ISPAM September 6 2014 Meeting

intrusions or large numbers of bird activity and bird feces should simply not be harvested. Disposition of that field should not rely on testing. In spite of this targeted approach, historical data suggest that for-cause testing has yielded marginally higher contamination rates. Further, results obtained in the field have been shown to be quite different than those upon receipt of the product at the processing plant. The latter could be due partly to the harvesting and handling practices exacerbating the issue. Testing for-cause approaches are subjective to the cause and there is little agreement on what a for- cause sampling plan should entail. 2.1.5. Investigative sampling Investigative sampling is usually performed in response to an observed contamination and often after the decision has been made not to harvest the field. This type of sampling serves the root cause analysis and perhaps has the highest chance of yielding reproducible results. 2.2. Industry production practices and controls of known hazards (DeAnnBenesh) 2.2.1. Most likely sources of contamination in field FDA’s 1998 Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables , and all subsequent guidances and standards for good agricultural food safety practices, identified five vectors as most likely sources of pathogen contamination of fresh produce, including romaine lettuce: • animal intrusion, whether domestic or wildlife; • water that comes into contact with the harvestable portion of the produce, whether by irrigation, crop protection sprays or flooding; • soil amendments such as manure, compost, other soil treatments or crop treatments applied to the soil; • health and hygiene practices of workers who come into contact with the harvestable portion during production or harvesting of the crop; and • the cleanliness and sanitation of harvesting equipment surfaces that come into contact with the harvestable crop. Location of the field can also be a factor, whether because of prior use of the field (e.g., animal grazing) or proximity to risk factors (e.g., near a dump, animal farm, wildlife concentrations, septic systems) that can be vectored onto the cropland by animals, water, wind or traffic. Research has suggested that certain weather events (e.g., heavy rain, high temperature and humidity conditions) have been associated with higher frequencies of pathogen detection in fields. 2.2.2. Recommended controls Controls and mitigations have been developed for each of the risk factors identified above. For example, worker health and hygiene practices can be controlled by providing accessible and properly maintained sanitary facilities (i.e., toilets, hand washing stations) and worker training; pre-harvest protocols for field evaluation to monitor for contamination due to animal intrusion;

Comment [DG1]: Not sure what this is trynng to say.