Meg Miller:
Hello, this is PMA public relations manager Meg Miller, and welcome back to our audio blog, “Ask Dr. Bob” with PMA’s Chief Science & Technology Officer Dr. Bob Whitaker. There is so much happening on the food safety front right now that we decided to do a series of posts about PMA’s government affairs activities in that area.  Bob, I know there’s a lot of ground to cover, so where should we start in this first post?
 
Bob:
Meg, lots of food industry groups are involved in government affairs, so let’s start off by talking about how PMA is different. For many industries, the typical approach to government relations is to be combative, to try to avoid government oversight wherever possible – understandable since past government oversight has often meant more work and cost. But in reality, our industry can no longer expect to avoid government involvement, especially on issues like food safety.  Increased regulation is our new reality, and in fact it may help us restore consumer confidence in the safety of fresh produce. The best way to ensure smart, cost-effective governance of our industry is to work with those who govern us, help educate them about our industry and ultimately develop solutions that work for everybody.

For several years now, PMA has taken a “solution provider” approach, to inform and influence government. We don’t want to walk in the door of an office, say at the Food and Drug Administration, just to complain about some injustice; instead we want to be sure FDA understood the issue. Then we want to offer potential solutions that address FDA’s need to protect public health while at the same time not burden the industry with unnecessary requirements that don’t reflect good science or current industry practices. We view our role not as being there to argue, but rather to inform and influence. It’s a balancing act.

Meg:
So can I ask, how’s that working?

Bob:
We can already point to a number of recent examples when we and our members have told our stories and shared our industry insight – in testimony, during visits to Capitol Hill or different agencies, and in comments submitted about proposed regulations – where we know our voice has been heard and we’ve made a difference in the outcome.

Another difference is our new Government Relations Committee, which met for the first time in January. Its mission includes overseeing PMA’s food safety advocacy work. Members aren’t professional lobbyists – and that’s exactly the point. They’re business people who want to help tell our industry’s story to government, to help inform and influence.

Meg:
So our strategic approach to food safety government relations is to “inform and influence”. How does that manifest itself, exactly?

Bob:
We’ve begun referring to the food safety and technology work we do at PMA as our “practice”.  This practice includes our work in education, such as seminars, symposia, Fresh Connections, and food safety training – in research, for example, our work with the Center for Produce Safety – and in advocacy, that is, working with government affairs, outreach to regulatory agencies like FDA, the Centers for Disease Control and Prevention, the Department of Agriculture and visits to Congress. 

Additionally, our work on government affairs has two distinct components. The first is operational. Our operational work is very member- and industry-focused. What do our members need to know to ensure safe food, and how do we help them deal with current and future food safety rules or requirements? This further breaks down into non-emergency and emergency areas. On a non-emergency basis, we meet with members routinely to listen to and help them when they have problems. On the emergency side, it seems not a week goes by without a call from a member involved in some type of traceback investigation with FDA or a state health department. We can help members interpret testing data, advise them on a course of action, and even help with communications strategies.

Meg:
You mentioned there are two components?

Bob:
Yes, Meg, the second is governmental. Our work with government is really split between working with members of Congress and their staff, and working with the regulatory agencies. We work to improve their knowledge of our industry, and of the science of food safety. Often the information they need is as simple as where particular crops are grown at different times of the year, or how products are harvested and handled. We also extend into microbiology, genetics, and physiology — the science behind food safety.

Related to all this is the interaction we have with the academic community on food safety research. It’s an important bridge between our operational focus in helping members navigate government affairs and our efforts to work with the government directly. By working with the academic community to educate researchers on what our industry does, we can shape their food safety research to yield findings that our members can use to build science and risk-based food safety programs that will improve industry’s food safety performance. At the same time, we can also use this interaction to help ensure the government agencies that fund research, fund the best research.

The Center for Produce Safety in particular has taken on this task of working closely with our funded researchers to help them understand current industry practices and establish working relationships with individual companies, so their work is relevant to our industry.  Time will tell how valuable this approach is, but thus far I believe we are seeing fantastic productivity from researchers, and very effective interaction between the research community and the produce industry.  We will actually feature a session at the CPS’s second annual Research Symposium in Orlando, Florida in June on this interaction between industry and research.  I should also note that CPS has partnered with FDA to hold symposia where research priorities are discussed with industry. This helps complete the circle of academic food safety research, the industry and FDA working together to influence regulations based on science and risk.

