SafeSprouts. It is a Matter of RiskReduction
International Specialty Supply
August 26, 2001
Thelast SproutNet stirred up several people to become interested in seed sampling. It also stirred up more than one grower to consider a class suit actionagainst the FDA.
Personally,I appreciate the efforts of the FDA and other health organizations. The industry has greatly improved because of their efforts.
TheFDA has reason to be concerned. Theoutbreaks, with few exceptions, have come from pathogens that enter thesprouting facility on the seed. Thereis no sanitizing method that will completely eliminate pathogens from seedall of the time. Even if your sanitizing method does remove all thepathogens, you still have to worry about who has handled that seed, and where ithas been in your facility prior to sanitization. Seed in not just aproblem, seed is the problem that has hounded the industry since thefirst outbreak.
Asan industry, if we want the health organizations to shut up we need to quithaving outbreaks. Yes, I realize that it will take a couple of yearswithout outbreaks to quiet the presses. Put plain and simple – nooutbreaks, no more bad press.
Soundseasy doesn’t it. Actually, it is. Sproutgrowers need to quit buying contaminated seed!
Abouta year ago, while attending a trade show, I was sitting at a lunch tablewith another sprout grower. There were about six others at the tableas well. As it turns out, one of them was a seed supplier. Irecognized his name because the company he works for also sales seed to thesprouting industry. The sprout grower had never heard of the companythough. A conversation struck up that went something like this:
Grower: “It’s always good to find more sources of seed. Doyou test your seed for pathogens?”
SeedCo: “Oh, absolutely, we always test our seed forpathogens”.
Grower: “Wonderful! What kinds ofseeds do your carry?”
Atthat point, I realized that the grower heard all they needed to hear. The company “tests their seed for pathogens”.
Ihad to ask: “How do you test your seeds for pathogens?”
SeedCo: “We send a sample off to a lab.”
Thismay have been what the sprout grower wanted to hear, but it told me that theseed company probably didn’t have a clue what they were doing. While writingthis article I called a nationally known pathogen-testing laboratory. The lab said that in order to test alfalfa seed for pathogens they need25 grams of seed for the salmonella test and 25 grams for the E.coli 0157:H7test. This is typical of most labs. If Seed Co. sent a sample to a lab who tests 25 grams, and if the lot of seedwere contaminated at .7 cells/kg with one of those pathogens, thelikelihood that any of the contaminated seeds would show up in the 25 gram sampleis only 1.7%!
However,had he sampled 25 grams from each of the 880 bags, sprouted it, andtested the runoff water, the likelihood of capturing the pathogen from thatsame lot of seed increases from 1.7% to over 99.9999%.
Inother words, Seed Co. did nothing except give the grower a false sense ofsecurity. Even if they had sent a50-pound sample to this pathogen test lab, the test would have been useless,because they only test 25 grams. Iam not saying that Seed Co intentionally deceived the grower. Theymay be trying very hard, or they might just be covering their rear, but whatthey are doing is useless.
Until growers become educated on how to purchase well sampledand tested seed, seed suppliers will continue to placate them. This is only natural. Many of the growers themselves were guilty ofthe same thing. A produce wholesaler would ask them if their sproutswere safe and they would say, “We test all our sprouts for pathogens.” Then the FDA went to the sprout facilities and found a great deal ofsprout growers didn’t even know how to either test or have their sprouts tested forpathogens.
Ifyou are involved in an outbreak, it will be little comfort to the victims, andprobably useless in court, that “your seed supplied said the seed had beentested for pathogens”.
Insiston two documents from your seed supplier:
1. General Procedures. Get the written procedures your seed supplier uses to sample and test the seedthey send you. These are general procedures and are not lot specific. Then evaluate these procedures! Just because the seed supplier is a majorsupplier to the industry does not mean they have the industry at heart. Make sure the procedures include sampling at least 3 kg of seed, with thelargest sample being no more than 30 grams (about two ounces), and that theentire sample is sprouted and the runoff water is tested after 48 hours.
2. Seed Sampling & Pathogen Testing – Lot Specific. Get the procedures they actually did on theparticular lot of seed you are purchasing. This should include who did theprocedures, and when it was done – An actual name and date! Don’tsettle for anything less. If the seed company did the work theywill be delighted you asked. If they didn’t do the work, don’tfinancially support them with your business. Demand properly sampledand tested seed! The alternative is to properly sample and test theseed yourself, which is a good practice even if the seed supplier does it also.
Seedpurchasing is the most important critical control point in your HACCP plan. An example of the information you should require from your seed supplier(and/or do yourself):
Lot Size: 880 50-pound bags (signature, date)
Samples taken: 440(signature, date)
Sample Size: Approximately 25 grams each (signature, date)
Total Sample: 11 kg (signature, date)
Method: Sprout production
Time Started: August 21, 2001 8:15 am (signature, date)
Tested: Run off water (signature, date)
Time Sampled: August 23, 2001, 9:30 am (signature, date)
Growing Time: 49.25 hours (signature, date)
Salmonella: Negative (signature, date)
E.coli 0157:H7: Negative (signature, date)
Ifyou don’t know the probability of detection on a particular sample size, askyour ISS sales representative.
If you do not have paperwork in your hands regarding the specific lot youare buying, that shows your seed was properly sampledand tested, it wasn’t. You have no idea how important, and powerful, thatpiece of paper is! It can protect your customers, save your company, andchange the industry.
Theseed supplier can’t guarantee that there won’t be an outbreak with the seed. However, if there is an outbreak, he can guarantee that he did all the safetysteps he said he did for the particular lot of seed you received. Thegrowers themselves need to be responsible for evaluating the information givento them about the lot to determine if the information is of any value. Thegrowers are the ones responsible for the end product.
This does not take an FDA mandate (although one would be helpful). Thistakes growers educated in risk reduction and insisting that their suppliers arealso.
Iam not advocating anyone replace any of their existing GPM’s with proper seedsampling and testing. I am saying that because nearly all theoutbreaks have been seed oriented, seed is the most important Critical ControlPoint and should be treated as such.
Whenall sprouting seed is properly sampled and tested, either by sprout growers orsprout seed suppliers, and all growers are using safe manufacturing procedures,the outbreaks related to contaminated seed will be gone. So will the badpress.