CDC’s Misguided Focus To Issue Food Safety Alerts

December 2018 – The produce industry has been struggling with food safety outbreaks on Romaine this year, and the most recent one led the CDC to issue a recommendation that consumers not consume, and retailers and restaurants not sell, Romaine lettuce. Since no reputable retailer or restaurant will sell something the CDC advises them not to sell, this in effect shut down the romaine industry.

The action caused layoffs to thousands of people who were no longer needed to harvest, pick, pack or ship Romaine, cost untold tens of millions and, in the end, accomplished literally nothing. We can now say, with certainty, it was a total waste of time and money.

How do we know this? Simple. The latest date an illness is known to have started is Oct., 31, 2018, but this broad warning to neither sell nor consume Romaine was issued just before Thanksgiving, more than three weeks later.

Of course, one can say better safe than sorry, and, of course, the CDC was not certain that the outbreak was over before it issued its warning. But, in fact, it should have known better. The CDC has no way of knowing that Romaine, or any other food item, is experiencing an active outbreak. It gets its information retrospectively by interviewing sick people.

Theoretically, a factory with a production flaw could keep churning out infected product. But with fresh greens, where almost every outbreak is a kind of “Black Swan” event with a root cause in the field, the pathogen is typically gone in a very short time frame. This is why we rarely can find its source with certainty.

It also means by the time the CDC starts issuing advisories, the greens are typically all gone. Who keeps month-old Romaine in the fridge?

The CDC, FDA and other agencies have put themselves in a ridiculous box. They want consumers to think that public health authorities can assure consumers all food sold in the United States is safe for everyone.

This is, however, simply not true.

Raw foods, not just produce, but raw eggs, sushi, steak tartare, raw milk cheeses — anything raw, has some possibility of having a pathogen on it. Remember Rocky Balboa training for the big fight by drinking raw eggs? He could have gotten a bad case of Salmonella enteridis.

In addition, some foods that are OK for most people are wildly dangerous for others. I arranged a stem cell transplant for my father as he was due to die from leukemia. Under this procedure, the hospital bombards a patient with chemotherapy to destroy his immune system. Stem cells from a healthy individual are then transplanted, and the patient grows a new immune system. But the patient is like a baby and can’t have immunizations for a year. In the meantime, on the hospital floor, all fresh foods are banned, and you can’t even have flowers in the room as they could have pathogens on them.

The CDC and the fresh foods industry have been remiss in not communicating to the public that uncooked foods are not right for everyone.

In the CDC’s Food Safety Alert on Romaine, there is a 1-year-old child that was stricken. The heart goes out to the parents, of course, but we need to make it clear that 1-year-olds should only be eating leafy greens if they are properly cooked.

The industry desperately wants the CDC to declare an “all-clear” and pronounce everything “safe,” but this is a bit of sleight of hand on everyone’s part. Ignorance may be bliss, but the truth is that the CDC has not the slightest idea whether the food being shipped on any given day is “safe” or not. There is always risk, and the CDC won’t know for weeks if that risk has manifested itself.

A lot of industry efforts are focused on traceability. This is wise because quick and accurate traceback may allow recalls and advisories to be limited in scope. However, even though we favor modern technologies such as blockchain, there is, already, quite speedy traceback if you are talking about big Salinas shippers selling to Walmart.

The problem is this is not a complete description of the produce industry. In discussing the Produce Traceability Initiative back in 2009, a brilliant wholesaler sent a note to Jim Prevors Perishable Pundit about “Ken, the guy with the Red truck,” describing the challenge of traceability in produce:

Putting in a system to trace product gets more difficult the further down we go in the distribution chain. Stand on the floor on a busy Terminal Market and try and imagine where the product goes after it is sold by the Wholesaler. A customer known as Ken, the guy with the Red truck, pays cash for a pallet of tomatoes. He takes the tomatoes to his garage where the boxes sit on the floor next to cleaning supplies, motor oil and who knows what else.

He and his kids (2 of whom just used the toilet without washing their hands) dump the tomatoes on a dirty tarp to sort them for color. The green ones sit in the garage for a few days to color up,  during which time one or two rodents snack on tomatoes. When they finally ripen, Ken delivers the tomatoes to some of the finest restaurants in town for all of us to enjoy.

Somehow, I dont think that Ken or even a legitimate small wholesaler or purveyor is interested in investing in a traceability system. They will have to be dragged kicking and screaming to the table. The problem is that the system is only as good as its weakest link, and unless Ken is a part of the system, it doesnt work.

There has been a lot of question of why traceback has been so difficult with Romaine. My bet is that it is due to “Ken and his red truck” and people like him. In this sense, the CDC is wasting its time talking to big producers who ship straight loads to Walmart and Sysco. If they really want to change food safety, the CDC has to focus on the procurement standards for independent restaurants, retailers and the purveyors who service them.              pb