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There’s a revolution going on in a grocery store near you. Fueled by consumer demand, it has been dubbed the “fresh revolution” by industry heavyweights such as the United Fresh Produce Association. It’s all about fresh produce — fruits and vegetables that nutritionists are praising as “healthy foods” and that shoppers are increasingly seeking out. “The exploding world of fresh foods at retail,” is the way United Fresh describes it in a news release about its annual conference and trade show set for June 20-22 in Chicago. FamilyFarmed-workshop-graphic That’s good news for many small- and medium-sized farms simply because of their proximity to stores and restaurants in their areas. They can offer fresher produce to those businesses because it doesn’t have to be transported long distances. Generally, the closer the source, the fresher the food. But there’s more to it than food miles. Retailers want food not only to be of the highest quality, but also to be free of foodborne pathogens such as E. coli, Listeria and Salmonella. They can’t risk their reputation by buying produce from a farm, regardless of size, just because it’s close by. The numbers serve as a wake-up call. More than 70 percent of U.S. consumers are concerned about food safety, according to the International Food Information Council Foundation’s 2014 Food and Health Survey. And 40 percent switched their choices of food based on food safety issues. Numbers also show the depth of the challenge for produce growers and shippers. The Centers for Disease Control and Prevention estimates that produce is the leading cause of food-related illnesses and attributes 46 percent of food contamination problems in the U.S. to produce. Clearly, small- and medium-scale farmers who want to achieve wholesale success have their work cut out for them. A variety of sources of information and training geared specifically to small- and mid-sized farms is available. That availability is expected to increase now that the Food and Drug Administration has published final rules for produce and other foods, as mandated by the Food Safety Modernization Act. One recent example of the training sessions designed for smaller operations was “Wholesale Success: Post Harvest Handling & Food Safety,” presented by organic farmer and food safety trainer Atina Diffley and FamilyFarmed. The event earlier this month at the research center at Washington State University in Mount Vernon was one of a series of workshops scheduled in 29 cities. A grant from the U.S.Department of Agriculture’s Risk Management Agency is helping to pay for the workshops.

Atina Diffley
Atina Diffley
Down to earth … literally As a Midwest farmer, Diffley knows her way around the agricultural block, including planting, harvesting, packing and selling from her personal experiences in Minnesota. Her goal is to share what she has learned about food safety with small- and mid-sized farmers in a practical way that’s relevant to their own farms. An important part of the equation is profitability, she said. “You’re competing with the bigger farms,” she told the farmers attending her workshop. “You’ve got to come up with a way to stay in business.” In describing the training she provides, Diffley said how farmers handle their products affects the food’s safety and therefore their relationships with buyers, who increasingly expect farmers to be proactive. Pointing to the pride in ownership that farmers have in the food they produce, Diffley said that farmers need to keep in mind “it isn’t only our food,” but that they’re food handlers growing someone else’s food. “No matter what size the farm or its financial position, food safety must be attended to,” Diffley said. The good news is that having a “food safety mindset” doesn’t necessarily mean you have to hire extra staff or buy expensive state-of-the-art equipment. Keep it, “scale appropriate” and “cost-effective” was Diffley’s first-hand advice. Make a habit of record-keeping Food safety shouldn’t be thought of as a separate job, said Diffley, but something to be integrated into the farm’s day-to-day activities. For example, no need to keep separate duplicate records for food safety; they can be part of a farm’s overall records. A practical application of that concept would be to use a crop progress check as an opportunity to document food safety efforts. During a trip to a field to check on how soon and how large harvest will be, a farmer can add food safety items to the field checklist, such as checking for animal activity among the produce and documenting action taken. Should there be a signs such as animal droppings or bird nests, the farmer can pull out some red flags and pop them in the soil 5 feet in every direction from the activity. That lets field pickers know not to harvest produce that may have been contaminated. Woman-farm-worker-at-white-board Another strategy Diffley recommends combines work organization, staff communication and accountability, and record keeping. White boards, for example, can be used in work areas to communicate with employees and track daily activities. As workers complete tasks, they add information. The main categories can be marked on the boards with permanent marker, whereas the daily information in the columns can be entered with an erasable marker. At the end of the day when the columns have been filled in, the farmer or farm manager can take digital photos of the white boards and download them into dated files that can be referred to in case there’s a problem with food safety. A swipe of the eraser, and the boards and their headers are ready for the next day. And, yes, record keeping is essential. In fact, Diffley refers to record keeping as the most profitable activity on a farm. And for good reason. Many good reasons, actually. To begin with, many of the records farmers keep help them make good decisions about all sorts of activities on the farm, during the current season and future seasons. And when it comes to food safety, those records will provide valuable information in the event a farm’s food is linked to a foodborne illness. In short, says Diffley, “record keeping must be a habit.” But, she stressed, it doesn’t have to be a headache. Farmer-photographing-white-board-records Keep it practical Diffley provided workshop attendees with straightforward templates to use when designing their own Harvest, Postharvest, Transportation and Equipment, and Sanitation Action Plan. Complete with columns, the templates’ headers use easy-to-understand phrases instead of government jargon to document food safety activities such as:

  • “What policies are being followed to reduce risk”
  • “How this is done”
  • “Who’s required to do this”
  • “When is it done”
  • “When training is done”
  • “Who, When and What records are kept for these actions”

The templates are based on good agricultural practices (GAPs) and the Food Safety Modernization Act’s Produce Rule. They can be downloaded to help growers develop a food safety system and implementation action plan. “There are no rules requiring specific formats for food safety plans,” Diffley said. “The important thing is that plans are relevant to your farm and that they are implemented. Use a system that works for you.” Diffley said the templates can be used to create final Food Safety Action Plans or to as pre-work for the FamilyFarmed food safety question tree. The On-Farm Food Safety Plan Tool, developed by FamilyFarmed.org, is a free, web-based resource for developing a farm’s Food Safety Plan. Such plans must be specific to each individual farm. This tool takes farmers through a series of questions, collects information and generates a customized on-farm Food Safety Plan based on user input. The tool is designed for use by small- to mid-scale growers, is available in Spanish and English, and includes a full set of record keeping tools to document food safety programs. There is also a sample plan to review for ideas. As for legal challenges pertaining to food safety, Diffley shared this warning: “If your actions aren’t documented there’s no way to verify that you’ve done them. And if you have a product liability policy and you can’t prove you weren’t negligent, the insurance company might not be able to insure your product. Also, food-safety auditors require record keeping that documents you’ve done what your plan says you will do.” Another thing for farmers to keep in mind is that one of the tools of the Food Safety Modernization Act is expanded access to farmers’ records. Washing produce: Keep it safe Diffley dove into the issue of water use on farms, starting with the quality of the water that should be used to clean veggies and fruits, as required by the Food Safety Modernization Act. Pure and simple, it needs to be very clean. “Potable” is the word for it. More specifically, water used for cleaning produce must have no detectable generic E. coli per 100 mL sample. In addition to direct contact with produce that is covered under the Food Safety Modernization Act, which for the most part is produce that will be eaten raw, the rule also applies to water coming into contact with surfaces after harvest, water used to make ice, and water used for hand washing after harvest. Untreated surface water may not be used for any of these purposes. Production systems that keep the crop as clean as possible during growing and harvesting are part of a strategic system, Diffley said. “Research shows that once pathogens are on produce it can be impossible to wash them off,” she said. “The best practice is to prevent contamination.” “Keep it clean in the fields,” she said, pointing to an example of growing a living mulch of millet between rows of strawberries to reduce the berries’ exposure to the soil. For some crops such as tomatoes, trellising to keep them off the soil and harvesting them when they’re dry can be effective and can help farmers minimize the need to wash them. soil-shovel-406 “You need to manage cut produce surfaces contacting soil and water on your farm,” she said. “Farmers are so comfortable with soil — it can be a new concept to think of the soil the food grows in as a potential source of contamination. “It helps to remember that while produce is being grown there are not generally cut cells. Then at harvest, that changes and it becomes easier for pathogen microbes to enter or adhere to the produce.” Diffley said farming operations of all sizes are moving away from using dunk tanks. “Wash systems need to be evaluated for food safety,” she said. “Dunk tanks can be one of the most risky practices on farms.” For farmers currently using dunk tanks, she suggested they think through the “why” of the dunk-tank process. “People used dunk tanks to clean, cool, and/or crisp fresh produce,” she said. “Systems to accomplish these goals without dunking can be (used).” Especially risky are produce crops that are “very dirty” such as root crops. They shouldn’t be washed in dunk tanks, simply because there’s too much dirt on them. “It’s too high risk,” she said. cantaloupe-wash-line There are other options, for example a spray-washing table or a rotating barrel-washer. Diffley recognizes that some growers still use dunk tanks. “Before putting food in a dunk tank, get the majority of the soil off,” she said, pointing out that any dirt or unwanted matter on the produce can transfer into the water and cross contaminate with pathogens. “Most of the cleaning should be done before the crop is put into the dunk tank.” She also said that while research on triple washing cut greens has shown it does a good job of cleaning them, it should not be interpreted to mean that pathogens can be washed off of the greens. Immersing greens in water can be a high-risk activity. If one leaf is contaminated, the water can carry pathogens to other leaves, or be imbibed internally. And she reminded the farmers that anyone washing the produce should be wearing clean clothing, or if they’re coming in from the field, aprons over their work clothes. And they must have washed their hands with clean water. While it’s important to use a water sanitizer, Diffley told the group that it’s also important to keep in mind that “you’re treating the water not the food.” When talking about sanitizers, she said that hydrogen peroxide based formulations have some benefits that chlorine doesn’t. For example, it leaves no taste residue, there’s no need to test the pH of the water, it can be effective longer than chlorine, and can be less affected by organic matter.  Also, they may provide the benefit of managing decay organisms. Some formulations such as Sandiate 5.0 and StorOx 2.0 are approved by the National Organic Program. Farmers using chlorine, which Diffley said is harder on equipment than hydrogen peroxide based products, can find helpful information on the University of California-Davis food safety website. As for water temperature management, Diffley has links on her website to crop specific research and guidelines for water use with cantaloupes, tomatoes and mangoes. Cooling produce: Keep it safe “Immediately removing field heat is key to maximizing shelf life,” Diffley said. “Farmers need to cool produce to ideal storage temperature.” The need to quickly cool produce to storage temperatures can be reduced by harvesting in early morning to minimize field heat. Produce can be cooled in forced air coolers or by using portable cold vehicles in the field. If produce is cooled quickly, moisture levels can be managed at the production stage and maintained after harvest by slowing respiration with quick cooling and with humidity management. Simply placing produce into a cold storage room is generally too slow for high-respiration crops with field heat in them, which is why many farms use forced-air systems for quick cooling. “In a forced air system you’re pulling out the heat, rather than blowing cold air in,” Diffley said. Before forced-air technology, many wholesale requirements called for packing certain crops in ice, which caused food safety issues. However, ice can be useful to small farms that often lack refrigerated delivery vehicles or sell in settings without electrified cold displays, such as farmers markets. “Ice can make a really big difference in keeping produce fresh,” she said. “Ice machines are expensive new, but can often be found used at bargain prices.” Water used to make ice must be potable, and the machine and scoop needs to be washed and sanitized. “You want to be sure you address food safety right from the start,” she said, pointing out that you don’t want to stack iced produce where it can drip down on other produce. Storage and transportation If you don’t have a refrigerated delivery vehicle, at a minimum, insulate your vehicle, advised Diffley. If produce is cooled before loading and covered with clean and sanitary insulating material, vehicles are insulated, and delivery times are scheduled during the cool of the day, delivery can be made without produce warming up excessively. Whatever system is used, said Diffley, temperatures readings should be documented for different parts of coolers and vehicles. Automatic digital data recorders are available for about $30. How to prevent back flow Diffley emphasized the importance of preventing contaminated water from back flowing into wells from dunk tanks or chemical tanks. “Hose ends should not be inserted into the water in dunk tanks or chemical spray tanks,” she said. “Garden hoses can harbor and breed bacteria. Every single faucet should have a back-flow preventer.” She urges farmers putting in new systems to install back-flow preventers in line between hydrants and wells. Co-management of food safety and conservation practices Diffley said food safety requirements and conservation practices are not mutually exclusive. She pointed out that the Produce Rule does not require farms to exclude wildlife from outdoor growing areas, to destroy wildlife habitat, or to clear borders around growing or drainage areas. Even so, because wild life could create food safety risks, measures should be taken to minimize wildlife incursions into growing fields. However, removing conservation habitat can be not only environmentally damaging, it can increase food safety risks. “There can be many food safety benefits to co-management,” she said. UC-Davis researchers, for example, found that wetlands or several meters of grass can filter up to 99 percent of E coli during rain events. Other research includes a study pointing to the importance of biological diversity — a reduction in rodent species diversity may cause increased pathogen prevalence in the individuals that remain, and biodiversity loss frequently increases disease transmission. Diffley said farmers should map the sources of potential contamination and then identify how pathogens can be moved on to produce, such as in water or with wind, or on equipment or people. She also discussed the impact of sunlight and UV light on microbe survival and reproduction. Using Wild Farm Alliance materials can help farmers co-manage to minimize the chance that their produce could get contaminated while protecting natural resources and habitats.

