Reconsider Lettuce Use In Light Of Recurring Contamination

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Foodborne disease outbreaks are becoming increasingly common, thanks to conventional agricultural and confined animal feeding operation (CAFO) practices. According to preliminary data from the U.S. Centers for Disease Control and Prevention, there were 25,606 foodborne infections, 5,893 hospitalizations and 120 deaths from food poisoning in 2018.1

Preliminary data from the Foodborne Diseases Active Surveillance Network for 2017 indicated there were 24,484 infections, 5,677 hospitalization and 122 deaths that year,2 but the CDC’s finalized outbreak surveillance report3,4 for 2017 brought those numbers down to 14,481 illnesses, 827 hospitalizations and 20 deaths.

Between 2009 and 2015, there were 5,760 reported outbreaks resulting in 100,939 illnesses, 5,699 hospitalizations and 145 deaths.Contaminated vegetables were responsible for 10% of these illnesses. Chicken was identified as the food category responsible for the most outbreak-associated illnesses (12%).

E. Coli-Tainted Lettuce Wreaks Havoc Third Year In A Row

The Thanksgiving holidays of 2018 were less than bright for many last year, as contaminated romaine lettuce sickened 62 Americans with E. coli. In the last week of November 2019, the CDC issued a food safety alert stating it is investigating a multistate outbreak of E. coli linked to romaine lettuce harvested from the Salinas, California, region.6

According to the CDC, illnesses were reported starting September 24, 2019. As of November 25, 2019, 67 cases had been reported across 19 states, 39 of which required hospitalization.Six persons developed kidney failure. Fortunately, no one has died as of yet.8 As reported by The Washington Post November 26:9

“The Food and Drug Administration and Centers for Disease Control and Prevention are recommending that consumers avoid romaine from the Salinas region.

Remarkably, the specific E. coli strain (O157:H7) causing the new outbreak is genetically indistinguishable from last year’s and another one in late 2017. Last month, the FDA retroactively identified an outbreak involving romaine lettuce that occurred in late summer, causing 23 illnesses.

Notably, the 2018 Thanksgiving outbreak was not the first one that year either. It was preceded by the biggest outbreak in the United States of E. coli illness in more than a decade, with 210 illnesses, including five deaths, linked to romaine from the winter growing region around Yuma, Ariz.”

Look For Harvest Location Labels On Your Purchased Greens

Last year, authorities were unsure of the origin of the contaminated lettuce, prompting improved labeling detailing where the produce was grown. As reported by California Leafy Greens Marketing Agreement (CA LGMA):10

“Over the past year, leafy greens producers in California and Arizona have been placing Harvest Location Labels on packages containing romaine lettuce to help consumers identify where product was grown. 

These stickers are something different than the address of the company responsible for packing the product that is usually printed on the back of packages and is required by law. 

The Harvest Location Label can take a few different forms. Products like Romaine Hearts are often packaged right after harvest in the field. Their Harvest Location Label will look similar to these:

Cattle Are Natural Reservoirs For This E. Coli Strain

While authorities claim it’s still unclear how the romaine lettuce in Salinas Valley got contaminated, the unique strain of E. coli that has now made an appearance three years in a row — E. coli O157:H7, also known as STEC — is typically associated with ruminant animals, and cattle in particular.11

While many E. coli strains are harmless or well-tolerated, this particular strain is a Shiga toxin-producing type of E. coli, which is why it’s so dangerous. In the U.S., an estimated 265,000 people suffer from STEC infections annually, and the O157:H7 variety is responsible for more than one-third of those illnesses.12

Generally, symptoms appear one to 10 days after eating the contaminated food and may include bloody diarrhea, stomach cramps and vomiting. The first of the two outbreaks in 2018 was eventually traced back to a concentrated animal feeding operation (CAFO) in the vicinity of the Yuma, Arizona, lettuce farm.13

Runoff from its manure lagoons is thought to have entered and contaminated a nearby canal, and this E. coli-tainted water was then used for irrigation on the lettuce fields. This could very well be what Salinas Valley farmers are dealing with as well.

There is no doubt in my mind that this deadly strain of E. coli is a result of the overuse of antibiotics given to CAFO cattle.  The E. Coli that was strong enough to develop antibiotic resistance is now deadly enough to kill people.

