The nation’s only produce surveillance program did not survive the first term of the Obama administration. When it did exist, USDA’s Microbiological Data Program (MDP) used to conduct 80 percent of all federal produce testing for foodborne pathogens.

The program paid labs at Land Grant universities to test local produce as it came out of the ground. The national budget for the MDP did not top $5 million, a hardly noticeable amount in Washington D.C.

But from the moment it began during the first Bush administration, the fresh produce lobby wanted the MDP dead. It was too successful, working as a “tripwire,” interrupting fresh produce distributions whenever dangerous pathogens were discovered.

Fresh produce works fast, moving from the field to your dinner plate in only a matter of days, and sometimes hours. Anything that interrupts that fast flow is a problem for the industry.

So if the little MDP was too much for the fresh produce industry to bear, you can imagine the hurt Canada is imposing, at least on a temporary basis, on California’s Salinas Valley, according to leafy greens growers there.

Starting Oct. 7 and continuing at least through Dec. 31, shipments of romaine lettuce grown in the Salinas Valley must be tested For E. coli O157:H7 before Canada will accept them as imports.

The Packer, a fresh produce industry newspaper, reports the added food safety compliance costs would add $1 to $2 per carton to producer costs.

Importers must either prove that romaine being imported to Canada is not from Santa Cruz, Santa Clara, San Benito, or Monterey counties, or else provide certificates of analysis from an accredited laboratory that confirms the lettuce has below-detectable levels of E. coli before it is distributed in Canada.

Testing can be accomplished in the U.S. or Canada so long as the lab is accredited.

The reoccurring E. coli outbreaks, prior to 2020, are the reason for Canada’s cautionary approach for the current import season.

Canada produce suppliers are attempting to source romaine from outside the Salinas Valley, known as “America’s salad bowl.”  Once local lettuce grown in Canada is no longer available, therefore some suppliers will have no choice but to obtain products from California.

“We are trying to understand (the import requirements) to make sure that we’re in compliance with the regulations, and we’re talking to the shippers and seeing what they think about it,”  Van Whole Produce Ltd.’s Leonard Jang told The Packer.  

Jang said the receiver likely will want E. coli testing done at the shipping point, not in Canada. That’s because if it fails the test in Canada, the disposal costs would fall on the supplier. And, adding to industry frustration, all testing will likely add two additional days of cold storage costs.

Import requirements for U.S. romaine are now being continuously updated by the Arizona and California Leafy Green Marketing Agreements, the Canadian Horticultural Council, the Canadian Produce Marketing Association, the Produce Marketing Association in the U.S., the United Fresh Produce Association, and Western Growers.

They are also wondering what is going to happen at the next seasonal transition when romaine harvests move from Salinas to the desert growing regions.

“I think the concern is that if this is a precedent set by the Canadian government and the way that they want to manage romaine from a longer-term standpoint, then there will be an economic impact,” Western Growers’ De Ann Davis, also told The Packer. “People will be more conservative in planting and it will impact trade.” 

Canada’s requirements are very difficult to comply with, according to Scott Horsfall, CEO of the California LGMA.  He fears the temporary rules could become precedents for other commodities.

“The imposition of this type of requirement at the last minute is really problematic,” he said. Canada’s post-harvest E. coli testing requirement hasn’t proven to be an effective way to protect consumers in the past. 

Horsfall said it is not possible to “test your way to food safety.” He pointed out the importance of preventive measures on the farm and in processing facilities.

“I think the hope is that, through discussions and through collaboration with the two governments, that something a little more reasonable can be accomplished,”  Horsfall said. He predicts romaine shipments to Canada during the next couple of months will be on the decline.

Declines of $11 to $13 million a week are predicted for California romaine shipments to Canada over the several weeks

The U.S. Food and Drug Administration is reportedly in talks with the Canadian Food Inspection Association about the future of the testing requirement. Industry representatives on both sides of the border are tracking those negotiations.

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