Making the contents of
our salads safe is very difficult work. That much is clear about the
“Guidance for Industry: Guide to Minimize Microbial Food Safety Hazards of
Leafy Greens,” an update to the current federal rules on how to keep those
delicate green leaves of lettuce from hosting disease and kidney failure.
The document to which I
am referring was released by the U.S. Food and Drug Administration in late
July, and, like most policy papers, is not entertaining, but it is
important because it’s part of the federal government’s efforts to improve
food safety and solve one of the most vexing issues in fresh produce: leafy
greens and the bacteria that love them.
It’s also a prelude to
actual food safety laws pending in Congress that will mandate rules and
mete out penalties to companies that don’t adhere to the often vague and
I took an interest in
reading this paper because growing wholesome heads of iceberg lettuce and
safe bagged salads of romaine is a concept never far from the minds of the
Salinas growers whose livelihoods depend on the reputation of these plants.
For me, the heart of the
matter, really, isn’t why FDA wants to update its guidance for leafy greens
safety but how they will do it. There’s so much research being done in
California, home to nearly all the nation’s leafy greens, that the old,
passive model of drafting policy is just that — old and passive.
The U.S. Department of
Agriculture, along with a team of other agencies, is in the midst of a
long-term study to determine how much E. coli O157:H7 really exists in
wildlife of the Salinas Valley and its environs.
Researchers at the Center
for Produce Safety at the University of California-Davis, and others
nationwide, are all trying to answer the most basic questions about how
this bacteria finds its way into lettuce long enough to make people really
I realize that ambiguity,
lack of information and conflicting data are antithetical to creating good
policy and that these problems still plague FDA’s newest rules for leafy
green food safety.
through the document made clear that it does not really acknowledge all the
research really smart people are doing. It also made me think, why not
create a wiki?
We’re in the midst of the
public comments period for the draft, but I think public input from the
growers, scientists, trade groups and the public should come as part of
crafting the document, not simply as criticism or commentary on what
already exists and bears the hallmarks of the government’s priorities.
A wiki would be a way to
give the public the best information out there on leafy greens, especially
in the controversial areas of plant and wildlife management, where FDA is
still recommending practices that have led growers to remove beneficial
riparian plants and kill local fauna.
An interactive, online
document that captures what’s known about (and what’s not) how to safely
grow the most common of vegetables would be a way to create policy that
better reflects the realities of growing, harvesting and processing, and
cut out the wasteful rules that damage water quality and prevent growers
from being good stewards.
It would be a first step
in eliminating the opacity of policy making and maybe even lead to laws
that protect consumers without sacrificing growers’ environmental practices
or their livelihoods.