Produce safety has been a hot topic in the news as of late—with massive lettuce and salad recalls in 2019, the public wants to make sure they are eating produce that has been safely processed, and does not contain pathogens. According to USA Today, there were 75,233 pounds of salad products recalled in 2019, the reason being possible E. coli O157:H7 contamination; making it #21 on its list of the top 50 recalls of 2019.

The FDA investigated a salad mix recall in December 2019, as well as pre-cut melons in April 2019, and fresh papayas in June. December 2019 also brought a blackberries recall.

So far in 2020, another bagged salads recall has already taken place, the cause being Cyclospora, and the year has already been chock-full of produce recalls: red onions in July 2020, enoki mushrooms in March, and clover sprouts in February.

With the bagged salads recall, one of the major recalls so far in 2020, Fresh Express brand recalled their salad mix; the products were sold in multiple states, and multiple retailers, including ALDI, Giant Eagle, Hy-Vee, Jewel-Osco, ShopRite, and Walmart, under each store’s brand name.

What is the best way to avoid these recalls, and what areas are affecting food safety in 2020? Food Safety Strategies talked to a variety of experts in the field to find out.


Produce industry challenges

“The area having the most positive impact to food safety currently is awareness, education, and collaboration, but we still have work to do,” says Dr. Elizabeth A. Bihn, Ph.D., executive director, Produce Safety Alliance, Geneva, NY.

“The food system can be quite complex with many individuals and companies involved in the growing, harvesting, packing, processing, distribution, and sale of produce. Every person, group, and step of the process is important to reducing microbial risks. When we say things like ‘Farm to Fork’ we really have to work to ensure every step and every person at every step is aware and engaged in the process. This is not easy as it requires both company commitment and worker education/training,” she expands.

In an industry that is seasonal and often has high worker turn over, this can be very challenging. It is also important to place produce safety in the larger context of business demands, Bihn notes.

“Fresh produce is a challenging business due to many factors (e.g., labor availability, weather, pest control, market fluctuations) and ensuring the microbial safety of fresh produce is impacted by all of these. Building produce safety into each step is important and since produce safety is a relatively new idea, evolving over the last 20 years, and many steps/groups in the process are still working to implement food safety practices,” she says.

In addition, some of the companies involved (i.e., trucking) may haul more than just fresh produce, so food safety may be very novel to them, Bihn expands.

“There are also several factors and processes that are still being developed with many things not completely understood yet. For instance, though much research has been done, we learn new things every year about how pathogens contaminate produce crops and persist in production environments. Though much has been done around traceability, there is still not one system that works for everyone from farm to fork,” she says.

“Some of this has to do with expense, some with infrastructure, but all of it is impacted by the fact that no two farms are the same and there are many different crops, farming environments, regional differences and other factors that make developing a universal system difficult.”

The good news is that all of these things are being talked about and worked on as we speak, Bihn elaborates.

“More growers are aware of produce safety and its importance so they are educating themselves and training their employees. Processors are moving forward with food safety and many (not all) retailers are involved in moving their food safety programs forward. It will take a sustained effort of working collaboratively across many different groups to fully implement produce safety.”

“Certainly things like the Food Safety Modernization Act have impacted awareness and the implementation of food safety practices throughout the food system, but produce safety has been primarily industry-driven and collaboration will be more important than regulation in achieving produce safety throughout the food system,” she advises.


FSMA’s Produce Safety Rule

2020 marks the second year of Food Safety Modernization Act’s (FSMA) Produce Safety Rule (PSR) inspection program at the Wisconsin Department of Agriculture, Trade & Consumer Protection (DATCP).

“The PSR established mandatory science-based minimum standards for the safe growing, harvesting, packing, and holding of fruits and vegetables grown for human consumption. Farms covered by the rule will be held to certain standards designed to reduce the presence of potentially dangerous bacteria in the food supply, with the ultimate goal of reducing the number of illnesses caused by contaminated produce,” says Shawn Bartholomew, product supervisor, Wisconsin Department of Agriculture, Trade and Consumer Protection.

The PSR is divided into six key requirements, which must be verified by annual inspections:

  • Worker Health, Hygiene, and Training
  • Agricultural Water for Pre- and Postharvest Uses
  • Biological Soil Amendments
  • Domesticated and Wild Animals
  • Equipment, Tools, Buildings and Sanitation
  • Required Records

The FDA rolled out inspections using a phased approach, says Bartholomew.

“Larger farms were inspected first, allowing farms with fewer resources more time to educate themselves on PSR requirements and to prepare their operations for inspections. Last year saw inspections only on Wisconsin’s largest farms, which the FDA defines as farms with more than $500,000 in annual produce sales. This year’s inspections included farms with annual produce sales between $250,000 and $500,000. Next year will include inspections at farms with annual produce sales between $25,000 and $250,000, the smallest farms covered by the rule,” he says.

Before the commencement of inspections, many of the state’s growers have taken advantage of the educational resources available to them to increase their knowledge of food safety practices on the farm, Bartholomew notes.

“One important resource is taking a Grower Training Class, developed by Cornell University and the Produce Safety Alliance. The class is based on Good Agricultural Practices, and it provides growers with the basics on FSMA, the PSR, and how to develop their own food safety plan. To date, more than 700 Wisconsin growers have taken the class.”

Another key educational resource is DATCP’s On-Farm Readiness Review (OFRR) program, he says.

