August 4th, 2023 – Pre-Harvest Testing
Channah Rock & Trevor Suslow, UA & TS Consultants
Address flooding requirements.
Submitted Comments
August 4th, 2023 – Pre-Harvest Testing
Teressa Lopez, Arizona Leafy Green Marketing Agreement
Submitted Comments
July 31st, 2023 – Pre-Harvest Testing
Greg Komar, CA Leafy Green Marketing Agreement
Proposed language for Flooding and romaine testing and data sharing was submitted at the beginning of the comment period. This new proposed language has edited 2 parts to the original flooding proposal and 1 part to the romaine testing and data analysis program. The flood edits include returning the original flooding buffer distance from the proposed 100 feet to 30 feet and only requiring pathogen testing when doing soil testing which removes generic E. coli or fecal coliform as required indictors. There is also an edit to the romaine testing parameters for acre size that is correcting an error from the original submission. The change to the acreage size for sampling is less than or equal to 10 acres vs less than 10 acres.
Submitted Comments
July 27th, 2023 – Pre-Harvest Testing
Dr. Gurmail Mudahar, Tanimura & Antle
Submitted Comments
July 7th, 2023 – Pre-Harvest Testing
Greg Komar, CA LGMA
The California Leafy Green Marketing Association submitted comments to the Pre-Harvest Testing Issues in the LGMA-approved Metrics
Download Submission
Submitted Comments
Hilary Thesmar – FMI
FMI on behalf of our retail, wholesale and product supplier members support the changes made to the commodity specific food safety guidelines. This is an important step forward and we encourage Western Growers and LGMA to continue to advance the food safety guidelines as we learn more about preventing contamination during production, harvesting, processing, storage and distribution.
February 15th, 2023 – Pre-Harvest Testing
Submitted Comments
Teressa Lopez – Arizona Leafy Greens Marketing Agreement (LGMA)
February 14, 2023
Arizona Leafy Greens Technical Subcommittee Comments on Pre-Harvest Product Testing
The Arizona Leafy Greens Technical Subcommittee (TSC) met on February 14th 2023, the meeting agenda included a review and discussion of the proposed document, 18. Issue: Pre-Harvest Product Testing (PHT) Pilot Program for Romaine. After careful consideration, the Arizona Technical Subcommittee supports a research approach based on environmental hazard and risk assessment rather than a LGMA metrics pilot program concept to accomplish the goals outlined in the introductory paragraph of section 18.
The Arizona TSC concurs with the statements regarding the potential benefits of a pre-harvest product testing program and insights into food safety system performance. As stated, “pre-harvest testing program’s objective is to increase the understanding of how practices may affect contamination, contamination prevalence over time, risk factors, and to inform the continual improvement of industry prevention efforts.” In an effort to reinforce this work the Arizona LGMA did adopt standards that require shippers that are conducting PHT to have standard operating procedures (SOP’s) to guide their programs. Additionally, the Commodity Specific Food Safety Guidelines for the production and harvest of lettuce and leafy greens (Metrics) require that PHT be completed if the environmental assessments deem it necessary.
The Arizona TSC believes if we are to aid the industry in the understanding of risk potential and prevention strategies, a research study should be designed and conducted based on a standardized sampling protocol, assessment of field and adjacent land hazards and risk factors, mitigation strategies, differences in product characteristics, and evaluation of sampling plan designs at a minimum.
The LGMAs are structured to verify metrics compliance and train to those findings. The Arizona TSC believes there is a substantial amount of data that needs to be compiled and evaluated to provide meaningful trend and/or risk analysis to inform future commodity specific best practices and guidance. The Arizona LGMA has the ability to fund this type of research if it improves the Metrics. Broad industry support and participation will be needed to conduct such a research project. The LGMAs are positioned to not only provide input into the scope of a PHT research project, but to facilitate and encourage industry involvement and standardization. The completed research may be utilized to inform future metrics.
The Arizona LGMA and the Arizona Attorney General’s Office is currently evaluating the ability and legality of implementing the proposed 18. Issue: Pre-Harvest Product Testing Pilot Program for Romaine. This evaluation will include a review of disclosure statements and conflicts of interest.
With that said the AZ TSC would like the following clarifications and considerations:
1. Provide a clearer definition of monocultured romaine with respect to mini/midi or petite varieties of romaine that includes these types of romaine in the description or offers a days-to-maturity clarifier.
