In sentencing me to jail in 1982, the judge said I had a memory of convenience.
I had said I had a memory of not much.
Spinach and lettuce growers seem to have a memory of not much, given the produce industry’s revisions to the 2006 E. coli O157:H7 outbreak in spinach that killed four and sickened 200.
In October, 1996, a 16-month-old Denver girl drank Smoothie juice manufactured by Odwalla Inc. of Half Moon Bay, California. She died several weeks later; 64 others became ill in several western U.S. states and British Columbia after drinking the same juices, which contained unpasteurized apple cider — and E. coli O157:H7. Investigators believed that some of the apples used to make the cider might have been insufficiently washed after falling to the ground and coming into contact with deer feces.
Almost 10 years later, on Sept. 14, 2006, the U.S. Food and Drug Administration announced that an outbreak of E. coli O157: H7 had killed a 77-year-old woman and sickened 49 others (United States Food and Drug Administration, 2006). The FDA learned from the Centers for Disease Control and Wisconsin health officials that the outbreak may have been linked to the consumption of produce and identified bagged fresh spinach as a possible cause.
In the decade between these two watershed outbreaks, almost 500 outbreaks of foodborne illness involving fresh produce were documented, publicized and led to some changes within the industry, yet what author Malcolm Gladwell would call a tipping point — “a point at which a slow gradual change becomes irreversible and then proceeds with gathering pace” (http://en.wikipedia.org/wiki/Tipping_Point) — in public awareness about produce-associated risks did not happen until the spinach E. coli O157:H7 outbreak in the fall of 2006. At what point did sufficient evidence exist to compel the fresh produce industry to embrace the kind of change the sector has heralded since 2007? And at what point will future evidence be deemed sufficient to initiate change within an industry?
In 1996, following extensive public and political discussions about microbial food safety in meat, the focus shifted to fresh fruits and vegetables, following an outbreak of Cyclospora cayetanesis ultimately linked to Guatemalan raspberries that sickened 1,465 in 21 U.S. states and two Canadian provinces (U.S. Centers for Disease Control and Prevention, 1997), and subsequently Odwalla. That same year, Beuchat (1996) published a review on pathogenic microorganisms in fresh fruits and vegetables and identified numerous pathways of contamination.
|Aug-93||Salad||E. coli O157:H7||53||Salad Bar||WA|
|Jul-93||Salad||E. coli O157:H7||10||Unknown||WA|
|Sep-94||Salad||E. coli O157:H7||26||School||TX|
|Jul-95||Lettuce||E. coli O153:H48||74||Lettuce||MT|
|Sep-95||Lettuce||E. coli O153:H47||30||Scout Camp||ME|
|Sep-95||Salad||E. coli O157:H7||20||Ceasar Salad||ID|
|Oct-95||Lettuce||E. coli O153:H46||11||Salad||OH|
|May-96||Lettuce||E. coli O157:H10||61||Mesclun Mix||ML|
|Jun-96||Lettuce||E. coli O153:H49||7||Mesclun Mix||NY|
Table 1. Outbreaks of foodborne illness related to leafy greens, 1992-1996.
By 1997, researchers at CDC were stating that pathogens could contaminate at any point along the fresh produce food chain — at the farm, processing plant, transportation vehicle, retail store or foodservice operation and the home — and that by understanding where potential problems existed, it was possible to develop strategies to reduce risks of contamination. Researchers also reported that the use of pathogen-free water for washing would minimize risk of contamination.
|Feb-99||Lettuce||E. coli O157:H9||65||Restaurant||NE|
|Jun-99||Salad||E. coli O111:H8||58||Texas Camp||TX|
|Sep-99||Lettuce||E. coli O157:H11||6||Iceberg||WA|
|Oct-99||Lettuce||E. coli O157:H7||40||Nursing Home||PA|
|Oct-99||Lettuce||E. coli O157:H7||47||Restaurant||OH|
|Oct-99||Salad||E. coli O157:H7||5||Restaurant||OR|
Table 2. 1999 U.S. outbreaks of STEC linked to leafy greens
Yet it would take a decade and some 29 leafy green-related outbreaks before spinach in 2006 became a tipping point.
|Oct-00||Salad||E. coli O157:H7||6||Deli||IN|
|Nov-01||Lettuce||E. coli O157:H7||20||Restaurant||TX|
|Jul-02||Lettuce||E. coli O157:H8||55||Bagged, Tossed||WA|
|Nov-02||Lettuce||E. coli O157:H7||13||Restaurant||IL|
|Dec-02||Lettuce||E. coli O157:H7||3||Restaurant||MN|
Table 3: Leafy green outbreaks of STEC, 2000 — 2002.
