Outbreaks A, B, and C sickened at least 188 people in 2019 when they ate romaine lettuce contaminated with E Coli O157:H7. 

The Food and Drug Administration (FDA) announced on May 21 this year that the E. coli O157:H7 contamination responsible for all three romaine outbreaks likely came from fecal material that reached the lettuce crops from nearby feedlots.

That conclusion was nothing new. In 2018, romaine contaminated with E. coli O157:H7 was grown in the Yuma, AZ, region. A large feedlot adjacent to an irrigation canal used to water lettuce was the suspected source.

In 2019, the romaine contaminated with E. coli was grown in California’s Salinas Valley. Cattle operations are smaller in Salinas than Yuma.

The California Leafy Green Marketing Association (LGMA) responded to the FDA report on the outbreak with the appointment of a special subcommittee to focus on how land adjacent to leafy greens farms may be contributing to foodborne illness outbreaks associated with romaine lettuce. The action is part of a comprehensive review of all existing food safety practices required under the LGMA program and is in direct response to the FDA report.

The Adjacent Lands Subcommittee is to review current LGMA standards related to grazing lands and adjacent properties, gather all relevant research done by the Center for Produce Safety (CPS), or other entities and consult with stakeholders for additional input. The Subcommittee plans to look at a number of factors including distance; slope and other physical properties; the impact of weather; potential barriers such as berms, diversion ditches or vegetative strips; and “good neighbor” policies as they relate to properties located near leafy greens farming operations.

The Subcommittee plans to engage with landowners of properties located near leafy greens farms including cattle and other crops like wine grapes. Current requirements under the voluntary LGMA call for assessments of environmental conditions in and around leafy greens fields.

Sandra Eskin, who directs The Pew Charitable Trusts’ work on food safety says the FDA report presents a food safety problem that cannot be solved by a single industry or regulatory athority.  Writing for Pew’s website, Eskin says “when it comes to preventing contamination of leafy greens by “pathogens commonly present in animal fecal matter,” it’s going to take cooperation from growers, ranchers, and local, state, and federal agencies.

The A, B, and C outbreaks of 2019 involved different strains of E. Coli traced to romaine from several fields in the Salinas Valley.

The May 21 report said the E. coli strain from the largest of the outbreaks was in a sample of fecal and soil matter taken from a cattle grate within two miles of multiple fields wher romaine had been grown. Other harmful strains unrelated to the 2019 outbreaks turned up in samples taken from an area between fields and grazing land and from on-farm water drainage basins.

Eskin goes on to make the following observations:

“The FDA report makes clear that allowing cattle to graze near fields that grow romaine lettuce or other leafy greens creates an unacceptable risk to the health of consumers, who often eat these foods raw. The question is how best to reduce this danger.

The report recommends that growers ” ‘redouble’ prevention efforts, “assess and mitigate risks associated with adjacent and nearby land uses,” and create buffer zones between fields and grazing lands as well as physical barriers to divert water runoff away from crops. An FDA action plan detailed agency efforts to reduce outbreaks linked to leafy greens, including plans to complete its report on the Salinas investigation and release revised standards for the quality of water used in production operations.

“These steps are necessary but not sufficient to effectively address this situation. Although the agency oversees produce safety, it does not regulate livestock operations; in fact, no federal agency does.

“The solution to a complex problem like this one requires a multidimensional approach. For example, a wide range of stakeholders could be brought together to develop a coordinated plan to address risks created when produce and animal agriculture businesses are located near one another. Produce farmers and cattle ranchers should be at the table, along with federal, state, and local authorities.

“State and local authorities have jurisdiction over land use, whether for cattle grazing or other activities. That’s why agencies at those levels need to consider adjacent land use when allowing cattle to graze on a particular property and put in place appropriate requirements and restrictions.

“The U.S. Department of Agriculture does not have jurisdiction on the farms, ranches, and feedlots wher cattle are raised; its oversight of meat and poultry safety begins when the animals are slaughtered and processed into products such as steaks and ground beef. However, the department does run programs that provide financial assistance to growers and ranchers that, for example, take steps to address natural resource and environmental concerns.

“USDA should evaluate whether these programs could help livestock operations to control fecal contamination from cattle more effectively. If existing programs do not allow for such incentives, then the department should consider establishing ones that do.

“FDA should lead an effort to find comprehensive solutions to the public health problems created when cattle and produce farms operate in proximity. Without such solutions, Americans may see still more outbreaks linked to romaine lettuce and other leafy greens in the years ahead.”