2. Provide a clearer definition of regionality.
3. AZ TSC asks for clarification on expectations of pooling sample.
4. AZ TSC asks for an overview of expectations and capabilities for laboratories on the proposed method.
5. AZ TSC asks for clarification on why STEC and Salmonella were removed from the original draft.
6. AZ TSC supports the removal of Appendix I until there is scientific research to support the outlined distances. Additionally, Arizona and California LGMA are about to pilot an Environmental Assessment Tool that will help standardize the evaluation of risks and the mitigations strategies utilized to minimize those risks that will be helpful in overall risk evaluation.
The Arizona TSC advocates continuous improvement and the use of the most currently applicable research as a guide to inform that improvement process. We recognize that participating in the Western Growers review process helps to achieve these goals and appreciate being a part of the first review of PHT. We would like to point out that we were not invited to participate in the most recent discussion on PHT and therefore seek a better understanding of some of the recent changes.
The Arizona TSC appreciates Western Growers facilitation of the metrics review process but would like to ask why the calendar for annual public comment timeline was changed and why industry was not given the same historical timeframe of 30 days for public comment as listed as the process on the leafygreensguidence.com website. Additionally, going forward the AZ TSC would like for there to be a way to submit the inline tracked changes document to the submissions page.
Thank you,
Arizona Technical Subcommittee
Greg Komar – CA LGMA
California region recommendations:
o Salinas Valley (North of Gonzales)
o Gilroy, Hollister and San Juan Batista area
o Santa Maria
o Imperial Valley
o Bard
o Salinas Valley (South of Gonzales)
o Watsonville area (Santa Cruz county)
o Oxnard
o Huron (Central Valley)
Will the program include “What is a Positive”? Will each Handler use their own definition of “Positive”? Some handlers may declare a positive based on a presumptive test result. Some handlers may send their presumptive sample to a lab to be cultured out. Some handlers may send their presumptive to be molecularly confirmed. If the program provides instruction on how the conclusion of “Positive” is reached, then all Handlers should use the same process. If the program does not want to provide a defined process for a conclusion of “Positive”, perhaps Handlers should report their method for determining “positive”, whether it based on presumptive, cultured or molecular method, and the lab associated with each result.
Dr. Gurmail Mudahar – Tanimura & Antle Fresh foods
Pre harvest testing Comments AZ
Gurmail Mudahar Ph.D. Food Science
VP R&D and Food Safety Tanimura & Antle
LGMA’s Proposed Appendix C for Pre harvest crop sampling and testing is based on the following assumptions:
1. Contamination is present at >1 CFU per pound, ie; in 30,000 heads (1.5 lbs each), there must be more than 45000 CFU of pathogens present per acre of romaine. To achieve 95% confidence, 5% of romaine heads (>1500 heads/ per acre) must be contaminated.
2. Contamination is randomly distributed throughout the lot
3. Maximum lot area is 40 acres. Nominal sample lot area is <5 acres increments in the lot.
4. Sample number is N60 and sample specimen size of 2.5 g to 25 g each.
5. Outer edible leaves of romaine are representative of contamination in a head.
This plan has serious technical errors and unrealistic assumptions as following:
1. When all GAP and LGMA requirements are implemented and verified by CDFA/ AZ inspectors, chances of very high level contamination (5% heads) in a normal field of romaine is extremely rare. This situation can happen only if there is any risk situation such as storm, floods, contaminated irrigation water or close proximity to a CAFO. There must be a pre requisite crop Assessment that should help to identify if the crop in a specific lot is exposed to very high levels of contamination and thus qualify for pre harvest testing. There should not be any need of testing of those lots that do not qualify for testing based on risk assessment
2. In order to achieve consistent and valid microbial results, all testing parameters should be fixed. Using same numbers of N for various size sampling lots (i.e.; 1, 5 or 40 acres) do not provide consistent and same results. There are 40 times more chances that pathogens will be detected from 1 acres than 40 acres using 60n sampling plan. For detecting random contamination, N should be proportional to the sampling lot area or there should be only one fix sampling size.
