Press Release
August 10, 2021

Jennifer Allen Discusses the Importance of Water & Soil Safety

The Importance of Water and Soil Safety
There are many steps produce growers can take to make their produce safer, writes Jennifer Allen


You may have seen in recent months that the Food and Drug Administration (FDA) has turned its focus to leafy greens, a type of produce that has become all-too associated with foodborne illness outbreaks. FDA believes the root cause of at least one of the latest California outbreaks is the presence of livestock operations “upstream” from produce growers.

Livestock defecate, and their feces flow downstream through rainfall and irrigation to surrounding crops. Leafy greens are particularly vulnerable to contamination in this manner because they grow in the ground, unlike crops whose edible, harvested parts are elevated above the ground. And leafy greens are typically eaten raw, so they lack a kill step. If the FDA is correct, then resolving this issue is not something that produce growers can do on their own. Cooperation from livestock operations is essential to addressing this problem.

But there are many steps produce growers can take to make their produce safer. And while the neighboring livestock issue might take some time to fully address, there are steps that produce growers should be taking right now if they are considered “covered farms” under FDA’s “Standards for the Growing, Harvesting, Packing and Holding of Produce for Human Consumption,” found at Code of Federal Regulations, 21, 112.


Read Jennifer's full article in Quality Assurance & Food Safety magazine.

Jennifer L. Allen

Jennifer Allen has a dual focus on litigation and food regulation, combining her litigation skills with her knowledge of FDA and USDA regulations to assist a variety of clients.

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