Rob Smith
Rob Smith
Farmers’ comments Susan Schuh, co-owner with her husband Steve of Schuh Farms, a 300-acre farm near Mount Vernon, WA, said she attended Diffley’s training session because the safety of her produce has always been important to her. “We don’t want to get people sick,” she said. “We know we have to be careful about it. I’m here so I can learn more about it and write a food safety plan.” Although the farm uses city water, which is potable, she said she was surprised to learn that washing produce can pose a problem. Rob Smith, operations director of Viva Farms near Burlington, WA, said that food safety is an important part of doing business as a farm. “It’s gone from the realm that a farm probably should do a food safety plan to that a farm definitely needs to,” he said. “That’s a big shift.”
Matthew Aamot
Matthew Aamot
Matthew Aamot, who currently works with Growing Washington, a farming operation that will be doing some wholesaling, is also starting his own farm, Kickerville Community Farm, in northwest Washington. “Food safety is truly more important than it ever has been,” he said. “You don’t want to comply with the law at the last minute. What we do now is important so that we’re ready. Ships don’t turn on a dime.” (To sign up for a free subscription to Food Safety News, click here.)

Since 2010, there have been waves of bills involving food and food safety washing through state capitals on subjects such as cottage foods, agricultural security, raw milk, and labeling food products containing genetically modified ingredients. The 2015 legislative sessions underway in 47 of the 50 states are different. In this second part of our look at what’s happening in the states, we find that the waves have crashed. Food and food safety are getting spotty interest, but legislators appear to be off doing other things, especially spending newly found money fueling state budgets. However, we do find: In Iowa, a raw milk bill failed to pass out of a subcommittee and cannot move forward as a standalone bill. House File 209 is not officially dead, but pretty close. Its language could be amended into other bills involving related subjects. Since it has not been reassigned to any other subcommittee, it’s on life support. Opposition turned out in force for the first subcommittee action. A Montana raw milk bill waiting for a vote on the floor of the House of Representatives would allow retail sales limited to small herds, but before it was allowed out of committee, liability for any deaths or injuries caused by the product was shifted to the consumer. A House vote was expected this week after House Bill 245 passed out of the Human Services Committee on a 14-3 vote Feb. 11. However, it has not been brought up yet. State Rep. Nancy Ballance (R-Hamilton) says the raw milk bill isn’t everything she wanted. She also says that raw milk is “not the scary product it was 50 years ago.” The U.S. Centers for Disease Control (CDC) recently reported that more illnesses and outbreaks are occurring as a direct result of state legislative decisions to loosen up on raw milk regulation. An animal cruelty bill patterned after Missouri’s has also been introduced in Montana to require reporting to appropriate law enforcement within 24 hours of any evidence of abuse. Senate Bill 285 is clearly aimed at animal rights groups that collect video or pictures for release when investigations are completed. State Sen. Eric Moore (R-Miles City) says that anyone collecting such evidence should report it immediately and not hold onto it “for political purposes.” In Nevada, lawmakers in Carson City get the first chance to decide on a voter-approved initiative to legalize recreational marijuana. If the legislature approves the initiative in the first 40 legislative days, it immediately become law. If not, it goes to the 2016 ballot for voters to decide. Tilapia and striped sea bass would be added to the list of of fish regulated by the New Mexico Department of Game & Fish if House Bill 201 makes it to the governor’s desk. The bill is a result of the aquaponics boom in the state. Department regulators, however, are concerned about tilapia getting into the waterways since it’s an invasive species. The bill would give the department authority to make sure that those farming fish get a permit and do not put the fish into waterways. North Dakota’s 80-year-old anti-corporate farming law may get some surgery this session to exempt dairy and pork operations that are no larger than 640 acres. “We cannot afford to ignore and do nothing about this issue,” Sen. Terry Wanzek (R-Jamestown) told the Senate Agriculture Committee. “Doing nothing is not an option.” Wanzek’s legislation would allow non-family farm corporations to own or lease agriculture land, as long as the operations don’t take up more than 640 acres of land, or a square mile. He says the changes are needed to help the state’s dying dairy industry and declining swine industry. Virginia Governor Terry McAuliffe has received a bill from the General Assembly that would reform the Alcoholic Beverage Control Board to bring about better prices, selection, and store choice. The Senate followed the House in unanimously passing identical bills, sponsored by Delegate David B. Albo (R-Fairfax) and Sen. Ryan T. McDougle (R-Hanover), to turn the board into an authority. It would take effect in 2018, setting minimum job qualifications for board members and the chief executive in an effort to reduce the political nature of the jobs, which command yearly salaries of more than $100,000, plus benefits. A so-called “ag-gag” bill in Washington state has gone nowhere since it was introduced for a quick public hearing. And in Wisconsin, rumors about the introduction of an “ag-gag” bill have yet to become reality after a month of noise over the issue. State Rep. Lee Nerison (R-Westby) promised to introduce such a bill, but he has not yet done so. “Ag-gag” is the name animal rights activists and some journalists use to describe laws that prevent collecting photographic evidence on private farms or ranches using an undercover identity. Wyoming’s “Food Freedom Bill” made the Senate’s “general file,” meaning that it could be heard anytime by the Committee of the Whole, the final hurdle before a possible final floor vote. House Bill 56 is popular with Wyoming lawmakers this year, while newspaper editorial writers are urging its defeat. (Editor’s note: This is Part 2 of a two-part story on current state legislation related to food safety. Part 1 can be found here.)

The humane treatment of farm animals won a huge public show of support last month when Starbucks announced plans to require dairy, meat, and egg products served in its coffee shops to come from suppliers that follow certain animal-welfare standards. For the coffee giant’s customers, the take-home message comes down to this: When you sip on your favorite brew or dine on breakfast, lunch and pastry items at Starbucks, you’ll know that the animals that provided the ingredients for those products were treated humanely. “Just as with our coffee, Starbucks goal is for everything we sell to be produced under high quality and ethical standards,” states the company announcement. “For the food and dairy we serve, this means a commitment to social responsibility standards with animal welfare as a primary focus. We are committed to working with and buying from farmers and suppliers who share our commitment to humane practices throughout an animal’s lifecycle.” The company acknowledges that, due to the complexity of agriculture and the many puzzle pieces involved in sourcing the products, this won’t happen overnight. It also does not supply any dates about when this policy, or parts of it, will go into place. “We’re working with the industry on creating reasonable timeframes,” notes the company’s announcement. Even so, the company points out that it has “significantly expanded” its cage-free egg offerings since 2008, increasing its purchases year over year, and that it is committed to continuing to do so. On Jan. 1, California, the fifth-largest egg-producing state in the United States, banned the production and sale of eggs from hens kept in extreme confinement (cages). Many of the approximately 280 million hens that supply eggs to U.S. customers live in cages so small they can’t even spread their wings. This also denies them the ability to follow natural behaviors such as perching at night, nesting, or dust bathing. Referring to the Starbucks announcement, Wayne Pacelle, president and CEO of The Humane Society of the United States (HSUS), wrote on his blog, “A Humane Nation,” that “this may be the most comprehensive animal-welfare policy of any national restaurant chain, because it will include both shell and liquid eggs, which are used in its pastries that are sold in such volume.” The Humane Society worked with Starbucks on its animal-welfare goals. (Despite repeated phone calls and emails to Starbucks, the company did not directly respond to Food Safety News.) How will it happen? Here are the steps Starbucks will be asking its suppliers to take, with the goal of improving the way farm animals are treated:

  • Supporting responsible use of antibiotics to support animal health. (In other words, not relying on antibiotics to prevent diseases in animals that are raised in overcrowded, and sometimes filthy, quarters, but instead to provide the animals with clean, healthy living conditions.)
  • Eliminating the use of artificial growth hormones, and, in the case of poultry, fast-growing practices. (Reacting to customer concerns, many large dairy producers have already stopped administering artificial growth hormones to their animals.)
  • Addressing concerns related to dehorning, tail docking, and castration, both with and without anesthesia.
  • Phasing out gestation crates for pigs and cages for chickens.

In the case of gestation crates, pregnant pigs spend almost all of each pregnancy in them. (A pig is pregnant for about 114 days.) According to Farm Sanctuary, the crates are only slightly larger than the pig’s body, which makes it difficult for them to lie down comfortably or to turn around. Several large pork-producing companies, such as Smithfield, Cargill and Hormel, have announced plans to phase out gestation crates in their own pork-production facilities. And, in September 2014, the parent company of Hatfield Quality Meats, the 16th-largest pork producer in the U.S., went one step further when it announced that it would move all the pigs it owns to group housing by 2017 and would demand the same of its contract and independent farmers by 2022. According to the company’s website, this shift to “free-to-roam housing” is based on its “diligent review of sound research and our ongoing commitment to give the best care to our animals.” Out in the marketplace, Costco, McDonalds and Burger King have already announced their intentions not to buy pork products from farms that use gestation crates. Despite the controversy over these crates, Purdue University’s Food and Animal Education Network points to some advantages these crates provide for the pregnant pigs. They allow for more precise individual feeding management of the pregnant pigs and reduce aggressive behaviors, which are often seen in group housing. The ‘smart’ and ethical thing to do While what Starbucks wants to do is better for animals, it also reflects “business savvy,” writes HSUS’ Pacelle on his blog. “We live in a society where major corporations increasingly recognize that their customers want to see animals treated with decency,” he notes. “We’ve been working for years with this enormous company — which has more than 12,000 retail outlets in the United States — to improve its animal-welfare standards.” A game-changer? “It’s always exciting when a large company even mentions humane treatment of animals,” Andrew Gunther, program director of Animal Welfare Approved (AWA), told Food Safety News. “Starbucks could change the world if it comes up with something solid on this.” But he also said that if Starbucks fails to follow through with this, it would be disingenuous to the many farmers who comply with his organization’s strict requirements. “My farmers work hard to earn the seal,” he said. “We want to see measurable standards that protect animals and the environment.” And, while many people think that only “Big Ag” has the resources to supply Starbucks, Gunther said he certifies dairy operations large enough to meet a regional need. In addition, he said that AWA dairies could certainly build a competitively priced supply (of dairy products) from animals raised according to “high animal-welfare” standards, given time and commitment. “There is probably no clearer link between animal protein quality and good welfare than in dairy cattle,” he said. “Starbucks could change the industry if it worked with farmers in a proactive way and stopped buying milk from zero- grazing confinement units.” Out in the “show biz” world of coffee, Gunther points with pride to Laila Ghambari, who won the honor of being named the 2014 United States Barista Champion in the Specialty Coffee Association contest. She sources the milk for her award-winning cappuccinos from cows raised by Pure Eire Dairy, an Animal Welfare Approved dairy in Washington state. Ghambari told a reporter that not only does she choose the dairy’s milk for its taste but also because she likes the humane way the dairy cows are treated. What does any of this have to do with food safety? As a starter, many animal-welfare advocates say that the humane treatment of animals is based on the belief that animals allowed to follow their own natural behaviors — cows grazing on grass, or chickens raised outdoors but with access to shelter, for example — are healthier. The underlying logic in this line of thinking is that healthier animals produce healthier meat, milk and eggs. “Animal welfare and food safety are so linked together,” Josh Balk, HSUS program director, told Food Safety News. “When animals are raised in unhealthy conditions (such as overcrowded or unsanitary quarters), they need to be treated with antibiotics to prevent diseases. But that can lead to antibiotic resistance, which has become a severe public health problem for humans.” According to the Centers for Disease Control and Prevention, each year in the U.S., at least 2 million people become infected with bacteria resistant to antibiotics, and at least 23,000 people die each year as a direct result of these infections. Some of these bacteria are foodborne pathogens such as Salmonella and Campylobacter. Then and now Looking back several decades, a large part of growing consumer interest in humane animal practices was fueled by food-safety concerns, which opened the door to a new awareness of how meat animals are actually being raised and slaughtered. In 1993, E. coli O157:H7, a potentially fatal foodborne pathogen, hit the headlines when more than 600 people fell ill and four people died of E. coli infection attributed to undercooked hamburgers served at Jack in the Box restaurants. From there, consumers started hearing about recalls of hundreds of thousands of pounds of meat contaminated with the pathogen. Other outbreaks involving poultry contaminated with Salmonella and Campylobacter followed. Suddenly, consumers, who had imagined farms to be what they typically saw on calendars and county fair promotions — a large red barn with cows grazing on green grass and chickens outside in the fresh air — began to realize that large farms now dominate the landscape and that many animals are being raised in confinement without access to the outdoors. Some people refer to this as “factory farming” or “industrial ag.” Others decry it as a system that promotes animal suffering — all in the name of profit. Yet others say it allows farmers to raise food more economically and therefore benefits the consumer with lower prices in the grocery store. Even so, many consumers are having a hard time with this. A good number of them don’t like to think that the food they’re eating comes farm animals that they believe (rightly or wrongly) are being mistreated. “From moms to construction workers, no one wants to support practices that make animals suffer,” Balk said. “There’s a huge disconnect in this for Americans, who value kindness to animals.” The situation is reflected in voter sentiment, with Balk pointing out that every state ballot issue promoting the humane treatment of animals has won 60 percent or more support at the polls. As for cost to the consumer, he said this has been an issue touted by “Big Ag.” “It’s fairly insulting to people of lesser means to say they don’t care about how animals are treated,” Balk said. “It’s a false narrative.” In an interview for a previous article, AWA’s Gunther told Food Safety News that, after World War II, the drive was to feed a growing nation with cheap protein. In many cases, the goal was to bring a lot of animals together in one place, as in confinement dairies, beef feedlots and caged poultry. However, that meant that low levels of E. coli, Salmonella and other harmful foodborne pathogens could multiply. “The unintended consequence was that we created the breeding grounds for dangerous pathogens,” Gunther said. “The system is designed to make animals carry pathogens.” After the E. coli outbreak associated with undercooked Jack in the Box hamburgers, industry reacted to the fact that people were getting sick, and, in some cases, dying from foodborne pathogens. It adopted interventions such as washing carcasses with acid to remove dangerous bacteria and designed plans to pinpoint critical places in the slaughtering and butchering processes where these dangerous pathogens could be lurking. These strategies did produce some successful results, according to the National Cattlemen’s Beef Association, with foodborne illnesses linked to beef dramatically declining over the past several decades. The other side of the fence Not everyone follows the banner that says animals raised based on their natural behaviors yield safer meat, dairy products and eggs. A discussion paper, “The Direct Relationship between Animal Health and Food Safety Outcomes,” released by the Council for Agricultural Science and Technology, cites research on the difference between keeping animals indoors vs. outdoors. “Housing livestock indoors can also provide advantages in managing many foodborne organisms,” states the paper. “Because outdoor environments cannot be cleaned or disinfected easily, pathogens can persist in the soil, standing water, outdoor structures and other micro-environments, infecting successive generations of livestock.” Also, according to the research cited in the paper, “Other studies have shown that foodborne pathogens such as Campylobacter and Salmonella are more common in chickens with outdoor exposure than in birds raised in conventional indoor housing (cages). And dairy cows were shown to be at greater risk of subclinical mastitis when kept in outdoor environments compared with cows kept in barns.” And, while many consumers are more concerned than ever about food safety, some researchers and veterinarians warn that there’s a lot of misinformation out there, many times fueled by public distrust of the U.S. government and its food-inspection system. As part of that “misinformation,” they point to the assumption that meat from chickens raised outdoors is safer. In contrast, they say, raising chickens indoors provides the birds with a lot of benefits, such as protection from the weather and wildlife, and, therefore, less stress, while birds raised outdoors are on dirt and vulnerable to wildlife. With concerns such as that in mind, they say that confining the birds is the best way to protect their health. And they note that the health of food animals directly impacts public health. What about organic milk and other dairy products? While organic groups are upset that Starbucks has not included organic dairy in its list of priorities, especially since many of the requirements for organic certification align with what Starbucks is attempting to achieve, Balk said that HSUS sees the company’s policy on animal welfare as another step in the process. Bottom line, the initial focus of Starbucks’ policy will be on practices that many consider especially cruel, he said. Balk compared the company’s plans to an escalator, saying, “This is moving the company on a sustainable path in the right direction.” The rest of the world This past spring, China’s Ministry of Education announced the country’s first animal-welfare curriculum, based on a push by the middle class for more humane treatment of animals. Europe, meanwhile, has been ahead of the U.S. in adopting animal-welfare standards. Wire battery cages for chickens disappeared from the EU in 2012, and the EU’s swine industry has agreed to stop all non-anesthetized castrations of male piglets by 2018. There’s more: Europe’s 2009 Treaty of Lisbon requires that when countries signing the treaty write new laws, they acknowledge that animals are “sentient beings.” In its recent announcement about humane farming practices, Starbucks said that it supports global science-based national and international standards and guidelines.