3. In order to achieve consistency in results, sample preparation and specimen size must be same at all the time. Considering average weight of edible outer leaves of romaine hearts is 25+5 g and open romaine is 35+5 g, suggested specimen weights of 2.5-25 g are not realistic. Moreover, one full or partial leaf (as suggested) is not representative of the entire head. Ideally, sample specimen should be representative of the entire edible portion of a head i.e.; cross section slice from middle area of the head that should include inner as well as outer leaves.
Considering very low level and sporadic type of contamination, routine testing of fruits and vegetables is not recommended by ICMSF (International Commission on Microbiology Specifications of Foods), United Fresh Produce Association and many more experts including Mr. Devon Zagory (a well-known expert on produce safety).
Food Safety is extremely important for our industry, however, proposed pre-harvest testing plan will not help in improving food safety but will provide a false sense of security and mislead customers and consumers.
References:
1. Would my sampling plan have detected contamination levels that resulted in outbreak? 2020 United Fresh Work group white paper.
2. Microbiological testing of fresh produce, A white paper of United Fresh Association 2010.
3. Microorganisms in Foods 2: Sampling for Microbiological analysis: Principles and specific applications. Pg. 198.
4. Microbiology testing of Fresh produce: Where is Value by Devon Zagory.
Jan 10, 2023
June 15th, 2022 – Pre-Harvest Testing
Greg Komar, Pre-harvest Testing Working Group
The Pre-harvest Testing Working Group submitted comments to the Pre-Harvest Testing Issues in the LGMA-approved Metrics.
Submitted Comments
Vicki Scott – Arizona LGMA
Arizona Technical Subcommittee Comments on Pre-Harvest Testing
July 6, 2022
The Arizona Technical Subcommittee (TSC) met on June 30, 2022. The agenda included a review and discussion of the proposed 18. Issue: Pre-Harvest Product Testing Pilot Program for Romaine. After careful consideration, the Arizona Technical Subcommittee supports a research approach based on environmental hazard and risk assessment rather than a LGMA metrics pilot program concept to accomplish the goals outlined in the introductory paragraph of section 18.
The Arizona Technical Subcommittee concurs with the statements regarding the potential benefits of a pre-harvest product testing program and insights into food safety system performance. As stated, the “pre-harvest testing program’s objective is to increase the understanding of how practices may affect contamination, contamination prevalence over time, risk factors, and to inform the continual improvement of industry prevention efforts.
The Arizona TSC believes if we are to aid the industry in the understanding of risk potential and prevention strategies, a research study should be designed and conducted based on a standardized sampling protocol, assessment of field and adjacent land hazards and risk factors, mitigation strategies, differences in product characteristics, and evaluation of sampling plan designs at a minimum. The LGMAs are structured to verify metrics compliance but not to compile and evaluate the substantial amounts of data needed to provide meaningful trend and/or risk analysis to inform future commodity specific best practices and guidance.
Broad industry support and participation will be needed to conduct such a research project. The LGMAs are positioned to not only provide input into the scope of a pre-harvest product testing research project, but to facilitate and encourage industry involvement. The completed research may be utilized to inform future metrics or standards.
The Arizona LGMA members of the metrics review work group previously provided comments on the proposed draft document to be considered in the upcoming webinar on July 13th. It is the Arizona Technical Subcommittee’s intent to have those comments shared within the webinar for the benefit of the attendees. We also offer the following for consideration (new comments):
1. AZ TSC asks that the audience be polled regarding whether a
hazard/risk assessment based sampling protocol or the prerequisite sampling protocol as proposed is preferred.
2. AZ TSC recommends a poll to assess attendee opinion on whether romaine should be the only commodity tested within the pilot.
3. Provide a clearer definition of monocultured romaine with respect to mini/midi or petite varieties of romaine that includes these types of romaine in the description or offers a days-to-maturity clarifier.
4. Revert to the earlier requirements concerning target organisms that includes EHEC with a note that the LGMAs need to revisit other metrics sections with references to only STEC. Arizona work group members’ initial concern was regarding harmonization with the overall document requirements.
5. Clarify the intended status of WG Appendix I.
6. Clarify why the new Appendix L is being created rather than incorporating the content intended for Appendix L into the existing Appendix C.
The Arizona Technical Subcommittee advocates continuous improvement and the use of the most currently applicable research as a guide to inform that improvement process. The Arizona Technical Subcommittee appreciates Western Growers facilitation of the metrics review process and the association’s enlistment of subject matter experts to provide advice during the 2022 review.
