Written Testimony - Perishable Pundit

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Maccabee Seed Company PO Box 401 Davis, California 95616 (530) 756-2508 with HUS are named after him. About thirty years ago the genes associated with shiga toxin laterally transferred to E. coli strains. Unlike dysentery, coliform bacteria were generally perceived as indicator species for fecal contamination and as early warning signals for far more serious diseases. With hindsight, the appearance of shiga toxin E. coli should have been treated from the beginning as a new disease entity; and as a model case for appearance of a toxin-associated, highly pathogenic disease, with many of the same characteristics public health officials would have to deal with in an intentional contamination. In my view, the FDA should lead an interagency working group covering all aspects of contamination and outbreaks including therapeutics. This should include special funding and research on HUS therapies. [The only therapeutic I know of entering phase II clinical trials is a (monoclonal antibody) mAb combination antitoxin; research originally done at the Uniformed Services University, sublicensed and now controlled by a biotech company in Canada; it has Orphan Drug status in the US and EU.] For the leafy green and salad industries, better therapeutics for HUS would mean that growers, handlers and consumers would be exposed to the risk of a greatly reduced harm. The FDA-led working group should also conduct a complete review of off-site health dangers posed by practices in the production of meat and milk in the cattle and dairy industries. Cattle and dairy have been repeatedly identified as the principal reservoir of O157 and other shiga toxin E. coli strains of concern. They have also been reported to be important origins and reservoirs of multiple antibiotic resistances of concern to human health. Both reservoirs should be identified and reduced. For the leafy green and salad industries, a reduction in the sources and reservoirs of contamination would mean a much smaller risk of causing a harm. They would have a safer environment in which to operate. An environment, for example, with uncontaminated irrigation water. Better therapeutics for HUS combined with reduction in the reservoirs and sources of contamination would result in a reduced risk of a greatly reduced harm. I think improvements in growing and handling practices will be more effective in a lower risk environment. Thank you for hearing my testimony. [Both of these risk reductions are scale neutral; they would benefit farm operations of all sizes from Hmong farmers with under 10 acres, to organic farmers with 2-300 acres, to the very large operations with tens of thousands of acres and multiple locations. Some proposed changes in food safety regulation are not scale neutral, and may adversely affect smaller farmers far more significantly. 2
Maccabee Seed Company PO Box 401 Davis, California 95616 (530) 756-2508 I was partly motivated to testify today by concerns expressed by NRCS (Natural Resource Conservation Service) and RCD (local Resource Conservation District) staff and local farmers. Their fear is that some of the food safety proposals attempt to create a sterile farm landscape ("farmscape"), which would undo decades of work on farms as environmental benefits. I have the same concerns. An approach to the food safety issue was developed by the Community Alliance with Family Farmers (CAFF) and summarized in testimony by Judith Redmond before the California Senate and Assembly Agriculture Committees, Joint Session, February 27, 2007. I agree with their conclusions, reached independently of my own work (available at www.caff.org). In my view, the outbreak record, and testimony at three California legislative hearings suggests the following priorities: 1. First, review or clean-up the major operations in the processed leafy green and salad industry from planting through packaging. This includes ensuring standard food safety procedures for processing and packaging. 2. Second, review or improve safety in the transportation of processed leafy greens and salads to the retail level; including records of temperature controls. 3. Third, review or improve the safety of the actual packaging ("bags"), as an environment for potential microbial growth. This would include checking the adequacy of safety of sell-by or use-by dates. 4. Fourth, review or clean-up operations in the Salinas valley, and other regions where there are found to be area-wide issues and concerns affecting most growers. 5. Fifth, provide information, testing and cheap accurate testing equipment for smaller farm operations to use to enhance their food safety. There are great benefits to U.S. consumers from the convenience of prepared, packaged fresh vegetable from baby carrots to salad mixes. There are also great benefits from the fresh fruits and vegetables of local producers in farmers markets, coops and regional or specialized markets. Food safety regulations designed for large national producers may end up harming local producers, even when they are ineffective.] [Statements contained in brackets will not be presented in oral testimony] Dan Cohen Maccabee Seed Company PO Box 401 Davis, CA 95617 (530) 756-2508 3
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Written Testimony - Perishable Pundit

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