when we work with them.

Q: What are those guidelines? And are they specific to your company, or do you follow the guidelines of GAP and those of other countries such as GlobalGAP?

A: We have our own criteria, which involves among other things a level and well-drained field — we don’t want moisture sitting there; no animal manure that can be used on the field, and no grazing six months prior to harvest. Criteria are based on all the work done on GAPs for seed growing. Most of our growers are also certified organic growers, whether in Italy, Australia, Canada or the U.S.

Q: Being certified organic is based on a particular set of requirements, but doesn’t necessarily guarantee food safety practices are being followed. You say you don’t conduct audits of your growers, so what verification methods do you employ?

A: We ask them to certify the processes we ask for. It’s self-compliance. We have a contract that we sign with our sprouting alfalfa growers and processors. The different standards between seed for food consumption and seed for feed production or non-human uses is in the areas of purity, cleaning out trucks, harvesters, etc.

In order to have certified USDA seed you need to follow GAPs. Any seed that is grown, whether growing corn for use with cattle or for human consumption, still has to be certified with a seed tag. If I grow alfalfa sprouting seed to sell to a sprouter, it has to be grown using GAP. If I grow alfalfa seed to sell to grow alfalfa for cattle feed, if I want it USDA-certified with that tag, I have to follow the rules for USDA certification.

[EDITOR’S NOTE: Despite strenuous effort we have been unable to identify a USDA “Certified Seed” program that had anything to do with alfalfa or food safety. Despite repeated requests Caudill Seed Company was unable to provide any website or other evidence that such a program exists. See interviews with USDA officials below to learn more].

Q: I didn’t think there was a USDA requirement, legal or otherwise for seed growers to follow GAPs, especially related to food safety.

A: There certainly is this kind of monitoring going on with us for alfalfa sprouting seed growers and processors. They have particular cleaning procedures they must follow, and there can be no feed lots adjacent to seed fields. When delivering seed to the processor, they must clean out any contamination in the trucks, and then there is a whole list of FDA guidelines to follow for processing, rodent control, etc.

There are USDA general agriculture practices for any seed company, food or non-food. There is a whole list of GAPs for producing seed for food consumption separate from producing for corn, or feeding alfalfa to animals. USDA has different requirements for farm animals and food consumption. Our criteria are what we do as a company for seed grown for human food. I can’t speak for other alfalfa seed sellers on their protocol.

[EDITOR’S NOTE: Once again, despite many attempts on our part we have not been able to identify any regulations from FDA or USDA, much less both agencies that would be relevant to food safety standards for this Italian-grown alfalfa seed. We also find no distinction in the laws or regulations requiring only specially grown seeds to be used for human consumption. Despite numerous requests, Caudill Seed Company was unable to provide us with websites or other references substantiating these claims. See interviews with USDA officials below].

Q: FDA says Caudill made the decision to voluntarily withdraw from the market all the alfalfa seeds bearing six digit lot numbers that start with 032. Why a withdrawal and not a recall? What is the difference? Does a recall have a greater legal obligation, where Caudill would be agreeing to pay for companies to ship back and dispose of product, etc.?

A: The biggest difference between a recall and withdrawal is that a recall is a request from FDA because they have discovered an adulterated product. A market withdrawal is voluntary, as this one is because there is no proof, only suspicion. It is a significant difference. There is no proof; there are only problems and suspicion.

They have to have scientific proof to have a recall. There has to be an exact match. There are multiple strains of salmonella. In this instance, the only way you should have a recall is if it traces back the exact fingerprint of Salmonella Saintpaul. To justify a recall you have to have an exact match from the sick person to the seeds or product, otherwise it’s just suspicion.

Q: But a recall is also voluntary. FDA has certain limitations in what it can mandate. In this case, FDA alerted retailers, restaurateurs and personnel at other foodservice facilities that they should ask their suppliers to verify that the alfalfa sprouts or seeds being provided do not come from an affected lot before buying or serving them. Is it just FDA saying this? Caudill is withdrawing all seed in the lot, but not advising all customers to send it back?

A: I am not an attorney, but I can tell you that we do follow FDA recommendations, so we would be saying the same things. Our attorney responded to the question this way:

“Recall” is defined at 21 CFR 7.3(g) as a firm’s removal or collection of a marketed product that FDA considers to be in violation of law. The definition makes perfectly clear that a “recall does not include a market withdrawal ….”