Thank you,
Arizona Technical Subcommittee
Gurmail Mudahar – Tanimura & Antle Fresh foods
Comments on Pre Harvest Product Testing Pilot Program for Romaine.
Gurmail Mudahar Ph.D. Food Science
Vice President, R&D and Food Safety , Tanimura & Antle Inc.
After learning from several Pre-harvest working group and WGA members, that outcome of the pre-harvest test pilot study will be used to fill knowledge gaps such as determination of buffer distances from high risk environmental and animal holding areas, I agree with the work group that there is a need for a large scope study in collaboration with the industry to understand real environmental risk to leafy greens. However, in order to conduct this study accurately, scientifically and with maximum involvement of industry, I have following concerns and suggestions:
1. Since the proposed study will be conducted at grower level, ideally, a grower Association such as WGA or another independent organization should manage this study. This study should not be associated with LGMA metrics, until recommendations of the study are published. However, LGMA can help in facilitation of the study.
2. Overall objective of the Pilot study need to be defined. The design of study must outline following details related to its objectives:
a. Hypothesis and expected outcome of the study needs to be defined. identify growing areas where samples to be taken.
b. Study need to consider if products grown differently such as romaine hearts vs. open romaine show different levels of pathogen presence.
c. Study must explain on who and how data will review and publish findings of the study.
In order to understand environmental risk in various growing areas and type of romaine, following experimental design and data collection form is suggested:
Sampling region Type of romaine
Closed head romaine (hearts) Open head romaine
Total samples STEC (% positives)* Salmonella (% positive)* Total samples STEC (% positive)* Salmonella (% positive)*
Salinas Valley (N of Gnzalas)
Salinas Valley (S of Gnzalas)
Hollister area
Watsonville area
Santa Maria
Imperial Valley
Gila Valley
Yuma Valley
Bard
Dome. Welton,
Huron
*Note: Root cause Analysis of all positive samples must be submitted.
3. Proposed crop testing time line before harvesting is not realistic. Due to sudden changes in weather, customer demand and logistics, occasionally harvesting decision are made on the day of harvest. These situations may not allow taking pre-harvest samples from the field as described in the proposed pre-harvest testing plan. This study should consider Pre-shipping (instead of pre-harvesting) testing timeline options for such situations.
4. Proposed sampling plan is very confusing, complicated and does not differentiate between smaller and large growing lots (10-40 acres). Sampling plan based on 90 percent of confidence may not generate realistic outcome of the study. To avoid sampling confusion, having higher level of confidence (95%) and be reasonable to smaller and commodity growers, a sampling plan similar to United Fresh White Paper recommendations should be considered as following:
If Lot sizes <10 acres or <10,000 cartons (24 ct equivalent): 1 set of 375 g each
If Lot size 10-20 acres or 10,000-20,000 cartons (24 ct equivalent): 2 sets of 375 g each
If Lot size 20+ acres or more than 20,000 cartons (24 ct equivalent): 3 sets of 375 g each
Gurmail Mudahar
July 4, 2022
Amanda Brooks – Yuma Safe Produce Council
Thank you for the opportunity to comment on the Pre-harvest Testing Working Group’s submission. The Yuma Safe Produce Council (YSPC) supports pre-harvest testing when risk assessments deem it is necessary. For cause testing applying to all leafy greens should be implemented to prevent potentially contaminated produce from being harvested. Identifying hazards and assessing risk are the primary role of the food safety professional and thus, they should have adequate training. All producers should have pre-harvest testing SOPs for when hazards present a risk. Data derived from pre-harvest testing can provide valuable information to industry and we encourage sharing of such data however this should be voluntary.
Historically, the LGMAs have leaned on academia to help fill knowledge gaps. Research is a key component to the continual improvement of industry prevention efforts and LGMAs should support efforts to learn about industry practices, contamination, and risk factors. The Work Group’s submission falls short in meeting all the pilot programs objectives because it does not provide a plan for how data will be aggregated and analyzed. Instead of breaking course, the LGMAs should rely on academia to collect, analyze, and provide the data necessary to inform the metrics.
