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Pundit’s Letter To The Signatories
Of The Buyer-led Food Safety Initiative

Pundit Note: With the chance to review the Good Agricultural Practices for Spinach and Leafy greens draft document, it became obvious that there is work to be done. As a result, the Pundit has decided to issue an Open Letter to the signatories of the Buyer-led Food Safety Initiative. You can find the letter below.

To the Signatories of the Buyer-led Food Safety Initiative:

Ron Anderson, Safeway, Inc.
Gary Bergstrom, Publix
Craig Carlson, Pathmark Stores
Jim Corby, Food Lion
Greg Corrigan, Raley’s
David Corsi, Wegman’s Food Markets
Brian Gannon, Big Y Supermarkets
Gary Gionnette, Supervalu Inc.
Reggie Griffin, Kroger Company
Mike Hansen, Sysco Corporation
Don Harris, Wild Oats Markets
Gene Harris, Denny’s Corporation
Mark Hilton, Harris-Teeter
Craig Ignatz, Giant Eagle
Jim Lemke, C.H. Robinson Worldwide
Mike O’Brien, Schnuck Markets
Frank Padilla, Costco Wholesale
Greg Reinauer, Amerifresh, Inc.
Roger Schroeder, Stater Bros.
James Spilka, Meijer, Inc.
Mark Vanderlinden, Price Chopper
Tim York, Markon Cooperative


For over three months, your work has been at the forefront of industry efforts to enhance produce safety and reduce the likelihood of consumers contracting foodborne illness.

The importance of your effort should not be understated. We have fielded countless calls from individual companies, state wide associations and from commodity-specific groups. Virtually without exception, it has been your initiative that they felt a need to address. They were far more concerned about what standards you, as their customers, would insist upon their meeting than they were with any document that the trade associations would produce or, even, some future prospect of government regulation.

Now, however, is the time to fish or cut bait. If published in anything approaching its present form, the draft document of the new Good Agricultural Practices for spinach and leafy greens — although an important advance for the industry in many ways — is likely to be severely attacked and thus unlikely to achieve your self-proclaimed goals of acting “…to protect public health and work toward restoring consumer and buyer confidence in fresh produce.”

We all acknowledge that we have imperfect knowledge of various pathogens and so, many choices have to be made with less scientific backing than we might prefer. In the absence of compelling scientific data, it is reasonable to look to past experience and those existing operations that have been spared from implication in the recent E. coli 0157:H7 outbreaks as a basis for industry standards.

It is notable that those implicated in recent outbreaks are not fly-by-night operators; they are respected organizations believed to have among the best food safety programs out there.

The fact that these programs failed lays out the enormity of the task for our industry. We cannot be satisfied with a program that brings the bottom half of the industry up to the current mean level of food safety program, as all those implicated were well above that mean, certainly in the top 20% in our industry.

So, if we really want to stop outbreaks, we must confront a staggeringly ambitious goal: To bring the bottom 99% of operators up to the current standard of the top 1% of the industry.

The draft of the GAPs for spinach and leafy greens are conceptual advances. The collaborators brilliantly developed a series of “Decision Trees” or detailed maps to guide growers, step by step, in determining the proper course of action. The collaborators also created certain minimum standards. These are, as you mentioned in your second letter, “…specific, measurable, and verifiable…”Surely the whole industry joins you in congratulating the associations and the drafters of these documents for these achievements.

Form, however, goes only so far. The substance of the GAPs matter, and the Buyer-led Food Safety Initiative has a unique opportunity at this juncture to assert its influence, before these drafts are made final, by declaring that these GAPs will not be accepted and will be superseded by buyer demands for a more rigorous program unless three criteria are met:

  1. Since the goal is to bring the bottom 99% of the industry up to the top 1%, no GAP document is acceptable unless it incorporates the same minimum standards as those top operators. For example, in the USA Today article ‘Fresh Express leads the pack’ in produce safety, a sidebar was included that detailed a few of these minimums. Some are applicable for GAP documents and others apply to the soon-to-be-unveiled Good Manufacturing Practices documents.

