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Pundit’s Mailbag — Clarification
Of Sprout Outbreaks

We’ve been writing a great deal about sprouts. As an area of the industry plagued by food safety outbreaks, we thought it important to understand and seek solutions to the problems seemingly endemic to these products. In addition, as the sprout industry has been wrestling with food safety issues longer than most of the fresh produce trade, there may well be lessons the broader industry can learn through careful study of how the sprout industry has wrestled with these difficulties.

One lesson is the importance of industry unity. The sprouting industry seems forever divided in twain… sometimes it is the large producers vs. the small guys, sometimes it is those active in the International Sprout Growers Association and those that are affiliated with Brassica Protection Products. In either case, it is difficult for an industry to wrestle with its problems when the industry is in such discord.

Most recently we ran a piece titled, Pundit’s Mailbag — Marketer of BroccoSprouts Calls For Strict Adherence To FDA Guidelines, which featured a letter from Earl Hauserman, VP Busness Development, Brassica Protection Products. That piece has caused some controversy in the industry and brought two letters, including one from Earl Hauserman himself:

I would like to make a correction to the letter I sent to you that you published in the Perishable Pundit on June 23, 2009, in a piece entitled Pundit’s Mailbag — Marketer of BroccoSprouts Calls For Strict Adherence To FDA Guidelines. In that letter I stated that:

“With regard to seed, it is completely untrue that all the outbreaks have come from Caudill Seed Company and that none have come from Bob Rust’s ISS. By my reckoning, of the 11 recalls/market withdrawals of alfalfa sprouts in 2008 and so far in 2009, seed from Caudill was implicated in only 5, seed from others, primarily ISS, was implicated in 5, and 1 was facility-related.”

I am unaware of any outbreaks that ISS seed has been implicated in. I regret this error due to my incomplete research.

— Earl Hauserman
VP Business Development
Brassica Protection Products LLC
Baltimore, Maryland

We also received a letter from Bob Rust of International Specialty Supply (ISS) dealing with the same article:

The June 23, 2009, letter by Earl Hauserman of Brassica Protection Products is interesting though terribly inaccurate. For example, it says:

“With regard to seed, it is completely untrue that all the outbreaks have come from Caudill Seed Company and that none have come from Bob Rust’s ISS.”

I suspect he is responding to a May 20th Pundit letter in which a correspondent wrote:

“Interestingly enough, it seems that out of all seed suppliers, one major supplier was responsible for most outbreaks that occurred in last 10 years.”

I contacted Mr. Hauserman and have given him ample time to retract his letter or correct his inaccuracies. He acknowledged this error in an email where he says: “I am unaware of any outbreaks or recalls that ISS seed has been implicated in. I regret this error due to my incomplete research.”

He is correct, yet he has not done so publically. Therefore, I will respond with hyperlinked references.

Mr. Hauserman also wrote: “We have had problems, but far, far fewer than the industry as a whole.”

Mr. Hauserman should have known this considering that Brassica sprout growers has been involved in all US sprout related outbreaks during the 2008-2009 period Mr. Hauserman referred to in his letter. Actually, Brassica sprout growers has been involved in all sprout-related outbreaks in the last five years. And all the seed used to produce those sprouts was, according to the sprout growers involved, supplied by Caudill Seed Company.

The outbreaks I am referring to are:

Salmonella saintpaul

Salmonella typhimurium

Salmonella bovismorbificans

According to the FDA, there is also a PFGE pattern link of 20 hospitalized victims’ to a sprout-related Listeria monocytogenes recall. Although the sprouts were grown by a Brassica Sprout grower, I am not aware of seed being the suspect in any Listeria recall or outbreak to date, including this one.

Other sprout growers using Caudill seed may have played a minor role in one or more of these outbreaks. I am unaware of any other outbreaks during this time period attributed to sprouts. If there were some reported illnesses from sprouts not either associated with Brassica growers or sprouts produced from seed supplied by Caudill Seed Company, I would appreciate hearing about it.

ISS seed was implicated in a single sprout-related outbreak ten years ago, and that is why we developed the ISS Seed Screening Program. ISS seed has not been implicated in any outbreaks since.

Our seed has produced sprouts involved in a sprout recall relating to confirmed positives of Salmonella or E.coli 0157:H7. The grower was certain that our seed was not the cause. The government did not implicate our seed nor did they contact us regarding this recall. However, this was Salmonella, and we assume that if it is Salmonella or E.coli 0157:H7, there is a good chance that it did come from the seed. We brought the seed back from sprout growers and tested it again. We could not find contamination. Regardless, we took the seed off the sprouting seed market and there were no reported illnesses.