“OFRR’s are a non-regulatory assessment of a farms existing food safety practices, where prior to an inspection a grower can request that DATCP conduct an in-person review on their farm to see how well their operations align with PSR regulations. At the conclusion of the OFRR, DATCP highlights the practices that comply with PSR regulations, as well as those practices that need addressing. Growers also receive an OFRR manual, which details specific steps a farm would have to take to comply with each PSR requirement. More than 80 farms have taken advantage of DATCP’s OFRR program since it began in 2019.”

Because so many growers have been willing to reach out for assistance, inspections in Wisconsin have been very good, he states.

“While any inspection brings apprehension, many growers have found that they are already doing most of the things required by the PSR. Most regulatory shortfalls have been of the record-keeping variety, while many others can be addressed on the spot. DATCP has been able to give credit to growers for the work they are already doing, and the department is willing to work with them to improve produce safety wherever needed,” Bartholomew adds.

“Wisconsin has always been a leader in food safety, and the growing partnership between DATCP and Wisconsin fresh produce growers will only continue this trend.”


COVID-19 challenges

The Produce Safety Alliance made various efforts to support the food industry during the current COVID outbreak. The efforts listed below are from the PSA blog.

The COVID-19 outbreak had a significant impact on the entire food system including fresh produce.  Many states continued to do inspections and so growers subject to the FSMA Produce Safety Rule needed to have access to training to meet the requirements outlined in the Produce Safety Rule provision 112.22(c). In response to this need, the Produce Safety Alliance (PSA) team quickly created a remote delivery option for the PSA Grower Training Course using video conferencing tools. Focus was placed on helping trainers adjust to remote delivery options to ensure every remote participant had a quality educational experience. This was done by: 

  • Offering weekly office hours for trainers to discuss the transition to remote delivery


Knowing that remote delivery was also going to be new for many participants, the PSA team prepared a set of instructions to help those preparing to join a PSA Grower Training Zoom meeting.

In addition to remote delivery, the PSA prioritized completion of an Online PSA Grower Training Course that had piloted in February 2020. The online option is a different experience than the remote delivery option, and the differences between the course types are clearly outlined on the PSA website. This course launched in April 2020.

These two options have been providing growers, packers, produce industry personnel, and regulatory personnel access to the PSA Grower Training during the COVID-19 pandemic. Food safety was not their only concern, though. Although COVID-19 is a respiratory, not foodborne, disease, it nevertheless brought unique challenges to the farm.


Other COVID-19 challenges

More from the PSA blog:

Who knew cloth face coverings would be all the rage in 2020? The PSA team quickly stepped up to help the produce industry understand the risks from SARS-CoV-2, the virus that causes COVID-19, and make modifications to farm practices and improve communication in order to reduce person-to-person transmission risks on the farm through:

  • Creating new educational materials in English and Spanish that highlighted how to implement social distancing on the farm as the most effective way to reduce spread of respiratory droplets, the main pathway of infection by SARS-CoV-2
  • Identifying food safety practices, such as cleaning and sanitizing steps,  that overlapped with COVID-19 risk reduction practices to help growers effectively respond to risks
  • Participating in Produce Industry Virtual Office Hours that gave growers and packers an opportunity to ask questions specific to their operations

The PSA team continues to support the produce industry in minimizing both food safety and COVID-19 risks on farms and in packinghouses. [They] are grateful to work alongside [their] amazing network of collaborators across the nation and around the world, and humbled to play a small role in protecting farm businesses and maintaining consumer access to safe, healthy fresh produce.


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Ten things being done to make leafy greens safer this fall (source: California LGMA)



  1. LGMA food safety audits are ongoing during COVID-19.
    Mandatory on-farm audits of all LGMA members by government officials have continued during the pandemic. Members have a remote option for document review and verification.
  2. The California LGMA is “heavying up” audits during the season transition.
    The California Department of Food and Agriculture is bringing in additional personnel to ensure that every LGMA member is audited at least once between now and November.
  3. LGMA requires 100% compliance.

  4. As always, the LGMA requires its members to be in compliance with all 300+ food safety checkpoints that make up every on-farm audit conducted through the LGMA program.
  5. 2019 irrigation water standards are being implemented and enforced.
    LGMA members are following new, more stringent standards approved in 2019 and these are being verified by government auditors. Farms must now comply with 92 different food safety checkpoints that deal exclusively with ensuring the safety of water used to grow leafy greens.
  6. New food safety updates approved by LGMA Board in August 2020.
    The LGMA recently approved several more changes to its required food safety practices in the areas of farm water use and field/equipment sanitation. These will become part of audits in the near future. Education and training on how to comply with these new requirements is underway now. Additional updates to other areas of the LGMA‘s required food safety practices will be announced soon.
  7. State agencies are monitoring compost used on leafy greens farms.
    The California Department of Food and Agriculture and sister state agencies are conducting a surveillance project to monitor compost used to grow leafy greens.
  8. Government inspectors are working to ensure leafy greens farms are in compliance with the Produce Safety Rule.
    Leafy greens farms in California and Arizona are being visited by additional state government inspectors acting in conjunction with FDA to ensure they are following all regulations under the Produce Safety Rule.
  9. New research projects are underway to learn more about potential risks involved in farming leafy greens.
    It’s clear that we need to know more. Several new projects are being conducted by government, industry and academia with the goal of better informing the required food safety practices implemented under the LGMA.
  10. The LGMA verifies with every audit that a traceability system is in place at all member companies.
    A recent survey of LGMA members shows 100 percent of LGMA members companies are tracking information that could assist government outbreak investigations.
  11. The LGMA supports a Leafy Greens Traceability Pilot to improve traceback through the supply chain.
    A coalition of food industry groups that includes the United Fresh Produce Association and the Produce Marketing Association is conducting a project aimed at improving the speed and efficiency of tracing product during an outbreak investigation.