With added food safety compliance costs of perhaps $1 to $2 per carton, the complications are just beginning for California Salinas Valley romaine shippers and Canadian importers.
Starting Oct. 7 and continuing to Dec. 31, the Canadian Food Inspection (CFIA) Agency requires that romaine lettuce from four counties in California’s Salinas Valley be tested for E. coli.
The Canadian agency will require importers to either prove that romaine is not from Santa Cruz, Santa Clara, San Benito and Monterey counties, or provide an official certificate of analysis from an accredited laboratory confirming the lettuce has below-detectable levels of E. coli before it is distributed in Canada, according to a news release.
Testing can be done in the U.S. or in Canada, according to the CFIA.
Produce associations in the two countries have collaborated on a continuously updated document answering questions on the import requirements for U.S. romaine.
The document was prepared by the Arizona and California Leafy Green Marketing Agreements, the Canadian Horticultural Council, the CPMA, the PMA, United Fresh and Western Growers
The testing is not related to any current outbreak. Food safety investigations by Canadian and U.S. authorities identified Salinas Valley romaine as a recurring source of E. coli outbreaks from 2016-19, according to the release.
Canadian receivers have been sourcing from non-Salinas growing regions as much as they can, said Leonard Jang, vice president and general manager for Van Whole Produce Ltd. Vancouver, British Columbia.
“We are trying to understand (the import requirements) to make sure that we’re in compliance with the regulations, and we’re talking to the shippers and seeing what they think about it,” Jang said.
While buyers in Canada are pulling product from some local deals, production there will end and buyers will have to seek product from California.
Jang said receivers will likely want testing for E. coli to be done at the shipping point, and not in Canada.
If the product is tested in Canada and fails, Jang said importers would be saddled with disposing of the load and would have sunk money into transporting the romaine without being able to sell it.
One shipper said the rules require a lot of communication with Canadian customers about how to handle the product and satisfy the protocol.
“Everyone’s goals are to move product through the system as quickly as possible, from field to consumer,” said Robert Verloop, chief operating officer for Coastline Family Farms, Inc., Salinas, Calif.
Verloop said the CFIA’s plan was not put together with very much industry engagement. “What is required is a little more industry interaction to come up with a workable plan based on the parameters of what we do,” Verloop said Oct. 8. For example, if product is tested for E. coli and then held until it is cleared, extra cooling space is required.
Testing protocols are also subject to different interpretations, he said.
“There are a lot of questions that resulted both on our side as a grower-shipper, but also on the receiving side, because they’re trying to figure out how they can continue to have a continuous flow of romaine coming to their stores,” he said.
The two-day delay the implementation of the regulation, from Oct. 5 to Oct. 7, allowed some of the protocol to be tested.
“We’re working on a moment-to-moment basis with our customers to make sure that we’ve covered all the bases for both sides,” Verloop said.
Verloop said Coastline does pre-harvest food safety testing of romaine, but the CFIA program requires more samples and greater costs.
“Their protocol is probably four times more sampling than what we normally would do,” he said. He noted staff has to break apart the shipment and retrieve representative samples. That could mean taking samples out of 60 boxes, with each of the samples put in a separate bag.
If the sample comes from a package of romaine hearts, that bag will be removed from the load because romaine hearts are in a consumer pack and the consumer would be shorted if the sample was removed from the pack.
With COVID-19 restrictions in place on farms and in packinghouses, Verloop said the new romaine requirements could not have come at a worse time.
“I know the trade associations here in the U.S. and Canada are working with the CFIA to try to make this system as efficient as possible, but I’m hoping we can find a way to reduce costs because this just adds a tremendous amount to the cost of goods for our Canadian consumers,” he said,
Verloop estimated that the added costs could range from $1 to $2 per carton. “It is hard to put an exact cost to it because it’s so dependent on the scope of the order, but it is not cheap, and eventually those costs have to be recovered.”
Verloop hopes for adjustments to the new rules.
“I think we can demonstrate other testing protocols that are just as reassuring and effective and efficient, but do not require the intensity that’s behind this,” he said, noting that CPMA is involved in helping to create an industry working group to engage with health officials.
Romaine shipments from some farms in the Salinas region will continue all the way through Thanksgiving, though farms in Huron and Yuma, Ariz., will begin in coming weeks.
Verloop said some Salinas shippers with only a few weeks left in their season have decided they can’t make the investment to ship to Canada.
The import requirements for romaine, romaine hearts and romaine in salad blends will change the dynamics of the market and raise costs for Canada, he said.
“I don’t think that’s the intent of CFIA,” he said. “They may not have understood the downstream implications to their rigid testing protocol, but that why we have working groups and trade associations to help improve that dialogue,” he said.
Verloop said he hopes that the cooperation and collaboration that the U.S. industry largely enjoys with the Food and Drug Administration and the Centers for Disease Control and Prevention can be expanded to include Canadian public health officials.
“Our two economies on the produce side are so heavily intertwined, that it would only make sense that we work collaboratively to find the common ground that is good for the industry, good for importers, retailers, food service operators and for the consumers,” he said.
Verloop said he believes the Leafy Green Marketing Agreement safety standards are strong.
“To have (the requirements) being (introduced) on a wholesale basis like this, with a lack of clarity and a lack of time to react to it, the net result is a lot of confusion and a lot of distortion and nobody wants that,” he said. “We would like to have an opportunity to demonstrate from a scientific standpoint, why the plant and the plans that are the protocols that we have in place we think are sufficient. So, maybe coming out of this, it will give us an opportunity to start having that kind of a dialogue more directly with (Canadian officials). And I have to hope that we can turn this around to be a positive at some point.”