CAFO Impact Will Be Investigated Further

To address the recurring contamination problem, a task force led by the United Fresh Produce Association and the Produce Marketing Association issued a set of guidelines for lettuce growers in September 2019.14

However, while admitting that nearby CAFOs pose a significant risk, the task force did not specifically address those risks at this time, placing the onus instead on romaine growers to comply with water testing and treatment. They also urge consumers to buy romaine from growers that follow and meet the revised CA LGMA water standards.15 According to the final report:16

“Under FDA’s produce safety rule, growers are responsible for assessing such hazards and taking appropriate measures to prevent potentially harmful contamination, including assuring that the irrigation water they use is safe and of adequate sanitary quality for its intended use. 

All value chain participants, from growers to processors to retailers, share responsibility for these risks and their consequences. Generally, however, Task Force members believe current scientific knowledge is inadequate, and insufficient site-specific data are being collected, to assess the degree of risk associated with the proximity of CAFOs … 

While collaborating with existing efforts when appropriate, PMA and United Fresh will organize a group of experts and industry leaders to address risks associated with CAFOs and cattle operations. 

This risk evaluation will include consideration of multiple vectors (water, insects, birds and dust) that may transmit pathogenic bacteria across distances and potential variables like weather, animal density, facility operational practices, diets, shedding frequency and carriage of human pathogens. 

It is expected that this analysis will identify knowledge gaps that fuel needed research, and site-specific data collection that leads to best practices for setting appropriate buffer zones. The group will develop an action plan by March 2020 …”

FDA And CDC Accused Of Hiding Earlier Outbreak

While the CDC issued a public warning for the Salinas-related outbreak that reportedly began September 24, 2019, Food Safety News claims17 it hid an earlier outbreak that started in the summer — and never really ended. In its November 3, 2019, report, Food Safety News notes that:18

“Another romaine lettuce outbreak with 23 people infected from July 12 to Sept. 8 in a dozen states were facts keep from the public. It was a little secret kept from the public by the government and growers … FDA finally went public only because it got caught …”

Indeed, an October 31, 2019, FDA announcement19 reported that a romaine-linked E. coli outbreak had been investigated; that the outbreak appeared to be over; and that romaine lettuce was unlikely to pose any further risk. According to the FDA:

“… a recent E. coli O157:H7 outbreak, involving 23 illnesses … was likely associated with romaine lettuce. No deaths were reported … Illnesses started on dates ranging from July 12, 2019 to Sept. 8, 2019. No illnesses were reported after CDC began investigating the outbreak on Sept. 17, 2019 …

The FDA and the U.S. Centers for Disease Control did not identify actionable information for consumers during this investigation. Additionally, when romaine lettuce was identified as the likely source of the outbreak, the available data at the time indicated that the outbreak was not ongoing and romaine lettuce eaten by sick people was past its shelf life and no longer available for sale. 

The FDA is communicating details about the outbreak at this time to help ensure full awareness by the public and to highlight the ongoing importance of industry actions to help ensure the safety of leafy greens.”

As reported by Food Safety News:20

“The CDC also offered the lame excuse that outbreak warnings are ‘generally posted when there is something actionable for consumers to do.’ This strikes me as a statement consistent with a cover-up. 

It has not been CDC policy. Outbreak reports are routinely issued without something actionable for people to do. And, public education about public health, part of CDC’s mission, is about keeping the public up to date on foodborne diseases.”

Food Safety News speculates the FDA may have had a reason to keep the outbreak hidden. Its Smarter Food Safety campaign was announced21 April 30, 2019, which promised to “leverage technology and other tools to create a more digital, traceable and safer food system.” 

Clearly, the recurring romaine lettuce outbreaks suggest the FDA still has a long way to go in this regard. The dates of the 2019 outbreaks certainly make it appear as though the FDA tried to dismiss the issue, but couldn’t because cases still kept rolling in.

According to the FDA, the first outbreak ended September 8, 2019. FDA also stated that no additional cases had been reported after September 17. Yet the Salinas-related outbreak is said to have begun September 24, just seven days later, and well before the October 31 announcement quoted above.

In other words, the two lettuce-related outbreaks appear to be one solid, still ongoing outbreak that began in July. It appears shorter only because the FDA dismissed the first half (July 12 through September 8) as having ended and being of no further concern. Yet, clearly, it was not over.