Although ISS has received accolades the world over for developing a seed safety program that has removed several contaminated lots of seed from the market, it is not likely ISS Screened Seed will always have a perfect record regarding outbreaks. We sample, sprout, and test 25 grams from each and every bag we screen. Besides testing the spent irrigation water for Salmonella and E.coli O157:H7, we also send a separate lab some of the sprouts to be homogenized and tested for Salmonella, E.coli O157:H7, Shigella, Listeria monocytogenes, and generic E.coli.

If generic E.coli is found, we test for Enterotoxigenic E. coli (ETEC). Still, there may be times when the seed is so lightly contaminated that seed sampling does not capture a pathogen in the seed. When this happens, we hope the microbiological testing by the sprout growers will discover it and our prompt communication with other sprout growers having the lot will minimize the risk.

We would never be ashamed of recalling seed anytime there is an elevated risk that it may be contaminated. A recall should not be an implication of guilt. Nor should a company consider the legal or financial ramifications of a recall. A recall is a responsible act to reduce the risk of foodborne illness.

When discussing outbreaks, one should focus on the number and severity of illnesses, not numbers of outbreaks. One outbreak involving 200 people is worse than 50 outbreaks of the same severity involving one or two people each.

Since March 2001, there appear to have been 14 reported sprout-related outbreaks in the US and Canada, involving over 1,100 reported illnesses. The average outbreak involved about 79 people. Again, none of those outbreaks or illnesses came from ISS seed.

These reportedly involve multiple outbreaks with the same PFGE pattern and multiple outbreaks of the same Phage type. They also include an outbreak in which a sprout grower told the seed supplier that his spent irrigation water had a confirmed positive, and the seed supplier never informed sprout growers using the seed of the confirmed positive. But I will save all this for later Pundits should this dialog continue.

As a member of the newly formed committee of the ISGA and FDA to improve the Sprout Guidance, I have suggested that sprout growers should have their seed suppliers sign a “communication agreement,” which obligates the seed supplier to inform them within 24 hours if there is ever a presumptive or confirmed positive on the seed lot they are using.

All of the information above is accurate to the best of my knowledge and presented to defend my company and enhance the safety of sprouted seeds. If anyone is aware of any additional information or information that is either incorrect or misleading, please let me know so I can make appropriate corrections.

— Bob Rust
International Specialty Supply (ISS)
Cookeville, Tennessee

It is clear that Mr.Hauserman made a mistake in his research of the matter and he has now publicly acknowledged that error.

At the same time, the significance of all this is not 100% clear. Caudill is the largest seed producer and the Brassica-affiliated producers are the largest producers of sprouts, so it is not surprising that most of the outbreaks should touch upon both organizations.

More broadly, with all the testing going on at the sprouting companies, it is unclear to what extent the recorded outbreaks reflects the contamination level of the seed.

Besides, the incidence of contamination discovered in sprouts released to consumers is so tiny that we really can’t derive any statistically valid information as to the safety of one firm’s seed vs. another’s from the outbreak statistics.

The odds of getting double zero on a roulette wheel in a Monte Carlo casino are one in 37 but that doesn’t mean it won’t show up three times in a row. And the fact that it shows up three times in a row doesn’t change the odds. And at roulette, we actually catch every double zero that shows up.

So it is that the fact that one seed company has three outbreaks in a row doesn’t tell us much, especially in light of the fact that we have very incomplete knowledge of the degree to which known outbreaks correspond to seed contamination.

In light of our limited knowledge, we think the wisest course is to follow sound practices likely to reduce the incidence of pathological contamination.

We mentioned here that Primus has been kind enough to donate its services in an experiment to grow alfalfa to be used in sprouting under conditions fit for human consumption. We asked for volunteers from retailers and those able to farm some alfalfa. We’ve secured a wonderful retail partner willing to advance the cause of food safety — and we will be unveiling its name soon.

We are still seeking a farmer to grow some alfalfa for this project. This can be either a traditional alfalfa grower looking to learn the most advanced standards in growing food for human consumption or a produce grower who is willing to set aside a few acres for alfalfa to participate in this pilot project.

There are many issues in sprout growing, but a precept of food safety is that prevention is better than remediation, and one of the known problems with alfalfa sprout production is that the seed is raised for animal use — and then diverted to human consumption. We believe that growing the seed with the same standards we would use for ready-to-eat products such as leafy greens would reduce the likelihood of contamination.

If you are a farmer willing to participate in this project and grow some alfalfa under such conditions, please let us know here. This would be a significant contribution to a safer food supply.

We thank both Earl Hauserman of Brassica Protection Products and Bob Rust of International Specialty Supply for trying to clarify these issues.

We encourage the whole sprouting supply chain to lay down the hatchet and try to work together to build a safer food supply.

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