“It’s been a road.” That’s how Jeff Miller, owner of Willie Green’s Organic Farm, a diversified 85-acre farm in western Washington, described the three-year process it took to get a “certified thumbs-up” for the strict food safety practices he has put into place for his salad greens and baby leaf spinach. In doing that, Miller is one of the first — if not the first — organic greens growers in the state to have earned the distinction of being able to sell his fresh greens as HACCP-certified. USDA describes HACCP, which stands for Hazard Analysis and Critical Control Points, as a production-control system — mandatory for meat, poultry and fish, among other foods, but voluntary for produce. As such, it is used to pinpoint the steps in food production where contamination can occur, and from there to craft a strict management, monitoring and verification system — every step of the way. For Miller, achieving HACCP certification for his washed, ready-to-eat salad mixes and baby spinach greens is good news not only for his farm but also for the many people who want to buy locally grown greens. That’s because he can now sell them to all of the Whole Foods stores in the Pacific Northwest, thus significantly expanding his customer base. “Our first truck of clam shell Salad Mix and Spinach went out this morning!” says a June 14 Facebook post accompanied by a picture of the jubilant farmer displaying a box of clam shell containers of his farm’s greens. “Look for it at Whole Foods! We are so excited!” The overall goal of HACCP is to prevent foodborne pathogens such as E. coli, Salmonella and noroviruses that can get people sick, or even kill them, from contaminating the food. This includes not only the processing the product but also the storing, packing and transportation of the product. However, for greens that will be eaten raw, such as in salads or on sandwiches, there is no “kill step” that can totally eliminate any pathogens that might be on them. In contrast, meat can be cooked and milk can be pasteurized to zap any pathogens that might be present. Since HACCP requires a great deal of due diligence to prevent produce from being contaminated in the first place, it is considered to be an important step forward for food safety when processing produce. An important foundation of HACCP certification is a program known as GAPs (Good Agricultural Practices), which requires strict adherence to food safety practices on the farm — from preparing the soil to planting to harvesting the crop. Miller acquired GAPs certification this spring. Like many smaller-scale farmers, Miller describes fresh-cut salad greens as an important part of his farm’s bottom line, primarily because they’re one of the first crops harvested, and also one of the last, thus giving the farmer the chance to sell them throughout the season. Those with greenhouses can often sell them year round. “Our business is based around them,” Miller said. Besides greens, he also grows about 50 varieties of fruits and vegetables. Learning from experience In 2008, an E. coli outbreak that sickened at least 13 people in Washington and Oregon, two of whom developed a condition that can lead to life-treatening kidney failure, was traced to spinach from Willie Green’s, according to a NEWS 21 article. That led Miller to make changes that focused on food safety and made it a top priority for his farm. “The outbreak happened,” he told NEWS 21. “You don’t want it to happen, but you do the best you can and improve and move forward.” From Whole Foods’ perspective For Whole Foods, Miller’s achievement in earning HACCP certification for his greens is especially good news because it lines up with the retailer’s goal of providing as much fresh, locally grown food as possible. “It’s a great fit for Whole Foods,” Susan Livingston, the chain’s Pacific Northwest marketing director told Food Safety News. “Our customers have been telling us for decades that they want to buy locally grown foods.” But sourcing locally grown foods often means that retailers and wholesalers need to set their sights on smaller-scale farms. And there comes the rub. Many of these farms can’t afford all the expenses that come with HACCP certification. Whole Foods has, for the past decade or so, required HACCP certification. “Our food safety standards are some of the most stringent in the industry, especially since so much of our food is sourced locally,” said Livingston. At the same time, Whole Foods recognizes that for many smaller-scale farms such as Willie Green’s, HACCP certification takes more than a desire to do it. It also takes a lot of time to make sure the proper food safety practices are being followed day after day — not to mention a lot of money. For that reason, Whole Foods granted Willie Green’s two loans through its Local Producer Loan Program. With the first loan, Miller put in 5 greenhouses so he could extend his growing season. He used the second loan to construct a processing plant, which he describes as “a quarter-of-a-million-dollar project.” “Without the backing of Whole Foods, none of this would have happened,” he said. Whole Foods’ regional forager Denise Breyley, who worked with Miller for the past 3 years on achieving HACCP certification, said that while smaller-scale farmers such as Miller have other outlets, among them farmers markets and farm stands, earning HACCP certification allows Willie Green’s to sell to larger buyers. “Food safety of produce is really important,” Breyley said. “It’s something all growers should be focusing on. I’m not sure how aware the public is about food safety. Many people think about it when they think about meat, but it’s also important for produce.” That’s especially true for fresh leafy greens. While they are praised by doctors and public health agencies alike for being nutritional powerhouses, a report done for the U.S. Centers of Disease Control and Prevention puts them at the very top of the list of the 10 riskiest FDA-regulated foods. One reason for that is that when a leafy green is cut, nutrients start oozing out of that cut. If there are any foodborne pathogens on the leaf, they’ll migrate toward those nutrients and hang on tight. And though washing the greens might dislodge some of the pathogens, it won’t dislodge all of them because those cuts can open up the a path for microbial invasions of the plant’s tissues. For the same reason, chemical sanitizers do only a marginal job of killing the pathogens. If, however, there are no pathogens