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Procedure vs. Substance

There is an awful lot of public discussion going on regarding the procedure by which food safety standards shall be set.

The Buyer-led Food Safety Initiative turned to the trade associations, the Western Growers Association turned to a State Marketing Agreement and Marketing Order, and United Fresh has called for Federal regulation.

All these initiatives and many others focus on the kinds of procedures that will build regulatory and consumer confidence. Fair enough… and we support efforts to develop proper procedures.

But in the end nobody will care about the procedure. What will rebuild regulatory and consumer confidence is long periods without outbreaks.

That means that the substance of the food safety standards adopted is crucial.

We were very supportive of United’s call for mandatory, federal standards. However, there was one point in the release that we would encourage the United Board members to carefully consider:

Our scientific and technical team has worked tirelessly in developing rigorous and measurable standards for Good Agricultural Practices for the production of lettuce and leafy greens.

Few have more respect than the Pundit for the tireless work of United’s scientific and technical executives. In fact we gave them an award.

Yet whether the draft GAP standards are “rigorous” or not is another question entirely.

Industry leadership has been going around for almost six months promising to do “everything possible” to make produce as safe as possible.

Ok, some of this is political cant; we do not intend to grow everything in greenhouses. So the definition of what is possible is elastic.

Yet surely we can all agree that whatever our top-volume producers were doing is feasible to extend to the whole industry.

By reputation Fresh Express has one of the best, if not THE best, food safety programs out there for ready-to-eat produce. It will be impossible to hold up as “rigorous” or as the industry doing “everything possible” a standard that is lower than what the biggest marketshare company is doing.

The last GAP document was signed off on by IFPA, United, PMA and WGA. IFPA has merged with United, so, presumably the next document will be signed off on by United, PMA and WGA. The Boards of Directors of these associations should direct staff not to sign off on any GAP document for ready-to-eat lettuce, spinach and other leafy greens that does not, at minimum, meet Fresh Express standards.

There has been a lot of approach to this issue as if nobody has done this before. and what we need is totally new approaches. But, in truth, the Fresh Express program detailed in an article in USA Today is pretty comprehensive. If we just copied the sidebar of the article and had a third-party audit that everybody was doing all this, we would have made enormous progress.

We’ve published it before in the context of an Open Letter to the Signatories of the Buyer-led Food Safety Initiative, but look at the details of what Fresh Express does:


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.


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.


  • 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.


  • Produce is trucked from the field to a cooling station.
  • Cooled to 34-38 degrees within four hours of being cut.


  • 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.


  • Iceberg lettuce is the largest-volume product. No hand, even gloved, touches the lettuce.

Safety measures

  • 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.


  • 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

These Fresh Express standards are consistently more rigorous than those in the draft GAP being proposed right now.

This is important to note: The previous GAP document, the one approved by United, WGA, PMA and IFPA, was issued in April 2006.

It didn’t stop the outbreaks of 2006 and this is not because we didn’t realize food safety was important. It was, exactly and specifically, because the document had been watered down in negotiations over its wording.

The same thing is happening again.

The members of the boards of the associations have to stand strong and say no. We are not here to negotiate on this issue. The Fresh Express standards must be the minimum on ready-to-eat produce and the only thing to discuss is how much more “rigorous” we can make them.

Remember, regulatory and consumer confidence can only be rebuilt with no more outbreaks.

If the FDA itself details food safety standards and we have more outbreaks, it won’t build consumer confidence in produce. It will just diminish confidence in the FDA.

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