On The Alfalfa Sprout Advisory
April 28, 2009
Source of Article:†
The FDA has issued a consumer
advisory not to eat alfalfa sprouts. United Fresh also issued a statement
urging sprout growers to follow good food safety practices.
We turned to frequent Pundit correspondent Bob Sanderson to see if we can
find a solution to this long running food safety issue with sprouts.
We asked Pundit Investigator and Special
Projects Editor Mira Slott to see what we could learn:
Mira touched base with Bob Sanderson en
route from a meeting in College Park, Maryland, between sprout growers and
Q: How did the meeting go?
A: The meeting included Dr. Stephen Sundlof,
Director of Center for Food Safety and Nutrition (CFSAN), FDA, Dr. David
Acheson, Assistant Commissioner for Food Safety at CFSAN and Jack Guzewich,
[RS, MPH] Sanitarian/Epidemiologist at CFSAN. It was an extremely cordial
meeting. The fact is that the cat is out of the bag, and while some
retailers are continuing to order as usual, many retailers wonít accept
There is a question of what might signal
an ďall clear.Ē The details are that there were a few outbreaks in the
Midwest, but the critical turning point was when an outbreak that started
in Omaha was linked to a later outbreak of Salmonella Saintpaul in Michigan
with the same fingerprint. The epidemiology implicated sprouts, but no
pathogen has been found in any seed or sprouts. Jack Guzewich explained
that a disproportionate amount of sprouts were found in the epidemiology,
leading to the consumer advisory not to eat alfalfa sprouts. But this is
not a recall.
Q: Are you satisfied with the information
FDA provided to justify a consumer warning not to eat any alfalfa sprouts?
Is there a reason FDA is unable to give a more targeted advisory?
A: Recent events have shown that
epidemiology can be very tricky. While the "no smoking gun" (the
Salmonella Saintpaul has, to-date, not been isolated from any seed or
sprout samples) seems to put a big question there, it isn't necessarily
good evidence that it wasn't sprouts. Contamination in seed lots can be
very sporadic; a needle in a haystack. But on the other hand...? It is very
The other side of the question is, what's
FDA going to do when epidemiology, based on statistical analysis rather
than direct detection, indicates huge probabilities of a particular disease
This is further complicated by the fact
that statistical analysis involves mathematics that can be very
counter-intuitive. Like, if 20 people got sick, and 10 remember eating the
food in question, and 7 don't think they did, and 3 are sure they didn't,
and in a random survey, 1 person in 20 says they ate that kind of food....
The other issue is that these Saintpaul
positives were associated with different seed lot numbers. Thatís unusual.
It suggests blending or mixing of lots, and that makes it very difficult to
trace. The CFSAN folks didnít know where the problem begins and ends. There
is certain reasonableness to this, but realistically it probably could be
If FDA could trace to the source seed ó
and it has sort of implied it is getting close, but no names have been
mentioned ó then there could be an announcement, the mother load of seed
found. What follows is that if a company is not using that seed, it is
probably not in trouble. But FDA said, and repeated, that there wonít end
up being an announcement to consumers that it is OK to buy sprouts. FDA has
been squeamish about the safety of sprouts all along.
Q: I thought the sprouts industry had
some of the strictest food safety measures in place. Why are these
A: The guidance and recommendations are
just that; compliance is not monitored with any consistency. The FDA very
rarely inspects with its own people, while it does join with state boards.
There are two main recommendations; one is very high levels of chlorine,
and the other is high amounts of testing, hold product and donít ship until
results come back negative. We take samples of water running off sprouts,
and 48 hours later we get the report from the lab. If itís negative, we can
Q: Are all industry producers operating
under such stringent standards as your company ó Triple
testing procedures starting with the seed?
A: No one seems to know whoís doing
exactly what. Thatís part of the problem. There is no
compliance-monitoring. Guidance is a recommendation. That was repeated over
and over again today.
Q: What is the solution? Did you discuss
this with FDA?