on the leaves, none of this will happen, which is why following food safety standards, as required under Good Agricultural Practices and HACCP, is so important. The possible risks associated with fresh leafy greens was illustrated in a tragic way in 2006 when an E. coli outbreak linked to raw spinach grown in California caused 3 deaths and 199 illnesses, including 102 hospitalizations. That “wake-up call” — both to the public and to the industry — led to the formation in 2007 of the California Leafy Greens Marketing Agreement, which requires the approximately 350 greens growers in California who sell to the major greens shippers in California to follow validated food safety practices. (These shippers —more than 100 of them — are members of the marketing agreement and account for about 99 percent of the volume of California leafy greens.) Shortly after the formation of the California LGMA, handlers and growers in Arizona formed the Arizona LGMA to regulate leafy greens grown in that state. The emphasis is on farming practices, said Scott Horsfall, CEO of the California LGMA, because FDA was already requiring HACCP-like practices to be followed in processing plants. What are processed fresh leafy greens? According to FDA, fresh leafy greens are those whose leaves have been cut, shredded, sliced, chopped or torn. As such, “leafy greens” can include iceberg lettuce, romaine lettuce, leaf lettuce, butter lettuce, baby leaf lettuce (i.e., immature lettuce or leafy greens), escarole, endive, spring mix, spinach, cabbage, kale, arugula and chard. The term “leafy greens” does not include herbs such as cilantro or parsley. An explanation of the difference between greens that are considered a “raw agricultural product” and those that are considered a “processed product” can be found in Food Safety News’ article Two Sides of the Coin for Food Safety of Cut Leafy Greens. Costs of HACCP When talking about some of the expenses associated with HACCP certification, Miller said he had to hire two people full-time to craft the farm’s Good Agricultural Practices and the HACCP plan, as well as to pass the audits. HACCP requires third-party audits that include monitoring and testing to make sure the proper food safety strategies are being followed. “The goal of HACCP is to minimize risk, and you have to put measures into place to do that,” Miller said. Documentation is key, he said, citing monthly testing of the water used in the plant as an example. And even something as simple as changing a light bulb needs to be documented and done according to standard operating procedures as outlined in the HACCP plan. Food safety doesn’t stop at the plant, either. To keep the greens cool once they leave premises, Miller has to hire a trucking firm to deliver them to Whole Foods. When asked where the critical “danger points” are in his operation, he quickly said that it’s the entire chain — from planting to harvesting to processing to transportation. “Anything that’s broken in that chain can cause problems,” he said. As challenging and expensive as all of this may be, HACCP does come with some flexibility, said Miller, explaining that there are no hard, fast rules for HACCP certification. “You write your own plan to minimize risks,” he said. “You explain what you’re doing.” Primus Labs uses a point system when conducting the audits, and while some discrepancies lead to a loss of points, some lead to automatic failures. Body condoms The workers are an important part of HACCP. Miller said his employees go through training and, when in the plant, wear sterilized boots, gloves, aprons and other clothing to make sure they can’t inadvertently contaminate the greens. “It’s like a ‘body condom,’” Miller said, describing the employees’ uniforms. In addition, boot-washing stations are set up inside and outside the plant — with sanitized mats placed in locations throughout the facility. “There are all kinds of points that can introduce contamination,” Miller said. When all is said and done, Miller said, it comes down to creating a culture that embraces food safety. And that starts at the top and trickles down to the employees. “As the owner, I can’t come into the plant without sanitized boots and gloves,” he said. “It has to be ingrained in the culture. It has to be second nature for all of us. It’s a different way of doing business. You have to set expectations and demand accountability. There’s too much at risk not to do that.” And, yes, there can be resistance on the part of the employees, and even the owners. “Fifteen years ago, I would have resisted,” he said. “But now, anyone resisting will be left behind.” Is it worth it? Miller said that obtaining HACCP certification for his greens does pencil out, although no one knows what the future might bring. According to a HACCP feasibility report focusing on leafy greens, HACCP certification for salad greens is expensive and challenging to do. But Kristen Wilmer, a CISA staff member, said people who want to sell to wholesalers are undoubtedly moving in that direction. What’s coming down the road Miller predicts that it won’t be long before all retail buyers will require farmers and processors to show that they’re adhering to strict food safety standards. Not only that, he said, but once the provisions of the Food Safety Modernization Act go into force, the regulators will require farmers and processors to go a step beyond Good Agricultural Practices and HACCP. “And that will probably put a lot of small farmers out of business,” he said. “It’s going to change the entire landscape of food production.” But beyond demands made upon farmers by retailers and regulators, there’s also this reality: “I don’t think any farmer wants to get people sick,” Miller said. Scott Horsfall, CEO of the California Leafy Greens Marketing Agreement, agrees with Miller that once the Food Safety Modernization Act goes into place, there will be demands on almost everyone. He also pointed out that “no matter what size a farm is, it’s important to have food safety practices in place.” “I applaud those who are already doing it,” he said, referring to Miller and other smaller-scale farmers who are taking the necessary steps. For Miller, it’s a matter of being realistic about the future of his farm. “I wanted to be ahead of the curve,” he said. “I saw the writing on the wall.” Editor’s note: This article has been updated to include information about the 2008 E. coli outbreak in Washington and Oregon linked to Willie Green’s.