The regulations go on to define “market withdrawal” (21 CFR 7.3(j)) as a firm’s removal or correction of a distributed product that (1) involves a “minor violation” that would not be subject to legal action by FDA or (2) that involves no violation and constitutes a normal practice, e.g., a stock rotation. In the case at hand, FDA has not concluded that Caudill Seed’s seeds constitute a violative product under the FDC Act. Nevertheless, because of the sprout outbreak and because sprouters may have failed to adequately disinfect Caudill Seed’s seed (a raw agricultural product), Caudill Seed felt that it was in the public interest to remove seed from the market that had been used to grow the sprout products implicated in the Salmonella outbreak. This was an entirely voluntary action on the part of Caudill Seed and was not requested by FDA and was not based on a conclusion by FDA that the seed was “violative” of FDA’s laws.

In sum, to be clear, the difference between a recall and a market withdrawal is clearly spelled out in FDA’s regulations and depends on whether FDA has concluded that the product at issue constitutes a serious violation of law. In the case at hand, FDA has made no such decision with respect to Caudill Seed’s seed.

The problem is that we are producing raw agricultural product that will have pathogens in it. We know that going in and we are trying to minimize it to zero the best we can. Most seed is grown with irrigation of some kind. If growing with irrigation — same as anything else — if a coyote goes through and does business through your field, and you comb through that product and it breaks into a million pieces and goes into a seed lot, and that feces has salmonella, it’s infested that whole seed lot.

By the steps we take, we hope to mitigate these problems, but sometimes they happen. On our product labels, no one goes as far as we do to say here is our raw product and these are the things you should know.

Lyle Orwig genuinely tried to help us and we appreciate it. However, he works for a prominent PR agency, Charleston/Orwig, and it is difficult to be both an expert on public relations and an expert on seed and food safety. We are all in favor of hiring professionals but we consistently find it a mistake to simply abandon the job of representing your company to PR professionals. Far more effective is utilizing outside agencies to coordinate interviews and to arrange for your own people, genuine experts in what they do, to talk to the press.

As a result of this “knowledge gap” there are several points made in the interview we question. We noted a couple with editor’s notes and left a few for readers to draw what conclusions they will. We did find seven points especially worth discussing:

1) Innuendo or Accusation?

If the seeds are treated with a recommended soaking chemical and the sprouters do that and test and hold, we wouldn’t be talking about this problem now. Not everyone tests and holds.

This is left to hang as a kind of innuendo. Are there specific customers that Caudill Seed knows are not following FDA recommendations? Why do they continue selling them? And if Caudill Seed doesn’t know of any customers not following FDA recommended procedure, why would it make statements of this nature, implicitly condemning members of its own customer base?

2) A Law or a Wish?

When we buy seed, it’s sorted, tested and bagged and when it’s bagged and the tag goes on it, we’ve followed our legal duty. Then it’s the sprouter’s responsibility.

Although we are not aware of a court case in which this claim has been tested, we doubt it is true as a matter of law. Products generally carry a warranty of suitability for the purpose intended. If a seed company sells to a sprouter, it knows this food is intended for human consumption. One day some sprouter put out of business due to an outbreak will sue the seed supplier and we will see what the outcome is.

3) Beware of Non-Quantified Testing

Q: What percentage of the alfalfa sprouting seeds is actually tested? Is the testing you’re doing statistically adequate to ascertain whether salmonella is in these seeds?

A: When we buy alfalfa sprouting seed, we take samples for a control lot, we grow alfalfa sprouting seed for 48 hours, but instead of following FDA guidance — say 25 million parts of chlorine to kill pathogens — we don’t do that, we just use water because if there is a pathogen we want to find it. If the seed is contaminated we don’t use it for commerce.

We find this often. Lots of people do testing, but when asked exactly how much, they grow silent. We did a substantial piece on finished product testing here. One of the key insights is that testing must be done with great frequency to be statistically meaningful. To publically talk about one’s testing regimen but not quantify it borders on being deceptive.

4) Equal Opportunity Pathogens

There is no such thing as pathogen-free anything. It’s like saying I washed my hands so why did I get a cold? Like growers that are doing things correctly, we’re testing the water, so if a pathogen is in that seed lot, it should come out in the irrigation water, tested and found, but there is no perfection in seeds or in finding salmonella in testing.

It’s a fact of life; you’ll never have the certainty of 100 percent pathogen-free seeds.

We found this interesting, mostly because just a few paragraphs earlier Mr. Orwig was less generous to the sprouters. In relationship to them, he said this:

If the seeds are treated with a recommended soaking chemical and the sprouters do that and test and hold, we wouldn’t be talking about this problem now. Not everyone tests and holds.

It seems that just as 100% pathogen-free seeds can’t be guaranteed, the same goes for sprouts — which is why we would think that a concerted effort to minimize pathogens at every stage of the process would be useful and advisable.

5) Food Safety and The Black Swan

Q: If the salmonella contamination was isolated to an individual sprouter, the source of salmonella could have come from the plant, or from not following proper guidelines and testing. The reason FDA got involved was because there were different sprouters in various parts of the country connected to the outbreak, with the common link traced back to an Italian seed lot.

