From the duh files: How well do you understand irrigation water risk management?

Doug Grant of The Packer writes food safety outbreaks have a massive effect not only on growers, but on all stakeholders throughout the fresh produce supply chain. Irrigation water has been identified over the years as a likely cause of fresh produce contamination, so it’s critical that our industry fully understands the potential risk involved and how these risks are being managed by growers.The Center for Produce Safety has numerous research projects involving irrigation water. One 2015 project titled “Evaluation of risk-based water quality sampling strategies for the fresh produce industry,” led by PI Channah Rock, Ph.D., University of Arizona, concluded that “localized environmental conditions play a large role in water quality.”

Further, that “growers must get a better understanding of their water sources through collection of water quality data and historical analysis.” Another outcome from this project was developing a computer app to provide guidance on the frequency of sampling based on risk factors (e.g. after rainfall).

Several other CPS research projects focus on predictive models for irrigation water quality, exploring the relationship between product testing and risk, reuse of tail water and evaluating alternative irrigation water quality indicators.

Let me introduce Natalie Dyenson, head of food safety and quality assurance at Dole. As you can imagine, she has a huge responsibility covering several product lines (fruits, vegetables, leafy greens and packaged salads) sourced from hundreds of growers throughout the Americas and other countries. She’s been involved with CPS for several years and takes a keen interest in new research findings.

With leafy greens as her top priority, she is still very concerned about the three romaine lettuce outbreaks during 2018. With all Dole crops, water quality risk assessment and testing are very important. Dole reviews water source (wells, reservoir, canals, etc.) and type of irrigation (foliar spray, furrow irrigation, flooding farms).
All water sources including deep wells are tested monthly, and after weather events such as wind and frost. Enhanced testing of product is done prior to harvest depending on their environmental risk assessments — for example, after an excessive rain event where potential contaminated water run-off could be introduced to the field.

Natalie said, “there is a huge potential to leverage historical water quality test data to help mitigate risk.” She’s also very interested in predictive models and is looking forward to the results of a CPS research project starting in 2019, “Development of a model to predict the impact of sediments on microbial irrigation water quality,” led by Charles P. Gerba, Ph.D, from the University of Arizona.

Previous CPS research has shown that sediments at the bottom of waterways can harbor 10 to 10,000 more fecal bacteria than surface waters. This new project will investigate the conditions where pathogens could be re-suspended in surface water and will design sampling strategies to minimize contamination to crops.

While discussing sediment in irrigation canals Natalie mentioned that it’s been observed that some non-Dole farmers are still laying irrigation intake hoses directly on the bottom of water sources (canals, ponds, etc.). A simple solution is to use a flotation device positioned so that the hose end extracts water just below the surface where there are fewer potential contaminants. While not a complete remedy to eliminate all organic matter and pathogens in the water supply, it is a simple tool to help reduce risk.

I’ve asked Terry to adopt his piece on GE foods in Canada, for my upcoming book, tentatively titled Food Safety Fairytales.

Schaffner has also agreed, I didn’t ask Margaret, but had a good chat with her today, so now i’m formally asking.

The book will be peer reviewed, so everyone will get credit. It is made to be sold at airports. I was gonna write it myself, but figured out I needed a little help from my friends, and that it’s OK to ask for help.

That’s Katija and Ben, back in the day, when we would go golfing at 6:30 a.m.

Do you know what’s in your water? Proposed regs put responsibility on growers

Federal regulators have softened some proposed restrictions to farming practices in the name of food safety, but the Yakima Valley’s tree fruit industry officials say the proposal is still too much.

two fistin wilsonFruit trade officials plan to submit comments to the U.S. Food and Drug Administration asking for additional allowances on proposed irrigation water quality standards called for by the Food Safety Modernization Act.

“It’s still complicated and still going to be costly for your grower,” said Chris Schlect, president of the Northwest Horticultural Council, a trade group that represents the fruit industry in federal affairs and international trade.

