lized. This approach may result in some
uncertainty, but the number of “
possible sources” should be finite. When
aligned with patient point-of-purchase
and illness onset date information, one
could rule out lots, brands, or regions
that were not involved.
2. Public health agencies should get
more specific sooner in their patient interviews. “Leafy greens” and “romaine”
are essentially catchalls. We need to give
the American consumer more credit.
They know whether they eat organic,
what brands they prefer, where they
eat, how often they eat what, and what
they eat. No one eats just “romaine.”
If we take the rather unique circumstance of the “Thanksgiving” strain of
E. coli O157:H7 that seems to reappear
each fall, as soon as the whole-genome
sequence is one that has a previous
product association, food history questionnaires should begin to get specific
very quickly. While there is concern
about drawing conclusions prematurely,
we must also use historical knowledge
to attempt to reach a resolution more
3. We need to rethink the traceback
approach when it comes to produce.
Common distribution patterns, specific
markets, source locations, and regional-ity can all be incorporated at the front
end of an investigation. Recognizing
that FDA may be trying to put a legal
case together throughout the investigation, there is an opportunity to identify
the source from a different angle if we
begin to approach investigations with a
public health focus. Rather than trying
to work backward step by step, why not
try to figure out what supply went into
the point-of-purchase locations involved
from the front end? By and large, the
supply chain knows where their product goes from the moment it ships out
the door. It may seem daunting at first
glance, but it’s worth a shot. In fact, it
is a shotgun approach and something
will hit the target. If it doesn’t line up,
it doesn’t line up. This does not mean
that the food industry must constantly
upload all traceability data to a central
repository on an ongoing basis. Rather,
as an investigation unfolds and illnesses
occur only in certain areas (e.g., only
restaurants in the Midwest), supply
chain knowledge can begin to help narrow the possible supply chains involved.
Whole-genome sequencing lets us
link illnesses and recognize outbreaks
that surely would have been missed
just a few years ago. Whole-genome
sequencing represents a powerful new
tool, and perhaps the epidemiology and
traceback approaches need to catch up.
Consumers are eating a greater diversity of foods and in different ways,
and these trends challenge food surveys
to keep up with consumption practices.
The sourcing and production of food
continues to evolve to meet consumer
demands, which sometimes results in
complex supply chains, particularly
when weather events disrupt expected
yields or timing of harvest. Tracing
foods, especially perishable foods, back
to their source is not easy.
Obviously, preventing contamination must remain the top priority for
the food industry. Avoiding outbreaks
obviates the need for a debate about
traceability. But recognizing that outbreaks may occur from time to time, we
need to reconsider how we use the tools
at our disposal so that our ability to
respond to outbreaks keeps up with our
ability to detect them. n
Drew McDonald is the vice president, quality and
food safety, at Taylor Fresh Foods, Salinas, CA. He
has over 20 years of experience in fresh produce and
fresh foods. He oversees the quality and food safety
programs across the foodservice, retail, and deli operations. Drew received his education from Lawrence
University in Wisconsin.
Jennifer McEntire, Ph.D., is vice president of food
safety and technology at United Fresh Produce Association. She was previously vice president of science
operations at the Grocery Manufacturers Association.
She has also had roles as VP and chief science officer
at The Acheson Group and as the senior staff scientist
and director of science and technology projects at the
Institute of Food Technologists. Jennifer earned a Ph.D.
in food safety from Rutgers University.
(continued from page 15)
NQAC Dublin is proud to offer
more than 150 unique
analytical methods to support
your business’ food safety
and quality testing needs.
Food & Beverage Experts
ISO 17025 Accredited
We receive, test & report
seven days a week!