A: Whatís needed is a way for industry to
police itself better because FDA clearly isnít going to, but if there are
more problems, it will issue very severe warnings.
Q: What impact do these warnings have on
A: FDA didnít blanket all sprouts, just
alfalfa sprouts specifically. Sprout growers are dealing with concerned
supermarket customers. How the public is responding we donít know yet.
People who like sprouts say, ĎWhat else is new?í and eat them anyway.
The industry is really in a panic and
thatís where my lack of sleep comes in. We need to make some kind of plan.
I think it will be pretty much on our own. In terms of public reassurance,
we have to generate it because itís not going to come from FDA. If the
retailers are scared off, they say they donít want to buy.
Q: Could you share more information about
the FDA investigation. Why are there so many lot numbers involved?
A: The tracing it to different seed lot
numbers has raised questions. If people think FDA is hasty, they probably
think CFSAN was not doing the epidemiology right, and itís probably not
Q: How are lot numbers determined? Could
the lots be adjacent on the same farm, for example? Do producers mix
different lots together, and if so, do they re-number them for
A: What determines what number gets put
on an amount of seed? It varies. You could have lot 69432 and mix 50 tons
with lot 78653, and the new lot mix is called 89245. Thatís the mess. To
the FDA, the outbreak indicates blending, which is common practice, not
necessarily devious, but probably not a good idea because it becomes next
to impossible to trace back. The bottom line is that blending of lots of
seeds used for sprouting is not advisable.
Q: Are there lots of seeds that are
specifically designated for sprouting?
A: Seeds donít become sprouting seeds
until someone determines this. I doubt if any alfalfa farmer says, ĎIím
going to plant for human consumption.í They grow to sell into the raw seed
market, and some of that becomes human food. And thatís a problem, because
itís treated like itís not for human food, and then changes later on.
Q: There must be significant differences
from a food safety perspective in the farming process for seeds grown for
A: Food for
animals doesnít need to be grown using Good Agricultural Practices (GAPs).
The main differences is that on an ag field you may have livestock to help fertilize
the field and help maintain it and save money, but the seeds can get
contamination in the field.
Technically speaking, that seed in the
bag coming to Jonathan Sprouts is not food for human consumption until it
just enters the door. Itís a line thatís drawn.
Q: Why not just require sprout growers to
use seed thatís grown with GAPs for human consumption?
A: If you did that, suddenly a big
proportion of sprout crop would disappear if it were only allowed to be
produced with GAPs. Maybe if there was a way to introduce the requirement
incrementally. Itís much more expensive to grow seed using GAPs.
In the seed business, yields can change
tremendously year-to-year, season-to-season. For a seed grower, this year
Iowa will be good and Arizona wonít be good, for example; thatís why
companies mix seeds in the raw seed business.
If a seed grower took a few acres and
said he was going to grow this using GAP, he would have to be much more
careful with intrusion of animals, water sources, how seed was handled and
bagged. It should be the way starting seed is grown for human food. These
issues are not just domestic.
Q: Has FDA determined that the seed
source is domestic?
A: There has been mumbling that it might
have come from another country. But I havenít had it confirmed, and there
are plenty of rumors going around. If someone goes to a field outside of
the country and finds the same strain of Salmonella, that would be pretty
big news, but so far we donít know anything.
Q: Do you believe that FDA is being
forthright with the industry regarding the information theyíve learned so
A: They clobbered us beforehand with the
press release advisory but were thoughtful to bring all the sprout growers
together for this meeting in College Park. We had a conference call,
actually a couple; on Friday they made the announcement that they were going
to issue a general advisory, not a recall, on all alfalfa sprouts.
Q: What actions did FDA want the sprouts
industry to take following the advisory, if not a recall? Doesnít an
advisory to consumers not to eat any alfalfa sprouts put retailers in a precarious
position about stocking the product anyway?