The Food Safety Modernization Act, or FSMA, is a 2011 federal law that mandated sweeping changes to the entire food production system to prevent the spread of food-borne illnesses, which kill 3,000 people a year nationwide and hospitalize 128,000, according to estimates from the Centers for Disease Control and Prevention.

It includes everything from hand washing to preventing acts of terrorism.

The FDA is charged with implementing the law and is taking public comments on its second attempt to impose the nuts and bolts of the regulation, spelled out in mind-numbing, scientific detail over several subsections that together would take up thousands upon thousands of pages.

“I don’t think any normal person can understand it,” Schlect said. “George Orwell would roll over in his grave.”

Growers objected most to a suggested stipulation that would prohibit any fruit from contact with water that does not meet the swimming quality standards set by the Environmental Protection Agency and would also require farmers to periodically test their water. If the test came back negative, the growers would have to shut off irrigation.

Most of the Yakima Valley farms rely on open canals and though many orchards use low sprinklers that water under the tree canopy, they also employ overhead sprinklers to cool fruit during the scorching peak of summer.

In the first round of public comments last year, Schlect and other grower groups argued the proposed rules would hold orchardists responsible for contamination upstream, and treat fruit that hangs on the trees the same as produce grown in the dirt.

While FDA officials didn’t soften the water quality standards in their revised proposal, they have suggested granting allowances for the time between the last round of irrigation and harvest. They also might allow growers to test water collectively, maybe at certain points in the canal.

Meanwhile, The Produce News reports that different standards for packinghouses under the Food Safety Modernization Act based on their location will cause confusion within the industry and are not science-based, produce industry groups told officials at the Food & Drug Administration during a Thursday public meeting on FSMA changes.

Under the FDA’s current interpretation of FSMA, on-farm packinghouses would need to meet produce safety standards, but off-farm operations, which must register with the FDA, would have to meet more extensive and costly preventive control requirements.

Registered facilities that only handle raw agriculture commodities and don’t conduct further processing should be covered under the produce safety rule, Reggie Brown, executive vice president of the Florida Tomato Exchange, argued during the meeting held in College Park, MD. Food safety and public heath benefits are likely to be best served by a single rule, he said.

My friend and collaborator, farmer Jeff Wilson addressed this issue over 10 years ago, long before youtube existed. We found the video.



Theatre of the bizarre as North Pole Republican wants to eliminate government regulation of food

A couple of our Alaskan food safety friends sent along updates on the ban food safety regulation movement in the state legislature that looks more like a Second City improv skit.

The Mudflats blog reports Alaska State Rep. Tammie Wilson, a Republican from North Pole, who has taken her quest for deregulation to new and unsanitary heights.

Behold House Bill 202 – Sale of Food by Processors to Consumers. Gone are the days of food inspectors, rules and regulations, requirements for refrigeration, and soap and water. All’s fair at the farmer’s market, no matter what you’re selling.

Most of Rep. Wilson’s testimony came in the form of a skit where the plot focused only on produce and baked goods. She played a beleaguered farmer, just trying to sell her humble wares at the market, and her aide played an uptight, joyless, and unreasonable inspector from the Department of Environmental Conservation (DEC).

The ensuing skit involved a lot of food props, and the committee members had also been given samples of peeled and sliced fruit, and cookies. “I do have a knife,” Wilson demonstrated to the audience, “and I will not use it on anyone, I promise.” (Cue a weirdly awkward moment as Wilson’s aide let forth with a too-loud cackle, and the rest of the room sat in uncomfortable silence).

And thus began the dramatic demonstration. Slicing of tomatoes was not allowed, because that was considered “food preparation.” Orange peeling was forbidden for the same reason. Next, she tried “an apple…one that we know daycares like to do. And I’m sure that they’re able, with no permit or anything, to be able to cut an apple for a snack.” No dice, says the inspector, “And as far as a daycare goes, if you have five or less children, you may cut. Any more than that, you’d be permitted.” (Remember this part for later, because it’s not true).
But we’re not done yet. Next up – a strawberry. Wilson begins to remove the green top.

