Food Protection Connection: New Guidance for Tomatoes and More (Part 1)

(reprinted from Dietary Manager, September 2009)

On July 31, 2009, the FDA released new guidance for ensuring the safety of tomatoes, leafy greens, and melons. Why focus on specific produce commodities? In the past 12 years (1996-2008), produce has been linked to 82 foodborne illness outbreaks, which makes produce a logical priority in a hazards-based analysis. The draft guidance is open for comment, after which it will be revised and then take effect “within two years,” said FDA Commissioner Margaret A. Hamburg, MD. An additional set of guidance addressing green onions is under development, according to the FDA.

The guidance was developed by the President’s Food Safety Working Group, which recommends a new, public-health focused approach to food safety. In a report issued in July 2009, the working group made recommendations for creating a stronger food safety system. The group is targeting three core food safety principles: 1) prevent harm to consumers, 2) use good data and analysis to ensure effective food safety inspections and enforcement of the law, and 3) identify outbreaks of foodborne illness quickly and stop them.

This column takes a look at tomatoes. The October 2009 column will examine leafy greens and cut melons.

Tomatoes - The Supply Chain

Of the outbreaks analyzed over the past 12 years, 14 traced back to tomatoes; five of these were associated specifically with cut tomatoes—always bacteria, notably E. coli. According to the FDA, new guidance for tomatoes is designed to “minimize the microbial food safety hazards of their products throughout the entire tomato supply chain.” Thus, the document emphasizes “establishing responsibility” along each step of the supply chain. Guidance covers the growing, harvesting, packing, processing, and distribution of tomatoes, along with retail and foodservice preparation.

Tomato growing models range from simple to complex, according to the FDA, which makes controls challenging. Says the FDA, “In some instances tomatoes may go from open field production and harvest directly to the consumer. Alternatively, tomatoes may be handled by a number of entities, beginning with open field or greenhouse production, harvesting, packing, multiple repackers and distributors, and finally to a retail outlet (or fresh-cut/value added processing then retail) before being offered to the consumer.”

For growing fields, the FDA has numerous specific recommendations, starting with an environmental assessment of the land, and excluding animals from the area. Guidance addresses ensuring a safe water source, as well as conducting microbial testing to detect any contamination. Sanitary facilities, hygiene, handwashing, and training for workers in growing and harvesting are also emphasized. The FDA provides guidance for harvesting, packing, storage, and transport, again outlining sanitary procedures, similar to many of those contained in the FDA Food Code, such as ensuring handwashing, and using sanitary storage containers.

In a greenhouse growing model, sanitation standards and employee hygiene standards also apply. Furthermore, the FDA is recommending that employees entering the greenhouse use a sanitizing foot dip to prevent introduction of microorganisms from feet. Pest control techniques are also outlined. Another standard appearing throughout the new tomato guidance is use of gloves for workers handling tomatoes.

Under new guidance, unwashed tomatoes will be labeled as such to flag the need for washing later in the farm-tofork chain. In addition, suppliers will need to enhance “traceback” procedures in the event of a foodborne illness outbreak or suspect product. The FDA is recommending “developing and maintaining standardized, clear records that can be used to enhance the ability to follow the movement of the product. Examples of such records include records with product identifying information (i.e., labels), invoices, inventory records, bills-of-lading, and shipping/ receiving records.”

“Value-added processing” and cutting tomatoes prior to distribution present risks that dietary managers will understand. According to the FDA, “Processing fresh produce into fresh-cut products increases the risk of bacterial growth and contamination by breaking the natural exterior barrier of the produce.” The FDA also notes that “transferring warm tomatoes from ripening rooms directly into an ice water bath to make the tomatoes firm before cutting may lead to water infiltration and, potentially, microbial contamination of the tomatoes.” This is an example of a procedure that must include steps for control of microbial hazards, including advice about disinfectant products. After cutting, tomatoes must be held at or below 41°F.

Tomatoes—in Food Service

In the foodservice environment, the FDA suggests numerous controls, including:

• Rejecting fresh-cut tomatoes delivered above 41°F
• Checking for traceback documentation when receiving tomatoes
• Following the most current edition of the applicable food codes regarding facilities and equipment, temperature control, cleaning and sanitizing, and personal hygiene
• Ensuring that whole tomatoes are free from obvious signs of filth and skin damage (e.g., punctures) prior to cutting, slicing, or dicing
• Washing tomatoes before cutting with continuous running water. Alternately, if disinfectants are used in the wash water, they should conform to the Code of Federal Regulations (21 CFR 173.315) and be used according to the manufacturer’s label instructions for concentration and contact time.
• Minimizing bare hand contact with tomatoes to be sold as ready-to-eat, using clean and sanitary utensils or gloves instead
• Chilling to and maintaining cut tomatoes at or below 41°F
• Storing cut tomatoes in a covered container and above other items that may cause cross contamination
• Developing and maintaining written food safety plans and SOPs for areas such as handling and storage practices, facility and vehicle sanitation, and employee training programs
• Maintaining records of control activities such as monitoring of storage temperatures; cleaning and sanitation of equipment, containers, and vehicles; employee training; and corrective actions taken.

Scientists have identified significant hazards affecting produce all along the farm-to-fork chain. Proposed guidance for all segments of the supply chain provides productspecific advice consistent with the Food Code approach. The guidance offers proactive controls for the multitude of factors that influence food safety—sanitary facilities, trash handling, pest control, chemical safety, plumbing and water supply, sanitary food contact surfaces, product labeling, safe storage, and employee health and hygiene. Although these standards do not take effect yet, they provide a direction for improving food safety. The October 2009 Food Protection Connection will explore advice on lettuce and cut melons.

by Sue Grossbauer, RD
Sue Grossbauer, RD, author of several books, is a regular contributor to DIETARY MANAGER magazine.