The work group’s submission will add significant costs and logistical challenges for signatories. The YSPC does not support a mandatory romaine testing program or pilot program and would like the LGMAs to consider a risk-based approach to pre-harvest testing that covers all leafy greens while supporting and potentially funding research projects that will aid in the continual improvement of prevention efforts.
Yuma Safe Produce Council
June 14th, 2022 – Pre-Harvest Testing
Aaron Anderson, Pacific International Marketing
The Pacific International Marketing submitted comments to the Pre-Harvest Testing Issues in the LGMA-approved Metrics.
Submitted Comments
May 31st, 2022 – Pre-Harvest Testing
Amanda Brooks, Yuma Safe Produce Council
The Yuma Safe Produce Council submitted comments to the Pre-Harvest Testing Issues in the LGMA-approved Metrics.
Submitted Comments
May 27th, 2021 – Adjacent Land Use/Production Locations
Amanda Brooks, Yuma Safe Produce Council
The Yuma Safe Produce Council submitted comments to the Adjacent Land Use/Production Location Issues in the LGMA-approved Metrics.
Submitted Comments
May 27th, 2021 – Adjacent Land Use/Production Locations
Kay Pricola, IVVGA
This submission provides comments from the IVVGA regarding Adjacent Land Use/Production Location Issues in the LGMA-approved Metrics.
Submitted Comments
May 27th, 2021 – Adjacent Land Use/Production Locations
Teressa Lopez, AZ LGMA
This submission supports the CA LGMA and the Adjacent Land Use Subcommittee comments.
Submitted Comments
May 26th, 2021 – Adjacent Land Use/Production Locations
Greg Komar, CA LGMA
This submission proposes updates to the glossary, acronyms, appendix list, Issue 5, Issue 15, and Table 7 of the LGMA-approved metrics.
Submitted Comments
April 27th, 2021 – Soil Amendments/Non-Synthetic Crop Treatments
Don Stoeckel, private citizen
This document suggests edits, clarifications, and changes to the Soil Amendments / Non-Synthetic Crop Treatments section of the LGMA-approved metrics.
Submitted Comments
April 27th, 2021 – Soil Amendments/Non-Synthetic Crop Treatments
Bill Hsu, Taco Bell
This document, submitted on behalf of the Leafy Greens Safety Coalition (LGSC), suggests changes to the Soil Amendments / Non-Synthetic Crop Treatments section of the LGMA-approved metrics.
Submitted Comments
April 27th, 2021 – Soil Amendments/Non-Synthetic Crop Treatments
Teressa Lopez, AZ LGMA
This submission represents a review of the proposed CA LGMA Soil Amendments / Non-Synthetic Crop Treatments revisions by the AZ LGMA Technical Subcommittee.
Sources Used:
Submitted Comments
April 26th, 2021 – Soil Amendments/Non-Synthetic Crop Treatments
Greg Komar, CA LGMA
In this submission, the CA LGMA provides suggested revisions to the Soil Amendments/Non-Synthetic Crop Treatments and Glossary sections of the LGMA approved metrics.
Sources Used: Fate of Coliform Bacteria in Composite Beef Cattle Feedlot Manure
Submitted Comments
April 26th, 2021 – Soil Amendments/Non-Synthetic Crop Treatments
Amanda Brooks, Yuma Safe Produce Council
The Yuma Safe Produce Council provided comments and suggestions for the Soil Amendments/Non-Synthetic Crop Treatments section of the LGMA-approved metrics.
Submitted Comments
June 12th, 2020 – Field Sanitation
Greg Komar, CA LGMA
This document contains the CA LGMA’s proposals and comments to the Field Sanitation section.
Submitted Comments
May 27th, 2020 – Field Sanitation
Teressa Lopez, AZ LGMA
In this document, the AZ LGMA proposes consolidating similar bullet points, transferring best practice bullet points into SOP’s, and created new suggested language to different areas of emphasis. The key areas of modification are Harvest Equipment and Tools SOP, Harvest Containers, and Food Packaging Materials.
Submitted Comments
May 4th, 2020 – Water Amendment
Greg Komar, CA LGMA
In the accompanying document, you will find suggested changes to be made to the LGMA-accepted food safety practices in the area of agricultural water (specifically related to drip and furrow irrigation and application of chemicals). The document includes new best practice language, enhancements to sampling requirements for system-based water use, enhancements to the post-harvest water section, and a new section for chemical water application water.
