California Fruit and Vegetable

Tag: Romaine Lettuce

  • Canada Reimplements Temporary Import Requirements for US Romaine Lettuce

    Canada will once again implement additional temporary import requirements for U.S. origin romaine lettuce for Fall 2023. The additional requirements will be in effect from September 28, 2023 to December 20, 2023. As with previous years’ requirements, Canada will require imported romaine lettuce and/or salad mixes containing romaine lettuce originating from the Salinas Valley counties of Santa Clara, Santa Cruz, Monterey, or San Benito to have a negative test for E. coli O157:H7 or a Proof of Origin for romaine and/or salad mixes from other U.S. growing regions.

    Since 2019, the Canadian Food Inspection Agency (CFIA) has implemented additional import requirements during the Fall period for U.S. romaine lettuce. Specific testing requirements for E. coli O157:H7 have been implemented since 2020 for romaine lettuce originating from the Salinas Valley counties of Santa Clara, Santa Cruz, Monterey, and San Benito. CFIA is once again implementing requirements for Fall 2023 during the time period of September 28, 2023 to December 20, 2023.

    Market Impact

    Since 2019, the implementation of additional import requirements for U.S. romaine lettuce during the final quarter of the year has acted as a market disruptor, with Canadian importers and U.S. exporters challenged to implement the new requirements. In November 2019, CFIA issued a notice that imports of romaine lettuce from the United States must not come from lettuce harvested from the counties of Santa Clara, Santa Cruz, Monterey, and San Benito. In October 2020, CFIA’s import requirements permitted imports from the counties of Santa Clara, Santa Cruz, Monterey, and San Benito with the completion of a negative E. coli O157:H7 test. These additional import requirements resulted in logistical challenges around sampling and diagnostic capacity, consumers and wholesalers reported higher prices, and were periodically challenged to source product. With potential threats to a consistent supply, wholesalers began seeking out additional suppliers.

    Prior to 2019, the five-year average of fresh lettuce imports into Canada in Q4 was 51,640 MT, with the U.S. market share reaching 99 percent, 62 percent of which came from California. During the past four years, when additional import requirements were in effect, the average Q4 imports were 47,350 MT. During this time, the U.S. market share was down slightly averaging 94 percent with California dropping to 53 percent market share. The average Q4 volume from Mexico almost quadrupled in the 2019-2022 compared to 2014-2018, increasing from one to five percent. Imports of Mexican romaine to Canada in Q4 may be particularly advantaged if additional import requirements for U.S. origin romaine lettuce continue to be burdensome for importers.

    Fall 2023 Requirements

    During this time, imports to Canada of U.S. romaine lettuce are required to be accompanied by a Proof of Origin confirming that any romaine lettuce and/or salad mixes containing romaine lettuce do not originate from the Salinas Valley counties of Santa Clara, Santa Cruz, Monterey, or San Benito. Should the romaine lettuce and/or salad mixes containing romaine lettuce originating from the Salinas Valley counties of Santa Clara, Santa Cruz, Monterey, or San Benito then CFIA requires testing for E. coli O157:H7 to confirm it is not detected in order for product to be import eligible. Importers will have a temporary condition on their Safe Food for Canadians (SFC) license for these requirements.

    The requirements remain similar to the 2022 requirements. For imports originating from the counties of Santa Clara, Santa Cruz, Monterey, or San Benito, importers must provide for a protocol in their preventive control plan outlining how they will implement the required sampling and testing. Each shipment must also have the completed attestation declaring that the appropriate sampling and testing was completed and E. coli O157:H7 was not detected in the shipment (Form CFIA/ACIA 5961). The official Certificate of Analysis for testing must also be included with each shipment.

    CFIA provides for two approaches to fulfill the sampling requirements:

    1) Finished-product sampling: sampling and testing is to be conducted before product is imported to Canada but is completed after all post-processing and handling steps are finished. A sampling lot is defined as 1 type or product of a size no larger than 1 truckload (maximum 20,400 kg/45,000 lbs). Each sampling lot must have a total sample weight of 1,500 g comprised of 60 randomized individual sample units of 25 g.