Ask any doctor or veterinarian to rate the important medical discoveries of the past century, and antibiotics would surely be at or near the top of the list. In this century, too, antibiotics are expected to remain an essential tool for treating animal and human diseases. But the “miracle of antibiotics” is being threatened. There are clouds hovering over their use in both human health and animal agriculture — with antibiotic resistance casting perhaps the largest shadow. According to the U.S. Centers of Disease Control and Prevention (CDC), antibiotic resistance occurs when bacteria change (or mutate) in a way that reduces, or even eliminates, the effectiveness of drugs such as antibiotics, chemicals or other agents that could otherwise be counted on to cure or prevent infections. On the health front, that matters because antibiotic-resistant bacteria survive and continue to multiply, causing more harm. Over time, warns the Food and Drug Administration’s (FDA) Center for Veterinary Medicine, the use of antibiotics and other microbial drugs will further complicate health workers’ efforts to select the appropriate antimicrobial for treatment. FDA provides an animation explaining how antimicrobial resistance both emerges and proliferates among bacteria on its website. In the case of food safety, foodborne antibiotic-resistant bacteria have already made their way into the food chain, which makes curing people sickened with the bacteria all that more challenging. According to a Sept. 2013 report released by the Centers for Disease Control and Prevention, of the 18 drug-resistant organisms highlighted as “alarming,” four are foodborne organisms: Campylobacter, E. coli, Salmonella and Shigella. The report also pointed out that resistant bacteria in food-producing animals are of particular concern because these animals serve as carriers. Resistant bacteria can contaminate the foods that come from those animals, and people who consume these foods can develop antibiotic-resistant infections. Are we headed for a post-antibiotic era?

Bacteria in a petri dish can’t grow near samples of antibiotics to which they are susceptible (left), but when they have developed resistance, the antibiotic cannot keep them from growing around it (right).
Image courtesy of CDC
In April this year, a report from the World Health Organization outlined a picture of the resistance problem on a global scale, warning that this serious threat is no longer a prediction for the future. “It has happened right now in every region of the world and has the potential to affect anyone, of any age, in any country…and is now a major threat to public health,” says the report. Dr. Keiji Fukuda, WHO’s assistant director-general for Health Security, put it this way: “Without urgent coordinated action by many stakeholders, the world is headed for a post-antibiotic era, in which common infections and minor injuries that have been treatable for decades can once again kill.” He didn’t stop there. Pointing out that effective antibiotics have been one of the pillars allowing people to live longer, be healthier and benefit from modern medicine, he had this warning to share. “Unless we take significant actions to improve efforts to prevent infections and also change how we produce, prescribe and use antibiotics, the world will lose more and more of these global public health goods, and the implications will be devastating.” No wonder, then, that the search is on for alternatives to antibiotics. A hot topic “There is a huge amount of interest in this. It really is a hot topic,” Hyun Lillehoj, a research molecular biologist at USDA’s Agricultural Research Service, told Food Safety News. An example of this interest, she said, is the audience of 600 people who attended her presentation about developing alternative strategies to reduce the use of antibiotics by using phytochemicals — a talk she gave during the 2014 Joint Annual Meeting this summer in Kansas City. Phytochemicals are natural chemicals found in certain plants that are believed to benefit health. Feed additives derived from a wide variety of plants and herbs, such as garlic, cinnamon and other spices, have been shown in experimental clinical studies to benefit food animal health and production. The Joint Annual Meeting that Lillehoj spoke at was hosted by the American Dairy Science Association, the American Society of Animal Science and the Canadian Society of Animal Science. Its theme was “Linking animal science and animal agriculture: Meeting the global demands of 2050.” As for finding alternatives to antibiotics, Lillehoj, who in September was inducted into the Agricultural Research Service’s Science Hall of Fame, said that “there are many different strategies we can use.” But she also pointed out that there’s no silver bullet — no one answer or strategy — that will replace antibiotics, in large part because there are so many different conditions livestock and poultry are raised in and so many different breeds. A farmer in Tunisia, for example, is going to be facing different challenges than a farmer in China or in the United States. “I believe scientists should be proactively working to develop science-based alternative strategies to reduce the use of antibiotics,” she said. “That is the focus of my research here for poultry.” She was quick to say that many companies have already taken proactive steps to reduce their use of antibiotics.
Hyun Lillehoj, molecular biologist at ARS Animal Biosciences and Biotechnology Lab
Photo courtesy of ARS
As a trained immunologist with 20 years experience in this field, she believes that some important headway can be gained by taking a closer look at the immune system. The immune system protects a person, an animal, or other organisms from becoming infected by dangerous foreign intruders. These “intruders” could include foodborne pathogens such as Salmonella, E. coli and Campylobacter. Reading reports Lillehoj has co-written about research done on alternatives to antibiotics reveals that this is indeed a complex topic with no easy answers waiting in the wings. Much of it calls for yet more research. Even so, Lillehoj said she sees huge opportunities to use immunology to benefit animal health. “Why don’t we activate the immune system,” she posited, referring to an approach that would include modulating the immune system to enhance disease resistance and to treat sick animals. Cyril Gay, a senior national program leader with the USDA, working with the agency’s National Animal Health Program, would agree. He describes what he refers to as the gut microbiome as a “promising new area of research.” Simply put, the gut microbiome, which lives in the gastrointestinal system, contains tens of trillion of beneficial microbes, including an estimated 1,000 different species of bacteria. In humans, that’s ten times more than all the other microbes in and on the body. As such, the microbiome plays a critical role in human and animal health for many reasons: It helps digest certain foods, fights off microorganisms that could be harmful and plays an important role in the development of the immune system. Gay said that one of the important questions being asked by scientists right now is whether shifts in populations of gut bacteria that result from certain dietary alternatives, such as probiotics and phytochemicals are associated with beneficial outcomes or are the result of interactions with the cells of the gut wall. Probiotics are “live microorganisms which, when administered in adequate amount, confer a health benefit to the host,” according to Gut Microbiota Worldwatch. In humans, they are commonly consumed as part of fermented food, such as yogurt, and dietary supplements. Both Gay and Lillehoj agree that finding alternatives to antibiotics in animal agriculture is going to take a keen understanding of the mechanisms of action, including an animal’s innate immune and digestive systems. As such, USDA has started a website as a resource on science-based information of the development of alternatives to antibiotics. “What’s becoming more and more apparent is that there is a need to integrate nutrition, health, and disease research,” Gay said in an e-mail to Food Safety News. Taking a similar tack, Loren Laine, professor of medicine at Yale University and president of the American Gastroenterological Association, told federal legislators during a videotaped presentation to Congress that “one of the most exciting and promising areas of science is the gut microbiome.” And though he was talking about human health, his comments also pertained to animal health. “There’s no question that understanding and manipulating the gut microbiome will be important in impacting diseases in the future,” he told the federal legislators. What about organics? Organic producers are not allowed to use antibiotics, or, if they do, in the case of treating a sick animal or bird, they can’t sell the meat, milk or dairy products as “organic.” For George Vojkovich, co-owner of Skagit River Ranch, which produces and sells pasture-raised organic beef, broilers, pork and eggs, it all comes down to good animal husbandry. His farming practices include building the soil, culling animals with genetic tendencies for certain health problems, using selective breeding, rotational grazing, planting a diversity of grasses and legumes and making sure the animals get the trace minerals they need. “There’s no silver bullet in any of this,” he said in an interview at his ranch in Western Washington, echoing Lillehoj’s outlook. “We build an animal’s immune system through nutrition. We look at food as medicine for the immune system.” As for cost, his customers are happy to pay $6.75 a pound for the ranch’s turkeys and $20 or more for its whole broiler chickens. But Vojkovich said that the benefits of eating food raised organically is actually an investment in health. Surveys have repeatedly shown that consumers who seek out organic foods are willing to pay higher prices for it. Oregon dairy farmer John Bansen, who switched over to organic dairying 15 years ago, said he did have some apprehensions about doing so. When he was raising his cows conventionally, he used antibiotics to prevent mastitis when drying up his cows after their milking cycle was over. “All of the articles said you needed to treat them with antibiotics, so every cow got treated,” he said. “I never really knew that I actually needed to do that. I just listened to the so-called experts.” For him, raising healthy cows is a matter of making sure that the good bacteria outnumber the bad bacteria. “It can’t be about ‘no bacteria,'” he said. He also believes that when the bacteria in the gut is healthy, the whole cow is healthy. “You don’t want to subtract from a cow’s natural immune function,” he said. “Our job isn’t to replace her immune system with antibiotics and vaccines.” He makes sure not to push his cows past what’s “biologically doable” to get more milk from them. “If an animal is stressed, it has trouble fighting harmful bacteria,” he said. He has his doubts about whether this can be achieved in what he calls “industrial-sized” farming operations. “When you overcrowd animals, it whistles in problems,” he said. Big vs. small Although many people believe that smaller “family-size” farms are the only places where animals and poultry can be raised without an excessive use of antibiotics, veterinarian Charles Hofacre, professor at the University of Georgia’s Center for Food Safety in the Avian Medicine Department, would disagree. He said that raising animals and poultry in large-scale farming operations without pumping them full of antibiotics is being done every day and has been done for the 30 years that he’s been a poultry veterinarian. “A small subset of very vocal people feel we should not raise food animals in a way to make a safe and affordable supply of meat to help feed the world, so they make it sound like the animals are not being well-taken-care-of,” he said. Hofacre and another veterinarian explain antibiotic use in the poultry industry and antibiotic resistance in a video. Hofacre and another veterinarian explain how the health of the birds in a 25,000-bird broiler operation is maintained and monitored and the role of veterinarians in this sort of operation. Farmers and consumers united in desire for solutions For farmers, the fear is that if antibiotics are overused, their animals or poultry will become immune to these drugs, something that some farmers have already seen. As a result, they’ll have fewer options to turn to when they need to treat a sick animal. Another concern farmers have is that many consumers are seeking out meats and poultry products from animals that haven’t been treated with antibiotics. (This trend is happening even though any meats or poultry or dairy products showing traces of antibiotics are banned from the marketplace.) Then, too, farmers are seeing ever-increasing regulatory restrictions on the use of subtherapeutic antibiotic growth-promoters in animal production. The U.S. Food and Drug Administration recently released guidance intended to phase out, by 2016, the use of medically important antibiotics in food animals for growth enhancement. It has also proposed a directive that ensures that all antibiotics administered to food-producing animals are given only under the care and prescription of a licensed veterinarian. Veterinarian Hofacre told Food Safety News in an email that the pharma companies are not doing research on producing any new antibiotics for food animals because they don’t see that there’s going to be any chance for approval — unless there is an antibiotic that doesn’t have a human equivalent. “That means we will have fewer options to treat animals when they get sick,” he said. Pointing to work done by Scott Russell at the University of Georgia, Hofacre said that “sick birds have a higher chance of having foodborne bacteria, so we need to keep them healthy. That is why so much of what a poultry veterinarian does is preventive medicine.” Meanwhile, two classes of antibiotics, flouroquinolones and cephalosporins, which the FDA deems to be critically important to human medicine — especially for treating foodborne illness in humans — have been phased out of chicken production for a number of years, according to the National Chicken Council. For consumers, the main fear is that they’ll be infected with antibiotic-resistant bacteria when they eat an infected animal’s meat. That’s especially worrisome because some of the antibiotics that would normally be effective against a foodborne pathogen such as Salmonella, E. coli or Campylobacter can’t, or won’t, be able to be used to treat the sick person. And some of these bacteria can also be resistant to more than one antibiotic. Although the CDC points out that the majority of drug-resistant infections occur in hospitals, it also says that there’s growing concern over antibiotic-resistant infections from food. New task force formed Two agricultural heavy-hitters — the Association of Public and Land-grant Universities and the Association of American Veterinary Medicinal Colleges — have joined forces to create the Task Force on Antibiotic Resistance in Production Agriculture, according to to a Nov. 17 press release from The Ohio State University’s College of Food, Agricultural and Environmental Sciences. The task force is made up not only of representatives from universities and veterinary colleges but also from animal agriculture and the pharmaceutical industry. The goal of the task force is to help advise the federal government on a research agenda and also to help provide information to the public about the use of antibiotics in production agriculture. Growing concerns about antibiotic resistance in veterinary and human medicine among scientists and the public provided the necessary push to create the task force. “The task force will draw on the expertise of its members to serve as a knowledgeable and important source of advice for the federal government as it develops its plans,” said Dr. Lonnie J. King, chair of the task force and dean of The Ohio State University College of Veterinary Medicine, in a press release. “It can also make recommendations on further research that should be undertaken to develop alternative solutions for some antibiotic use in production agriculture.” ——– Did you know?   Antibiotic resistance: Sometimes it’s ‘natural’ If you think of bacteria as living beings that — like us — do whatever is necessary to survive, you’ll understand how antibiotic resistance is sometimes a natural response to that same survival instinct.    Here is some information from a June 2014 USDA report, Antibiotic Resistance in Agriculture, published in Crops, Soil and Agriculture. The research was focused on environmental sources of  antibiotic resistance from bacteria that live in soil and water. According to the report, researchers are only now beginning to understand the complex relationships between antibiotic resistance in the environment and common agricultural practices such as using animal manure or biosolids for fertilizer or reclaimed wastewater for irrigation.  