A: Look at the hundreds and hundreds of tests we did when FDA found this. FDA came to the Caudill property and went through seed lots, took thousands of samples, going through all the equipment, and couldn’t find Salmonella Saintpaul in any of our facilities, product, or seed — nowhere.

We understand the frustration executives at Caudill must feel in this situation. As was mentioned in a letter from Primus that we featured in a piece here, these are Black Swan events. They have enormous impact but are so rare that they go beyond any normal range of expectation. It is only after the fact that we can say that if we can rationalize the event and say that had we followed X and Y procedures, the event wouldn’t have happened.

As a result the FDA testing means little. It doesn’t mean the Caudill seed wasn’t at fault — and, by the way, despite popular assumptions, a positive test result would not have proven that Caudill seed was at fault either. These results just increase or decrease the likelihood of a connection.

6) Seed Blending and Traceability

As far as blending of seed, in order to get a full container of product, some times the production of two or more fields or producers will be combined. But that doesn’t alter our ability to trace back to those two or three farms.

Our interview with Michael McCartney regarding traceability, which you can read here, emphasized the importance of starting traceability with the seed. One doesn’t have to be a traceability expert to know that if you blend seed you make traceback more complicated. Now one knows that the contaminated seeds came from one of two or three fields or farms as opposed to one. So blending seed is a really bad idea.

7) Self-Compliance for food safety or Liability Reduction?

We ask them to certify the processes we ask for. It’s self-compliance. We have a contract that we sign with our sprouting alfalfa growers and processors.

We really shouldn’t pick on Caudill Seed Company specifically, but this attitude is all too common up and down the food chain. Everyone puts things in contracts in hope that it will lessen liability, and food safety often focuses on getting a contract signed and acquiring proof that the counterparty has adequate insurance. If a company is really serious it either staffs up to confirm things itself or it, at least, requires a third-party verification.

Sprouts are a very tiny part of the produce industry, but they are the segment whose food safety problems go back the longest. We need to act now to clean up this segment.

Is Mr. Orwig’s accusation that many sprouters are not following FDA recommendations true? If so, who is buying from these vendors? And clearly, we need to find a route by which seed is grown for human consumption with the goal of reducing pathogen contamination.

Is Mr. Orwig’s accusation that many sprouters are not following FDA recommendations true? If so, who is buying from these vendors? And clearly, we need to find a route by which seed is grown for human consumption with the goal of reducing pathogen contamination.

Mira contacted FDA to get more clarity:

Sebastian Cianci, FDA spokesperson, provided the following information for our readers:

● A brief explanation of the differences between a market withdrawal and a recall can be found on FDA’s website at: http://www.fda.gov/oc/po/firmrecalls/

● The references made by Caudill’s attorney (21 CFR 7.3(g) and 21 CFR 7.3(j)) can be found at:


● The information in this document may also prove helpful in understanding recalls. http://vm.cfsan.fda.gov/~lrd/recall2.html

● Information on the outbreak can be found at http://www.fda.gov/oc/opacom/hottopics/

[Editor’s note: In a most telling statement, FDA sent a letter on May 1, 2009 to suppliers of seeds, distributors and sprouters, pointing out the following: “As you are aware, seeds are considered the most likely source of contamination in most sprout-associated outbreaks. Therefore, it is important that sprout growers source their seeds from suppliers with an appropriate program to screen their seeds for potential contamination with pathogens.”]

Mira also reached the person at USDA charged with seed regulations and testing…

Dr. Richard Payne
Chief of Seed Regulatory and Testing Branch
Agricultural Marketing Service (AMS)

Q: What are the USDA regulations for alfalfa seeds? What are the requirements for labeling seed, and is there a distinction between alfalfa sprouting seeds grown for human consumption and those grown for animal feed or crop use?

A: Let me start with a little background. The Federal Seed Act is a truth in labeling law:

…that regulates agriculture and vegetable seed shipped in interstate commerce. An aside is that in the Constitution, one thing the federal government regulates is interstate commerce. There are certain required pieces of information that have to be on the seed label. I’ll address alfalfa. First of all, there is no requirement for information about seed pathogens to be on the label. Some of the information that is required to be on label: Percent pure seed, percent inert matter like broken seed and pods, percent other crop seed, and percent weed seed. These are percentages based on weight. There’s a specified quantity of seed to be tested for alfalfa, then physical separation for four compounds and that weighed for percentage.

Also on the label should be percent germination, and percent hard seed, which is something unique to alfalfa and clovers, and so forth. Percentage derived is based on a number, 400 are planted and a percent of normal seedlings is determined. Some product doesn’t involve moisture and is called hard seed. Then the date of the test to provide the germination information.