A: FDA leaves it up to us. One of our big
customers is taking all of our product off the shelves. FDA says itís not a
recall, itís just an advisory. This customer may not buy from us, maybe
theyíll charge us a lot of money for this recall. This isnít a recall, but
youíve got a potentially dangerous food on the shelves. FDA is bound by
legal, and they canít be mandating certain actions.
My own point of view: Iíve been in this
business 30 years, involved with the FDA the last 10, but itís really only
in the last three that I understand how they work. Solutions will have to
come from the industry. FDA may provide huge problems and the most they can
do is say the Salmonella Saintpaul strain has been isolated to seed lot
such and such. We need to talk to the customers and say this is the problem
and convince them itís OK to start buying our product again. FDA doesnít
say itís safe to start eating alfalfa sprouts.
Q: Will the industry start partnering
with seed companies to grow with GAPs?
A: It needs to happen ó people with
courage and vision to take a risk and limit purchases to companies that
only use seeds grown with GAPs. It also could be good public relations to
say, Ďmy seeds were grown using GAPs.í
Q: Youíve been progressive in food
safety. Are you looking to start the process?
A: Weíve never gotten close to seed
production before. Seeds come in bags or trucks and we take it from there.
We are looking more to partner with seed farmers. What would it cost you to
commit to GAPs? We must talk to the farmers about costs. They might get a
failed crop. In the scheme of things, I doubt the cost will be beyond what
the industry can handle. But it is a paradigm shift.
The industry is not even as big as it was
10 years ago because of all these food safety problems. I had a feeling
from talking with people that the industry had lots of potential, but
somehow weíre all stuck in first gear. We donít have outbreaks for a year
or two and everyone is holding their breadth. That is not the kind of
investment most people would be attracted to. We could put in controls.
If the seed is an unknown quantity, we
can do a lot of testing, and if the testing shows a problem, we have to
throw it all out and itís a big loss. Farmers would like the food safety
mechanisms to move upstream and for processors to have better controls.
This is what concerns me about
irradiation becoming widely accepted. Would there be a tendency to get lax
before the finished product processing? I see the same issue with the pistachio
recall, where FDA saw no need for going back to the orchards
because of the kill step in the processing plant. Food safety must be
applied across the entire supply chain.
Bob is a real insider with deep knowledge
of the business, and he has given us two very simple changes that could
make a world of difference. The FDAís approach has been premised on the
idea that the sprouter of the seeds will put them through a disinfectant
That is a good policy, but why not back
it up and insist on seed more likely to be safe and traceable?
Most alfalfa is raised for animal feed,
so they make no effort to avoid animals or animal excrement in the growing fields.
Later on, when a sprouting facility buys the seed it suddenly becomes food
for human consumption. Yet it was not grown under any procedures designed
to keep it clean and free of pathogens.
Any buyers out there who want to make a
productive contribution, here is an opportunity: Make a policy that next
year you will only buy alfalfa sprouts that are grown from seed certified
to have been raised on a third-party audited, GAP-compliant farm. This
should also be added to the FDAís Guidance Document.
Blending of seed lots makes traceability
almost impossible, so the practice should be halted. Part of the GAPS for
raising alfalfa seed to be used as human food should require its
segmentation into traceable lots ó no blending allowed.
Finally, buyers need to treat sprouts as
one of the high-risk produce items. That means insisting on third-party
We still find that issuing these broad
recommendations not to consume really makes no sense. The risk is still
very small, and the FDA would gain credibility by releasing information ó
what the FDA believes the risk to be ó rather than a recommendation.
Bob alludes to a sense of consumer
complacency that sprout eaters have developed over these FDA advisories.
Like the boy who cried wolf, consumers who kept eating spinach and then
tomatoes and then jalapeŮos and then pistachios and now sprouts and never
got sick start to turn a deaf ear to FDA advice. That could be deadly one
day, and the food industry needs a credible FDA to give an ďall clear.Ē The
way to maintain credibility is by allowing people to take reasonable risks
after they are informed with information.
Many thanks to Bob Sanderson for taking
time out of a most hectic day to keep the industry informed.