  • Bacteria evolved antibiotic resistant genes naturally over millennia of evolution in order to survive in a hostile environment. These genes typically express proteins that give the bacterial cells the ability to either break down antibiotics or prevent their entry into the cells.
  • Genes that code for antibiotic resistance have been found in ice cores from the time of the woolly mammoths.    
  • Naturally resistant antibiotic resistant bacteria have also been found in soil from a 4-millions-year-old cave in New Mexico.  Even more amazing, the soil contained bacteria that was resistant to a suite of modern antibiotics — even some recently developed antibiotics.  
  • The same kinds of  antibiotic resistant genes in cattle and chicken waste have been found in Antarctic ice and the Sargasso Sea. In other words,  antibiotic resistant genes occur not only in agricultural environments but also in non-agricultural environments.  
  • Antibiotic resistance can occur in meat products from antibiotic-free animals. So even though putting limits on the use of antibiotics in agriculture is a good start, it is not necessarily going to be enough to keep antibiotic resistant bacteria from getting into the food chain.    
  • When antibiotics are used to trigger growth (weight gain) in animals, up to 75 percent of the dose is shed in the feces. As a result, these antibiotics may kill susceptible bacteria in the soil and water, thus potentially enriching the environment in antibiotic resistant bacteria.  
  • Just because antibiotic resistance is found in an environmental sample doesn’t necessarily mean it poses a threat to human health.  
  • A lot more research on naturally occurring antibiotic resistance in non-agricultural environments is necessary in order to identify increases (or decreases) triggered by agricultural practices.    

Information supplied here thanks to: Jean McLain , associate director of the Water Resources Research Center at the University of Ariizona and Lisa Durso, research microbiologist at USDA’s Agricultural Research Services, Lincoln, Neb. 

This is the moment of the year we all wait for, when the editorial writers come down from the hills after the election battles to shoot some of the wounded. The one I’ll take is easy, the Black Knight of the national GMO labeling campaign. Those old enough will remember the Black Knight from Monty Python and the Holy Grail. With some skill as a swordsman, the Black Knight is said to have suffered from unchecked overconfidence and staunch refusal to give up.  In the movie version, the Black Knight ends up getting both his arms and legs cut off, but continues to guard his bridge on his stumps, refusing to quit. That’s a pretty good depiction of where the national GMO campaign is at the moment. It’s on its stumps. After losing in California in 2012, and Washington State in 2013, the national GMO labeling campaign moved on to Oregon and Colorado in this past Tuesday’s election. (It had failed to quality for 2014 ballot placement in Arizona.) On Tuesday, it lost narrowly in Oregon after putting up an $8 million campaign that was opposed by the biotechnology and grocery industries with spending of more than $20 million. While outspent, the pro-GMO camp in this small market state enjoyed its most competitive campaign ever, but it still came up short. It had written off Colorado to put its national resources into Oregon, which was probably a good decision in that GMO labeling was crushed in the Centennial State in a near $17 million campaign that one television commercial after another featuring local farm leaders speaking directly into the camera. The “yes” campaign in Colorado spent less than $1 million Voter turnout in Oregon hit 68 percent, high for an off-year election. The boost may have come from recreational marijuana also being on the ballot, and many of those voters may have helped the GMO initiative too.  Oregon’s Measure 92 was typical — it would have required the words “Genetically Engineered” on raw food and “Produced with Genetic Engineering” or “Partially Produced with Genetic Engineering” on food packaging. It would raise prices without much, if anything, in the way of consumer benefits. There are obviously some in the organic, soap and supplements business who must think they’d benefit, but that’s more of a follow-on story if it ever happens.  Personally, I’ve found it hard to believe that for the price-conscious among us, the words “genetically engineered” would cause me to pay organic prices for anything. That is sort of an admission that I agree with those who say the best thing the food and biotech agriculture sectors could do would be to just embrace GMO labeling and move on. They say science and food safety is on the industry’s side and they’d be better off taking the money being spent on campaigns (About $120 million since 2012), and pour it into ongoing consumer education. But like the Black Knight, bravado is still coming out of the national GMO labeling movement’s mouth, although there is talk of taking a year off before filing for another state initiative campaign. Maybe we could all use that time to change the rhetoric and the narrative on this issue and give both sides a way out. Instead of the “right to know” blather we’ve been hearing since before California in 2012, how about we all agree on a “right to know something important” labeling plan.  Here’s the idea: We’d come up with a uniform approach with a panel on all food packages listing all your various food types; GMO, organic, conventional, non-GMO, etc. Behind each one there would first be an on or off  or red light, green light indicator, like with the  light “on” if the product is organic. Then, and here’s where it gets good, there would be more  indicators on the panel after the food type indicators: recalls, outbreaks, illnesses, and deaths.  We’d rely on the federal Centers for Disease Control and Prevention (CDC) to update these numbers every year. We’d have to work out the details, but think of the true consumer benefit that would result from this approach versus the failed initiatives of the past. This new approach would create a powerful new incentive for food safety. Food companies would do everything possible to make sure their package did not have to report any illnesses or — god forbid — deaths on their product labels for the next year.  Consumers, who are often misinformed about food safety, would be educated at the check-out counter and could make more informed decisions. The “right to know something important” labeling campaign is going to require bringing both the GMO and the organic camps together. That assumes either of them would want something important on the label, but that is something I seriously doubt.  It sure would be a way of finding out if anybody in the grocery business really believes in this right to know stuff, would it not?

