Update: The lettuce recall described in this article was expanded to include product sold at Canadian Burger King and Pizza Hut locations. First it was just plain old lettuce, then it was California-grown lettuce, and now the latest from the Canadian Food Inspection Agency (CFIA) is that was lettuce from a grower who has signed onto the California Leafy Green Products Handler Marketing Agreement. In explaining how that lettuce contaminated with E. coli O157:H7 came across the border from the U.S., CFIA now points to how involvement in the Leafy Green Marketing Agreement (LGMA) is a quick ticket across the international border for California-grown lettuce. The idea is simple. Since the 115 California leafy green producers submit to a mandatory food safety program, they can check “Box 22” on their Confirmation of Sale’s (COS) document and enter Canada almost without slowing down.

Amazing Coachella
And, the LGMA agreement may be the most stringent food safety program for leafy green producers on the planet. It includes mandatory government audits for lettuce, spinach, and other leafy greens that follow a “best practices” model to reduce risk. It focuses on water, soil and other environmental conditions along with farm worker hygiene and harvest controls. Still, the current E. coli O157:H7 outbreak, with at least 26 illnesses in three provinces, marks the second time in two years that California-grown lettuce served in Canadian restaurants has been responsible for a foodborne illness outbreak. Last year’s outbreak involved two restaurants in Canada’s New Brunswick and one in Orange County, California. Genetic fingerprinting connected Amazing Coachella Inc., a Coachella, CA-based producer, to the illnesses in both countries. This year’s outbreak involves KFC and Taco Bell outlets, restaurants of the Yum! Brands chain that receive fresh lettuce in the middle of winter from FreshPoint, a distributor in Toronto. CFIA has yet to name the actual grower, a subject that is giving the tight leafy green community in California something talk about. “We’ve been reaching out some,” says April Ward, LGMA’s communications director who is based in Sacramento. Her members are talking about it, but no one has coughed up the name of the responsible grower – yet. LGMA, in a statement issued on Chairman Ryan Talley’s blog, promises to fully cooperate with all those investigating the latest incident. “Consumers should know that if there is an outbreak determined to be associated with California leafy greens, the LGMA is committed to working with health officials to assist in determining the cause,” he said. “Traceback and recall capabilities that are a mandatory part of our program can be initiated and any product with the potential to be associated with the outbreak is removed from market channels to protect consumers.” “Information about any implicated farms is made available to authorities, and re-inspections can be done,” he continued. “If it is determined that an outbreak is the result of any on-farm practice, the food safety measures included in the LGMA program will be examined and, if necessary, changed.” Talley said when LGMA hears about an possible outbreak involving one of its members, “We jump in to learn more.” While California lettuce growers are aware of the Canadian outbreak involving their product, they aren’t too into speculating about who is involved. Tom Lathos, chief operating officer at Sun Coast Farms, said he’d sooner end his day at the beach, doing some January surfing. Letting a pathogen slip through does not mean a producer loses its LGMA status. Under the program, a producer can be decertified or ordered to take corrective action. But Amazing Coachella Inc. remains in good standing as an LGMA member. The LGMA program includes roles for both private sector auditors and California Department of Food and Agriculture inspectors. It was created in response to the 2006 E. coli O157:H7 outbreak associated with spinach grown in California’s Salinas Valley, often called the “America’s Salad Bowl.”  