With so much effort expended on California lettuce and leafy greens, an obvious question has been what can various segments of the industry do to get ahead of the game.
We’ve run a project here at the Pundit to look at what different commodity groups and geographical sectors are doing to enhance food safety. The series started in the east when we ran Pundit Pulse — New Jersey Dept Of Ag’s Al Murray to see how a state department of agriculture could work to enhance food safety across all commodities. We then ran California Strawberry Industry Moves To Make Food Safe as the California Strawberry Commission prepared to hold a Food Safety Summit.
We then turned to tomatoes, first in the east with Pundit’s Pulse Of The Industry: Florida Tomato Committee’s Reggie Brown and then to the west with Moving Food Safety On To Other Commodities: California Tomato Farmers Raise The Bar.
Now we turn to almonds, a particularly intriguing exploration because the Almond Board of California is using a marketing order to impose mandatory regulation. We wanted to see what was behind it and how it would work, so we asked Pundit Investigator and Special Projects Editor Mira Slott to see if she could find out more:
President and CEO
Almond Board of California
Q: Mandatory pasteurization of California almonds will be required starting September 1. How did this ruling come about and what instigated its development? Hasn’t the Almond Board been aggressively pursing food safety for years?
A: To understand the current ruling on pasteurization, it is important to examine the context of how this industry has evolved collectively to determine its own destiny and fate in regard to many things; food safety being one of the most important. Certainly within the last 15 to 20 years, the Almond Board has positioned food safety as a critical component of the marketing order. The industry pulled together to collectively make change for the better and the marketing order provided the legal framework to move forward in a proactive mandatory way, rather than leave it to voluntary compliance.
It has been an evolution learning to take responsibility for problems and get them solved, doing research, global marketing communication, environmental issues, food quality and food safety. With that background, in our case when the salmonella issue hit our industry in 2001, we accelerated work on several fronts. We needed to figure out how a product like ours could get contaminated with a foodborne pathogen like this, which was not clear at the time since prior to that the product wasn’t associated with salmonella, and how the industry could improve safety policies. In 2004, another salmonella incident hastened industry efforts to find solutions, speeding up research on technological alternatives out there to combat dangerous bacteria and salmonella.
In the summer of 2004, the Almond Board instigated an action plan, basically a comprehensive food safety program, not just about pasteurization. It involved revamping Good Agricultural Practices, making food safety information more accessible and customizing it to almond product-specific problems. A key goal was to figure out how to pasteurize product, what technology had to be developed and efforts to guarantee safety to ourselves, our customers and to consumers while assuring that the process wouldn’t debase the natural attributes of products. We wanted to be a provider of safer product but not at the expense of altering the great taste and crunch.
Q: From all you’ve described, it sounds like the almond industry has been building a good foundation to pre-empt potential issues that could surface if and when another food safety incident related to almonds surfaces.
A: In a nut shell, getting out in front of things as fast and professional as you can is a true benefit. Even though arduous and difficult choices have to be made, the industry ends up in a better position to know what to do and how to act collectively when a food safety problem occurs down the line, and avert it spiraling out of control.
Q: Is that what happened in the case of the spinach E. coli crisis?
A: Even before the first salmonella incident, we were working on improving food safety.
The timing of where we were by the time the second salmonella incident hit put us in a far better position to deal with the consequences. We were much further ahead in designing a solution for our industry compared to what happened in the leafy greens industry when the spinach outbreak happened.
Having said that, human nature is such that sometimes it takes a shocking incident to get the industry going. Within the growing community, farmers tend to be conservative and cost conscious. Many have been farming three, four and five generations, and having all these experts telling them they are doing something wrong doesn’t sit right with them. It takes a jolt to get people to notice and take necessary actions that could significantly change the way they do business.
Q: In the case of the spinach outbreak, some executives believe it escalated to crisis mode, in part due to the fragmented nature of the industry, and discombobulated communication with government regulators, customers, consumers and media.
A: The almond industry has been working with regulators on pesticide reduction for maybe 15 years, cutting costs and diminishing the implications of certain pesticides on almond crops. We have a culture of taking these things on, sitting down with interested parties and working with regulators to make them part of the solution. We’ve collaborated in all kinds of different crop testing here in the states in a collective effort to reduce pesticide application. We’ve twice received the U.S. EPA award recognizing our industry for excellence in pesticide abatement and reduction.
Q: When did the pasteurization regulatory process get underway?
A: To detail the process, you’d need to go back to the last three years, when the food safety action plan was developed and adopted by the board. Then the real work began to develop pasteurization technology for our industry. Of course we had nothing. We collaborated with pasteurization and sterilization businesses, and universities that work with pasteurization technology, spending several million dollars. In addition, protecting the integrity of the product involved a huge investment in sensory technologies. We had to make sure we were not shooting ourselves in the foot by improving food safety but altering product quality.
Q: Did you discover a satisfactory solution?
A: Fortunately, we have come up with steam pasteurization systems that kill any pathogens without impacting sensory quality issues. It took thousands and thousands of hours analyzing different research and development projects we funded. It also involved keeping the industry and the regulatory community informed. The regulatory community has been extremely supportive and cooperative. Exemplified by our experience with the EPA, if regulators see you working on a solution and keeping them involved and part of the peer review in the proper way, it works smoothly.
This wasn’t the case with what the spinach industry went through. Half of Washington was banging on the table. The produce industry was playing catch up and reacting defensively. Initiating change and bringing governmental agencies into the fold is a much better way to arrive at a food safety program instead of doing emergency actions.