Now for alfalfa and clovers, the tag needs to show the country or state of origin. If seed has some kind of chemical treatment, a fungicide, for example, the name and information about the chemical treatment if present on the seed. Also, the variety name, or option of variety not stated. Somehow you have to deal with designation of variety.

Also, noxious weed seeds, some are federal and some are classified by individual states. If weeds become established, they could cause problems and be expensive to kill. They need to be identified by number per pound.

The tag includes the shipper’s name and address, the name of the interstate shipper and their address. There’s an option here, if seed is grown in Oregon, cleaned, conditioned and bagged in Oregon, and say it’s shipped to Georgia for resale in Georgia, the Oregon company could put the Georgia name provided it puts the AMS number on the label. They get that from our office.

Q: Is there any differentiation on the requirements based on the eventual use of the alfalfa seed?

A: We are just involved with covering seed shipped in interstate commerce; we don’t designate or make a difference by potential use. Some states may require this but the Federal Seed Act does not. On occasion, seed of alfalfa and clovers may be inoculated with bacteria to fix nitrogen to help plants grow better. Pursuant to that, the company has to put the year and month to identify when the bacteria would not be effective. I assume something for sprouting wouldn’t include this because this is for plants grown in the field.

Q: Are there other tags or regulations for alfalfa seed besides the one for interstate commerce? Is there a USDA seed certification?

A: The individual states have seed certification agencies for varietal purity. And there are certain minimum requirements and standards in the Federal Seed Act regulations that the seed programs have to meet. But this is certification for varietal purity. It usually involves field inspection and field history prior to harvest, and then after a test for purity, germination and weed seed at the state level. Now some may have additional standards and requirements above those in the Federal Seed Act that may be for germination and weed seeds. But that’s the only involvement our program has in certified seed. There’s also an Association of Official Seed Certifying Agencies (AOSCA).

Q: Caudill Seed Company says USDA has established GAPs for any seed that is grown, and these differ based on use and that these must be followed for seed certification. Is this the case?

A: The only GAPs that are written down that we’re involved in would be certifying seed for varietal purity, such as different field requirements and certain isolation distances, and fields have to be inspected. There are requirements about what was grown in that particular field the earlier year, since there could be carry over from dropped seeds. Again, this pertains to varietal purity, not food safety.

Then there’s the Association of American Seed Control Officials (AASCO)

RUSSL, the Recommended Uniform State Seed Law, is almost identical to the Federal Seed Act, to help individual states maintain uniform state seed laws. The state seed control programs are responsible for seed produced and sold in their state, where the Federal Seed Act regulates interstate commerce, and they mesh together.

There are certain requirements that Animal Plant Health Inspection Service (APHIS) has. It is responsible for enforcing import provisions of the Federal Seed Act, and also the federal noxious weed seed list. It will check for prohibited product. It also deals with phytosanitary certification, in the need to be free of certain pests if being imported.

I’m not familiar with requirements related to testing for pathogens like salmonella or E. coli.

From the point of view of the Federal Seed Act, it doesn’t go into the usage; it addresses seed for seeding purposes. There could be states that make distinctions for sprouts. The kind of seed, alfalfa and its origin needs to go on the label, but there is nothing related to food safety at the federal level for the seeds.

You could contact Rodney Young at APHIS to get his perspective on imports and exports

The American Seed Trade Association at one time was putting out GAPs for seed companies. From time to time, it tries to come out with various good practices for their members, coming up with something seed companies can provide to retailers to help maintain quality of seed.

Mira touched base with Rodney Young to learn more…

Rodney Young
Animal and Plant Health Inspection Service (APHIS), USDA

Q: Do your regulations address food safety in imported seeds?

A: APHIS is involved in the regulation of imported agricultural products. Our requirements are really not about food safety issues. These phytosanitary requirements Richard Payne is talking about would be written to prevent introduction of plant pests into the country through importation. This involves seeds for propagation. It doesn’t really apply to foodborne illnesses. The USDA has an agency, the Food Safety and Inspection Service FSIS), that handles food safety issues. [This is the public health agency of the USDA and deals primarily with meat, poultry and eggproducts].

On our side with alfalfa seed, I really don’t know about distinctions for sprouting for human consumption. For years, I was dealing with imports of alfalfa seeds from Canada. The main thing we required was no noxious seeds, which is part of federal seed requirements; if a company imports alfalfa seed, it has to have a label that says what it is. These import requirements are really not that strict for seeds. When we get into phytosanitary requirements from around world, we may prohibit importation of wheat in a country because of pests, for example. Our policy is related to regulation of disease in plants.

