On February 5, 2004, the FDA wrote a letter to the lettuce and tomato industries to voice its concern about the frequent outbreaks linked to those products. In the letter, the FDA counted 14 such outbreaks since 1996 that it had investigated. Among other things, the letter stated:

In view of continuing outbreaks associated with fresh lettuce and fresh tomatoes, we strongly encourage firms in your industries to review their current operations in light of the agency’s guidance for minimizing microbial food safety hazards in fresh lettuce and fresh tomatoes, as well as other available information regarding pathogen reduction or elimination on fresh produce. We further encourage these firms to consider modifying their operations accordingly, to ensure that they are taking the appropriate measures to provide a safe product to the consumer. Since the available information concerning some of the recent outbreaks does not definitively identify the point of origin of the contamination, we recommend that firms from the farm level through the distribution level undertake these steps.

On September 30, 2005, a year and a half after the FDA’s 2004 letter to the lettuce industry, the Minnesota Department of Health issued a press release stating that 11 Minnesota residents had been infected by E. coli O157:H7 from contaminated Dole romaine lettuce. Two days later, the FDA issued a nationwide public health alert regarding Dole pre-packaged salads. Further investigation indicated that 22,321 cases of potentially contaminated Dole romaine lettuce had been sent to market from a processing facility in central California. Ultimately, at least 32 people were sickened in the outbreak.

One month after the 2005 Dole lettuce outbreak, the FDA wrote the industry again. The November 4, 2005 letter began as follows: “This letter is intended to make you aware of the Food and Drug Administration’s (FDA’s) serious concern with the continuing outbreaks of foodborne illness associated with the consumption of fresh and fresh-cut lettuce and other leafy greens.” The letter continued:

FDA is aware of 18 outbreaks of foodborne illness since 1995 caused by Escherichia coli O157:H7 for which fresh or fresh-cut lettuce was implicated as the outbreak vehicle. In one additional case, fresh-cut spinach was implicated. These 19 outbreaks account for approximately 409 reported cases of illness and two deaths. Although tracebacks to growers were not completed in all 19 outbreak investigations, completed traceback investigations of eight of the outbreaks associated with lettuce and spinach, including the most recent lettuce outbreak in Minnesota, were traced back to Salinas, California.

After pointing its finger steadily at central California, the FDA closed its 2005 letter to the industry by encouraging action to correct the problems within the industry, specifically outlining certain steps that the industry needed to take.

September 2006 changed everything. It was the month that the word “outbreak” truly became part of everybody’s vocabulary. It was the month that E. coli O157:H7-contaminated spinach caused 204 confirmed illnesses nationally; left 102 people hospitalized, 31 with hemolytic uremic syndrome (HUS); and caused three deaths . . . at least by the CDC’s official count. Among the dead were an elderly Wisconsin resident; a two-year-old Idaho boy named Kyle Algood; 81-year-old Ruby Trautz; 86-year-old June Dunning; and 83-year-old Betty Howard. And for those who survived their acute HUS illnesses, many will require a life-time of medical care, including kidney transplants, that may cost well over one hundred million dollars in the end accounting.

The large-scale investigation that followed, complete with an armed FBI raid, ultimately proved that the spinach had been grown, packed, processed, and bagged in the Salinas Valley, California.

On the heels of this devastating outbreak, fresh spinach sales stopped entirely for almost two weeks while the nation was gripped by a panic bigger than any it had before seen with respect to a single food product. Sales over the next several months plummeted from pre-outbreak levels. Ultimately, spinach sales did not reach pre-recall levels until the end of January 2008.

But the heavy impact of California failures wasn’t over yet, not even for the year 2006. Before the year ended, at least two more major lettuce-associated outbreaks hit: one at Taco John’s restaurants in the Midwest, and one at Taco Bell restaurants in the East; both as a result of contaminated iceburg lettuce grown in California. The Taco John’s outbreak left 81 people ill, 26 hospitalized and two with HUS; and the Taco Bell outbreak caused 71 confirmed illnesses, 53 hospitalizations, and eight cases of HUS. Again, traceback investigation in both outbreaks proved that the lettuce had gone to Taco John from the Bakersfield area and to Taco Bell from near Huron in the Central Valley.

Out the other end of this vortex came the Leafy Greens Marketing Agreement (LGMA). The LGMA website, states as follows:

In 2007 California farmers came together to raise the bar for food safety. As a result the California Leafy Green Products Handler Marketing Agreement (LGMA) was formed. Members of the LGMA are working collaboratively to protect public health by reducing potential sources of contamination in California-grown leafy greens.

To date nearly 120 handlers, representing approximately 99% of the volume of California leafy greens, have joined the LGMA. These companies have committed themselves to sell products grown in compliance with the food safety practices accepted by the LGMA board. LGMA membership requires verification of compliance with the accepted food safety practices through mandatory government audits. These food safety practices were developed by university and industry scientists, food safety experts and farmers, shippers and processors. California leafy greens are now grown under a unique system that has become a model for leafy green growers in other states.

It is in everybody’s interests for Salinas Valley to produce a safer product. The area is one of the largest exporters of fresh produce anywhere, accounting for 570 million pounds of the world’s produce exports every year. http://www.salinaschamber.com/ag_industry.asp. Salinas Valley produce goes to consumers across the country, as well as many of the world’s other major economies, including Canada, Japan, Hong Kong, Taiwan, Mexico, and the European Union.

Critical questions remain unanswered on the efficacy of the LGMA, and Salinas area processors’ efforts to implement its principles. Has this 3.8 billion dollar a year agricultural Mecca come up with any solutions to its complex problems? How well have the LGMA, the many lawsuits that individual producers have faced, and the FDA-led governmental pressure really worked? If not, why not? And what is the price of failure? More to come on this major public health issue.