Ditch Packaged Greens And Grow Your Own

There are many reasons to avoid commercially grown greens, especially prepackaged greens, as the additional machine processing (cutting, washing and bagging) virtually guarantees maximum spread of any lingering pathogens. Several other reasons to avoid packaged greens are listed in “Why Greens Keep Making People Sick.”

With so many recalls and outbreaks affecting leafy greens and lettuces in particular, one way to safeguard your health would be to skip buying this largely unnecessary ingredient.

It’s important to keep in mind that washing your produce, while certainly recommended, is unlikely to remove all pathogens. Rough surfaces provide lots of places in which bacteria can hide, and it takes but a few cells of E. coli to make you sick.

The best, and perhaps only, way to safeguard fresh produce is to implement cleaner farming practices, and a major factor is making sure the water used to irrigate the fields isn’t being contaminated by nearby CAFOs, which are hotbeds for potentially hazardous bacteria.

You can avoid most of the hazards associated with fresh produce by growing your own. When it comes to salad, lettuce doesn’t actually add much nutrition to your diet to begin with, so you’re better off swapping it for homegrown sprouts.

Leafy greens are a top source of food waste, which means the water and energy put into its production is wasted as well. If you’re on a budget, you’ll also want to make the vegetables you do buy count, nutritionally speaking.

There are many other vegetables that are nutritionally superior, less expensive, and better for the environment than lettuce. For instance, onions, broccoli and Brussels sprouts all have a relatively small environmental footprint.22

However, if you like salad, consider swapping your lettuce for sprouts. Sprouts are nutritional powerhouses and are easy to grow, even in small spaces. In one 10 x10-inch tray, you can harvest between 1 and 2 pounds of sunflower sprouts, for example.

My Sprout Doctor Starter Kit contains everything you need to get started. Note: If this link doesn’t take you directly to the kit, try a different browser and type in Sprout Doctor Starter Kit on shop.mer Easy growing instructions are presented in the video below.

Once your sprouts are ready, harvest some to make a delicious non-lettuce salad. For inspiration, check out my favorite lunch recipe. It’s a “salad” unlike any you’ve probably ever seen — packed with nutritionally rich sprouts, healthy fats and much more.

Basic Cleanliness Guidelines For Your Kitchen

As mentioned, while washing your produce is no guarantee that all potentially hazardous bacteria have been removed, basic hygiene is certainly part and parcel of food safety. Below are a few tips that will guide you in handling produce and other foods safely. Always:

  • Wash your hands with soap and water before handling food, and most especially after handling raw meat
  • Keep babies and children away from your food preparation area
  • Loose produce is touched and handled by many other people before it is purchased by you, so wash it well before eating
  • Use separate cutting boards and utensils for raw meat
  • Use a scrub brush to remove dirt and debris from root vegetables or any fruit or vegetable with a rough skin
  • Rinse all produce, even bagged varieties, well under running water
  • When chopping more than one type of food, wash your counter, cutting board and utensils frequently to avoid cross contamination
  • Do not prepare food for others when you are sick

Sources and References
1 MMWR April 26, 2019; 68(16);369–373
2 MMWR March 23, 2018; 67(11);324–328

3 Surveillance For Foodborne Disease Outbreaks US 2017 Annual Report (PDF), Page 2
4 Foodborne Disease Outbreak Surveillance System, Annual Summaries
5 Surveillance for Foodborne Disease Outbreaks — United States, 2009–2015
6 Food Safety Alert November 26, 2019
7 Food Safety Alert November 26, 2019, Investigation Details

8 CNN November 27, 2019
9, 11 The Washington Post November 26, 2019
10 CA LGMA November 26, 2019
12 U.S. Centers for Disease Control and Prevention, National Enteric Disease Surveillance: STEC Surveillance Overview [PDF]
13 USA Today August 7, 2018
14 Romaine Task Force Final Report and Recommendations, September 2019 (PDF)
15 CA LGMA, Committed to Safe Leafy Greens
16 Romaine Task Force Final Report and Recommendations, September 2019 (PDF), Page 3
17, 18, 20 Food Safety News November 3, 2019
19 October 31, 2019
21 April 30, 2019
22 Environment Systems and Decisions November 24, 2015