You need to act as an industry now to implement solutions instead of having them imposed on you. You can be the designer of a more effective program that also meets the needs of the industry. Taking an aggressive stance provides a lot more latitude to do the right thing and do well for the industry.
For the almond industry, it has taken a lot of work making a program acceptable to pass muster with the USDA; to satisfy USDA mandates and make it fair and doable across the industry, providing alternative measures for organic users, etc.
Q: Does the almond industry utilize USDA food safety auditing services?
A: We do have USDA inspections of incoming product, analyzing all quality aspects. This is a mandatory requirement for incoming product from growers to the processors. That is the only mandatory inspection auditing procedure we have in place. Some companies employ USDA auditing services for outgoing product to get USDA certificates.
The Almond Board will make sure the pasteurization processing is being properly administered and companies are meeting minimum requirements. USDA will conduct inspections and do spot checks of those plants that must adhere to the pasteurization requirement.
Q: You’ve only mentioned the isolated 2001 and 2004 incidents of salmonella. In the relative scheme of food safety problems, will pasteurizing almonds really make that big of a difference?
A: It’s important to emphasize that the food safety program our industry has adopted is not just about pasteurization. We are working toward addressing all points of the supply chain as food processors. If you have contaminated product it is not the ideal strategy to solely rely on the last part of the supply chain to catch it. We want all parts of the chain involved.
Before 2001 the industry didn’t have a salmonella issue. The problem is so rare, so low, in most cases it is impossible to find. The pathogen was not prevalent in almonds to begin with. Our ability to detect food pathogen problems has improved dramatically in the last 10 years. And discovery of these problems is repeatedly reported around the world. This combination has created a heightened awareness of food safety issues.
Q: A problem inherent in most fresh produce is lack of a kill step to eradicate E. coli and other lingering bacteria. Does pasteurization of almonds eliminate any risk of dangerous pathogens on the product?
A: The pasteurization is effectively a kill step. Our technology will remove any presence of foodborne pathogens from the product. Then it is up to the rest of the supply chain to handle product in a safe fashion. This includes the consumer, as a lot of pathogens are found in the home.
This is a much more difficult problem for leafy greens than for our product. At the same time, it is important to remember that we didn’t have a pasteurization process for our industry until we spent a lot of money and research to find one. Hopefully the methodology to come up with solutions can be translated. It takes conviction by the industry to address the problem head on. It is human nature to think this is an isolated incident. It takes leadership to coordinate an industry in this fashion.
Q: As president of the Almond Board, you must have played a key role in the evolutionary process.
A: Obviously in the aftermath of salmonella incidents in the almond industry, communicating to industry members, customers and consumers was essential. There was real leadership from our industry. A dedicated food safety quality committee on our board was the true genesis, where new technologies and ideas were vetted, where the action took place. I arrived in September 2002, confronting the second incident that hit in 2004, and have obviously been working in this direction to improve food safety throughout my tenure.
Q: From a cost standpoint, is this new pasteurization mandate a big burden for the industry?
A: The increase in cost comes with the benefit of making product more food safe. At the end of the day, the decision is made regardless of cost. It is something we must do. Cost will be integrated into the manufacturing procedures and will become folded into product pricing.
Q: Is it important to have mandatory programs in place?
A: For an industry to rely on 100-percent compliance is important. Our industry for the most part doesn’t have its own consumer brands. Most product is used as in ingredient in other products, although the snack industry is growing quite a bit. It only takes one company to have a compliance issue and it affects the whole industry. The pasteurization rule will be implemented starting September 1, but it is vetted by the industry, all industry created and mandated. This is all about the industry deciding what’s best for industry.
We had the benefit of having an organization like ours to protect the industry and make sure what was communicated to our customers and consumers had the right factual content and that we contacted the right media to deliver the message. I find it sort of surprising the spinach industry didn’t get on top of it quickly. Consumers want to know facts, and what are you doing about it.
We have a team that on a moment’s notice can act if something needs to be taken care of urgently and work with communications to make sure the media is involved. Crisis management is so important. You must be organized ahead of time to get the right facts and information out to the right people.
Many thanks to Richard for filling us in on this important story, filled with lessons for the broader produce trade. Here are 10 key ones:
- You have to start with science, and knowing how contamination occurs. This reinforces the enormous importance of the new Center For Produce Safety at U.C. Davis which we reported on right here.
- The goal has to be to find a kill step, because otherwise the industry is still vulnerable.
- Every commodity and region should get in front of the issue so it can drive the process. Better to drive than to be driven.
- The time to act is now — while the jolt from the spinach crisis is still being felt and the whole issue of food safety is a crisis in people’s minds.
- Get the regulators involved and let them see you are working on the problems professionally, realistically and expeditiously.
- The spinach industry was not prepared, it was reactive and defensive. Don’t get caught playing catch-up.
- Even with a kill step, every part of the chain needs to be optimized. It is not an effective food safety policy to expect the last process to catch the problem and fix all the errors at that stage.
- Our ability to detect pathogens has advanced so much that many who never thought of their product as dangerous will soon find they are having a food safety crisis.
- Kill steps only work up to the point in the process at which they are applied. Vigilance is still required after that point, especially by consumers who can contaminate food at home.
- In an industry with few consumer brands, 100% compliance is essential. An outbreak will hurt the whole industry.
Ten commandments for food safety, by an industry segment at the top of its game. It is all very impressive. It is worth noting, though, that a state marketing order cannot require that producers in other states or other countries follow the same food safety procedures. Almond producers may be able to live with that. Producers of most commodities won’t. Once again thanks to Richard Waycott and Almond Board of California for their willingness to share knowledge with the whole industry.