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Sampling Plan Update

Current Situation:

Fields will not be sterile

Industry data: leafy greens field operating under GAPs will still have

about 0.2% frequency of detectable pathogens in field

Sampling to prove “pathogen-free” is impractical

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Sampling Plan Update

Objective:

Evaluate existing sampling protocols (industry, FDA “site-specific risk-

b d

h”)

ase approac

Identify/recommend/develop a field sampling protocol, e.g.,

For routine sampling (e.g., to meet a customer requirement)

For cause or investigative sampling (e.g., if a potential food safety issue is

identified)

Directional/gradient sampling (e.g., from least likely to most likely areas)

Define a sampling lot, while considering field assessments and historical data

Determine what level of statistical confidence can be achieved

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