In February we committed to sharing the progress of the Romaine Task Force, which is a cross-functional group of executive industry leaders from across the supply chain, experts from academia and other disciplines, and government officials from the Centers for Disease Control and Prevention, the Food and Drug Administration, and state departments of health and agriculture, charged with creating learnings for our industry to prevent future outbreaks and to increase consumer confidence through improved food safety response and effectiveness.
While outbreaks linked to romaine were the impetus of our action, this effort has applications across all produce commodities and for this reason, we’re seeking stakeholder input on the task force recommendations.
The summary of the task force’s recommendations, along with an updated Q&A related to provenance labeling and a framework to improve traceability, are available on both the PMA and United Fresh websites. Comments can be e-mailed to [email protected] by April 12.
The Task Force is focused on four distinct areas, and is proposing the following recommendations:
1. Science/Prevention. Our first goal must be to stop contamination from occurring, thereby reducing outbreaks. Therefore, the task force proposes to:
- Support current efforts to develop a science- and risk-based model for evaluating and managing agricultural water, based on the source of water and its use.
- Develop guidance for produce industry-specific Root Cause Analysis to assist growers, processors, regulators and other stakeholders in assessing the cause of a pathogen in the event of positive environmental or product samples.
2. Traceability. Now is the time when we must define the path forward for supply chain-wide traceability. When a consumer gets sick, we must find a way to identify the responsible product and the data tracing its origin. To do this, the task force recommends that industry:
- Develop systems and approaches that identify and narrow the scope of possible lots/suppliers of leafy greens at any given retail or foodservice establishment at any given time, and retain that information for immediate use in a traceback investigation.
- Support use of the language of PTI and urge PTI labeling of all cases/packs of leafy green products.
- Gather feedback from FDA to refine a template industry can use to standardize the way traceback data are shared.
3. Labeling. Recognizing that the purpose of provenance labeling is to provide consumers easy access to information about growing regions associated with romaine products in the event of an advisory, the vision is that this is an interim step until better traceback mechanisms are in place. To date, the task force has:
- Published and disseminated a revised Labeling Q&A that provides guidance on how to label consumer packaging of romaine to include standardized terminology for growing regions.
- Recommended that for bulk, unpackaged product, or product destined for foodservice use, operations should refer to information on cases to determine if a product is subject to an advisory.
4. Investigation. Outbreak investigations are inherently slow due to reporting of illnesses, product identification, and traceback. Together, with all stakeholders, we must evaluate and improve upon the entire process to reduce risk to consumers, minimize disruption in our supply chain, and keep consumer confidence in our products. This includes the following:
- Engage FDA/CDC leadership to evaluate legal options to facilitate government/industry collaboration to accelerate and narrow outbreak investigations.
- Evaluate needs and opportunities for increased funding to FDA, CDC and states to accelerate and narrow outbreak investigations.
- Consider potential value/methodology of a voluntary blinded industry database of pathogen testing (environmental, raw product, finished product) which could enhance knowledge and inform prevention strategies.
- Determine the value of trialing a voluntary database of harvest dates and shipping information that would support a rapid “trace-forward” in the event of an outbreak.
The Romaine Task Force has been working to develop each of these and other areas. Some of the efforts, like the provenance labeling Q&A, will be completed in the near term.
Others, like improved funding to support public health officials, will require ongoing effort. The timing of others, like improved traceability, is subject to the will and motivation of the supply chain.
As each effort progresses, additional stakeholders and subject matter experts will be solicited so that the approaches are science- and risk-based as well as practical. Change is already underway within the industry, with more to come.
We look forward to your feedback, participation, and dedication to improving produce safety.
Tom Stenzel is president and CEO of the Washington, D.C.-based United Fresh Produce Association. Cathy Burns is CEO of the Newark, Del.-based Produce Marketing Assocation.