It is said that federal "Good Agricultural Practice" guidance ensures that fresh produce does not transmit pathogenic foodborne illness. Is this a reasonable inference?

The federal government’s Good Agricultural Practice (GAP) guidance offers advice with respect to the use of manure. The relevant text is reproduced below.

Basically, the guidance exhorts growers to be careful. Beyond that, it’s not very illuminating. Here is what GAP says about animal manure:

• "Growers must also be alert to the presence of human or animal fecal matter that may be unwittingly introduced into the produce growing and handling environments."
• "A variety of treatments may be used to reduce pathogens in manure and other organic materials. Treatment may be performed by the grower using organic materials generated on the farm or by a supplier. Choice of treatment will depend on the needs and resources of an individual grower or supplier."
• "A variety of treatments may be used to reduce pathogens in manure and other organic materials. Treatment may be performed by the grower using organic materials generated on the farm or by a supplier. Choice of treatment will depend on the needs and resources of an individual grower or supplier."
• "Management practices required to achieve the time and temperature necessary to eliminate or reduce microbial hazards in manure or other organic materials may vary depending on seasonal and regional climatic factors."

The GAP’s manure management suggestions seem equally unremarkable:

• "Manure storage and treatment sites should be situated as far as practicable from fresh produce production and handling areas."
• "Consider barriers or physical containment to secure manure storage or treatment areas where contamination from runoff, leaching, or wind spread is a concern."
• "Consider good agricultural practices to minimize leachate from manure storage or treatment areas contaminating produce."
• "Consider practices to minimize the potential of recontaminating treated manure."
• "Consider incorporating manure into the soil prior to planting."
• "Applying raw manure, or leachate from raw manure, to produce fields during the growing season prior to harvest is not recommended."
• "Maximize the time between application of manure to produce production areas and harvest."
• "Where it is not possible to maximize the time between application and harvest, such as for fresh produce crops which are harvested throughout most of the year, raw manure should not be used"

Elsewhere, the GAP says the federal government is largely ignorant about the pathogenic risks posed by manure:

• "Research on pathogen survival in untreated manure, treatments to reduce pathogen levels in manure, and assessing the risk of cross-contamination of food crops from manure under varying conditions is largely just beginning" (emphasis added).