What was absent in this decade of outbreaks, letters from regulators, plans from industry associations and media accounts, was verification that farmers and others in the farm-to-fork food safety system were seriously internalizing the messages about risk, the numbers of sick people, and translating such information into front-line food safety behavioral change.
|Sep-03||Lettuce||E. coli O157:H7||51||Restaurant||CA|
|Nov-03||Spinach||E. coli O157:H7||16||Nursing Home||CA|
|Nov-04||Lettuce||E. coli O157:H7||6||Restaurant||NJ|
|Sep-05||Lettuce||E. coli O157:H7||11||Dole, bagged||Multiple|
Table 4: Leafy green STEC outbreaks, 2003 — 2005.
So why was spinach in 2006 the tipping point?
It shouldn’t have been.
But it lets industry apologists say, how the hell could we known?
Tom Karst of The Packer reports the crisis of confidence in the status quo of produce safety practices arrived with a thud a little more than 10 years ago.
Beginning Sept. 14 and continuing until Sept. 20, 2006, the U.S. Food and Drug Administration issued daily news releases that flatly advised consumers “not to eat fresh spinach or fresh spinach-containing products until further notice.”
The agency had never before issued such a broad warning about a commodity, said Robert Brackett, who in 2006 was director of FDA’s Center for Food Safety and Applied Nutritions. Brackett is now vice president and director of the Institute for Food Safety and Health at the Illinois Institute of Technology,
“In this particular case all we knew (was) that it was bagged leafy spinach, but we had no idea whose it was or where it was coming from,” he said in December of this year.
“It was a very scary couple of days because we had all of these serious cases of hemolytic-uremic syndrome popping up and people getting sick, and it was so widespread across the country.”
The Centers for Disease Control and Prevention reported about half of those who were ill were hospitalized during the 2006 spinach E. coli outbreak.
“It was shocking how little confidence that FDA and consumers had in the produce industry at that moment,” said David Gombas, retired senior vice president of food safety and technology for the Washington, D.C.-based United Fresh Produce Association.
Given the history of outbreaks, the only thing shocking was that the industry continued to expect blind faith.
“For FDA to say ‘Don’t eat any spinach,’ they blamed an entire commodity, and it became very clear to the produce industry at that moment they had to do something to restore public confidence and FDA confidence in the safety of fresh produce,” Gombas said Nov. 30.
“One of the things that was very different and had the greatest impact was the consumer advisory against spinach — period — regardless of where it came from,” said Trevor Suslow, extension research specialist and director of the University of California-Davis Postharvest Technology Center.
The stark warning — immediately followed by steeply falling retail spinach sales — was issued in the midst of a multistate E. coli foodborne illness outbreak eventually linked to Dole brand baby spinach.
The product was processed, packed and shipped by Natural Selection Foods of San Juan Bautista, Calif., which markets the Earthbound Farm brand.
U.S. Department of Agriculture data shows that California’s spinach shipments plummeted from 258,774 cartons in August 2006 to 138,278 cartons in September, a drop of nearly 50%.
Shipping point prices for spinach on the California coast dropped from $8.45-10.45 per carton on Sept. 14 — the day that FDA first issued its advice to avoid for consumers to avoid spinach — to $4.85-6.15 per carton on Sept. 15.
No market was reported by the USDA for the rest of September because supplies were insufficient to quote.
The final update on the 2006 spinach outbreak was published by the CDC in October. By March 2007, the FDA issued its own final report about its investigation on the cause of the outbreak.
The CDC said in October 2006 that 199 persons infected with the outbreak strain of E. coli O157:H7 were reported to CDC from 26 states. Later, the tally of those sickened was raised to 205.
Gombas said the FDA warning in mid-September caused leafy green sales to crash, not fully recovering for nearly a decade.
“There were outbreaks before that, but none of them were as devastating to industry or public confidence as that one.”
The FDA and the California Department of Public Health issued a 51-page report on the extensive investigation into the causes of an E. coli O157:H7 outbreak associated with the contaminated Dole brand baby spinach.
The report said investigators identified the environmental risk factors and the areas that were most likely involved in the outbreak. However, they were unable to definitely determine the source of the contamination.
The investigation explored the source of the spinach in 13 bags containing E. coli O157:H7 isolates that had been collected nationwide from sick customers, according to a summary of the report.
Using the product codes on the bags, and employing DNA fingerprinting on the bacteria from the bags, the investigators were able to match environmental samples of E. coli O157:H7 from one field to the strain that had caused the outbreak, according to the report.
The report said E. coli O157:H7 isolates located on the Paicines Ranch in San Benito had a (pulsed-field gel electrophoresis) pattern indistinguishable from the outbreak strain. The report said the pattern was identified in river water, cattle feces and wild pig feces on the Paicines Ranch, the closest of which was just under one mile from the spinach field.
According to investigators, the sources of the potential environmental risk factors for E.coli contamination at or near the field included the presence of wild pigs and the proximity of irrigation wells and waterways exposed to feces from cattle and wildlife.
From 1995 to 2006, researchers had linked nine outbreaks of E. coli O157:H7 infections to, or near, the Salinas Valley region. But the 2006 spinach outbreak was different.
There were guidelines for growers in 2006, but not a way to make sure growers were following them, said Joe Pezzini, CEO of Ocean Mist Farms, Castroville, Calif.