 Hank Giclas Western Growers Association |
 Michelle Smith Ph.D. CFSAN |
Are Your GAP Programs Really Working?
Fresh Cut
November 2004
Are the occasional food safety problems receiving media
attention due to failure to employ Good Agricultural Practices (GAP) programs
or to GAP programs that are in place but are not working efficiently?
The challenges out there may be due to one or the other or both, according
to Hank Giclas of Western Growers Association (WGA), speaking during the
International Fresh-cut Produce Association's ExecTrends 2004 conference
held Sept. 27-28 in Alexandria, Va. Depending upon the particular circumstance,
there are "big differences" in recommendations for what can
be done to bring about improvement.
Vice president of Strategic Planning Science and Technology for WGA, Giclas
was one of two speakers participating in the food safety session, "Assuring
Produce Safety from Field to Fork."
In Place and Functioning
First, make sure that all GAP programs are universally in place and then
check to see that they are indeed functioning, Giclas advised.
Trade associations such as IFPA, United, PMA, WGA and others have been
working on an array of initiatives and projects to improve food safety,
the speaker said. Efforts include attempts to identify weak points in
current systems, including conducting GAP surveys, GAP reviews and research
and data gathering.
Correcting problems that remain hidden until after the fact can be a challenge,
the speaker said. In communication with FDA, DHS and others, WGA has repeatedly
emphasized the need for definitive information on outbreaks that will
allow for a 'fix.' However, identifying the source of contamination or
breakdown in the system often happens well after the event is over or
the season has ended.
Giclas said he is concerned with the marketing ploys used by many in the
industry to convince the public that their particular products are safer
because they use such and such a service. Often, this is not the case
and contributes to demands from larger customers to utilize the services
of a particular food safety monitoring company or risk losing market share.
One customer may demand one company and a second customer a competing
firm. The end result can be frustrating to producers, especially those
with numerous customers and less than helpful in assuring uniform food
safety standards.
A second speaker in the session was Michelle A. Smith, Ph.D., an interdisciplinary
scientist with the U.S. Food and Drug Administration, Center for Food
Safety and Applied Nutrition.
Smith recently spearheaded the development of a proposed action plan for
fresh produce safety from farm to table that continues and builds on previous
efforts. Her presentation focused on the "Guide to Minimize Microbial
Food Safety Hazards for Fresh Fruits and Vegetables," first published
in October 1998, and available on the Web at: www.foodsafety.gov/~dms/fs-toc.html#prod.
Treat as High Risk
Citing food safety concerns for fresh produce, Smith reminded that fruits
and vegetables are grown in a non-sterile environment. There are opportunities
for contamination, and they are likely to be consumed raw. These are factors
consistent with FDA's definition of "high risk foods," she said.
How producers and others in the supply chain address opportunities for
contamination will ultimately determine how risky an item is. The guide
provides information that can help the industry reduce, although not eliminate,
associated risks.
Initially, some argued they have been growing food this way for 200 years
and don't intend to change. However, attitudes are changing, Smith pointed
out. The guide has, and is, helping boost awareness of common microbial
hazards for fresh produce, and its recommended practices, when adapted
to specific operations, are helping minimize hazards. The publication
provides helpful information dealing with water, manure and municipal
biosolids, worker health and hygiene, sanitary facilities, field/packing
facility sanitation, transportation and traceback.
What can the industry do to further reduce microbial risks?
"Learn about risks, educate on GAPs, develop a food safety plan and
document your activities," Smith advised. "There may be an implication
that the increase in the 1990s in foodborne illness associated with fresh
produce is the result of an increase in imports from foreign countries.
However, our experience has been that outbreaks caused by produce from
foreign and domestic sources have actually occurred in proportion to the
amounts of product from these sources. While the challenges may differ
by commodity, region, or country, there is plenty of work to go around."
Recent foodborne illness investigations show that many causes of produce
contamination are preventable, she said.
Finding the contaminated items is not the primary reason for a microbiological
survey. The primary goal of sampling is to gather information, she explained.
Such surveys help collect baseline data on the incidence of microbial
contamination, identify vehicles and causes, focus research to reduce
contamination, assess effort to reduce food-borne illness and modify policy
or fine tune GAPs and GMPs.
On the positive side, surveys show 96 to 99 percent of all produce is
free of target pathogens, i.e., E. coli 0157:H7, Salmonella and Shigella,
Smith noted.
An Action Plan
"We have come a long way, but the outbreaks continue," she reminded
the group, introducing FDA's latest food safety action plan, "From
Production to Consumption: A Proposed Action Plan to Minimize Foodborne
Illness Associated with Fresh Produce Consumption." The proposed
Action Plan is posted on the Web at: www.foodsafety.gov/~dms/prodplan.html.
FDA hopes to make the final Action Plan, which incorporates comments on
the proposal, available soon.
The produce safety action plan is designed "to fill food safety gaps
in the production, handling and preparation of produce to minimize foodborne
illness associated with fresh produce consumption," Smith said. From
farm to table, it builds upon existing programs and covers fresh fruits
and vegetables.
"Key to the success of the produce safety action plan will be collaboration
with food safety partners, industry, consumer groups and all our stakeholders,"
Smith said. Challenges with contamination at both retail and foodservice
levels remain, however, and these areas do need to be addressed.
Foodborne illnesses associated with fresh produce are real and require
constant industry vigilance, Smith reminded.
Is commodity specific guidance coming? FDA's primary guidance is broad
scope, she said, although the agency has some commodity specific guidance,
such as for sprouts, when necessary. There have been very good efforts
from industry groups and universities to develop commodity specific guidance
proactively, she noted, adding that certain commodities that appear to
pose higher food safety risks are showing up. UFFVA and PMA recently organized
working groups to develop guidance for these commodities.
"This action plan is only one of many steps to achieve the goal of
produce safety. Working in collaboration with other food safety partners,
the problem can be solved," the speaker declared.
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