Tom KarstScott Horsfall, chief executive officer of the California Leafy Green Marketing Agreement, Sacramento, visits with Caroline Smith DeWaal, food safety director of the Washington, D.C.-based Center for Science in the Public Interest, Oct. 2 after a workshop at the United Fresh Washington Public Policy Conference/WASHINGTON, D.C. — The future of government testing of fresh cut produce may depend on how willing the industry is to test for pathogens and share the results with the Food and Drug Administration.
Testing finished product for pathogens is attracting more interest, an FDA official said at a United Fresh Produce Association Washington Public Policy Conference session on Oct. 2.
Jenny Scott, senior advisor to the Office of Food Safety at the FDA’s Center for Food Safety and Applied Nutrition, said the idea of industry voluntarily sharing the results of testing data with the government is a sensitive one. However, she said the Food Safety Modernization Act does give the agency access to a facility’s food safety plan, including the results of testing or any other verification procedures.
“The question I have for you is what fresh-cut processors can show to FDA to demonstrate that the pathogens are being controlled, because that is the expectation in the inspection of fresh-cut facilities under the regulations required by the Food Safety Modernization Act,” she said.
While the regulations for Food Safety Modernization Act have not yet been issued, Scott said the law requires facilities to conduct a hazard analysis and implement preventive controls for identified hazards. Under the law, facilities are businesses that are required to register under the Bioterrorism Act of 2002 and she said fresh cut processors are generally subject to the legislation’s preventive control requirements.
The food safety law requires verification of preventive controls, Scott said. Under the law, preventive controls are adequate to control the hazard, and monitoring is being conducted.
Scott said the law states preventive controls should be in place to effectively and significantly minimize or prevent the food safety hazards. Environmental and product testing programs are ways this can be accomplished.
“It doesn’t say you have to do testing, but it does say you have to verify the hazards are being controlled,” she said.
The law also said preventive control plans should be reviewed at least every three years.
Scott said that given the number of outbreaks of foodborne illness from fresh-cut produce, it is reasonable to assume that fresh-cut processors would identify pathogens such as salmonella and e. coli O157:H7 and Listeria monocytogenes as hazards that are known or reasonably foreseeable.
She said that given the hazards, the industry must consider preventive controls for pathogens on fresh-cut produce and the raw material and how those controls would be verified.
While product testing is generally not a means for controlling a hazard, Scott said that product testing does play an important role in verification of preventive controls.
“Once control measures are put in place, then it is important to verify that they are doing what you expect them to do, and that may include some testing,” she said.
At that point, product testing can show if something has gone wrong, Scott said.
“We do think product testing is an important verification activity, particularly when preventive control is weak, if you don’t have a kill step for a pathogen,” he said.
Caroline Smith DeWaal, food safety director at the Center for Science in the Public Interest, Washington, D.C., said the National Turkey Federation started collecting testing data for food safety from their members to show results of data. The data is blinded as to origin but is made available to members and others to show trends.
“I know you represent lots of different kinds of produce and so your testing is more complicated, but I think the trade association can play a role in helping you guys develop food systems and even in doing this kind of data sharing,” Smith DeWaal said.
Samir Assar, director of the produce safety staff at the Office of Food Safety at the FDA’s Center for Food Safety and Applied Nutrition, said the agency hopes to be more transparent with its testing data as it hopes the industry will share more of its testing data.
Assar said a new FDA project of genome sequencing of pathogens may offer the industry insights on the source of pathogens. “It’s an innovative tool that (industry) can take advantage of,” he said.