    2) Pre-harvest sampling: field sampling may be completed no more than 7 d prior to harvest. A sampling lot is defined as a 2 acre field or less. CFIA requires the field to be a homogenous romaine lettuce crop subjected to homogenous agricultural conditions. A total sample weight of 1,500 g comprised of 60 randomized individual sample units of 25 g must be taken from each sample lot. This option is primarily designed to accommodate field-packed product.

    The CFIA website provides for additional details on sampling requirements and testing requirements, including accepted methodologies and laboratory accreditation requirements, which are required.  — By Alexandrea Watters, USDA Foreign Ag Service

  • The Recent Romaine Recall and the LGMA

    Although the Center for Disease Control announced on January 9, 2019 that the recent e-coli outbreak is over, there is another part of the story that doesn’t seem to be getting allot of traction. During the investigation the FDA made the comment that based on the spread of the traceback it’s highly unlikely that it originated from a single farm. I don’t have any first-hand knowledge that hasn’t already been publicly disclosed, but I do understand how the produce supply chain works. A single source could be a possible scenario when you think through how one farm can go to multiple processors and terminal markets. There are two troubling allegations floating around about this outbreak that need put to rest.

    First, that the only grower/shipper implicated so far was not a member of the California Leafy Greens Marketing Agreement (LGMA). The LGMA recently sent out a statement confirming that is accurate so that’s not up for further debate. Since it was formed in 2006 the backbone of the LGMA has been that members voluntarily subject themselves to minimum food safety standards verified through unannounced inspections conducted by California Department of Public Health (CDPH) inspectors. The LGMA was never intended to stop all recalls but that through a HACCP type approach to continuously reduce risk starting at the field. Since the marketing agreement was voluntary the failsafe were the commitments made by some of the largest retailers and food service distributors at the time that their buy side would support LGMA members for West Coast sourced leafy greens.

    Being a member of the LGMA is not cheap. One recent study suggested that the incremental cost per acre since 2006 to abide by all of the minimum food safety standards and inspections that come with LGMA is close to $180 per acre. A non-LGMA farm can have the most stringent standards in the industry on paper. However, without incurring the incremental costs associated with maintaining “trust but verify” standards, supported by unannounced site audits they would have a substantial cost advantage over LGMA members.

    The second issue is how a non-LGMA member can get their leafy greens into the retail and food service channels. Just prior to the outbreak the romaine supply was extremely tight in many areas which was reflected in the USDA Mostly Market reports for romaine. Maybe it’s just coincidence, or maybe there is a hole in the process that the buy side needs to step up and address, especially when the industry is short. This is the second recall situation I am aware of in the past three years where the trace back implicated a California shipper/handler that was not an LGMA member.

    I’m not suggesting that somehow LGMA members have a safer product than anyone else. I am suggesting that we owe it to ourselves as an industry and to consumers to ensure that everyone is at least working from the same floor. How high someone wants to go above that floor is an individual business decision. The LGMA may not be the perfect solution to maintaining minimum standards on an industry wide basis, but right now it’s the only solution.

    If the buy side isn’t going to step up and support LGMA for leafy greens sourced from the West Coast, especially when supplies are tight, then maybe it’s time to rethink it. When everyone is allowed to revert back to their own standards, then we really have no standards which is where we were in 2006.

  • Minimizing Risks for Food Recalls & What to do During Them

    Any grower or packer that has experienced a food recall knows how stressful things can get and all that is at stake; yet those who have never experienced them tend to be the least prepared for a recall when it occurs. Watch this brief video interview with Rachael Dettmann Spiegel as she addressed growers, hullers and processors at the recent Almond Alliance Convention on how to prevent recalls from happening — but also how to deal with them in the event that a food recall does occur, like the one that has been all over the news recently with romaine lettuce.