This sidebar details specific elements of one of the world-class food safety programs:


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

Over and over again, we find that the draft GAP documents do not hold the industry to the same standards.

To take one example: Fresh Express requires at least one mile between a growing field and an animal feed lot. The draft GAPs suggest 500 feet and, even worse, say that “This distance may be either increased or decreased depending on risk and mitigation factors.”

This variable transforms the GAP into a difficult-to-enforce advisory. The Buyer-led Food Safety Initiative is in a position to say… First, that the standard should be at least the one-mile standard. Second this is a minimum, it can be increased due to findings in a HACCP analysis — but never decreased.

This position, that the Fresh Express standards must be adopted industry-wide as the new minimum, is the key opportunity for the Buyer-led Food Safety Initiative.

  1. The rules are important, but creating mechanisms by which the rules are likely to be followed day in and day out is just as crucial. In the USA Today article, Jim Lugg from Fresh Express is quoted as follows:

    Before Fresh Express contracts to buy crops from growers, growers must complete a five-page questionnaire that details everything from the water used to irrigate crops to how growers keep birds off fields to whether worker toilets are cleaned by growers or service companies.

    “We prefer an outside company because we know the (toilets) are getting done, and the records are on the door,” says Lugg.

    Familiar as you all are with retail and foodservice operations, you know that the right policy is often not as important as the implementation plan. If in a retail produce department you want to make absolutely sure that everyone has a clean apron when they go out on the floor, you don’t hand them a “Decision Tree” to consult. You make the rule that every time an associate goes on the floor he has to put on a fresh, clean apron.

    Specific requirements that outside services be used or that internal resources be set up as a dedicated function with dedicated personnel are crucial to successful implementation. You can’t have a busy farmer with a thousand other things to do “promising” he will take care of cleaning latrines.

  2. We have learned from recent experience that these situations can be exacerbated by an inability to promptly trace back to source any problem. The draft GAPs have lots of references to the need to retain documents. This is essential but not sufficient. The documents must be retained electronically with backups kept automatically in case of fire, etc. In addition they must accessible 24/7/365. There can be no “looking for documents.” If the CDC or FDA were in any of your stores with suspect product, they should able to click a few buttons on a laptop or computer at the store and have access to full traceback information on that product. There are private companies such as that offer systems similar to this.

In any case gentlemen, this is your moment. Remember the industry had GAP documents on spinach and leafy greens before the recent outbreaks. They proved inadequate. What happened was they got watered down in the negotiation process. These draft GAPs, although stronger than the last document, show distinct evidence of also having been watered down.

They are draft documents, though, so now is the time for them to be changed. And you, gentlemen, are the people with the influence to see them changed. Remember it was well respected processors who were implicated in the recent outbreaks, so simply improving poor operations won’t solve our problem. We need to bring everyone up to the world-class level.

Let the associations know that you want the draft GAPs to 1) Impose minimum standards equal to that currently done by the top 1% operators such as Fresh Express, 2) Insist upon procedural requirements that determine people will use outside contractors in key instances such as latrine cleaning, unless they can substantiate a dedicated capability to do such work in-house, and 3) That all records required by the GAPs will be stored electronically and available via remote access 24/7/365.

None of this will be easy. The Fresh Express standards could take significant amounts of land out of ready-to-eat production for years in the event of a flood. In the absence of new information, though, the best option we have is to insist that all producers work to the standards we know are world class. Insisting on this is the best way to protect your customers, the consuming public. As it happens, you may be saving the industry as well.

Things are rushing toward completion with sub-optimal requirements. This is your moment to stand athwart history and yell “Stop” and make everyone re-look at these issues. An insistence on world-class standards now will save this industry much time, money and heartbreak later. It may save the life of one of your customers.

It will also mean that the Buyer-led Food Safety Initiative will be known as one of the most consequential industry initiatives of all time.

Good luck and God speed.

Your friendly Pundit

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