I’ve looked at regulating weeds for planting purposes. I know there are cleaning procedures for planting purposes that involve mixing metal filings with the seed and running seed over magnets. In this way you could remove weed seeds from alfalfa, but it uses these metal particles for cleaning this alfalfa seed, and you could see the metal on the seeds. You wouldn’t use this for sprouting purposes and I would think you would have to distinguish the seeds because they would be unfit for human consumption.

If I was going to grow sprouts in my kitchen, I would never use these seeds. For this reason, I would think there should be regulations for using alfalfa seeds for sprouts.

Finally, Mira sought clarification from the Association of Official Seed Certifying Agencies:

Chet Boruff
Association of Official Seed Certifying Agencies (AOSCA),
Moline, Illinois

Q: Dr. Richard Payne at the USDA provided information on federal seed regulations for interstate commerce, and what is required on labeling. Could you shed more light on the seed certification process? Does this go beyond federal law for interstate commerce? Are there different types of seed certifications based on whether the seed will be used for human consumption?

A: Dr. Payne is the best authoritative source for accuracy in terms of certifying seed. He is correct when he says it deals with purity of variety. Different seeds have different attributes and characteristics, which you can’t tell just by looking at the seed. It has to be planted to ascertain if it produces the traits and outputs you want. All seed certification does is insure that the seed in the bag is the variety the buyer thinks he or she is getting.

Q: Are there any food safety measures involved in the certification process?

A: Seed certification has nothing to do with food safety; especially in the case of alfalfa sprouts where contamination may or may not have been on the seed.

Issues of food safety are just so far out of our authority.

Q: To clarify, the fact that alfalfa seeds are certified does not signify those seeds were grown with any particular food safety measures in place?

A: Yes. That is correct. When discussing the alfalfa salmonella outbreak, seed certification is such a peripheral issue that it could confuse people. The same can be said about organic certification. There are some people who argue just as strongly the other way, that organic is less safe from salmonella or E. coli. It may be that organic growers use different plant nutrients, compost or manure because they can’t use certain commercial fertilizers. Some might say in doing so, there is a higher likelihood of food safety problems.

Just because something is organic, does not mean it’s any safer. Organic is something to do with the process under how the crop is grown. It may have different internal characteristics because it didn’t use pesticides. That doesn’t say what is on the outside of that seed isn’t carrying some kind of pathogens. Maybe it comes down to perception that organic food is more wholesome. I believe this is a different matter than food safety and disease and pathogen control

Q: So what does seed certification represent to a buyer?

A: Seed certification is intended to make sure the variety’s purity is maintained throughout the process. That is the underlying reason. We work very closely with Dr. Payne’s agency at USDA. The way it works is that for the U.S. and most developing countries around the world, seed certification is accepted business, with overall arching standards. We have representatives working in the U.S., Canada, Australia, New Zealand, Chile, and Argentina to cover counter-seasonal production. A company in Iowa that harvests in the fall can ship south and plant crop and have it back in Iowa for the spring, allowing for two seasons out of one year. That’s why we have members around the globe.

Q: Is your organization paralleling the Federal Seed Act requirements in certifying seed?

A: Seed certification started back in the early 1900’s. We had several companies doing certification. Then in 1919, 13 states and Canada saw the need for a standard way of doing business and got together to form this organization. We pre-date the federal seed law in the U.S., which was written in the 1930’s, and the most common international seed certification program initiated after World War II.

When the government started putting together standards, it turned to AOSCA, which became a baseline for the Federal Seed Act and international certification. Over time, there have been changes and amendments, but the core standards remain the same.

Q: Has there ever been any talk about integrating food safety standards into the certification process?

A: I’ve been here five years now, and discussions have come up for food safety, but our focus and responsibility continues simply on insuring the right variety. Our goal is not to duplicate efforts, and there are other agencies that deal with food safety.

Q: But is the issue of food safety in the growing of alfalfa seeds being addressed? We are seeing FDA food safety guidelines for sprouting and processing operations but what about in the fields when growing alfalfa seed for human consumption? That’s the crux of the issue we’re trying to determine.

A: When looking at growing seeds, there is a notable distinction regarding alfalfa seed for sprouting that should be taken into account. If talking about soybeans, it probably doesn’t make any difference how the seed itself is grown because it will be planted in a soil medium with other contaminants that could come about.

The issue with alfalfa seed for human consumption is that the seed itself never comes in contact with the soil. They’re just sprouted in some type of growing medium, so the consumer comes into contact with the initial seed coat itself. That’s the issue you’re dealing with.

Q: Couldn’t there be a significantly increased risk of alfalfa seed contamination in the fields from wandering animals, for example, without designating strict GAP measures for growing alfalfa sprouting seed?

