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Pundit’s Mailbag — Consumer Has Shared Responsibility In Food Safety

Our piece, Consumers And Foodservice Operators Should Not Rewash Fresh-cut Produce, detailed that a panel of experts had studied the available research and came to this conclusion. At least one grower thinks the panel made a mistake by failing to emphasize consumer responsibility for safe produce:

Unfortunately, the report focuses too much on the aspects of cross contamination and not enough on the visual inspection and safe handling of fresh produce.

You should look at the brochure prepared by [the Western Institute for Food Safety and Security,] WIFSS at UC Davis. It gives great advice on handling and preparation of fruits and vegetables in the kitchen and if followed would minimize the chances of cross contamination.

Then they throw it all away as you have in your “endorsement” of packaged product even though there is no kill step for that product.

There is no substitute for the consumer doing their part by looking at the product and using proper methods of preparation.

If the product is decayed or looks/smells like it has been spoiled, you should not eat it, period. If the use date is out of date, throw it away regardless of how it looks.

Make sure that the cold chain is intact because if it is not, the chances of foodborne illness is greatly increased with time and cross contamination will not be your biggest risk.

— Bardin Bengard
Bengard Ranch
Salinas, CA

Bardin doubtless expresses the sentiments of many growers… that consumers need to be asked to do their part in ensuring food safety. The panel, though, was required to assess reality based on the literature available and came to the conclusion that in light of the safety of the product, the way consumers and restaurant workers typically wash produce poses more dangers — because of the risks of contamination — than eating it right out of the bag.

One possibility is more education. If consumers and restaurant workers were more diligent about hand washing, about not contaminating cleaning surfaces by touching their noses or coughing/sneezing into their hands before cutting or preparing food, perhaps the assessment would change. Yet it seems unlikely that the change will be very dramatic despite the whole Fight Bac campaign and the new Be Food Safe campaign. For one thing, facilities are inadequate, as the study reports:

The personal hygiene risk factors associated with produce that are most in need of attention at retail and foodservice operations include adequate, available and accessible hand washing facilities. These personal hygiene risk factors were found by the survey to be not in compliance with the 1997 FDA Model Food Code 33.3%, 26.2%, and 20.6% of the time, respectively.

Hands are a very common vehicle for the transfer of human pathogens to food products, and food handlers’ hands may become contaminated when they engage in activities such as handling raw meat products, using the restroom, coughing or handling soiled tableware.

Food safety procedures for cleaning and sanitizing food contact surfaces and utensils for handling produce were found to be not in compliance with the 1997 FDA Model Food Code in 44.4% of the observations in this study. Proper cleaning and sanitization of food contact surfaces is essential to preventing cross contamination. Results for selected types of facilities and selected assessment criteria are shown in Table 1:

Table 1. Percent of facilities out of compliance with
assessment criteria based on 1997 Food Code

Type of facility Contaminated equipment/
protection from contamination
utensils cleaned and sanitized
Poor personal hygiene2 proper hand-washing
Fast food restaurant 21.9 50.9 31.2 53.8
Full serve restaurant 37.3 56.6 41.7 72.7
Retail stores/
20.5 44.4 22.3 33.3

Bardin’s recommendation for a source of information on how to handle produce is a good one. You can download a copy right here.

The study also contains similar suggestions.

Yet, as sympathetic as we are to the notion that the industry is wise to urge all sectors to do their part, we have a sense that the industry is standing athwart history on this one.

If consumer participation in food safety could be expected or mandated, then E. coli 0157:H7 in hamburger would not be a beef industry issue. It would always be the consumers or the restaurant’s fault for improperly cooking meat if anyone got sick.

Yet in the years following the 1993 Jack-in-the-Box outbreak, there was a clear shift away from this perspective. In mid-1994 a man named Michael Taylor was appointed as Chief of the USDA’s Food Safety and Inspection Service. Shortly thereafter, on September 29, 1994, Taylor said that the USDA would from that date forward regard E. coli O157:H7 in raw ground beef as an “adulterant,” because the epidemiological evidence showed that in the hands of consumers it was ”ordinarily injurious to health” — thus it was an adulterant that should never, ever be present in the product.

In mid-October, 1994, Taylor announced plans to launch a nationwide sampling of ground beef to assess how much E. coli O157:H7 was in the marketplace. Five thousand samples would be taken during the year from supermarkets and meat processing plants “to set an example and stimulate companies to put in preventive measures.”

A positive result would prompt product recalls of the entire affected lot, effectively removing it from any possibility of sale — even though no one had gotten sick and consumers and restaurants could make the hamburger 100% safe just by thoroughly cooking it.

So even where there is a kill step, the rule has become that it is unacceptable to sell product that is dangerous.

Certainly this doesn’t mean we shouldn’t urge consumers and restaurants to do all kinds of things to keep food safe. Certainly we can continue to preach from the hymnal of shared responsibility.

Yet, at least on our fresh-cut product, we really have to ignore all that when it comes to our production specs.

And if down the road bulk produce starts causing people to get sick, don’t expect a “blame the consumer” strategy to carry much weight with regulators or the consuming public.

Many thanks to Bardin for helping us to address this important issue for the trade.

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