Meg: 
Thanks so much, Bob. It is great to see how all these programs are connected and the scope of the work PMA and our volunteers are doing on food safety and government affairs. Next time we’ll talk about our specific areas of activity. Listeners, you can learn more about any of our food safety topics at AskDrBob.pma.com. Thanks for joining us!

Julia Stewart:
Hello, this is Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob” with PMA’s Chief Science & Technology Officer Dr. Bob Whitaker. Bob, we’ve just devoted 10 posts to talking about the in’s and out’s of testing fresh produce for food safety. So, let’s hear it, bottom line, what’s your thinking?

Bob:
Let’s be straight, right up front, our industry has seen far too many outbreaks, and we must be fully committed to the safety of our products. If product testing could keep contaminated produce from getting into the supply chain and making people sick, then the issues of supply chain disruption and added cost would be moot. At the very least, the supply chain issues with regard to perishability and the costs associated with product testing would have to be considered in context with other costs involved in implementing a comprehensive food safety program – and the marketplace would ultimately determine how best to sustainably absorb those costs.

In our previous posts on product testing, we’ve tried to lay out some of the benefits and limitations of the various types of tests currently being used in the industry. We’ve discussed the very real issues associated with product sampling.  We have tried to do this with an eye on the perishable nature of our products, and some of the science that lies behind current testing methods.  I hope our listeners have picked up a few nuggets to help them as they assess how to set up their own product testing programs.  As far as whether you should or should not do product testing, that’s a decision that each producer has to address individually.

In reality, when it comes to product testing, it seems that the “horse is already out of the barn”.  While the scientific basis of product testing is arguable with current technologies, the marketplace is making some form of product testing a requirement of suppliers of some commodities.  Essentially, that moves the issue of product testing from a scientific debate to a business decision.  We can understand why buying organizations might want their suppliers to do product testing from a liability perspective.  I’ve even heard from some buying organizations that believe their requirements for product testing, while it may have limited preventative value presently, will actually help the industry to produce safer food in the future by forcing the supply side to examine all risk factors.  I have to admit, the issue of product testing has kept food safety in the forefront of industry’s focus.

Simultaneously, we see a science-based group like the Food and Drug Administration that, despite being clearly aware of the technical pitfalls of product testing, is nonetheless increasingly using product testing to do surveillance in the marketplace.  That reality alone means the produce industry has to continue to focus on some of the issues we’ve raised in this series. Each company must be sure they fully understand what these tests mean and what actions they will take should their in-house testing program or a government testing program turn up a “positive” result for their products. 

Julia:
So what’s the bottom line?

Bob:
Bottom line, Julia… product testing is just one tool in our food safety toolbox. Companies that think they can test their way to safety with today’s technologies are potentially whistling in the wind, as they say.  Product testing is clearly a part of our landscape, but sometimes I wonder if all the resources that went into testing were instead leveraged against preventing contamination in the first place, whether our industry’s overall food safety performance might be more improved.

Product testing and sampling is clearly an area where further research is needed and I urge our listeners to use the Center for Produce Safety, the local universities and cooperative extensions, and other resources to closely monitor new innovations and developments in this area.

Julia:
This is certainly a challenging area for the industry and for researchers alike. Well, this concludes our series on product testing.  In addition to listening to these and other Ask Dr. Bob blog posts, we invite PMA members to visit our new online Food Safety Resource Center on PMA.com. We are regularly posting new food safety content there to help you meet your company’s food safety needs.

Please email us at askdrbob@pma.com if you’ve got a question you’d like to see Dr. Bob address in a future post. Thanks for joining us! In addition to listening to these and other Ask Dr. Bob blog posts, we invite PMA members to visit our new online Food Safety Resource Center on PMA.com and check out the lab testing white paper in the Education section.

Julia Stewart:
Hello, this is Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob” with PMA’s Chief Science & Technology Officer Dr. Bob Whitaker. We’re continuing to talk about the benefits and challenges in product testing. Bob, there is a tremendous amount of product testing going on today in some commodities. What are some of the things we should consider when looking at all this testing and the resulting data?

Bob:
I think there are three basic questions we need to ask about testing, as well as what this data may mean and what we might do with it:
1. What pathogens should we be testing for?
2. Does a positive test result necessarily mean that the product would cause disease? And,
3. How can a company use the data generated for product testing programs to improve its food safety program?

First, let’s take the question “What pathogens should we be testing for?” Today, you’ll find many companies who test for E. coli O157:H7 and Salmonella species – others add a test for nterohaemorrhagic E. coli or EHECs – meanwhile still others are beginning to look at shigatoxin-producing E. colis or STEC’s – and a few even include Listeria monocytogenes in their product testing protocols.  Meanwhile, there are still some who look for indicator species like generic E. coli or total coliforms, even though the correlation between these and actual pathogen contamination is questionable in produce. 