A: Picturing most alfalfa seed fields, these are typically not grazed by livestock. Back to my animal science days, cows typically don’t digest pure alfalfa out of the field. In this case, the plant would be cut for hay, it typically dries, and is put into a bale, or into a silage process to improve digestibility. In order to get the optimum seed for alfalfa, most of these production fields will be intensively managed as seed fields rather than used for a dual purpose, where a farmer would allow cows to graze on the field. In growing alfalfa for seed, they just wouldn’t do that. I can’t speak for other countries, but it would be extremely unlikely for that dual purpose approach to happen.

With our process to insure purity of variety, it begins some two years earlier. We need to know the land history so there is no contamination from one variety to the next. But as far as contamination for food safety, we have no responsibility, outside the responsibility of our given task.

Q: To clarify, buyers can be assured of the variety’s purity, but the purity doesn’t have anything to do with a safer end product? Does the responsibility for food safety start only after the seed is purchased then?

A: What I believe happens is the alfalfa is grown for seed, the producer has the seed available for sale and someone buys it, but the seed salesman has no idea what process it has been grown under. I don’t know if one variety makes sprouting better than another; my knowledge is that there are no specific alfalfa sprouting varieties.

After the alfalfa seed is grown, we come to a fork in the road; a large amount of that seed is sold for animal feed and crop use, and a smaller percentage is used for sprouting. When we reach the fork in the road, whose responsibility is it to make sure the seed is free of any pathogens? I believe it’s the purchaser growing the alfalfa sprouts. Once it leaves the seed company’s custody, it is out of their control. If alfalfa sprouts do show positive proof of a pathogen, who is to say it originated from the seed or in the processing or somewhere else in the distribution chain?

Many thanks to Lyle Orwig, spokesperson for Caudill Seed Company, Sebastian Cianci, FDA spokesperson, Richard Payne, the Chief of Seed Regulatory and Testing Branch for AMS at USDA, Rodney Young at APHIS and Chet Boruff of theAssociation of Official Seed Certifying Agencies.

H1N1 Flu Virus Far From Over

A few weeks ago, Junior Pundit primo, aka William, age 7, was washing his hands, drying them and then washing and drying them again. When we inquired as to what he was doing he explained, “Daddy, there is a terrible flu going around and you can die from it. I don’t want to die. I am too young to die! So you have to wash your hands really well.”

By this past weekend, his advice had changed: “Dad, the flu turned out not to be so bad. If you get it, you have to stay home from school for a few days and you feel like any other cold or flu. So it is OK now to go to Disney.”

As they say, from the mouth of babes you get the truth, and William’s perspective generally mirrors what he was taught in school. The crisis we feared — with millions not merely sick but dead — doesn’t seem imminent:

Elizabeth Weise of USA Today wrote a piece, Swine Flu Outbreak Getting Longer-term Look by the CDC:

With about 2,600 cases of swine flu reported in all but seven U.S. states, the Centers for Disease Control and Prevention is changing its focus from identifying cases of H1N1 to a comprehensive, longer-term perspective.

Though not ignoring people still falling ill, researchers say they have enough understanding of the outbreak to begin looking ahead at what the new strain of influenza will do during the Southern Hemisphere’s winter flu season, which is just beginning, and how H1N1 may have evolved when it comes back to the Northern Hemisphere next fall for the regular flu season, says the CDC’s Anne Schuchat.

The World Health Organization reports 4,694 cases of H1N1 flu in 30 countries and 53 deaths as of Monday. The outbreak is still classified as Phase 5 — just below a pandemic — because it doesn’t appear to have established itself outside North America, WHO’s Keiji Fukuda says.

The CDC has linked three deaths in the USA to the new flu. The number of confirmed cases is almost certainly only “the tip of the iceberg,” Schuchat says.

In the USA, more young people than old are getting sick; the median age for reported cases is 15, Schuchat says. “We would love to nail down” why, she says.

One theory is that it’s simply because the first people who got sick were young, and it has remained in that population. Another possibility is that previous outbreaks of influenza shared at least some genetic attributes with this one, which gives older people partial protection.

The CDC and the World Health Organization are working on plans to develop a vaccine against the strain, though a decision on whether to move forward with production has not been made.

About 40% of people being tested for influenza in the USA are positive for the H1N1 virus, and the remaining 60% are positive for regular seasonal flu viruses, the CDC says.

Doctors can’t let their guard down, Schuchat says. “We need to guard against complacency as we move into a new normal.”

We asked Pundit Investigator and Special Projects Editor Mira Slott to update us on the situation by speaking to a medical/public health authority and an industry participant:

Marc Schenker, MD, MPH
Professor of Public Health Sciences
UC Davis School of Medicine

Q: What is your assessment of how the H1N1 virus outbreak is being handled?

A: My background is as a professor of medicine and public health pulmonary physician. There is no casual dissemination of this virus at this point from going to work or at work. It is not that type of dissemination. It is typically in schools with people in close quarters and known cases that have spread.

