shows and technical meetings, and while my message to industry was not always
well received (they would have to change the way things had been done for over
20 years), the exposure led to many opportunities for Earthbound Farm to be involved in projects that range from creating a new online auditing tool for farmers
to working with NASA and the FDA to create a satellite-based risk modeling tool.
Earthbound’s Progressive Food Safety Program
Following the government and internal investigations, there was no “smoking
gun” that would explain how the spinach we had packed was contaminated or
how it made it through the washing, drying and packing process. Without a specific answer, we were forced to re-envision our entire program.
The government investi-
gation traced the product
back to one of four farms
that were co-packed by
So we had a few facts to work from: contamination likely occurred in the field,
a relatively small amount of product led to a pretty significant outbreak and the
process used was not adequate to control the risks on that day. Another important
fact was understanding that for 20 years of processing salads, Earthbound’s sys-
tems had always controlled any pathogens that might have come in from the
field. But that day in August, the system did not.
We dissected every step of the process, from field selection to loading the finished product onto a customer’s truck and identified every possible enhancement to the current program to reduce or eliminate contamination. Without a
kill step to eliminate the hazards, the best approach was to develop a multi-hurdle
program that would put several controls in place throughout the process.
Today, Earthbound Farm now has over 2,000 SKUs, all of
which undergo strict safety controls.
bound also requires pathogen testing
for all inputs going into the field
(water, soil amendments and even
transplants). These inputs are tested
for the presence of E. coli O157:H7,
non-O157 STEC (shiga-toxin producing E. coli) and salmonella. All inputs
must test negative for the presence of
these pathogens to be used. In addi-
Earthbound requires pathogen testing for
all inputs going into the field.
Improving Controls in the Field
Earthbound identified several food safety enhancements in the field. Many
were in step with the Leafy Greens Marketing Agreement (LGMA—a California
(then Arizona) marketing agreement enacted in the months following the out-
break), but several exceeded those metrics. We believed that without adequate
science to support the metrics established by LGMA, it was prudent to pursue a
more rigorous approach. We also believed that where the science was lacking, ag-
gressive data collection would help everyone “get to the science.”
Like the LGMA, Earthbound requires a preseason field assessment, a prehar-
vest field assessment and testing for generic E. coli in water and E. coli O157:H7
testing for inputs of animal origin (compost, fertilizers, etc.). However, Earth-
tion, Earthbound tests all open water
sources weekly (more frequent than
LGMA requirements) for the presence
of pathogens in addition to the
generic E. coli requirement from the
LGMA. While the generic E. coli is not
pathogenic in and of itself, it’s consid-
ered an “indicator organism,” mean-
ing that its presence indicates the
presence of pathogens.