“This may have seemed ridiculous, but you know, it is ridiculous! Do I want to poison anybody? It’s not a good thing to be a Representative and poison your constituents. I just want to put that on the record.”

The TV cameras were rolling, but there was no audio hookup yet. This happens so people don’t embarrass themselves by saying something stupid into a “hot mic” that they weren’t intending to say in public. In this particular case, that didn’t matter. Behold our food-prepping farmer, who beautifully illustrates the hazards of her own bill during the ten minutes before the meeting started:
Who could object to dirty cutlery, snotty carrots, unrefrigerated egg custard, and the underside of Tammy Wilson’s germy fingernails in their strawberries? Ridiculous. As long as there was no willful attempt to poison, that should be enough.

Kristin Ryan, Director for the DEC, identified the Food Safety and Sanitation program as “the main target of Rep. Wilson’s bill” and began her testimony by stating what really should be the obvious:

“The DEC recognizes the interest from small food business owners throughout the state to sell products. Provisions in HB202 could cause significant risks for the general public, and increase foodborne illness outbreaks.

When you purchase food to eat, you assume it is safe. While no one intends to harm their customers, food-borne illnesses are common, and can easily happen. Precautionary measures are important to make and serve safe food. At a minimum, you need a sanitary environment, employees to wash their hands, and proper temperature control.”

The Republican bill would eliminate the ability of the DEC to investigate if an outbreak of food-borne illness was occurring. The agency would not be allowed to inspect, test, or stop the sale of a food product that is making people sick.

Because Republicans love freedom. And food safety inspectors don’t.

Hello, you want to do what with that food?

How to handle, store and prepare food were the most common questions Canadians had for a national food safety hotline according to new research.

But those results mask the more detailed questions callers often had about how food was produced.

The results, published in the current issue of Food Protection Trends, detail 3,764 telephone inquiries from January 2003 through December 2005 to a national food safety hotline that was established at the University of Guelph. Other prevalent themes were specific products and brands, food preservation, non-food safety topics and emerging issues.

“The call center was a unique contribution to Canadian food safety at the time,” said Dr. Douglas Powell, a professor of food safety at Kansas State University. “But information needs are continually evolving, which is why we publish daily food safety information in the form of an electronic mailing list (bites-l), a blog ( and twitter.

The other authors, Ben Chapman and Sarah Wilson, are both adjunct professors at Kansas State, and the three continue to collaborate on new food safety messages and delivery media.

By collecting data on information needs, an information service whether it’s a call center or social media — can serve as a research tool, revealing information gaps and opportunities to develop or improve resources.The citation is below, as is the original FSN gang (Food Safety Network, circa 2002).

Understanding food safety information needs: using a national information service as a research tool
Food Protection Trends, Vol. 31, No. 7, Pages 437–445
Sarah Wilson, Benjamin Chapman and Douglas Powell
In December 2002, a public information service was launched as a component of the Food Safety Network (FSN) at the University of Guelph. Its core activity was a national toll-free call center through which the Canadian public had direct access to food safety professionals. The call center received 3,764 inquiries from January 2003 through December 2005. Data were collected on call characteristics (day, time and call duration), caller demographics and themes of the inquiries. Analysis determined that inquiries came primarily from individuals identified as consumers and were largely focused on the themes of food storage, handling and preparation. Other prevalent themes were specific products and brands, food preservation, non-food safety topics and emerging issues. Callers obtained the call center’s contact information from a variety of sources, including government, the media, and referrals by food and health professionals. Food safety questions posed by callers varied widely in terms of the topic of concern and the degree of complexity. By collecting data on client information needs, an information service can serve as a research tool, revealing information gaps and opportunities to develop or improve resources. This project provides a blueprint for other organizations seeking to engage the public through an information service.