So, which organisms should we test for?  A producer needs to make the decision on what to test for based on the risk profile of the particular products they grow and produce, the timing window they have between testing and when they need to ship, and the costs involved.  It’s important to avoid a “one size fits all” approach.  Instead, we should employ a science- and risk-based approach to determine commodity-specific and/or pathogen-specific testing strategies. 

For example, let’s say we’re a tomato grower. Then we’d clearly want to prioritize testing for Salmonella species, since this pathogen is most commonly associated with tomatoes.  On the other hand, if we are a leafy greens grower, then we’d want to broaden the pallet of tests to include Salmonella and E. coli O157:H7 and perhaps consider adding EHEC or STEC’s to cover all pathogenic strains historically associated with these foods. 

Julia:
So let’s look at the second question: Does a positive test result mean the product would cause disease? 

Bob:
You can look at this question from a number of perspectives.  Clearly, the most important is public health.  The Food, Drug and Cosmetic Act – that’s the federal food safety law we in the produce industry are currently subject to – considers product that tests positive to be adulterated, and prevents that product from being put into commerce.  The Food and Drug Administration will always act first and foremost to protect public health.  Further, as of September 2009, you have the obligation to report any products that may pose a public health risk via the Reportable Food Registry – so, if you had a positive test result and the product is in the marketplace, you’d need to report that to FDA. 

From a strictly scientific perspective, we know that new strains of E. coli have emerged in the last 30 years, most notably, E. coli O157:H7; and, unlike its harmless brethren, as few as 10 cells of O157:H7 can cause significant health issues in a person, particularly children, the elderly or other at-risk populations. Conversely, we can now identify more than 2,000 strains of Salmonella, whose illness-causing dose rates are much higher than with E. coli O157:H7, if they cause human illness at all.  Also, Salmonella infection is generally not lethal, and we’re learning that Salmonella may be more common in the environment than originally thought. 

So, while the zero-tolerance approach currently mandated by the FD&C Act is appropriate for a pathogen such as E. coli O157:H7, today’s science may or may not justify such a strict standard for other, perhaps less harmful pathogens.  We’re also starting to understand that perhaps a positive PCR test result or even a bacterial culture may not necessarily correlate to that organism’s ability to cause human illness.  Research is showing that our screening for DNA fragments that are associated with the pathogen’s ability to produce toxin, or to attach to the intestines, might not by themselves be proof that the organism can cause disease.  Other factors such as the pathogen’s acid tolerance and the physiological state of the pathogen likely play a critical role. 

Julia:
So, how can the data generated by a product testing program be used?

Bob:
Obviously, enacting a product testing program is an important decision and a significant financial commitment.  So, it seems reasonable that a company that chooses to do product testing should look to use the resulting data to improve their food safety programs.  In order to do that, you must have procedures in place to receive testing data from lab partners, to store and sort that data, and then analyze the data so that trends can be identified and acted upon.  For instance, you may be able to use product testing data in conjunction with additional data from your GAP or HACCP programs to identify and prioritize specific risk factors.  As an example, a preharvest risk assessment that identifies an animal intrusion event has occurred may be used in conjunction with a concentrated in-field product testing program to verify if the intruding animal species carried a pathogen, and perhaps even what buffer zone distances are necessary to manage the potential risk. 

Julia:
Bob, you’ve raised some interesting issues here to consider when setting up product testing programs.  How much data from product testing do you think is out there in the industry?

Bob:
Julia, that’s difficult to say.  Right now, the clear focus has been in leafy greens crops.  Some companies have large, sophisticated product testing programs that have generated thousands of data points.  In the last year there’s been a great deal of discussion around how industry might combine some of this data or “mine” it to see if it’s possible to prioritize risks.  We talked about this with FDA during a meeting after the Center for Produce Safety’s research symposium in June.  Sometime in the near future, we should do a blog series on data mining, as it’s a subject all unto itself with a number of positive and negative aspects.

Julia:
That sounds good, Bob; I’ll hold you to it!  Speaking of holding you to it, I promised our listeners that as we concluded this blog series, you’d sum up the real value of product testing.  So next time in our final blog in this series, let’s summarize some of the discussions we have had on this subject and see what the plusses and minuses are.  Until then, thank you, listeners, and we’ll see you back here next time.