(This article by Douglas Karas was first published in the October/November 2014 issue of Food Safety Magazine and is reposted here with permission.) In the spring of 2012, the U.S. Food and Drug Administration (FDA) began to hear from the U.S. Centers for Disease Control and Prevention (CDC) and other public health partners about cases of Salmonellosis. The case count grew quickly. In the first week of April, 93 illnesses were reported. The next week, there were 116, and, a week later, there were 139. By early May, the number of cases had nearly doubled. The final count: 425 people had been reported ill by the end of the outbreak. But by using traceback analysis, FDA was able to follow a trail of tuna shipments to its source, leading to the recall of 58,000 pounds of frozen tuna and helping to prevent additional illnesses. FDA, CDC, and state and local agencies worked together in a huge effort to determine whether tuna imported from India was the culprit. During a multistate foodborne disease outbreak, public health partners conduct surveillance to identify and interview people who have become ill. CDC serves as lead coordinator to help detect the outbreak, define its size and extent, and to identify the source. Investigators determined that this outbreak involved two strains of Salmonella — Salmonella Bareilly [1] and Salmonella Nchanga (Figures 1 and 2). Once the interviews with case patients began to point toward sushi as a possible carrier of the outbreak strains of Salmonella, there remained the complex task of figuring out what ingredient in the sushi might have been contaminated. Because the evidence pointed to an FDA-regulated product, FDA took the lead on determining how the outbreak occurred, looking for ways to control it and identifying ways to prevent future outbreaks, which included testing foods, assessing food safety measures in restaurants and food processing facilities, and announcing food recalls. FDA also traces foods to their origins, and, in this investigation, the traceback was a key means of identifying the food carrying Salmonella. Such tracebacks are painstaking efforts that require investigators to be both detectives and scientists. Teams must track a contaminated food or ingredient back to its source so that it can be taken off the market, preventing future illnesses. This process often requires collecting, reviewing and analyzing hundreds — sometimes thousands — of invoices and shipping documents. Investigators then connect that information to other bits and pieces gained from interviewing staff working at firms in the supply chain and from observations of investigators visiting the firms. Searching for Clues in the Maze All investigators know traceback is laborious. They might as well be looking for clues in a maze. First, the investigator must enter the labyrinth. But which of the hundreds of entrances is the right choice? Once inside, investigators have even more decisions to make. From the very beginning until the end, scientific methods and investigative skills must be harnessed to identify the source of the outbreak. And, once they reach the center of the maze, investigators must still find their way back, carefully choosing between pathways with more offshoots, dead ends, twists and turns. If they do everything right, investigators exit the maze with a map, new knowledge and understanding that can be used to prevent additional illnesses. But the size of the outbreak can have a dramatic impact on the complexity of the investigation. Imagine standing before a maze, one that begins with just a few entrances but grows to have 425 entrances, each representing a reported illness in the outbreak tally. That was essentially the challenge presented to investigators during the 2012 investigation of the Salmonellosis outbreak linked to tuna. To determine how these people got sick, investigators stepped through certain doorways and followed clues. Analysts identified clusters of illnesses, selecting clusters at four restaurants to trace back. Then investigators painstakingly reviewed thousands of invoices and records from 45 companies that could have supplied the tuna to the restaurants. This allowed them to rule out 44 firms. The one remaining company supplied all four restaurants. They had navigated the maze and created a map, which we call traceback. Inside the Investigation It is hard to grasp the effort and difficulties involved in a traceback investigation. Before the restaurants and the supplier at the heart of the 2012 investigation were identified, this is what happened: State and local health officials on the front lines identified and interviewed patients, working with CDC to determine what food was making people sick. The outbreak grew, and, as more information became available, the leading suspect became seafood, specifically spicy tuna sushi. But if people were made ill by sushi, what ingredient in the sushi might be carrying Salmonella? The candidates included mayonnaise, sesame seeds, fresh and frozen tuna, hot sauce, seaweed and rice. FDA worked with state agencies to identify the brands of ingredients in common use at restaurants. The effort excluded all but tuna as the most likely candidate, and the traceback began. During this step, the traceback team looks for clusters of patients who reported eating or shopping at a common location. It is important that the patients have a good memory of what they ate, or their purchases were documented in some way, such as with a grocery store shopper card or a purchase receipt. Ideally, the team will identify at least three pathways to trace in different geographic areas. They must also determine what time period to investigate. If the time frame is too wide, it could bog down the investigation and collection of records. If it is too narrow, the team may miss vital information. “It takes a team effort to stop an outbreak,” says Kathleen Gensheimer, M.D., director of FDA’s Coordinated Outbreak Response and Evaluation (CORE) Network. “The FDA district offices, the federal, state and local authorities, scientists at FDA headquarters and in the field, and members of industry, everyone brings something to the table. Without that teamwork, it just couldn’t happen.” During the investigation, investigators had to gain an understanding of each supplier’s handling of the tuna. Practices such as stock rotation and inventory control can help narrow which suppliers to follow. The availability and accuracy of records can make or break a traceback investigation at this point. “Recordkeeping varies from one company to the next, so with each supplier you have to learn and understand a new record system and new operating practices,” says Gensheimer. “Many companies keep excellent records, but when recordkeeping is not good, it can lead to a dead end.” Ultimately, FDA followed the trail of tuna shipments from the four restaurants through 45 separate suppliers before finding the source of the bad tuna. Going Back to Move Forward Finding the common supplier, though, is only half the battle. When FDA knows where the food came from, there’s still another question. Where else did this food go? The next step is a trace-forward analysis, which can identify new pathways of exposure that need to be blocked. Analysts examined shipping records, invoices and information on product-handling practices to track shipments from the common tuna supplier to 20 additional restaurants that served tuna to customers who reported becoming ill during this outbreak. The results of these traceback and trace-forward investigations quickly led to the recall of 58,000 pounds of frozen tuna and an alert to FDA inspectors at U.S. points of entry to detain further shipments of frozen tuna from this supplier to prevent future illness. The Evolving Process Although the traceback method was used as far back as the 1920s during a typhoid outbreak linked to fresh oysters in New York City, Chicago and Washington, D.C., the increasingly global marketplace makes the technique both more important and more challenging. FDA began to place more emphasis on traceback in the late 1980s and 1990s, as Salmonella Enteritidis outbreaks were linked to fresh shell eggs, and relied on it in the late 1990s as more outbreaks were detected. “The FDA’s focus on traceback really goes hand in hand with the evolution of FDA’s mission from one focused primarily on enforcement to a mission focused more on prevention,” says Jack Guzewich, a former senior adviser on environmental health at FDA. “We began to broaden our view of what evidence we could act upon — going beyond positive laboratory samples to acting on epidemiological evidence. That made a huge change.” Historically, you can chart the rapid development of FDA’s traceback process from outbreaks of Cyclosporiasis linked to raspberries in the late 1990s. Prior to that, FDA traceback investigations were for packaged products, in which much of the needed information is on the package label, and, because these types of product have a longer shelf life, the risk of illness is prolonged. “This meant a fairly straightforward traceback process could be followed,” says Guzewich. “Fresh produce, on the other hand, often has no such label, so a much more complex and difficult traceback effort is required.” FDA adopted a traceback process in use by CDC and state regulatory and public health agencies at the time and developed it further. Shortly afterward, FDA issued its first guidance to its staff for conducting traceback investigations related to produce, which led to the development of a traceback course in the late 1990s. In 1995, following the advent of PulseNet, a database of the DNA information from bacteria related to illnesses across the country, health officials could identify multistate outbreaks that might previously have gone unrecognized. “FDA depends on close collaboration with partners at CDC, state and local public health, and food safety agencies to identify the outbreaks and to provide much of the information used in tracebacks,” notes Guzewich. “They could not be accomplished without this cooperation.” Into the Future Over time, FDA’s traceback methods have become more refined, and the agency has offered a course so that its staff and members of state and local agencies can learn about the techniques and methods developed and standardized over the past few decades. “With this course, we want to formalize the traceback process and make what we’ve learned available to health officials across the country,” says Katie Vierk, a developer of the course and a team leader at CORE. “Responding to an outbreak is a very collaborative effort. If everyone is aware of and using the same process, it is a tremendous help during an outbreak response.” The course covers all the steps in the process, from logistics to the information that must be collected, and how to best analyze and present the data. “All of this is important, because our goal is to be able to document the traceback and, if needed, take appropriate action,” adds Vierk. “At the end of the course, students participate in a simulated traceback exercise using real data. We’re teaching practical, usable skills and we want to demonstrate that right away.” Congress also had the intention of improving product tracing when the Food Safety Modernization Act (FSMA) was developed. In that legislation, Congress directed FDA to establish pilot projects for produce and processed food to explore and evaluate fast, effective food-tracing methods and technologies. The pilot projects were completed by the Institute of Food Technologists (IFT), under contract with FDA, culminating in March 2013 with the release of a final report.[2] IFT consulted with the U.S. Department of Agriculture, state agencies, consumer groups, and the processed food and produce industries on proposed foods and ingredients and product-tracing technologies for the pilot projects. The 45 companies volunteering to participate in the pilots included tomato growers in the U.S. and Mexico, an import company, tomato processors, ingredient suppliers, processed food manufacturers, food distributors, retailers and foodservice chains. Tomatoes were among several foods chosen for testing because they have been involved in a number of significant outbreaks, have a complex food supply chain, and were identified by most industry associations as a top candidate for inclusion. A frozen Kung Pao-style meal containing domestic peanut products, red pepper spice and chicken was also chosen for testing, as were dry versions of this type of meal into which consumers would add their own chicken. Jarred peanut butter was also tested. In the final report, IFT noted that the pilot participants appeared to have many of the tools and processes in place to contribute to a successful traceback by regulatory agencies, though there were challenges. For instance, most participating firms provided documents that could not be electronically manipulated. The formats of the documents allowed for easy transmittal of information, but forced those trying to use the data to either extract them manually or use an optical character reader. This slowed the analysis of the data and opened it to the potential for errors to be introduced. In addition, inconsistencies in the terminology, numbering systems, formatting, legibility and language meant that traceback analysts had to spend additional time following up with the firms to make sure the data were accurate. “The IFT experienced exactly what the FDA experiences in real outbreaks. During an outbreak, people are getting sick and we need to act fast but are stymied by these challenges,” says Sherri McGarry, the manager of this project and a senior adviser in FDA’s Office of Food and Veterinary Medicine. The IFT final report also noted that some participating firms had never considered how their records would need to be pieced together with those of their suppliers in a traceback investigation. The report noted that the participants were surprised by the process used and expected an experience more like a mock recall, in which they would be provided with a lot number and asked to identify where the product was sent. “Most firms have a good handle on what comes in and a good handle on what goes out, but there’s a gap in the middle,” says McGarry. “Here’s an example. Let’s say you have five shipments of a type of fruit from five different growers. Some of that fruit was repackaged and sent out unprocessed, while some of it was put into fruit salads. If a firm can tell you how the incoming shipments link to the specific outgoing shipment, it would speed traceback dramatically as we link shipments again and again through the supply chain.” An added advantage was that industry participants were able to identify benefits from improved record-keeping. They reported that, depending on their place in the supply chain, better record-keeping could potentially improve internal processes, help expand distribution, reduce insurance costs and improve consumer confidence and brand reputation. The findings of the pilot projects and input from stakeholders will help FDA recommend product-tracing improvements in a report to Congress, as required by FSMA. Also, FDA will use the information from these pilot projects and earlier studies to draft a proposed regulation, also required by FSMA, to establish record-keeping requirements for facilities that manufacture, process, pack or hold high-risk foods to help in tracing products more quickly, reducing illnesses in the event of food contamination. “Traceback is an important part of any foodborne outbreak response. Once epidemiology identifies a common food as the vehicle for the bacteria or virus, we still may not know what specific ingredient is causing the problem,” says Gensheimer. “At that point, traceback can be used to help identify the sources of ingredients and, potentially, the source of the ingredient carrying the contamination. Once we know that, we can get the product off the market.” References 1. www.cdc.gov/salmonella/bareilly-04-12/index.html 2. www.fda.gov/food/guidanceregulation/fsma/ucm270851.htm

(This report by Rick Schmitt was first published June 26, 2014, by FairWarning, a Los Angeles-based nonprofit news organization focused on public health, safety and environmental issues, and related topics of government and business accountability.) In April 2012, a team of inspectors from the U.S. Food and Drug Administration (FDA) investigated a seafood company in southern India that had been exporting tons of frozen yellow fin tuna to the United States. What they found was not appetizing: water tanks rife with microbiological contamination, rusty carving knives, peeling paint above the work area, unsanitary bathrooms and an ice machine covered with insects and “apparent bird feces,” according to the report. FDA issued an “import alert” that barred Moon Fishery India Pvt. Ltd. from shipping fish to the U.S. But the damage to public health had been done. By the time FDA got around to inspecting the plant, a Salmonella outbreak was erupting around the country. Ultimately, 425 people in 28 states and the District of Columbia were sickened, with victims ranging from babies to octogenarians. According to the Centers for Disease Control and Prevention (CDC), 55 people were hospitalized. The fact that tons of bad fish had sailed into this country was not a surprise. FDA has been outgunned and overmatched for years as a rising tide of imported food has found a place at the U.S. dinner table. Because of budget constraints, ordinarily only 1 to 2 percent of food imports are physically inspected by the agency at the border each year. Typically, operations such as the one in India are inspected only if something goes terribly wrong. And the threat of illness from imports may be growing. According to an analysis of FDA data by FairWarning and the Investigative News Network (INN), FDA today rejects about the same number of shipments of foreign food as it did a decade ago — when imports were less than half the current level. The violations that FDA inspectors are finding pose some serious health risks. According to the analysis by FairWarning and INN, some 16,700 shipments of imported foods were barred over the past decade because they included a “filthy, putrid, or decomposed substance” or were “otherwise unfit for food.” That was the leading reason imports were rejected. According to FDA records, foods rejected in 2013 included hard candy from Mexico deemed “filthy” or “poisonous,” Salmonella-infected cumin and ginger from India, and fish from Vietnam with excessive levels of histamine.

