We’ve run several pieces related to Costco and the reintroduction of spinach into its warehouses. First we ran Consumer Studies On Spinach Reviewed…And Costco’s Proactive Approach, which mentioned a USA Today article that detailed Costco’s new requirement that spinach suppliers random-test at the processing plant.
Then we followed up with a piece called Pundit’s Pulse Of The Industry: Costco’s Dale Hollingsworth, which gave Dave, Costco’s Corporate Produce Buyer, a chance to expand on the USA Today article.
Finally we ran Pundit’s Pulse Plus! — Costco Clarification, in which both Dale Hollingsworth and Craig Wilson, Assistant Vice President of 
Food Safety and Quality Assurance for Costco, expanded on its food safety program.
The articles were all focused around Costco’s decision to reintroduce spinach to its produce departments. We went to our local Costco to see what was being sold. In Costco’s Boca Raton, Florida, store they were selling both a one-pound clamshell labeled as “Certified Organic Young and Tender Baby Spinach,” which 
was marketed under the New Star brand, and a 40-oz (2.5 lbs) resealable bag of “Young Fresh Spinach Leaves,” which was marketed under the Metz Fresh brand.
The two packages conform to exactly what Costco told us they were carrying. Yet the Metz Fresh bag stood out with something we have 
never seen before. Although it clearly said that the spinach was “pre-washed,” there was a large starburst on the bag in bright red that told the consumer to “Wash Product Before Use.”
The New Star label on the clamshell was more subtle. Although it said that the product was “Triple Washed,” it also said that consumers ought to “Rinse Before Use.”
“Rinse” is somewhat obscure and New Star seems to have this on other products. It is possible that one could urge a rinse and refrigerate to crisp the product, but the big red “Wash Product Before Use” on the Metz Fresh bag startles, and we can’t find it on other Metz Fresh product. We can’t help but believe that Costco is driving this type of language.
There are a few issues with this concept:
- The FDA has specifically said that pre-washed product should NOT be washed again by consumers. Although theoretically an additional washing just before use could make the product safer, the judgment of the FDA is that in practice, the likelihood of cross-contamination means an additional wash step is more likely to do harm than to do good. Is it really wise for the industry to urge consumers to do things that the FDA is saying they ought not to do?
- The scientific consensus seems to be that E. coli is very difficult to wash off due to the many nooks and crannies on a leaf. Are we giving consumers a false sense of security by urging this course of action?
- How many consumers will follow this recommendation? Although, theoretically the product can be washed thoroughly, it is not like an apple that a consumer can wash and wipe dry and eat all in two seconds. These are salad greens and require drying, etc. One wonders what research has been done on the willingness of consumers to follow this recommendation. If a big chunk of consumers ignore the advice, it may be an attempt at liability-shifting language but not have any practical effect on safety.
- Finally, the use of language urging people to wash or rinse the product raises this important question: What is the definition of “ready-to-eat” produce? The draft Good Agricultural Practices document makes a distinction between ready-to-eat and other product. For example, in the draft GAP document, there is a section related to machine harvesting of lettuce/leafy greens that will be further processed into ready-to-eat product. The section includes restrictions that only apply if the product will be ready-to-eat. So here is an issue: if a processor that is a signatory to the California Marketing Agreement puts a “wash before use” statement on a bag, is he still required to have his growers follow the more stringent requirements for ready-to-eat produce? And if a retailer requires such a statement on the bag, might it wind up with product grown to a lesser standard?
The whole purpose of the Marketing Agreement and the Buyer-led Food Safety Initiative is to rebuild regulatory and consumer confidence. How can we do that if our packaging instructions run directly counter to the recommendations of the FDA?
