Produce Recalls

Richard Willis

Every day untold numbers of consumers walk into their local grocery store and purchase lettuce in some form whether that may be in bag form or as a’ whole head’. Consumers are not provided with sourcing information and operate with the presumed understanding that the product they intend on purchasing is safe quality food, free from contamination and adulteration. According to Food Safety Magazine; a major university report suggests; lettuce and other greens can bring in about $2 billion annually a state. (Beach, 2017)

As an example, the study also found an unnamed county ranked second among 429 U.S. counties for harvesting lettuce and spinach acreage. Leafy greens have accounted for an average of 17 percent of that state’s agricultural receipts every year since 2010. The question facing consumers; how safe is our produce and what steps can be implemented to communicate to consumers when a recall voluntary or mandated occurs. There is a tremendous amount of planning and behind the scenes orchestration which takes place in the flow of food along the supply chain: which begins when the seedlings are produced, short of genetically marking each plant intended for public consumption. The use of optical character recognition software allows for traceability and timely response to those in the supply chain. Of course, all of this presupposes that the entire supply chain is on the same page regarding the necessity for a food safety management plan. The communication portion of the consumer advisement should provide concise and accurate information to consumers. For example, fast forward to the warning from the CDC which recently included whole heads and hearts of romaine lettuce, in addition to chopped romaine and salads and salad mixes containing romaine.

Consumers have been advised to wash produce including leafy greens, however everyone needs to understand that harmful bacteria reside in areas that topical washing cannot be reached. Leafy greens fall into the category of a ready to eat food as such, there is no kill step involved prior to being consumed, hence the need for supply chain management and transparent traceability. There are, of course, advocates placing the responsibility on the labeling of products for consumers to identify a specific region.

Traceability labeling and coding, such as that developed by the Produce Traceability Initiative, would mean finished product sent to retailers and foodservice operations could be traced back through the supply chain virtually immediately. (, 2016) The next step is to utilize existing regulatory mechanisms to inspire many fresh produce companies to adopt voluntary traceability labeling. Both internal and external traceability programs are needed to effectively track and trace product up and down the supply chain, achieving whole-chain traceability. At present, most companies have “internal” traceability programs, but not “external” traceability programs. Internal Traceability = confidential or proprietary data and processes companies use within their own span of operations to track/trace product. External Traceability = the data exchange and business processes that take place between trading partners to track/trace product. Whole-Chain Traceability = Internal + External traceability. (, 2016). Traceability is the key to executing a proactive retrieval of lots implicated in a suspected or confirmed pathogen-detection event. A quiet (notification not required) non-release or reverse-distribution of product that remains under the control of a produce shipper or handler is highly preferred, given the negative consequences of a recall notification of buyers or public health regulators. Though frequently referred to as a “market withdrawal,” this term is not strictly accurate for most produce shipping situations in the context of its FDA definition. Market withdrawal occurs when a product has a minor violation that would not be subject to FDA legal action, as would be the case in knowingly shipping adulterated food. This situation has become more common, though infrequent, as a direct consequence of the increased application of pathogen testing to fresh produce. This is especially problematic when lots are artificially created from a larger production or processing unit but only individual sub-lots are tested for specific buyers. Test results and their implications relative to a specific farm or production block may not be known prior to shipping of the linked lots. Arguably, product in a refrigerated transport vehicle may not be considered under the control of all parties. Newly enhanced traceability capabilities have undoubtedly played a key role in the rapid electronic notification and lot identification to prevent suspect product from reaching retail shelves and consumers.

One appealing aspect of improving internal traceability has been the recognition that data capture and analysis using manual bar code reading or automated identification systems, such as radio frequency identification (RFID) labels, is capable of significantly improving efficiencies and becoming a driver for improving unit operations. Tracking lot-associated data over time from site history, seed lot, all crop inputs, seasonal weather fluctuations, maturity and other factors may lead to the identification of patterns that affect quality, profitability and safety. (Suslow, 2009)

Seasonality of market suppliers may also contribute to identification delays of potentially pathogen laden produce. Some products are harvested during the winter months while others within the same region are summer producers activating a potentially different distribution network. Today we live and are serviced within a global supply network which is integrated and seamlessly woven into our food supply network. While lot monitoring mechanisms infused with binary response ques; the goal must be to provide consumers with safe quality foods and confidence in the supply chain behind the curtain.

Beach, C. (2017, April). Food Safety Magazine. Retrieved from Leafy greens industry says outbreak is opportunity to learn: (2016). PRODUCE TRACEABILITY INITIATIVE. Retrieved from

Suslow, T. (2009, April/May). Produce Traceability and Trace-back. Retrieved from Food Safety Magazine:

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