William Hubbard
FDA declined to make officials available to comment for this story, either on background or on the record. The agency also refused a request by FairWarning to accompany inspectors at a port of entry. In response to questions, an FDA spokeswoman provided publicly available links to the agency website, previously issued press releases and congressional testimony by agency officials. While acknowledging gaps, the agency says technology, including a new computer system, is helping inspectors zero in on some of the worst offenders. Imports were supposed to face tighter scrutiny by now. In January 2011, President Obama signed into law a bipartisan overhaul of the way FDA regulates imported and domestically produced foods, known as the Food Safety Modernization Act. But outsized hopes for the law have gone unfulfilled because of agency foot-dragging, flagging interest in Congress for public funding, and food industry opposition to proposed user fees to finance the reform. Smorgasbord of Tainted Food At least eight foodborne illness outbreaks — tied to hundreds of illnesses, hospitalizations and deaths — have occurred since the law was passed. The smorgasbord of tainted foods includes a brand of ricotta cheese from Italy that was linked in 2012 to a multi-state outbreak of Listeriosis, a bacterial infection. Among the victims: a California woman, 27 weeks pregnant, who gave birth prematurely after eating some of the cheese. Her child tested positive for Listeria and later died. That adds to an already large toll of food poisoning victims. CDC estimates that one in six Americans suffers from a foodborne illness each year, with children, the elderly and the infirm suffering disproportionately. Economic costs of disease outbreaks to consumers, farmers and food processors are huge — more than $100 billion a year, according to one estimate. Rejected: Top Reasons Imported Foods Have Been Refused by FDA “They look at very, very little. They sample very, very little. There is a risky environment out there for food because FDA is so weak,” says William Hubbard, a former FDA senior associate commissioner who is now a consultant. “It is still a little bit of an honor system.” Carl Nielsen, a former director of FDA’s import operations who has testified before Congress about gaps in monitoring imports, says nothing has changed for years. “It is the same system. It is the same lack of resources. It is a huge, huge problem,” he said. To be sure, some of the worst cases of illness in recent years have involved home-grown foods. Some three dozen people died in 2011 after eating cantaloupe from a farm in Colorado. Three officials of a Virginia peanut company are scheduled to stand trial this summer on fraud and conspiracy charges in connection with a Salmonella outbreak that killed nine people and sickened 700. But rising imports have brought rising concern. “It is important to note that while FDA is not able to physically inspect a large percentage of food entries, all import entries are electronically screened using an automated system, which helps field inspectors determine which products pose the greatest risk and, therefore, should be physically examined.” — FDA, in a 2013 report to Congress. Stepchild of Food Safety About 15 percent of the food that Americans now consume is imported, including about half the fruits and vegetables in the winter and most seafood throughout the year. Virtually all spices and many ingredients in processed foods come from abroad. FDA-regulated imports originate from an estimated 130,000 facilities worldwide in 150 countries, a daunting number to oversee even under the best of circumstances. FDA has been a stepchild of federal food safety. It is responsible for 80 percent of the U.S. food supply, including imports, but its resources are dwarfed by those of the Food Safety and Inspection Service, an arm of the Agriculture Department, which regulates meat, poultry and eggs. The Food Safety Modernization Act called for a big increase in FDA inspection staff and set bold new goals for preventing contamination at foreign food plants. Under the law, private auditors are to certify that foreign plants meet federal standards, complementing the work of FDA inspectors. Importers, for the first time, will have to vouch for the manufacturing practices of the suppliers they do business with overseas. With bipartisan support, the law was hailed as a milestone, one of the most significant changes in food regulation since Upton Sinclair’s “The Jungle” exposed sordid conditions in the meatpacking industry at the turn of the last century, triggering the first federal food laws. Today, key regulations covering imports called for under the new law have not been implemented, and the agency is under a consent order to pick up the pace, following a lawsuit by a public-interest group. FDA is far behind in meeting other mandates, too. The law requires the agency to inspect 19,200 foreign plants by the 2016 fiscal year. In 2012 — the latest year for which data are available — the agency had inspected just 1,342 plants, with little hope of much growth anytime soon. “Reaching the goal of 19,200 foreign inspections called for by FSMA,” FDA wrote in a report to Congress last year, “would require hundreds of millions of dollars in new funding which the agency cannot realistically expect to receive.” Congress has shown little appetite for supplying those funds. “This is mindless, what is happening,” said Rep. Rosa DeLauro (D-CT), a lead sponsor of the food safety legislation. “We need to provide the money to FDA so we can protect people.” The idea that imported foods are available for consumption without ever being inspected, at the source or at the border, surprises and unnerves many Americans.
Sheila Lewis
Sheila Lewis, a Virginia-based auto broker, was one of the 425 people who got Salmonella poisoning after eating tuna from Moon Fishery, the Indian business that became the target of an FDA “import alert.” She was on a buying trip to Pennsylvania in March 2012 when she capped off a day of shopping with a meal at a favorite sushi bar where she ordered the spicy tuna roll. When Lewis started feeling ill, she thought it was related to the fact that she suffers from Crohn’s disease, an inflammatory bowel disorder, so she did not immediately seek medical treatment. Doctors later told her that the wait almost killed her. Her suffering from Crohn’s has since become more acute, which she suspects is related to the tuna poisoning. Team Dispatched to India Federal authorities traced the outbreak to four restaurants in the U.S. that had bought tuna “scrape” — so-named because it is scraped from the bones after fish is filleted — from Moon Fishery. FDA immediately sent a team to inspect the plant in Kerala and issued the order blocking further imports the day the inspection was completed. Lewis is unsettled by the timing and the discovery of decrepit and unsanitary conditions. “That is not something that happens overnight. How often was this facility being monitored?” she says. “After several hundred people have been sickened and hospitalized, now we go out and check what their facility looks like? That is such crap.” Since 2007, Moon had sent about 150 shipments of tuna into the U.S.; it is unclear how much, if any, was inspected. According to the records, four shipments of the “scrape” came through the port of New York in early 2012, including one in March when Lewis and others got sick. Four shipments in May — after the FDA import alert — were rejected for Salmonella, including shipments of tuna loin and “scrape.” FDA declined to comment on the inspection history of the tuna and the plant in India. In a report last year, the agency highlighted the tuna case as a “landmark” example of interagency cooperation in tracing the cause of an outbreak. The gatekeepers in this system are FDA entry reviewers who are stationed at ports of entry and use computers to track and decide the fate of hundreds of scheduled shipments from abroad each day. When they make the rare decision to inspect cargo, they take into account the food and region of origin as well as the history of the manufacturer and importer. A software program FDA calls PREDICT (Predictive Risk-based Evaluation for Dynamic Import Compliance Targeting) gathers the data and scores each shipment. A Rising Tide of Food Imports FDA also bars products through import alerts, which put importers on notice that their products will be detained and warehoused until they can prove them safe. FDA manages scores of food-related import alerts, some of which have been outstanding for years, covering everything from Basmati rice from India to frog legs from Bangladesh. But the number of import refusals, as a barometer of the system, has remained generally unchanged for a decade, even as the volume of imports has greatly increased. According to the analysis by FairWarning and INN, the refusal rate in 2012 was just over half the rate of 2002. Seeking a Technological Fix FDA acknowledges the limits of its inspection program but believes that its new technology has improved its ability to target suspect foods. “It is important to note that while FDA is not able to physically inspect a large percentage of food entries, all import entries are electronically screened using an automated system, which helps field inspectors determine which products pose the greatest risk and, therefore, should be physically examined,” the agency said in a report to Congress last year. Yet FDA apparently has no idea of the scale of the risk from imported foods. Consumer groups have pushed the agency for years to determine how many inspections it would take to intercept most problem foods. Critics say the process has been driven by available resources rather than science. “They just do a back of the envelope calculation,” said David Plunkett, senior staff attorney for the food safety program at the Washington, D.C.-based Center for Science in the Public Interest. “Shouldn’t you be able to put together a program that says if we sample ‘X percent’ we have a 90-percent chance of catching most of the problems out there? We don’t do that.” One of the things that FDA inspectors missed last year was a shipment of pomegranate seeds from Turkey. The shipper, Goknur Foodstuffs Import Export Trading, an Ankara-based grower and processor of fruits and fruit juices, had previously sent lots of fruit to the U.S. without incident. But a few episodes had raised red flags. Shipments Turned Back According to the review of import data by FairWarning and INN, a shipment of apple juice concentrate from Goknur was rejected by FDA at the port of San Francisco in 2004 due to fear it was tainted by mycotoxin, a highly toxic mold. Another Goknur shipment was turned back in 2010 because a fruit container appeared to be made of a “poisonous” or other hazardous substance. Four shipments in 2011 were rejected for failing to accurately list ingredients.

Michael Walters
Last year, CDC blamed pomegranate seeds from Goknur for an outbreak of Hepatitis A that sickened 162 people in 10 states. The seeds were used by other companies to make organic fruit drinks. FDA declined to discuss its handling of the case, but experts say the prior problems with Goknur should have made inspectors more vigilant. “The history of a line is extremely important,” said Dean Cook, a retired former supervisory inspector for FDA at the port of Baltimore. “The fact that the manufacturer was negligent in one area kind of bleeds over into his disregard in other areas,” Cook said. “The question here is whether the entry reviewer was aware of the past violation. A lot of it goes back to resources.” Goknur, in court papers filed in response to personal injury claims, has denied that the seeds caused the Hepatitis outbreak. An attorney for the company in the U.S. said she was unable to comment. In a news release last year announcing import restrictions on the pomegranate seeds, Michael R. Taylor, FDA’s deputy commissioner for foods and veterinary medicine, said: “The Hepatitis A outbreak shows how we have improved our ability to investigate and respond to outbreaks, but also why we are working to build a food safety system that more effectively prevents them.” Last May, Michael Walters, a youth detention center worker in Colorado, was among those who got sick from the pomegranate seeds. They were an ingredient in an antioxidant fruit mix he bought at Costco, which he used for smoothies and health drinks. “I was loading up twice a day with this stuff, trying to promote good, vigorous heart health,” says Walters, 61, who had recently undergone quadruple heart bypass surgery. On vacation with his wife in Yellowstone National Park to celebrate their 25th wedding anniversary, Walters began to feel tired, feverish and nauseous. At first, he thought it might be his heart. His daughter made the connection with the berry mix when she noticed a recall notice on the Costco website. Walters was later diagnosed with Hepatitis A and was hospitalized because his doctors were worried about his liver shutting down. Six months later, he says, he was able to return to work. Walters was one of eight consumers sickened by imports who testified at an FDA hearing last fall on stalled regulations called for by the new food safety law. Walters appreciated the opportunity to speak but could not help notice that the room was crowded with food industry representatives. He worries about how their influence will shape the process going forward. He also worries how consumers are supposed to protect themselves, given that imports have become an everyday staple. He is trying to have some faith in the system and is hoping for the best. “Overall, it’s just really set us back at a time in life when you’re supposed to be reaping the benefits of 45 years of work,” he testified at the FDA hearing. “I urge you all to continue on this path with the food modernization act and implement it and enforce it as quickly as you can … to prevent this kind of affair from having other people suffer as we have.” Denise Malan of the Investigative News Network contributed to this report.

