It’s a consultant’s cliché that you can’t manage what you don’t measure, but when it comes to leafy greens and pathogens, there is a strong element of truth to it. By the time regulators halt sales of contaminated greens, the public is already reporting illness. Without rapid ways to track and share information, food safety suffers. A recent announcement of an investigation by the U.S. Food and Drug Administration (FDA) and the U.S. Centers for Disease Control and Prevention (CDC) of a multistate outbreak of Cyclospora illnesses highlights why a well-positioned public-private partnership (PPP) including farmers, packers, retailers, and government officials could seize on early hazards and warning signs to improve food safety earlier.
Leafy Green Food Scares
Food safety is a public good. And, the U.S. is fortunate to have what is regarded as one of the safest food supplies in the world. That said, there are—more frequently than we would like—reports of hazards in the U.S. food supply. According to FDA, in 2018, there were two outbreak investigations of Escherichia coli O157:H7 related to leafy greens, followed by three in 2019. (Beyond E. coli, Salmonella, Cyclospora, and Listeria monocytogenes also have been found in outbreak investigations over the last few years.) Foodborne illness, caused by ingesting food contaminated with microbiological hazards, is a source of preventable illness and mortality in the U.S.
The food safety landscape is made up of the efforts of many different stakeholders. Food suppliers who are responsible for food safety from farm to shelf need awareness, knowledge, and skills to improve food safety. They need funds, and they need management strategies. Food suppliers also need access to markets to generate sufficient returns to invest more in food safety and sustain their ongoing businesses. The broad network of actors that support food safety includes many who do not directly participate in food market activities, but whose efforts are indispensable, such as industry organizations, training organizations, regulatory and nonregulatory government agencies, research institutes, third-party certification programs, inspectors, auditors, testing laboratories, and PPPs.
In the U.S., FDA and CDC work together to conduct epidemiological studies and gather laboratory information (including whole-genome sequencing) during outbreak investigations. This work has been beneficial in improving processes and practices. Recently, FDA issued a report on its investigation of what were actually three distinct outbreaks occurring in the fall of 2019. In the report, FDA stated it believes ruminants, most likely cattle, are the source of contamination in these outbreaks, but exactly how the pathogens ended up on leafy greens remains a mystery. To address this, the California Leafy Green Products Handler Marketing Agreement (LGMA) formed an Adjacent Lands Subcommittee to make romaine lettuce safer.
Data Already Exist
The leafy greens industry, and the produce sector more broadly, is working to learn more about how leafy greens and other fruits and vegetables are being exposed to pathogens like E. coli in the environment through a series of research projects. Work is going on at the University of Arizona with FDA. Work is also underway in California’s central valley in cooperation with FDA and the California Department of Food and Agriculture.
However, more can be done—with an eye towards providing society with information to prevent future outbreaks. Data from growers and packers are already available, and regulators also collect data. But more efforts are needed, especially from the private sector. Currently, public sector data to measure some impacts exists on a limited number of cases, including FDA’s and state officials’ inspection data, and CDC traceback data.
However, these data are limited, not comprehensive, and not well-targeted for predicting the future and preventing future outbreaks. The private sector—producers, manufacturers, suppliers, and sellers—also collects data, both for internal and external purposes. Some of that data are reported to the government and provided for government and third-party audits, but much of it pertains to internal compliance and control measures. This includes data around the number of test results within acceptable values, audit scores through internal or third-party audits, “risk” scores for industrial plants and suppliers, external certifications of facilities, frequency of required audits, and number of regulatory violations. If private sector data—including environmental data—could be made available and aggregated with trend information over time, it could prove useful for public health actions, improve food safety, and increase food security.
As noted in the White Paper by the Joint Institute for Food Safety And Applied Nutrition (JIFSAN), the convergence of public and private sector interests is a sweet spot for public-private collaboration. This convergence is a necessary. Public and private partners may have different motivations and goals, but in the sweet spot, benefits meet expectations on both sides. Both sectors already share many goals—fair competition and level playing fields, orderly and predictable markets, rule of law and avenues of recourse, clarity and feasibility of regulations, and consumer awareness and empowerment. If partners start with a narrowly scoped sweet spot, they can address sensitive issues around confidentiality, competition, conflicts of interest, institutional integrity, public trust, and consumer confidence. With the Food Safety Modernization Act (FSMA) as the starting point for collaboration, data-sharing platforms facilitate efforts to tier risks and inspection priorities, thereby promoting food safety in the near and long-term.
Data Sharing in PPPs
The publication “Principles for Building Public-Private Partnerships to Benefit Food Safety, Nutrition, and Health Research” can serve as a guide for the establishment of a PPP to address needs with leafy greens. PPPs start with a goal that unites and galvanizes both sectors—in a space where public government and private corporate interests converge. The future end point highlights what shared efforts can achieve above and beyond what each party could accomplish on their own.
To start, partners have to be motivated to partner. Each partner brings their own set of drivers, along with unique skill sets and comparative advantages. In PPPs, diversity is built in. While many partnerships rely on like-minded and like-situated partners, the value of bringing public and private sectors together lies in their differing profiles. Transparency in PPPs starts with transparent acknowledgement and appreciation of these different starting points, forming the basis of mutual respect among partners. If the public sector does not recognize and leave room for private sector considerations, it is difficult to sustain PPPs. Likewise, if the private sector does not embrace public sector ambitions in promoting public health, the partnership rests on a shaky foundation. Each sector can acknowledge and accommodate the interests of the other sector as long as this does not undermine its own interests.
Partnership incentives are built into the design and structure of the partnership. Borrowing from the JIFSAN report, incentives take the form of if-then relationships: “if” being the action, and “then” being the desired result. Linked this way, each desired result becomes a reason to act.
For example:
• If I contribute financially, I can be part of the decision making—I have an incentive to contribute.
• If I contribute more, I can stimulate more activities—I have an incentive to contribute more.