*This document is a revised version of the April 7, 2020 submission from Greg Komar with the CA LGMA.
Submitted Comments
May 4th, 2020 – Water Amendment
Teressa Lopez, AZ LGMA
The accompanying document includes comments and suggestions on chemical compatibility, physical disinfection, on farm practices regarding harvest and post-harvest contact, and more.
Submitted Comments
May 4th, 2020 – Water Amendment
Amanda Brooks, Yuma Safe Produce Council
This proposal provides notes and suggestions on chemical compatibility, agricultural water treatment, document consistency, and root cause analysis.
Submitted Comments
May 4th, 2020 – Water Amendment
Paul Monadragon, Ag Partners SW
The document suggests including additional components within the metrics that make clear (more clear) that UV is an equally acceptable approach to be used.
Submitted Comments
May 4th, 2020 – Water Amendment
Lacy Litten, Innovation Produce
The focus of this proposal is on agricultural water systems, sourced mainly from Type A wells commonly found in the Santa Maria and Salinas Valleys. While Type A well water likely carries the lowest risk, the most recent metrics revision only gives a snapshot of water quality through initial and routine testing. The proposal suggests allowing monthly water sampling to verify water quality throughout the entire growing season. There are no proposed changes to Type B water nor B->A water.
Submitted Comments
May 4th, 2020 – Water Amendment
Jeremy Vanderzyl, Duncan Family Farms
This proposal includes a request to change the current treatment and sampling metrics to remove the rigidity of compliance and instead focus water sampling as a tool to developing risk assessments and allow for flexibility in the treatment process.
Submitted Comments
April 7th, 2020 – Water Amendment
Greg Komar, CA LGMA
In the accompanying document, you will find suggested changes to be made to the LGMA-accepted food safety practices in the area of agricultural water (specifically related to drip and furrow irrigation and application of chemicals). The document includes new best practice language, enhancements to sampling requirements for system-based water use, enhancements to the post-harvest water section, and a new section for chemical water application water.
Submitted Comments
Mark Shakespeare – Walmart Inc.
a) Furrow irrigation – require an addition to irrigation records that notes that furrow irrigation water did not come into contact with the edible portion of the crop if applied < 21 days before harvest.
b) Furrow irrigation – if furrow irrigation water does contact edible portion of the crop < 21 days before harvest, then this would trigger corrective actions (irrespective of the water quality microbiological test results).
The 2024 LGMA Approved Guidelines Amendment Process
Western Growers supports the continuous improvement of the LGMA-approved leafy green food safety guidelines and facilitates a yearly systematic amendment process.
Starting in 2022, the “Priority Setting Committee,” established by the LGMAs, is responsible for assessing annual priorities. At the beginning of each year, the Priority-Setting Committee sets the topic(s) for the remainder of the year.
Submit Comments
Important Documents
Harvesting Equipment Sanitation Working Draft (Download Here)
Water Working Draft – FSMA Ag Water Rule Alignment (Download Here)
Participate in the Process
If you are interested in summitting comments to for the proposed working drafts, follow these submission guidelines:
- Download the “Working Draft” under Important Document
- Use the Word function “New Comment” to provide details on how the proposed change will enhance food safety, along with the rationale behind the change
- When you are ready to submit please submit your document by clicking on “Submit a Comment” button below. This will take you to a form where you can attach a new version of the working draft with your comments.
Note: We are only accepting proposals that follow the above steps. Comment should be submitted as a word document, scientific rationale should be included for comments submitted.
Important Dates and Events
| Event | Dates | Details |
|---|---|---|
| Priority Setting Process | Jan 15th – Mar 1st | Find a copy of the report and supplemental documents |
| Priority Working Process | Mar 1st – May 31st | WG and CA LGMA select the Priority working group. WG facilitates working group meetings. The priority working group proposes science-based changes for the set priority. |
| Comment Submission Process Begins | June 3rd | Comment period begins. WG, LGMA announce comment period being open |
| 30 day – comment period | June 3rd – July 2nd | The public submits comments through this website |
| Webinar – review comments and proposed changes | July 11th at 1 PM PT | WG hosts a webinar. Public comments are reviewed and vetted
Register here |
| Final Report | July 15th | WG prepares a report of comments and public vetting for the CA LGMA board to consider and discuss |