Two years ago, when Oregon parents Jill Brown and Jason Young met Brad and Tricia Salyers, the families had no idea that they would eventually be sharing in a tragedy that sickened four of the Salyers’ children and left Brown and Young’s youngest child, Kylee – 23 months old at the time – with such severe medical complications that she would need a kidney transplant from her mother. All of that and more happened beginning in April 2012 when the children were among 19 people – 15 of them under the age of 19 — who fell ill with E. coli O157:H7, a potentially fatal foodborne pathogen. Soon after, Oregon health officials determined that the outbreak was caused by raw milk from Foundation Farm near Wilsonville in Western Oregon — the Salyers’ family farm. Four of the sickened children were hospitalized with kidney failure. Foundation Farm had been providing 48 families with raw milk. Raw milk is milk that hasn’t been pasteurized to kill harmful and sometimes deadly foodborne pathogens such as E. coli, Listeria, Salmonella and Campylobacter. While many raw milk advocates say it has inherent nutritional advantages and even helps cure or ease the symptoms of ailments such as asthma and various allergies, most food-safety experts discount those claims as anecdotal, saying they’re not based on science. They also warn of the serious risks to human health associated with drinking milk that hasn’t been pasteurized. The symptoms of E. coli O157:H7 infection typically include bloody diarrhea and other digestive-tract problems. In some people, this type of E. coli may also cause severe anemia or hemolytic uremic syndrome (HUS), a complication in which toxins destroy red blood cells, which are typically smooth and round. The misshapen or deformed blood cells can clog the tiny blood vessels in the kidneys, causing them to fail. Statistics from the Centers for Disease Control and Prevention (CDC) underscore the potential dangers of raw milk. According to the agency, between 1998 and 2011, 148 outbreaks due to consumption of raw milk or raw milk products were reported. In those outbreaks, there were 2,384 illnesses, 284 hospitalizations and two deaths. Estimates from the agency put raw milk consumption at 3 percent of total milk consumption. Currently, 29 states allow some form of on- or off-farm raw milk sales, but only a few allow sales in grocery stores. In Oregon, it is against the law to sell raw cow’s milk, although there is an exemption for very small herds (no more than three cows on the premises, with no more than two of them being milked). Under that exemption, the milk must be sold on the farm and no advertising of the product is allowed. CDC has documented fewer illnesses and outbreaks from raw milk in states that prohibit sales. Goals in common The irony of this story is that the two families shared a common goal to provide their children with nutritious food. Now they share another goal: to warn people that raw milk can be dangerous to drink, or even deadly. As parents, they want to let other parents know that they shouldn’t feed raw milk to their children, no matter what some raw-milk farmers and advocacy organizations might say. “There might be some benefits of raw milk, but there are huge risks,” Jill Brown, Kylee’s mother, told Food Safety News. “There needs to be more public awareness that this is a high-risk food. If I had known what I know now, I would never have fed it to my daughter.” Despite formerly selling raw milk, the Salyers agree. “The people who bought our milk thought it was the healthiest choice for their kids,” said Brad Salyers, co-owner of Foundation Farm. “But I see things differently now. By far, it’s the most dangerous food you can feed them because of the chance it can be contaminated with E. coli or other harmful pathogens.” Knowing he fed raw milk to his children, Salyers’ thoughts on the topic now veer into the emotional: “It breaks my heart that anyone would give it to their children,” he said. “What’s even more troubling is that some of our friends who saw what our kids went through are still feeding raw milk to their children.” Salyers rankles at what he says is the proliferation of too much misinformation about raw milk’s purported health benefits. “It’s duping people into thinking you can safely drink raw milk,” he said. The worst part of this, he added, is that children are especially vulnerable to contracting E. coli or other pathogens from raw milk, primarily because their immune systems are still developing. According to a recently released statement from the American Academy of Pediatrics, the health claims related to drinking raw milk have not been verified by scientific evidence, and, therefore, do not outweigh the potential health risks that raw milk poses to pregnant women and children. “Children depend on their parents,” Salyers said. “They don’t make the decision to drink or not to drink raw milk. They’re at the mercy of their caretakers.” “We definitely want to get the word out about the dangers of raw milk,” Tricia Salyers said. Sold their cows Once the Salyers saw what Brad Salyers refers to as the “devastation that HUS can cause in children,” they immediately sold their cows. “We didn’t want to put kids at risk,” Salyers said, pointing out that four of his family’s five children came down with E. coli, with one of the four developing HUS. “She fought for her life for 27 days,” he said. He objects to conspiracy theories that paint the government and food-safety scientists as “the enemy” when it comes to restrictive raw milk laws and the information they provide to customers (and farmers) about the potential dangers of raw milk. “They’re so cynical that they can’t see straight,” said Salyers. “They put their trust in some organizations with myopic agendas — places that glorify raw milk as ‘miracle’ food. That’s nonsense. It’s based on a lot of misinformation.” So why do people ignore warnings about the potential dangers of raw milk? According to a 2011 study that looked at what motivated people in Michigan to drink raw milk, cynicism about government surfaced. The study’s authors told Food Safety News that they were surprised to find that only a small percentage of those surveyed trusted public health officials regarding which foods are safe to eat or drink. The survey respondents also took issue with some of the survey’s other statements, once again revealing sharp differences of opinion with official government views on the potential health hazards of drinking raw milk. For example, when asked if they agreed or disagreed with the statement that, “Drinking raw milk increases your risk of getting a foodborne disease,” an average of 44 (or 78.6 percent) disagreed. Only six respondents agreed with the statement, and another five (or 8.9 percent) respondents said they weren’t sure. As for those who think that “knowing your farmer” is safeguard enough,  even raw-milk dairies with high sanitation standards and licensed and inspected by states that allow raw milk sales – California and Washington state are two of these – have been subject to recalls due to the presence of pathogens such as E. coli and Campylobacter in their milk. Those recalls are typically triggered by foodborne-illness outbreaks that have sickened people. According to CDC, while adherence to good hygienic practices during milking can reduce contamination, it cannot eliminate it. “The dairy farm environment is a reservoir for illness-causing germs,” CDC says. “No matter what precautions farmers take, and even if their raw milk tests come back negative, they cannot guarantee that their milk, or the products made from their milk, are free of harmful germs.” Logistics come into the picture here. There’s no way to test every part of every batch of milk 365 days a year. While testing will provide important clues about whether things are being done right, it doesn’t ensure that all of the milk a farm produces will be safe. Or, as Dr. Tim Jones, epidemiologist with the Tennessee Department of Health, puts it: “Those who consume raw milk are playing Russian roulette with their health; the glass they drink today may not have deadly microorganisms, but the one they drink tomorrow may cause serious health problems or even death.” Germs such as E.coli, Campylobacter and Salmonella can contaminate milk during the process of milking dairy animals, including cows, sheep and goats. Animals that carry these germs usually appear healthy. Brad Salyers said that a health official who visited his farm after the outbreak told him that it’s not just about making sure the cow’s udder is clean. Contamination could occur from something as simple as one drop of rain containing some E. coli O157:H7 bacteria picked up from the cow’s hide trickling down the side of the cow. Not only are these germs extremely tiny, it takes only one or two of them to replicate inside the milk and make someone sick. And, unlike earlier strains of E. coli, this toxin-releasing strain, which wasn’t identified as a cause of human illness until the 1980s, is far more virulent. This chronology can confuse people. They don’t understand how their grandparents who drank raw milk all of their lives never got sick from E. coli. But scientists believe E. coli didn’t pick up the genes that cause human illness until late last century. Now that this disease-causing strain of the bacterium is commonly found in most cowherds, people can, and do, become ill from drinking contaminated milk. Even more confusing for some is that cows that have this strain of E. coli in their systems generally don’t show any signs of being infected with it. Then, too, it can come and go on a farm. It can be present in some of the cows or in water tanks or the soil for awhile and then disappear from one or all of these possible “harboring” places, only to return again. What happened? Like most mothers, Jill Brown wanted to feed her family the best food possible. For her, that meant growing a garden, buying as much food as she could from local farmers, and eventually buying raw milk for her toddler, who was an avid milk drinker. Her quest to find raw milk was in large part triggered by her desire to steer clear of “industrial agriculture” and buy from a local farm instead. She saw it as a good fit with the philosophy of the “local food movement,” which her family and many of their friends embrace. “I wanted to know where the milk I was buying was coming from,” she said. “My research led me to believe that raw milk from a local farm would be healthier than the milk I bought at the store.” After finding Foundation Farm through an Internet search, Brown became a herd-share member. Under a herd-share arrangement, people can buy a share of the herd, or even an individual cow, with the understanding that they are not customers of the dairy but rather owners of the herd and the milk produced by the herd. Some refer to this arrangement as a “legal loophole.” In Oregon, herd shares have not been challenged in court, according to information from the state’s agriculture department. Foundation Farm was providing raw milk to 48 households under a herd-share arrangement. On the legal front, the families couldn’t sue the Salyers after the outbreak because the Salyers didn’t have insurance, and they were leasing the land where they were farming. In short, they had no assets that could be taken and sold to raise money for the aggrieved families. While it was a commitment to go to the farm once a week to get the milk, Brown believed it was well worth it, despite the inconvenience and additional cost. “It felt good to know that we were getting ‘real, actual milk,’” she said.  “[The Salyers] seemed to be doing everything right.” In talking with them, she had learned that, before setting up a herd share, they had visited other raw-milk dairies and had improved on what they saw. Even though, for the most part, no one in her family except Kylee drank milk, the toddler loved it and thrived on the raw milk from Foundation Farm. But it was short-lived. Brown said that Kylee probably only drank it for three months before things went wrong. “It was pretty sudden,” Brown said. “We went to the farm to get some milk on Friday, the last day of spring break.” The following Wednesday, Kylee was sick, an “exploding diaper” the first sign of problems to come. On Friday, her dad stayed home with her and took her to the pediatrician, who said she had a stomach bug. By Saturday, she couldn’t keep food down and was becoming dehydrated. They took her to the emergency room, where she was put on an IV, with oral rehydration administered every 10 minutes. They chose to take her home that night, and, on Sunday, she was starting to feel better. But, on Monday night, they were called back to the hospital. When Brown stood Kylee up, she was dismayed to see her walking backward, apparently disoriented. She rushed Kylee to the emergency room and was told that her kidneys had shut down. Kylee was admitted to the pediatric intensive care unit, and, the next day, she received the necessary set-up lines to start dialysis. “That’s when our whole life changed,” Brown said. “From there, every step of the way, things got worse and worse. Each day brought more bad news.” Kylee developed edema, was having a hard time breathing, and her eyes were crossing. “She had had a stroke,” said Brown. Once a happy, energetic toddler, Kylee now couldn’t walk or say words, although for the first couple of days she did say “mama,” “papa,” and “no.” Even though test results from a stool sample submitted on Monday were not back yet, Kylee was diagnosed with HUS. Brown went to work researching the medical problem. “When you’re Googling ‘bloody stool or vomiting,’ one of the top things that comes up is raw milk,” she said. Several days after Kylee had been admitted to the hospital, another child with E. coli was admitted. By April 21, a total of 19 people were confirmed ill with E. coli traced to raw milk from Foundation Farm. Of those, 15 were under the age of 19. Four of the Salyers’ five children were among those ill, with one of them among four children suffering from HUS. Kylee was on a ventilator, but she wasn’t getting better. Before long, the other children who had been hospitalized were talking about going home. But that wasn’t in store for Kylee. The lab results came back and showed that her bowels were necrotic and that she needed surgery. Her heart stopped while she was in surgery and she had to be brought back to life. “That was probably the hardest part,” said Brown. But then suddenly, Kylee started doing much better. They took her off of dialysis in early June. She had been on dialysis for eight weeks. After five weeks of rehab in the hospital, Kylee could go home, and Brown started going to work two days a week. November and December were good months. Kylee was getting stronger and sitting up on her own. But then in January, lab tests came back that didn’t look good. By February, the toddler had to go to the dialysis center in the hospital three times a week for three hours a day. She was also admitted frequently throughout 2013 for multiple staph infections and other issues related to her kidneys. Brown quit her job in May to stay home, finding it too hard to manage a household with two other children and be at the hospital for Kylee. In the meantime, Kylee struggled. Being on dialysis, she had only 15 percent kidney function and didn’t have the energy for weekly physical therapy sessions. The doctors decided that the toddler needed a kidney transplant. Brown and Young started the donor “work up” for a kidney transplant in June and July and were scheduled for the transplant on Sept. 9. “She’ll get 120 percent of her kidney function from this,” Brown told Food Safety News several days before the surgery. “The hope is that she’ll feel better and have the energy for therapy.” Kylee’s father Jason Young told videographer Terry Tainter that when they realized that their toddler was going to need a kidney transplant, the word “now” took on new meaning. “One of the biggest things that went through my mind at that point is that this is now,” he said. “This is now a lifelong thing. There is no full recovery from this anymore. And there never will be. It’s always going to have to be someone else’s organ that keeps her alive.” People who have kidney transplants often have to have another in future years, something that both Brown and Young know. All in all, the little girl has spent close to 200 days in the hospital since she was admitted in April 2012, with her mother by her side much of the time. The good news is that, as of mid-February 2014, the last time she had to be hospitalized was September 2013. Before the transplant surgery, Tricia Salyers started a fundraiser. After the operation, she let Facebook readers know that Kylee was making “HUGE” strides forward in her recovery. “What a miracle this transplant has been,” she said, adding that all sorts of bills have been coming in from, among them, the insurance company, the hospital, and pharmacies. Salyers said that the $7,500 fundraising goal would get Brown and Young through the end of the year and pay off current medical debts. On Jan. 26, Brown was happy to report that the goal was met, although medical bills will burden the family for years to come. Through all of this, Brown and Tricia Salyers became friends. “I’m so glad I chose to move on and forgive,” Brown said. “It’s so easy to blame the farmer. But they were just as much blindsided as we were. They fed all of their kids the milk. I do believe they thought they were doing things right.” Kylee will continue to need physical therapy and speech therapy for a long time, only part of which insurance will cover. But the family recently received some good news. The Wheel to Walk Foundation has approved Kylee for a grant to help cover the cost of her intensive therapy that insurance doesn’t cover.  Even so, there are still a lot of uncovered expenses, including medical equipment and medications such as immunosuppressants to prevent her system from rejecting her mother’s kidney. Although Kylee is for the most part stable medically, she still can’t speak words, can’t walk, uses a special table to stand, and eats through a special tube. Because she understands what’s going on around her, she experiences a lot of frustration in not being able to express her thoughts and feelings in words. With limited insurance and no chance of getting a settlement to help pay the bills, and with their two-story house no longer suitable for a child with Kylee’s  disabilities, Brown and Young have had to sell their home. The sale is expected to close in mid-March. In another unforeseen bond tying the two families together, Tricia Salyers, who went into real estate after she and her husband sold the cows, handled the sale of Brown and Young’s home. The farmer’s perspective “We were foodie-type people,” said Brad Salyers. “We felt the food system in this country was messed up. We were trying to get back to basics.” That led them to information that extolled the benefits of raw milk from grass-fed cows. “We believed all the hype about its benefits,” he said. They started buying raw milk from a farm but eventually decided to buy their own cow, thinking they could improve on what they saw at the farm. Once they had their own cow, they quickly realized they were going to have a surplus of milk. Thinking that they could find people who would want it, the Salyers visited other farmers known for their dedication to cleanliness and learned from them. “I felt I had enough information to put the necessary safeguards into place,” Brad Salyers said. “I’m not one to take shortcuts or wing it.” Once they started making their raw milk available, demand grew and soon there was a waiting list. “It snowballed,” he said. “We got more cows. Before long, we had five and were milking three.” Now when he hears people talk about the safety of raw milk from grass-fed cows, he warns them not to jump to conclusions. “Cows aren’t like horses,” he said. “Cows like to lie down a lot. Their udders and hides can be in manure. It’s dangerous because that’s where E. coli can be.” But he said he also thinks there can also be problems with an imbalance of nutrients and bacteria in their digestive system. He thinks that’s what happened when he switched the cows from dry forage to pasture too quickly. He called the vet because one of his cows wasn’t acting quite right. When the vet came, he found an improper pH balance in the urine. He told Salyers he was pretty sure he’d find some bacteria. David Smith, a veterinarian and professor at Mississippi State University College of Veterinary Science, told Food Safety News that it’s possible that the switch in diet resulted in the cows’ shedding E. coli O157:H7 in their manure, but he also said the diet change “did not make it appear out of nowhere.” “It was on the farm,” he said, pointing out that this strain of E. coli is common to all beef and dairy herds and that it should be assumed that it is present in some cattle on all cattle farms. It was while the vet was there that Tricia Salyers came out to the barn and told her husband that the doctors at the hospital had confirmed that Kylee was ill with E. coli O157:H7. When Salyers walked back into the house, the phone was ringing. It was a state official asking him if they had informed their customers about the problem. Tricia, meanwhile, had already e-mailed their customers the information. “It was the scariest time of our lives,” he said. Why did they do it? “I blamed myself for the longest time,” Brown said about the devastating effects raw milk had on her daughter. “But I know that I’m an amazing mom who was trying to do the best for my family.” When doing research on raw milk, she discovered that “it’s a two-edged topic with no middle ground between. On one side are government and dairy industry representatives pointing to the inherent risks of raw milk. On the other hand are the raw-milk advocates who fervently believe that locally grown and produced foods, including raw milk, are healthier than foods produced on what they refer to as ‘industrialized farms.’ “I do follow their philosophies about local foods, and since raw milk was part of what they believed in, I went along with it,” Brown said. The fact that she did still baffles her, especially since she considers herself to be levelheaded. She was on debate teams in high school and college and knows how important it is to gather objective information and not to be swayed by emotion. “Debate is all about being well-researched,” she said. “You learn to look at every side. That’s why I get so frustrated about what I did. I know now that different choices could have been made.” It discourages her that despite continuing news about E. coli outbreaks caused by raw milk, so much of the information spread about raw milk praises its health benefits. The Weston A. Price Foundation is a good example of one such information source. Its website shows a happy, healthy-looking family with this headline above the photo: “They’re happy because they eat butter.” Under the picture is some more information: “They also eat plenty of raw milk, cheese, eggs, liver, meat, cod liver oil, seafood, and other nutrient-dense foods that have nourished generations of healthy people worldwide.” Brown doesn’t think that raw-milk dairy farmers are dishonest or “sleazy,” and she thinks that they’re trying to offer the community what they believe is a “valuable resource.” “But many of them are not educated enough,” she said. “Our farmer didn’t know the risk. I do believe that they thought they were doing it right.” Like Brown, Brad Salyers also has misgivings about his experience with raw milk. Describing himself as a Christian, he said he trusted in the Lord to help him deal with what he describes as “the guilt and shame that was mentally devastating.” “I had to believe that in my heart I was making the best decision for my children with the information I had,” he said. Salyers said he would like to see farmers be more educated about raw milk. As a contractor, he had to take classes to get his license, and he believes something similar should be put in place for raw-milk producers. He also believes that raw-milk producers should be required to carry liability insurance. “It’s just part of running a business,” he said. “I don’t see why a farmer producing such a potentially dangerous product shouldn’t have to have insurance.” In retrospect, he said he wouldn’t hesitate to support legislation that would safeguard children from raw milk, even though he knows it goes against the principle of “freedom of choice.” “It’s just too dangerous for the children,” he said. What about locally produced, ‘gently pasteurized’ milk? Buying milk from a local farm conjures up scenes of contented cows grazing on lush green pastures, complete with a farm family dedicated to the health of the cows and the quality of the milk. For the most part, but not always, this is “raw-milk country”— small-scale dairy farmers who can sell their milk at higher prices than milk sold in the stores. Those higher prices are based in part on the higher expenses that come with producing milk on such a small scale but also on the willingness of raw-milk customers to spend more money for what they consider to be a premium product. Raw-milk farmers and raw-milk customers alike extoll this business model, saying it helps keep family-scale dairy farmers in business instead of being pushed off the map by ever-expanding dairy operations that depend on what’s referred to as “efficiency of scale” to stay in business. “It used to be that the only alternative to conventional mass-produced milk was raw milk,” said Steve Judge, founder of Bob-White Systems and developer of the LiLi (Low Input-Low Impact) Pasteurizer. “But our goal is to give people the choice of either raw milk or farm-fresh ‘gently’ pasteurized milk.” The LiLi pasteurizes the milk without homogenizing, separating or standardizing its nutritional value and farm-fresh flavor, according to the company’s website. Judge said that in designing the LiLi Pasteurizer, he wanted a small machine that would allow small-scale farms to sell farm-fresh pasteurized milk direct to consumers. With the LiLi Pasteurizer, the milk gets heated to 163 degrees F and held at that temperature for 15 seconds, after which it is immediately cooled to less than 60 degrees F. After the milk is pasteurized, it’s sent to a cooling tank where it can be cooled to 38 degrees F in less than an hour. This allows for a pasteurization speed of two gallons a minute. “I believe that the minimal damage done to milk by properly done, high-temperature, short-time pasteurization is a worthwhile compromise if it also expands the availability of locally produced farm fresh milk,” he said. Although the LiLi can work for small dairies of four to 10 cows, Judge said it could handle milk from up to 100 cows. Bottom line, he said, “Anywhere you grow grass, you can do this.” Better yet, it meets all state and federal regulations. While raw-milk proponents say that pasteurization kills many of the healthful components such as vitamins and enzymes, Judge said that he sent samples of raw milk and milk pasteurized with the LiLi to a food-safety lab for a comparison of 50 different nutrients. While there was a drop in lactic acid colonies and a slight drop in Vitamin B-12 in the pasteurized sample, other vitamins did just fine, including vitamins C and D. “There was minimal damage,” he said. That pretty much lines up with a recent rundown of a nutrient comparison between raw and pasteurized milk provided by the Purdue University Extension. As for flavor, Judge said that one taste of milk pasteurized with the LiLi would convince anyone that it’s indistinguishable from raw milk. “It has a bright, clean, fresh flavor,” he said. Other farms offer vat, or batch, pasteurized milk, which they also describe as “gently pasteurized.” In this method, the milk is heated to 145 degrees F and held at that temperature for 30 minutes and then cooled as quickly as possible. Proponents of this method also say that it provides a good option to raw milk. In contrast, said Judge, most conventional milk bottlers use a method that heats milk to 170 degrees F and holds it at that temperature for no less than 15 seconds. Proponents of this method say that it destroys most bacterial pathogens, while largely protecting milk proteins from degradation. “Ultra-pasteurized” refers to milk heated to at least 280°F for not less than two seconds. Unfortunately, said Judge, as of yet, there is no association of dairy farms that produce “gently pasteurized milk,” although an Internet search will yield some farms in various locations that do. Of course, for those whose main reason for buying raw milk is that they want to support local farms, there’s always the option of pasteurizing the milk at home. What about those allergies? Many parents who buy raw milk for their children do so because their children have allergic reactions to pasteurized milk. Many say that their children do better on raw milk. Some go so far as to say that raw milk can cure allergies, eczema, asthma and other ailments. Like other raw-milk farmers, Brad Salyers said that many of his customers had children with allergies. It’s not surprising that milk comes into the picture. According to the U.S. Food and Drug Administration (FDA), milk is at the top of the list of the eight major food allergens that account for 90 percent of food-allergic reactions. And, even though most food allergies cause relatively mild and minor symptoms, some food allergies can cause severe reactions and may even be life-threatening, says FDA. Also, according to the agency’s site, there is no cure for food allergies. And the agency recommends strict avoidance of food allergens and early recognition and management of allergic reactions to food. Following this line of thinking, Mike Tringale, an official with the Asthma and Allergic Foundation of America, told Food Safety News that raw milk isn’t a cure for an allergy to pasteurized milk. “The milk protein in pasteurized milk is in raw milk, too, so anyone with a milk allergy would still be affected,” he said. “Allergies in general are caused by a chronic disease of the immune system, and it’s genetic – you inherit a hypersensitive immune system.” Interestingly enough, though, people don’t inherit specific allergies. For example, a person’s mother can be allergic to cats and the dad to dogs, yet the child can develop an allergy to peanuts, or other triggers. Tringale describes allergies as “what happens when a person’s body misinterprets the foods or pollens in his or her environment.” Speaking specifically about milk, he said that pasteurized or raw milk doesn’t eliminate the allergenic protein in milk, which is what makes milk white. He discounts assumptions such as the idea that getting back to simple agrarian life makes the body more defensive against allergies, calling them “old wives’ tales.” He does say, however, that some research is turning up evidence that babies raised on farms or with cats and dogs may have a lower prevalence of allergies later in life. “But the jury is still out on that,” he said. But when it comes to raw milk, he pointed out that it is not going to change your immune system. “The thought that this can cure allergies is actually a dangerous thought,” he said. As for doing “their homework” on milk allergies, Tringale said that parents need to work with their doctor to make sure they’re on the right path. If they don’t do that, they haven’t done their homework. And, when all is said and done, it doesn’t come down to deciding in favor of either pasteurized or raw milk. “The real question is, ‘How do I supply nutrition for my children if I can’t feed them milk?’” he said. Fortunately, said Tringale, this doesn’t have to be hard – at least if a child has only one or two allergies. There are ways to make sure that children have nutritious diets. He recommends an interactive website, kidswithfoodallergies.org, which allows parents of kids with allergies to talk with one another for support, to find recipes and share ideas. However, parents with children who have more than one or two allergies need to work with a nutritionist to make sure their children are getting all of the necessary nutrients. “Getting as close to good health as possible is what people should be aiming for,” he said. “It’s important that in trying to do that, they’re not making poor choices.” Updates on Kylee’s progress can be found on her Facebook page. Food Safety News will feature a video interview with Kylee’s parents on Wednesday, February 19.