In that outbreak, 205 were sickened and 5 died. Talley says the LGMA program meets and/or exceeds the requirements of the new Produce Safety Rule, recently published by the U.S. Food and Drug Administration (FDA) under the two-year-old Food Safety Modernization Act (FSMA). All LGMA members use the organization’s service mark on bills of lading to assure customers that its products were produced under the best food safety practices available today. Growers who today can use that service mark include: Agro Jal Farms Inc, Santa Maria Amazing Coachella Inc/DBA Peter Rabbit Farms, Coachella Amigo Farms Inc, Yuma Andrew Smith Co, Spreckels Anthony Costa and Sons, Soledad Apio Inc, Guadalupe Babe Farms Inc, Santa Maria Badlands / El Don, Brawley Baloian Packing Co Inc, Fresno Beachside Produce LLC, Guadalupe Bengard Ranch Inc, Salinas Big E Produce, Lompoc Blanton Produce Co, Salinas Boggiatto Produce Inc, Salinas Bonipak Produce Co, Santa Maria Boskovich Farms, Oxnard C and E Farms Inc, Salinas Cal Cel Marketing Inc, Oxnard Channel Islands Farm, Inc, Oxnard Church Bros LLC, Salinas Classic Salads LLC, Salinas Coastal Fresh Farms, Westlake Village Coastline / Sunridge Farms Inc, Salinas Country Sweet Produce Inc, Bakersfield Creekside Organics Inc., Bakersfield Crystal Organic/Grimmway Farms, Bakersfield D’Arrigo Bros. Co. of CA, Salinas Dan Andrews Farms, Bakersfield Deardorff Family Farms, Oxnard Diamond Produce Co, Salinas Dole Fresh Vegetables, Salinas Duda Farm Fresh Foods Inc-Cal, Salinas Durant Distributing, Santa Maria Dynasty Farms Inc, Salinas Earthbound Farm, San Juan Bautista EpicVeg, Lompoc Ernie Strahm & Sons, Inc – Holtville Faurot Ranch LLC, Watsonville Field Fresh Farms, Watsonville Fisher Ranch Corporation, Blythe Fratelli Farms, Hollister Fresh Choice Marketing Inc, Oxnard Fresh Express Inc, Salinas Fresh Kist, Nipomo Fresh Origins LLC, San Marcos Fresh Roots LLC, Salinas George Amaral Ranches Inc, Gonzales Gold Coast Packing Co, Santa Maria Greengate Fresh LLLP, Salinas Growers Express LLC, Salinas Ippolito International, Salinas Jayleaf LLC, Hollister Joe Heger Farms LLC, El Centro John S Tamagni and Sons, Inc, Spreckels Kawaguchi Farms, Arroyo Grande Keber Distributing, Thermal Kenter Canyon Farms, Sun Valley Lakeside Organic Gardens LLC, Watsonville Mann Packing Co Inc, Salinas Misionero Vegetables, Salinas Muranaka Farms, Moorpark Nava Enterprise Inc, Oxnard New Star Fresh Foods LLC | organicgirl, Salinas North Country Produce, Paso Robles Ocean Mist Farms, Castroville Pablo’s Produce, Oxnard Pacific Coast Produce, Santa Maria Pacific Fresh Produce Inc, Oxnard Pacific International Marketing, Salinas Pacific Marketing Co, Salinas Pacific Pride Marketing LLC, Oxnard Pajaro Valley Fresh Fruit And Veg Dist, Watsonville Pismo Oceano Vegetable Exch, Oceano Premium Valley Produce, Inc, Scottsdale Pure Pacific Organics, Salinas Purepak Inc / Pacific Ridge Farms LLC, Oxnard Ratto Bros Inc, Modesto Ready Pac Foods Inc, Duarte Real Fresh Farms Inc., Santa Paula River Ranch Fresh Food LLC, Salinas Royal Rose LLC / European Vegetable Specialties, Salinas Sabor Farms, Salinas Salad Savoy Corp, Salinas San Cristobal Distributing Inc, Oxnard San Miguel Produce, Oxnard Santa Barbara Farms Packing, Lompoc Scarborough Farms Inc, Oxnard Seaboard Produce/Variety Marketing, Oxnard Silva Farms, Gonzales Steinbeck Country Produce, Spreckels Strahm Farms Inc, Holtville Sun Coast Farms, Santa Maria Sun Terra Produce Traders Inc, Newport Beach Sunamerica Produce, Salinas Sunfresh USA Inc, Santa Paula Sunsation Farms Inc, Monterey Talley Farms Inc, Arroyo Grande Tanimura And Antle Fresh Foods, Inc, Salinas Taylor Farms, Salinas The Nunes Co Inc, Salinas The Salad Farm LLC, Salinas True Leaf Farms, Salinas Vessey And Company Inc, Holtville William Consalo and Sons, Bakersfield One of them likely shipped lettuce to Freshpoint.

