Here at the Pundit, we unveiled the draft Good Agricultural Practices in conjunction with an offer of an honorarium in the amount of $500 for the best suggestion to improve the draft GAP document. Now, although it has an April 25, 2006 cover date, there actually is an updated version of the draft GAP document available, and you can see it here.
We are upping the honorarium to $1,000 because we need more help: The new draft, although more rigorous in some instances — recommending 30 feet from the edge of a crop instead of 20 feet for distances to grazing land, homes and other such things — is also weaker. It calls for 400-foot distances to “concentrated animal feeding operations” and “composting operations,” etc., whereas the earlier draft called for 500 feet.
One problem with the draft GAP document is that it retains this phrase:
proximal Safe Distance — this distance may be either increased or decreased depending on risk and mitigation factors.
It reads to the Pundit as if the authors are using the word proximal in its medical sense. The National Cancer Institute defines it this way:
In medicine, refers to a part of the body that is closer to the center of the body than another part. For example, the knee is proximal to the toes. The opposite is distal.
So they are saying that this is some kind of center of the range and that you can then add or reduce the distance as a result of risk and mitigating factors.
The problem with this way of thinking is that this kind of variable standard is precisely the complaint regarding the current GAP documents, which are unenforceable because they treat each field individually. It is impossible to walk in and say, “This guy is in violation,” without first doing a HACCP study.
We all understand that under certain circumstances, core food safety measures need to be increased. But there should be a minimum standard that is easy to enforce.
The current document will not build regulatory and consumer confidence because it doesn’t allow for easy verification of adherence to minimum standards.
Besides, it is going to be a tough battle to convince consumers that the industry is really serious about food safety if we don’t insist on food safety standards for ready-to-eat produce at least as high as those used by Fresh Express, the largest producer of ready-to-eat salads.
We’ve printed those standards before, but it is worth printing them again. They were revealed to the public in a USA Today article entitled ‘Fresh Express leads the pack in produce safety.’ A sidebar detailed a few of these minimum standards. Some are applicable for GAP documents and others apply to the soon-to-be-unveiled Good Manufacturing Practices documents.
Take a look at these standards:
SEED TO SUPERMARKET
Fresh Express, the No. 1 maker of packaged salads, is considered an industry leader in food safety. Fresh Express processes 1.2 billion pounds of raw lettuce and spinach a year. It buys lettuce and spinach from growers, who must meet certain standards.
— GROWING —
Fresh Express gets most of its product from California’s Salinas Valley. Fields and operations are inspected three times each crop cycle.
Fresh Express won’t accept produce from fields if:
- They’re within one mile of a cattle feed lot or dairy operation. Cattle operations may cause E. coli to get into runoff water and onto a field, especially during floods.
- They’ve been flooded within five years.
- They’re within several hundred feet of a cattle pasture.
- They’re within 150 yards of rivers, or habitat that attracts wildlife that may spread contaminants.
- They catch water runoff from cattle pastures.
In Salinas, Calif., well water irrigates fields and is drawn from aquifers 800 to 1,000 feet below ground.
- Water is tested monthly for pathogens during the growing and harvesting season. Before the recent E. coli outbreak, water was tested at least three times a year.
Because animals can spread E. coli, tracks in a field make that part of the field unfit for harvest. Often, 30% to 40% is affected. Two years ago, Fresh Express stopped buying lettuce from Florida because growers couldn’t keep frogs out of the crop, which then had to be destroyed. To protect fields:
- Rodent traps, checked daily, are set about 50 feet apart along the field’s edge. Carbide cannons, which sound like shotguns, are set off by timers to scare off birds.
- Fences may be required to keep out deer, wild pigs, cattle and other animals. Evidence of wild pigs makes land unharvestable for two years.
- Workers’ dogs are not allowed in fields or in trucks.
- Fresh Express prefers growers use cover crops to add organic matter. Crops such as wheat and barley are planted but plowed under before harvest.
- Raw animal manure is banned because it may contain E. coli.
- Composted animal manure is being phased out because of fear that bacteria may survive fermentation and heating.
— HARVESTING —
- Spinach is typically harvested between 2 a.m. and 6 a.m., when cooler temperatures help keep product fresh. Lettuce, which is hardier and is a bigger crop, is typically harvested in the morning and afternoon.
- Iceberg lettuce workers cut lettuce from root. Outer leaves taken off. Core cut out. Each head is placed onto tray and a water jet sprays the cut area, where bacteria can cling.
- Lettuce goes up a conveyor belt, is sprayed with chlorine-based solution for cleansing and goes into plastic-lined bins on truck. Plastic liners are used only once.
- Workers must wear gloves, hairnets, aprons, long sleeves so that no skin touches produce.
- Portable latrines with water for hand-washing must be within a 5-minute walk, or 1/4 mile, from workers. One latrine is needed for every 20 employees of each gender.
— COOLING —
- Produce is trucked from the field to a cooling station.
- Cooled to 34-38 degrees within four hours of being cut.
— SHIPPING TO PROCESS —
- Produce is trucked from cooling stations to Fresh Express processing plants in Salinas, near Dallas, Chicago, Atlanta and Carrollton, Ga.
- Trucks are cooled to 36 degrees and are swept and hosed down before loading.
- Temperatures inside the trailer are monitored. If temperatures aren’t kept above 32 degrees and below 40 degrees, produce is discarded. Salinas Valley to Atlanta is the longest drive, about 66 hours.
— PROCESSING —
- Iceberg lettuce is the largest-volume product. No hand, even gloved, touches the lettuce.
- Workers wear gloves, gowns, hairnets and hard hats.
- Gloved hands go through a hand-sanitizer rinse.
- Trays filled with ammonia-based solutions are spaced throughout the plant so workers disinfect soles of shoes.
- Packaged produce is washed and rinsed several times with chlorinated water, which the industry says removes 90% to 99% of microbes, including bacteria.
How iceberg lettuce is processed
- Cut automatically. Drops into agitating chute with chlorinated wash water. Goes up conveyor belt where water drains off.
- Drops into another agitating chute with chlorinated water. Sprayed with water from above.
- Moves to another conveyor belt where produce is sprayed from above and water drains off.
- Dried and bagged.
— SHIPPING TO CUSTOMERS —
- Produce is on supermarket shelves within 24 to 72 hours of harvest.
- Bagged salads, packed in boxes, go into trucks that have been swept and cooled to 36 degrees.
- Trailer temperature is monitored throughout the drive. If temperatures aren’t kept above 32 degrees and below 40 degrees, produce is discarded.
- Trucks are locked until unloaded at a customer’s distribution center.
Source: Fresh Express
We’ve been talking to food safety experts around the world. Just got off the phone with one in Dubai and, universally, they say Fresh Express’ standards are pretty comprehensive. We would recommend just adopting the standards as minimums for ready-to-eat product. If the drafters of these GAP standards are unwilling to do so, they should at least feel compelled to justify why these standards are excessive.
It’s best to answer the question now. The alternative is to wait and let the consumer media, Congress and regulatory bodies ask the same question later.