What do you do as an employer? Recommendations are pretty clear:

First, any employees that have symptoms should stay home. Don’t take the risk of disseminating the virus until it is clear what illness it is. That’s the major recommendation.

The second general precaution and what has been said by the President on down, washing hands, covering coughs and preventing aerosols (sneezes, coughs, etc.) from disseminating.

For anyone in food handling, hand washing is part of the 10 commandments; it’s in the bible.

Q: In New York City, Mayor Bloomberg spoke poignantly at a press briefing that he continues to ride the subway every day to work, trying to allay fears to avoid cramped public places. At the same time, local organizations were just cancelling public Cinco de Mayo celebrations in anticipation of large crowds.

A: Should you avoid going to work, movie houses, crowds? No. This is not necessary. There is no need to panic. People should continue riding the subway. It is not necessary to stop. I agree with Mayor Bloomberg.

Q: Some scientists are extrapolating numbers from earlier pandemics to highlight the potential risks. Is this an over-reaction?

A: It is important to realize that people haven’t gotten the virus by walking down the street or taking public transportation. In addition, it is important to realize this is not 1918 Spanish Flu or SARS, where there was a high fatality rate. The H1N1 virus seems to be mild illnesses. Obviously, we need to prevent an epidemic, or pandemic. You have to walk a fine line. People need to realize these are serious recommendations, but this is not a killer virus and we’re all doomed.

Q: What other advice can you impart to alleviate the potential spread of the virus, while assuaging panic?

A: There are other recommendations. If I do have symptoms and am concerned, call into a health care provider. Do not go into an emergency room or doctor’s waiting room with other people and put them at risk. Finally, medication for flu virus can be given early in the course of illness. But the medication is not for prevention; that is not the way it is being stocked.

Q: Is there enough to go around if the situation gets worse? There have been reports that we will have major shortages in vaccines and other equipment such as masks if the virus escalates.

A: In California, we have enough for a quarter of the population. There’s a lot. And the same applies to other states. Distribution obviously is an issue if people panic. I hope that’s not the case. Hoarding is a terrible thing.

Q: The produce industry is a strong trading partner with Mexico, and there is concern that business will suffer as a result of this outbreak. What information can you share with the industry to insure the relationship continues to prosper?

A: Mexico is, of course, going through enormous trauma with this. We should be helping and supporting the country. It is not at all clear the virus started in Mexico and came here.

Go back to AIDS. It was believed Haiti was the source and it came to the U.S., but when it was looked at more closely, it was learned that it started here and went to Haiti. No one knows where H1N1 originated. No one understands why there were more severe cases there. I speculate that poor communities could be more vulnerable, and illness is more of a problem.

We should not be victimizing or stigmatizing people or products from Mexico. They are being as aggressive, collaborative and appropriate as they can, while dealing with a horrendous situation. We must realize this is a global phenomenon, with no winners and losers or good guys and bad guys. This includes farm workers, millions crossing borders.

There is no evidence of danger from farm workers in produce fields. This virus is spread through aerosol transmission… if someone coughs or sneezes on you it’s a risk. It’s not something on an avocado, which wouldn’t survive. You don’t get this virus from eating pork, or from eating fruits and vegetables. The second commandment is wash fruits and vegetables, and that should always be followed for food safety reasons.

I work on immigration and health. People reacting to this outbreak by disparaging Mexican immigrants is just another example of the need for having a policy on immigration that will help address these issues. Disease doesn’t respect national boundaries or legal status. It’s a medical issue. Lack of immigration policy only exacerbates the problem.

Allison Moore
Communications Director
Fresh Produce Association of the Americas
Nogales, Arizona

Q: What has been happening on your end since the swine flu outbreak? Has there been significant fallout?

A: The big thing from the start was people had questions, concerns and misinformation about what was going on. We acted to stem the tide of rumors, trying to calm association members calling in, who were anxious to learn, what do we need to know, and what should we tell our customers and buyers? We put together concise, accurate information and references back to the government agencies.

Q: What were the main concerns and misconceptions?

A: Hopefully, we can fill a vacuum so often consumed with false anecdotes and rumor, to send something out to let people know the borders are opened. It has been said many times and in different venues. The Department of Homeland Security said publically and in Congress that closing the borders is not the solution. Containment is not possible. We must focus resources on mitigating and alleviating the situation. We are reiterating the scientific information and medical advice that the spread of the virus comes from person-to-person contact, sneezing and coughing, and the importance of practicing proper hand-washing and covering your mouth when you cough.

It is helpful this information from CDC that the virus is spread by the ill person, not through food. The border remains open, and every indication shows it will remain open. There is no plan to close borders.

The big questions from our members and our customers is: Will we have consistent supplies, and how is this spread so I can take appropriate measures? Is it safe to buy food products and sell to consumers, and will we have enough supply?