  • Joepalooka1

    the evidence seems overwhelming that when a food illness outbreak occurs, in the great preponderance of occasions the source is the fields not the restaurant premises. Interesting article.

  • johnmunsell

    Admittedly, I know less than zero about the production and processing of lettuce.  Media articles have stated that lettuce from several farms is frequently commingled and jointly processed at the packing sheds, which may include a water bath.  The possibility of cross contamination is easily percieved, making the determination of a single noncompliant producer difficult.  Nevertheless, the produce  industry, media, and public health officials waste little time offering excuses for the lack of traceback capability. 

    Compare this to the meat industry, where USDA/FSIS and the largest slaughter plants (& their national associations) typically defer to the difficulty, almost an impossibility, of determining the one non-compliant slaughterhouse source of E.coli.  Why the difference between government/industry attitudes?

    104 lettuce producers who participate in the California Leafy Green Products Handler Marketing Agreement are listed above.  In California alone!  The  four largest meat packers kill & process over 80% of our domestic feedlot-fattened steers and heifers.  They employ enormous political clout, with deep pockets.  FSIS is paralyzed with fear of litigation from the largest packers if the agency were ever audacious enough to attempt meaningful enforcement actions.   

    FSIS has been dragging its feet on Traceback protocol for years, preferring to stay out of court, while imperiling public health.  When meat samples test positive for E.coli, tracebacks could be accomplished in many instances, if FSIS and the industry truly desired accurate tracebacks to the source.  They don’t.

    John Munsell

  • Mike_Mychajlonka_PhD

    I’m confused.  If LGMA requires all of its members to participate in a traceback program as a condition of membership and we know where the contaminated lettuce ended up, how can LGMA not know the origin of the contaminated lettuce (i.e., grower)?  Alternatively, is it the intent of LGMA’s traceback program to allow LGMA to identify and recall contaminated product while keeping the identity of the member involved confidential?  Lastly, E. coli O157:H7 contamination of lettuce suggests (but certainly does not prove) the possibility that waste from a CAFO was used (at least at some point) to fertilize the crop in question.  Was such a fertilizer used without first sanitizing it?  How is anyone to answer this question if the identity of the grower continues to be withheld?

    • Under the LGMA’s rules:

      Raw or partially composted animal manure cannot be applied to any field used to grow leafy greens; if they are applied to a field, leafy greens cannot be planted there for a minimum of one year.
      Only fully composted animal manure can be applied to leafy greens, meaning they must be composted in accordance with the California Integrated Wast Management Board’s regulations (heat treated, tested for pathogens and not to be applied within 45 days of harvest).

      These requirements are verified by government auditors for LGMA members, each member is audited an average of five times a year.

      • Mike_Mychajlonka_PhD

        Thank you for this information.  It is good to know.  Can you also tell us the actual heat treatment conditions?  These may be important since the Shiga toxin actually causing the problem is more heat-resistant than its carrier (STEC).  After composint, are you required to test fort Shiga toxin or just for STEC?  Also, I would be curious regarding your thoughts on a recent paper [Fremaux et al. (2008) “Persistence of Shiga toxin-producing Escherichia coli O26 in various manure-amended soil types,” Journal of Applied Microbiology, Vol. 104, pp. 296-304].  These authors showed that their test organisms were ab le to persist over a year in such soils.

