Hundreds of audits of California leafy greens operations during the 2015-2016 season found 99.5-percent compliance with industry food safety standards, according to the latest annual report from the Sacramento-based California Leafy Greens Products Handler Marketing Agreement (LGMA).

LGMA reported there were 470 announced and unannounced audits during last year and this year of its approximately 100 members, known as handlers, and that 385 citations of various types were handed out.

These audits are mandatory for LGMA members, who are audited an average of five times each year, with 185 checkpoints per audit.

On average, there were about 0.8 citations issued per audit. By category and percentage, they were given out for:

• Field Observations, 34 percent;
• Water Use, 26 percent;
• Worker Practices, 15 percent;
• Field Sanitation, 12 percent;
• Soil Amendments, 5 percent;
• Environmental Assessments, 4 percent; and
• General Requirements, 4 percent.

“For the past two years the average has been less than 1 citation per audit of an LGMA member,” according to Ron Ratto, president of Ratto Bros. Fresh Produce Inc. of Modesto, CA, and chairman of the LGMA advisory board.

Because the group already adopted and implemented food safety practices similar to federal requirements under the Food Safety Modernization Act’s (FSMA) Produce Safety Rule, Ratto added that “the leafy greens industry has had a nine-year head start on the new laws.”

A LGMA audit is based on seven categories of the group’s accepted food safety practices, which are called the LGMA Metrics.

For example, under the General Requirements category, handlers must meet specific requirements related to food safety management, including having a written compliance plan, a current list of growers, a documented traceability program, and two designated people available at any time to oversee the food safety program.

Ratto noted in the annual report that LGMA had a third-party review of the metrics done in 2015 by four nationally known food safety scientists. These reviewers found the metrics to be scientifically valid and to incorporate most current best practices, he stated.

“They also confirmed that the LGMA Metrics appear to meet or exceed the requirements of the new federal Produce Rule,” he said in the report.

The audit process Field inspections and audits of LGMA handlers in the Golden State are done by six or seven people from the California Department of Food and Agriculture (CDFA) who are licensed by the U.S. Department of Agriculture.

Steve Patton, chief of CFDA’s Inspection and Compliance Branch, said these auditors use the LGMA Metrics as a checklist when they visit leafy greens operations throughout the state.

“We go through and look at various things on the farm, but we are not a consulting service,” Patton said. “They (LGMA) take care of the compliance end, with the exception that if we find an immediate public health risk, we would contact the Department of Health.”

Once the CDFA auditors finish their ground-level work, the information is reviewed by LGMA for potential citations and follow-up training.

“They go out and make observations in the field with the handlers on paperwork and things and they send me their observations, and I determine whether their observations are in line with the metrics,” explained Jonathan Field, LGMA’s compliance officer.

Field can elevate an audit finding from a “Minor Infraction” to a “Minor Deviation” when a problem indicates that specific training is needed. He gave the example of when the auditors show up and the workers have pencils, gloves, or cell phones in their pockets, things which are typically not allowed when a crew is in the field harvesting produce.

“They find an employee with pencils in his pockets, so food safety comes and takes the pencils out and it’s done,” he said. “But why did that person have pencils in his pockets? Who was responsible for checking crews to make sure they don’t have pencils in their pockets? Are they being trained?”

Field said that a more effective approach would be to stop the harvest, call the crew together, and note that the company’s standard operating procedures say that no employee can have anything in their pockets while working in the field.

“Then, in a week or a few days later, when the crews come to harvest, the food safety person comes out and they do training about what is allowed in the field and in the pockets. Then there is a document available with the signatures of all the employees who took the training,” he said.

If they choose, LGMA handlers can adopt higher safety standards for their operation than the established metrics, Field said, but that means they are responsible for meeting their own higher standards during an audit.

“The metrics are the standard by which the industry is measured, so you have to adhere to those standards,” he said. “Your company can be higher, but when the auditors go out and check levels, you could be OK with the metrics but be out of compliance with your own standard operating procedure.”

LGMA recently produced a video of Field explaining how the group’s inspection and compliance program works.

Four citation categories Possible LGMA citations are grouped into these four categories:

• Flagrant Violation: A violation that significantly increased the risk of delivering unsafe product into commerce. Penalties can range from temporary to permanent decertification.
• Major Deviation: Does not necessarily result in unsafe product. Corrective action must be provided within five days. This citation can be elevated to the Flagrant level if not corrected.
• Minor Deviation: Does not necessarily result in unsafe product. Corrective action must be provided within five days. Multiple violations of the same type within a year may raise the citation level to a Major Deviation.
• Minor Infraction: Does not necessarily increase the risk of unsafe product. Corrective action can be taken before the auditor leaves the premises. Multiple violations will lead to a Minor Deviation.

The 2015-2016 annual report indicates there were no Flagrant Violations cited during that period, although there were 13 Major Deviations, 239 Minor Deviations, and 133 Minor Infractions.

One Major Deviation in the Environmental Assessment category involved a field close to an equestrian center. According to the annual report, the LGMA handler worked with the owners to make sure that any manure on their premises was moved to an appropriate distance from the leafy greens field.

In the Field Observations category, a Major Deviation was noted because a worker was seen eating lettuce in a part of a field under active harvest. The report states that the worker was reprimanded and temporarily suspended, the crew retrained on the issue, and the company foreman instructed to remind the crew prior to each day’s harvest that eating in the field is not allowed.

LGMA’s enhanced focus on training is designed to make sure the group’s members don’t become complacent, particularly about less serious infractions.

As stated on the LGMA website, “So rather than allowing minor corrections to continue being made in the field during an audit, we wanted handlers to go back and train people not to make these same mistakes again.

“We know that training can make a big difference in how leafy greens workers comply with required food safety practices as it helps ingrain the proper procedures into their everyday work habits.”

Complying with FSMA Field called California’s food safety programs “probably a step ahead from the rest of the country” due to the focus on training and compliance and ongoing efforts to encourage employees to take responsibility for helping to provide safe products.

“LGMA has made a very strong effort to work with FSMA and with the government to make sure that we were going to comply with what they needed,” he said. “The leafy greens industry in California is very confident that they will comply with FSMA and, in most cases, exceed the requirements of FSMA.”

From his state agency-level perspective, Patton said he is in “complete agreement” with that assessment.

“They are head and shoulders above other industries simply because they put themselves there,” he said. “LGMA has done a great job of getting information and training out to their members, and it’s working. There really has been a success story.”

The California Leafy Greens Products Handler Marketing Agreement was formed one year after the 2006 E. coli outbreak linked to Dole bagged baby spinach produced in the Salinas Valley. According to the U.S. Centers for Disease Control and Prevention, 199 people from 26 states were infected with the outbreak strain, 102 were hospitalized, 31 developed hemolytic uremic syndrome, and three people died.

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