Making the contents of our salads safe is very difficult work. That much is clear about the âGuidance for Industry: Guide to Minimize Microbial Food Safety Hazards of Leafy Greens,â an update to the current federal rules on how to keep those delicate green leaves of lettuce from hosting disease and kidney failure.
The document to which I am referring was released by the U.S. Food and Drug Administration in late July, and, like most policy papers, is not entertaining, but it is important because itâs part of the federal governmentâs efforts to improve food safety and solve one of the most vexing issues in fresh produce: leafy greens and the bacteria that love them.
Itâs also a prelude to actual food safety laws pending in Congress that will mandate rules and mete out penalties to companies that donât adhere to the often vague and complicated requirements.
I took an interest in reading this paper because growing wholesome heads of iceberg lettuce and safe bagged salads of romaine is a concept never far from the minds of the Salinas growers whose livelihoods depend on the reputation of these plants.
For me, the heart of the matter, really, isnât why FDA wants to update its guidance for leafy greens safety but how they will do it. Thereâs so much research being done in California, home to nearly all the nationâs leafy greens, that the old, passive model of drafting policy is just that â old and passive.
The U.S. Department of Agriculture, along with a team of other agencies, is in the midst of a long-term study to determine how much E. coli O157:H7 really exists in wildlife of the Salinas Valley and its environs.
Researchers at the Center for Produce Safety at the University of California-Davis, and others nationwide, are all trying to answer the most basic questions about how this bacteria finds its way into lettuce long enough to make people really sick.
I realize that ambiguity, lack of information and conflicting data are antithetical to creating good policy and that these problems still plague FDAâs newest rules for leafy green food safety.
Reading through the document made clear that it does not really acknowledge all the research really smart people are doing. It also made me think, why not create a wiki?
Weâre in the midst of the public comments period for the draft, but I think public input from the growers, scientists, trade groups and the public should come as part of crafting the document, not simply as criticism or commentary on what already exists and bears the hallmarks of the governmentâs priorities.
A wiki would be a way to give the public the best information out there on leafy greens, especially in the controversial areas of plant and wildlife management, where FDA is still recommending practices that have led growers to remove beneficial riparian plants and kill local fauna.
An interactive, online document that captures whatâs known about (and whatâs not) how to safely grow the most common of vegetables would be a way to create policy that better reflects the realities of growing, harvesting and processing, and cut out the wasteful rules that damage water quality and prevent growers from being good stewards.
It would be a first step in eliminating the opacity of policy making and maybe even lead to laws that protect consumers without sacrificing growersâ environmental practices or their livelihoods.
E-mail firstname.lastname@example.org. Follow Dawn on Twitter at http://twitter.com/withersd.
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