At the importer and distributor level, we’ve done all we can to arm our members.

We are working with other associations to put out accurate information. The swine flu doesn’t affect the produce industry directly. It is important to put out a consistent message and to show we are all on the same page.

Q: You say the outbreak doesn’t affect the industry directly, yet companies do a large amount of trading with Mexico, migrant workers are in the fields, trucks are going back and forth across the border, so there is at least the perception that the industry is impacted directly, and heightened concern that it could seriously harm business. Has anyone stopped buying Mexican produce?

A: Right now we haven’t heard that anyone’s going to stop importing produce; some growing regions are phasing out right now naturally and shifting to other parts of Mexico and Canada, and even the U.S., so any change in importing is due to the natural evolution of growing regions. Remember we are moving into summer when many US-producing regions come online.

We are working with growers and produce businesses to take the right steps to mitigate any spread of swine flu, following the recommendations of health officials. There are always rumors floating around that someone is going to stop buying, but we have no proof of that right now. We have received questions from the buying community, and hopefully we’ve been able to give them the government information they need to pass on to their own executives and to customers.

It’s really about putting out calm, rational information. These are the facts, and we need to base our decisions everyday on the facts. I’m heartened to see that most people have really behaved that way. Rumors are counter-productive. We need to focus on the fact that swine flu is not spread by food.

I want to reiterate that the border remains open, and there are no plans to close it. Government agencies both here and in Mexico are proactive in pre-planning and implementing common sense measures.

Q: Do you believe the U.S. has taken the proper level of precaution? Some folks see an over-reaction, others question whether the world will be prepared if a pandemic occurs?

A: I feel the U.S. reacted fairly well. President Obama was quick to point out the unfounded irrational thinking to suggest Mexican people should not come to the U.S. He used good reasoning in looking at travel restrictions. President Obama is maintaining a common sense approach. In cluster areas, close schools and offer additional outreach, limit travel to certain places for essential purposes.

A lot of public health officials have it right. Instead of acting on irrational fears, focus on good hygiene, don’t share utensils and cups, and follow the basic health message going out. They are advising consumers to take personal responsibility, don’t go to school if sick. This is nothing new for the swine flu, but the recommendation for any flu season.

We’ve tried to get out in front of the rumors and address the facts; these are the points to remember: it isn’t related to food, borders remain open, and there are common sense things to do in order to stop the spread of the virus. In times like this, people need to avoid knee jerk reactions.

None of this seems earth-shattering, and though young William is surely getting all the latest information from his school, it is not clear that he getting the final word. And even if he is, risks may be building for the next time.

Rob Stein over at The Washington Post wrote a piece titled, Viral Threat Emerged in a Ready World, which posits that a dangerous pathogen intersected with extensive preparation to cause an initial feeling of great urgency. The piece quotes, among others, Michael T. Osterholm, who we interviewed here:

“We’ve been getting ready for something like this for years,” said Michael T. Osterholm, director of the Center for Infectious Disease Research and Policy at the University of Minnesota. “And then this comes along, and all of a sudden the alarm goes off that says: ‘Oh, my God, it’s here.’ “

That alarm activated a network of disaster plans put in place after seemingly disparate crises and threats, including Sept. 11, the anthrax letters, SARS, Hurricane Katrina and the ominous avian flu virus, which has been skulking around Asia and other parts of the world for several years.

“What we’ve seen is a combination of lessons that we’ve learned from these events and the alarming news we were getting out of Mexico,” said Thomas V. Inglesby, deputy director of the Center for Biosecurity at the University of Pittsburgh. “All these things put together really set things off.”

An influenza virus can mutate easily, and there is a real danger that because the danger is not imminent, we could fall victim to the “boy-who-cried-wolf” syndrome:

Experts stressed that it remains far from clear that the danger from the H1N1 virus, as it is formally known, has passed, and they are concerned that the sharp shifts could leave the public jaded and complacent.

“I’m afraid that a kind of epidemic fatigue or the-boy-who-cried-wolf syndrome could set in,” said Stephen Morse, founding director of the Center for Public Health Preparedness at Columbia University’s Mailman School of Public Health. “But what’s the alternative? Not to talk about it? Not to respond? It’s a real Catch-22.”

Mike Osterholm gets the final word in the article:

With the virus in the Southern Hemisphere, experts will be watching what happens as winter sets in.

The virus could mutate at any moment to become more lethal.

“We’re dancing with this virus right now, and no one knows what will be the next step that the virus will take,” Osterholm said. “All of us have to understand that we are not done with this dance yet — not by a long shot.”

Complacency may be the enemy as much as the virus. Many thanks to Marc Shenker and Allison Moore for helping to keep the industry informed.

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