        • Animal manure must be composted in accordance
          with the California Integrated Waste Management Board’s regulations, which
          require it to be:

          Under aerobic conditions for a minimum of 131 F
          for (15) days or longer with a minimum of (5) turnings of the compost pile

          Tested using FDA/EPA/ AOAC methods at an
          accredited laboratory for following pathogens and acceptance levels:

          Fecal coliforms: 
          <1000 MPN/gram


          E. coli 0157: H7:  Negative

          Sampled in individual lots not more than 5,000 cubic

          Applied a minimum of 45 days before the crop is

          • Mike_Mychajlonka_PhD

            Thank you for this information.  E. coli O157:H7 has been said to require only about 100 minutes of exposure  to a temperature of 131F (55C) to produce a 6-log reduction of the original population.  The times you cite should be more than enough to eliminate this organism, assuming that that all portions of the compost pile are at the same temperature.  Is this really feasible?  It seems to me that straight composting relies upon natural fermentation to generate its heat.  Kill rates may be quite difficult (or impossible) to predict if growth is occurring in one portion of the compost pile while thermal death happens elsewhere.  In any case, the real problem causing EC and HUS is not the STEC (which is widely viewed as non-invasive) so much as the Shiga toxin, which is known to be much more heat resistant than the organism carrying it.  Apparently, the California Integrated Waste Management Board has no requirements for testing Shiga toxin directly.  Please correct me if I am wrong.  Also, it strikes me that 5,000 yards represents an awful lot of material.  As I recall, a good-sized dump truck will carry about 10 yards.  How many replicate samples must be taken of this 5,000 yards of material in order to assess the microbiological parameters you have cited with reasonable statistical assurance?

  • flameforjustice

    Doesn’t matter what they implement concerning food safety when no one complies and there is no serious consequences and punishments for when they don’t comply.Every time you eat you’re potentially putting your health and life at risk.Unless you grow your own in a sanitary healthy way and enviroment.

  • Ben Mark

    Where is the traceback to the source?! As some of the listed farms buy from smaller growers and drop it into their brand name there is no way to find the source in an easy way. FSMA will change it, as every step from beginning (land preparation for the seed, irrigation water,including the traceback to the seed) and every handler from field-to-fork has to record the daily sanitztion practices of the knifes of each laborer.

  • husna

    If beef was implicated as the source of E.coli in the
    outbreak, then the course of this discussion would be different.  

    If adequate sanitation protocol is not in place, the
    bacterial contaminants in food preparation facilities can spread very easily due
    to common food hygiene malpractices.


    Train employees in GMP’s and HACCP to prevent
    such fallacies from occurring and reward them for following through.

    an ozonated water system/UV light to disinfect/sanitize the fresh/bagged
    produce at the food serving facility.

    Decontaminate food contact surface/equipment using
    pulsed UV light



    Kim, C. and Hung,
    Y.-C. (2012), Inactivation of E. coli O157:H7
    on Blueberries by Electrolyzed Water, Ultraviolet Light, and Ozone. Journal of
    Food Science, 77: M206–M211. doi: 10.1111/j.1750-3841.2011.02595.x

    And, M. A. and
    Yousef, A.E. (2001), Efficacy of Ozone Against Escherichia
    coli O157:H7 on Apples. Journal of Food Science, 66: 1380–1384.
    doi: 10.1111/j.1365-2621.2001.tb15218.x

    Khadre, M.A., Yousef, A. E. and Kim, J.-G. (2001),
    Microbiological Aspects of Ozone Applications in Food: A Review. Journal of
    Food Science, 66: 1242–1252. doi: 10.1111/j.1365-262

  • southerngirl45

    I don’t see where CA Leafy Greens Marketing Agmt   addressed  Mike_Mychajlonka_PhD’s original question and concern of 2 weeks ago asking why the identity of the E.Coli source of outbreak is kept confidential. It is in the best interest of the public to know who these growers are so we can avoid their products if we so wish.

  • southerngirl45

    I don’t see where CA Leafy Greens Marketing Agmt   addressed  Mike_Mychajlonka_PhD’s original question and concern of 2 weeks ago asking why the identity of the E.Coli source of outbreak for the lettuce in question was kept confidential (in the case cited in the article & in other cases). These are LGMA growers and are supposed to be held to strict standards, which should include public awareness.  It is in the best interest of the public to know who these growers are so we can avoid their products if we so wish.

  • Will

    is the lettuce in el paso tx safe to eat?