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Labeling food containing genetically modified ingredients might be a federal issue at some point, but the states are not done with it yet. Next month, two state capitals within easy earshot of the major media outlets – Albany, NY, and Annapolis, MD – are going to be holding public hearings on serious GMO labeling bills. Until those states and others make their own decisions, it’s unlikely that labeling advocates are going to want to turn decisions on the matter over to the much-maligned U.S. Congress. Moving the GMO battle to Washington, D.C., is the idea of the powerful Grocery Manufacturers Association. It has enlisted  28 food and agricultural organizations to help persuade Congress to preempt the states with federal legislation making GMO labeling a more prescribed, but largely voluntary, pursuit. The GMA coalition won expensive initiative battles over GMO labeling in 2012 and 2013 in California and Washington state, respectively. The cost of those victories, however, has the food and agricultural interests looking for a federal solution. The GMA-led formation of the “Coalition for Safe Affordable Food” to try and keep the issue in D.C. was met with disdain by many labeling advocates. Andrew Kimbrell, executive director of the Center for Food Safety, said the new coalition was organized to “steal away consumer choice in Congress.” But Leah Wilkinson, director of ingredients, pet food, and state affairs for the American Feed Industry Association, and a member of the coalition, says there needs to be a “federal GMO labeling solution.” “If a labeling solution is not agreed upon and even a few of the pending state initiatives are successful, the feed industry’s costs of doing business goes up, on-farm production costs go up, and ultimately the consumer pays the price, with no important information in hand,” Wilkinson says. In reality, both sides have looked to Washington, D.C., for a solution for some time. The pro-labeling side got there first with federal legislation sponsored by U.S. Sen. Barbara Boxer (D-CA) and U.S. Rep Peter DeFazio (D-OR) to mandate national labeling of GMO foods. At this point, the GMA-led group does not have specific legislation, but there is a list of elements that members want to see in their “solution.” These include:

  • No “patchwork” of 50 state GMO safety and labeling laws, meaning that the U.S. Food and Drug Administration will continue as the nation’s authority.
  • Labeling should advance food safety and require safety, health and nutritional reasons for any mandated GMO labeling.
  • Standards should exist for voluntary labeling to inform consumers whether GE processing was or was not used.
  • FDA will define “natural” so that the term is used consistently.

“Foods made with genetically modified ingredients (GMOs) are safe and have a number of important benefits for people and our planet, said GMA President Pamela G. Bailey. “Our nation’s food safety and labeling laws should not be set by political campaigns or state and local legislatures, but by the FDA, the nation’s foremost food safety agency.” Campaigning is expensive. GMA and its allies spent more than $70 million to defeat the initiatives in California and Washington state. A mix of organic, supplement and alternative medicine interests spent about one-third of that pushing their ill-fated ballot measures. While the sides circle each other in Washington, D.C., play continues in the states. Both Maryland and New York are girding for debates that will get underway in earnest in March. Last year, a GMO bill died late in the session in Albany. GMO bills are back in both the Empire State Senate and the Assembly. Bipartisan sponsorship by Democrat Linda Rosenthal in the Assembly and Republican Ken LaValle in the Senate on a bill that requires all GMO food sold in the state to be labeled will get hearings in both chambers, probably in late March. Meanwhile, Maryland’s House Bill 1191, which is cross-filed as Senate Bill 0776, has been scheduled for a hearing before the Health and Government Operations Committee on March 11 at 1 p.m. The House/Senate measures require specified raw foods and packaged foods that are entirely or partially produced with GMO ingredients to be labeled.

The House took a new approach to passing the long-stalled farm bill on Thursday: it passed a version that included farm programs, but left off the nutrition section, which represents 80 percent of the bill’s price tag. While much of the focus in Washington is on the political implications of splitting the farm bill into two, food safety advocates are concerned because the version that cleared the House could further delay implementation of the Food Safety Modernization Act. A little-known provision in the bill sponsored by Rep. Dan Benishek (R-MI) that was added to the farm bill last month would require the U.S. Food and Drug Administration to conduct a “scientific and economic analysis” of FSMA regulations before they can move forward, a requirement that could further delay regulations that are severely behind the deadlines set by Congress. Benishek, who has tree fruit farmers in his Northern Michigan district, says he wants to make sure FDA is getting the rules right so it doesn’t hinder farmers. Apple, cherry, and other tree fruit growers have been among the most outspoken critics of proposed FSMA regulations for produce safety. The groups are particularly upset about new water testing requirements they view as onerous and unnecessary. Sandra Eskin, director of the food safety campaign at the Pew Charitable Trusts, thinks Benishek’s amendment could “significantly delay” the rules FDA is working on. “What this provision does is totally undermine the process we have for regulations in this country,” said Eskin, noting that FDA has published regulatory impact reports that include analysis on the costs and benefits of each proposed rule. The bill specifically says FDA may not enforce any of the FSMA regulations until the analyses are published to the federal register, but some in the produce industry think that the requirement might not stall the rules if it becomes law because FDA is already focusing on the science and considering the economic impact. Consumer advocates are hoping that Sens. Tom Harkin (D-IA), Dick Durbin (D-IL), and others who were champions for the sweeping food safety law, will ensure the measure is stripped when the House and Senate reconcile their respective versions in conference. Sen. Harkin took to Twitter Thursday afternoon and said the House had passed “a farm bill that nobody wants,” adding that it “would undermine critical food safety law” while foodborne illness continues to impact 1 in 6 Americans annually. The farm program-only farm bill cleared the House 216 to 208 with no support from Democrats. House Majority Leader Eric Cantor said leadership is in discussions about bringing the nutrition title, which deals with the Supplemental Nutrition Assistance Program, to the floor “sometime in the near feature,” but the path forward for SNAP is not clear. The House version seeks $20 billion in cuts to nutrition assistance over the next 10 years — significantly more than the Senate’s $4 billion scale-back. Senate Agriculture chairwoman Debbie Stabenow (D-MI) said the House’s first phase of the farm bill is “not a real Farm Bill and is an insult to rural America.” She pointed out that splitting the bill in two was “strongly opposed by more than 500 farm, food and conservation groups.” “We will go to conference with the bipartisan, comprehensive Farm Bill that was passed in the Senate,” said Stabenow. Frank Lucas (R-OK), chairman of the House Agriculture Committee — who had made it clear he thought splitting the bill was a bad idea — said the vote was “an important step toward enacting a five-year farm bill this year that gives our farmers and ranchers certainty.” Lucas said he would be continuing conversations with lawmakers in both chambers to find a path “that ultimately gets a farm bill to the President’s desk in the coming months.”