# Bad things happen, and then good things happen as a result



## daveomak.fs (May 9, 2019)

*There’s good call for optimism, but grave reasons for concern remain*
By Coral Beach on May 8, 2019


The pattern is well established. Bad things happen, and then good things happen as a result. 

But, one man who is uniquely positioned to peer into the future with an informed eye doesn’t think the food industry or government need to wait for the next crisis to take the next big step toward safer food.

In his keynote presentation this morning at the 21st annual Food Safety Summit, Mike Taylor, formerly of the FDA and the USDA, said the triad of consumers, government and industry can make enormous progress toward safer food based on what they know right now. And Taylor has the personal experience and first-hand knowledge to know what people know.

With four bullet points on food safety crises, Taylor illustrated how desperate situations sparked meaningful change in the past 25 years:


Jack in the Box and a deadly E. coli outbreak led to mandatory HACCP (Hazard Analysis and Critical Control Point) plans;
BSE in the UK preceded GFSI;
Spinach and another deadly E. coli outbreak spurred the industry to develop Leafy Greens Marketing Agreements;
Produce, peanuts and melamine drove Congress to approve the Food Safety Modernization Act.
A fifth bullet point — romaine lettuce — is yet to trigger the sweeping changes of attitude and practices needed for the next giant step forward. It is an example of how a change in direction by some can help move others toward a new destination, Taylor said.

Leaders in the leafy greens industry are beginning to take meaningful action in the wake of two large E. coli outbreaks in 2018 that were associated with romaine lettuce. Taylor said one crucial step they have taken is to increase the distance between produce growing fields and feedlots, or concentrated animal feeding operations (CAFOs) as they are sometimes called. 

Previously the Leafy Greens Marketing Agreements for growers in California and Arizona called for 400-foot buffers between feedlots and produce fields. In the wake of the 2018 romaine outbreaks, that distance has been quadrupled. 

The organizations, whose members produce almost 90 percent of the leafy greens grown in the United States, have also adopted new water testing and treatment procedures. Members must comply with LGMA procedures or face expulsion, which means tremendous potential for lost revenue — many if not most buyers already insist that their leafy greens suppliers be LGMA members in good standing. 

“The LGMAs’ new water metrics are a big, big step. They are even tougher than those in the FSMA Produce Rule,” Taylor told *Food Safety News* during a phone interview. He cautioned that it’s not just more stringent testing and treatment rules that will make a difference in the long run. 

The water precautions touch on a bigger, more pervasive food safety threat. Taylor said he hopes the new awareness will impact the safety of all foods grown in fields, especially fresh produce, which is usually consumed without having gone through a kill step.

“They (the LGMA water rules) establish the presumption that surface water is dangerous,” Taylor said, “especially if it’s used within 21 days of harvest. … You must test and treat. You have to. No question.”

Taylor said the 2018 romaine E. coli outbreaks are the bad things that are leading to good changes, but some players in the food industry are still not willing to act. They want more examples of why practices dating back a century need to be changed.






Mike Taylor delivers the keynote address at the 2019 Food Safety Summit on May 8. _Photo by Dan Flynn_
“The cattle people probably aren’t going to be very happy with me today,” Taylor said, referring to the food safety problems created when those in animal agriculture put on blinders and encourage others to do the same.

“The cow people won’t let folks come in and collect samples. We need a microbial map, otherwise you’re just pretending (to address food safety),” Taylor said.

People in the meat industry have long chanted the retort “show me the data” but they won’t allow the data to be collected, much less analyzed. 

For example, the owners of the McElhaney Five Rivers feedlot in the Yuma, AZ, area only allowed outbreak investigators very limited access to the 100,000-plus head operation. It is adjacent to lettuce fields and the open air canals that provide irrigation water for them. The denial of access is particularly troubling considering the two large-scale, nationwide E. coli outbreaks in 2018 were associated with romaine grown in the area, Taylor said.

Other CAFO operators in other areas are similarly closed-minded, keeping their gates closed when researchers from academia and government have sought permission to test dirt, dust and runoff water.

There is virtually no doubt in the scientific, industry, consumer and government communities that the E. coli bacteria found in the Arizona canal water is linked to contaminated dust and or runoff water from the massive feedlot. But there is still a disconnect as far as the animal agriculture sector is concerned.

“The vectors for the transmission of pathogens from feedlots is incredible,” Taylor said. “Look at the picture of the feedlot. Look at the canal in it. You’ve got a glaring hazard.” 

Taylor said he is confident, though, that the wind is changing. Consumers are more aware and are demanding answers and action from industry and government. Some in the industry are pursuing innovative alternatives to the status quo. Government is approaching new standards and oversight from a prevention point of view.

The alignment of goals and strategies is key, Taylor said, ticking off four more bullet points:


Foodborne illness is bad for everyone;
Comprehensive prevention strategies are what works; 
Continuous improvement is required as challenges evolve; and
Strong food safety cultures are the foundation for sustained good performance
Taylor said he believes the driving force behind the winds of food safety change in the United States is the community of individuals and entities that constitute “the buyers.” Whether they be individual consumers, regional grocery chains or mega-retailers, when buyers won’t buy unless there are meaningful food safety measures in place, producers have no choice but to move into the 21st century.

He is optimistic about the situation.

“At least we’ve seen a significant change in direction among some,” Taylor said. “Hopefully that can get key players to commit to a better path.”






*Mike Taylor
About Mike Taylor: *_The FDA’s Deputy Commissioner for Foods and Veterinary Medicine from 2010 to mid-2016, Mike Taylor is co-chair of the board of the non-profit consumer advocacy group Stop Foodborne Illness. Earlier in his career, Taylor began his government service as a staff attorney at FDA, where he worked on seafood safety and nutrition labels. Later Taylor worked for USDA’s Food Safety and Inspection Service, where he became acting undersecretary for food safety. Taylor was the government official who, after the deadly 1992-93 Jack in the Box hamburger outbreak, ruled that the pathogen E. coli O157: H7 is an adulterant in meat. Taylor also practiced law in the private sector_.

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