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On-farm food safety of leafy greens Report September 2016

TABLE OF CONTENTS Executive Summary ........................................................................................................................................... 2 Summary of key findings ................................................................................................................................... 3 Background ........................................................................................................................................................ 4 Consultation informing this report .................................................................................................................... 4 Overview of the leafy greens industry in Australia and New Zealand .............................................................. 4 The food safety of horticulture products .......................................................................................................... 5 The regulatory context .................................................................................................................................... 5 Opportunities to deliver better food safety outcomes in the production of leafy greens ............................ 7 Evidence informing food safety in the production and consumption of ready-to-eat leafy greens ........... 7 Products have different food safety risks depending on a complex interaction of factors ............................... 7 The evidence base for food safety in the horticulture sector is underdeveloped ............................................. 8 Attitudes and behaviours about food preparation have implications for food safety ........................................ 8 Guidance and oversight of food safety practices ........................................................................................... 9 A significant minority of the sector do not participate in industry-based food safety programs ....................... 9 Inconsistency in interpretation and implementation of standards and guidelines results in inconsistent risk management ................................................................................................................................................... 9 The value of audits is limited if they are treated as administrative formalities ............................................... 10 The ‘less visible’ supply chain and weaknesses in traceability may carry risks for effective incident management ................................................................................................................................................. 10 Embedding a culture of food safety ............................................................................................................... 11 The commercial value of food safety is not recognised ................................................................................. 11 Competition is a barrier to businesses sharing information about food safety .............................................. 11 Availability and uptake of relevant, timely and useful information, education and training is limited ............. 12 Tools, technology and infrastructure are available but not always utilised or adapted for food safety purposes ....................................................................................................................................................... 12 Conclusion ........................................................................................................................................................ 13 Appendix A: Food Standards Australia New Zealand work on food safety culture ............................................. 14 References ......................................................................................................................................................... 16

Executive Summary The nature of leafy greens means they may carry an inherently high food safety risk. Despite these risk factors, contamination and incidents of foodborne illness, while serious, are rare. This paper considers the opportunities to improve the food-safety of leafy greens. In February 2016 there was a Salmonella outbreak linked to lettuce produced in Victoria. This incident demonstrated that food safety incidents can have significant human health implications. These incidents (even if they occur very infrequently) can also negatively affect industry’s reputation and its relationship with trading partners. For this reason, the Food Regulation Standing Committee (FRSC) agreed to Victoria undertaking work to: 

examine whether, and to what extent, current farm practices in the production and processing of leafy greens are managing food safety risks, and



assess regulatory and non-regulatory options open to Australian and New Zealand governments to maintain or improve the safety of leafy greens. 1

Leafy greens are often grown in or near soil where they are subject to contamination. They are typically consumed raw, without a heat treatment that would kill pathogens. Despite these risk factors, microbiological data available from Australian and New Zealand surveys suggests there is a low level of contamination on fruits and vegetables. Incidents of foodborne illness relating to leafy greens, and horticulture more generally, while serious, are rare. As outlined below, there are three key elements that work together to support food safety in the production and processing of leafy greens. 

evidence about risk profile



guidance and oversight



food safety culture

The available evidence and stakeholder consultation does not identify serious systemic or sector-wide food safety issues.

evidence about risk


food safety culture

However, there are issues around the adequacy of the evidence base, oversight and industry culture in relation to food safety in the production of leafy greens. These issues affect more than one jurisdiction. Consumers, retailers and the Australian leafy greens industry in multiple states and territories have an interest in the food safety of leafy greens. Governments and industry are already undertaking activities to address the issues identified. These efforts are essential to maintain and improve the food safety of leafy greens. FRSC has an important oversight role and will continue to actively monitor existing and new activities to improve the evidence base, oversight and culture around food safety in the production of leafy greens.

On-farm food safety of leafy greens report

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Summary of key findings Evidence informing food safety in the production and consumption of ready-to-eat leafy greens 1.

A robust evidence base is fundamental to enable industry and government to better target investment in, and maximise the effectiveness of, food safety efforts.

2.

The evidence base for understanding and effectively managing particular risks arising in relation to leafy greens products and processes, and the complex interaction of multiple risks, is currently underdeveloped and underutilised.

Guidance and oversight of food safety practices 3.

Easy to understand, fit-for-purpose guidance materials and external oversight support businesses to adopt best practice food safety measures.

4.

A significant minority of the leafy greens sector do not participate in industry-based food safety programs.

5.

Inconsistent interpretation and implementation of standards and guidelines results in inconsistent risk management.

6.

The value of audits is limited if they are treated as administrative formalities.

7.

The ‘less visible’ supply chain and weaknesses in traceability reduces the timeliness and effectiveness of incident management.

8.

Industry and Food Standards Australia New Zealand (FSANZ) have already commenced work to improve the effectiveness of guidance and oversight.

Embedding a culture of food safety 9.

A strong food safety culture within businesses and across the industry is a prerequisite to maintain and improve the food safety of leafy greens.

10. Good food safety culture requires leadership commitment, a capable and supported workforce, and appropriate systems, tools, technology and infrastructure. 11. Strong leadership within individual businesses and across the sector is needed to prioritise food safety as having commercial value and promote information sharing about best practice between businesses. 12. Food safety training and education is not currently fit-for-purpose and uptake is low. 13. Easy to use risk management technology and tool could assist growers to more effectively and efficiently manage food safety risks.


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Background In February 2016 there was a Salmonella outbreak linked to lettuce produced in Victoria. The company initiated a voluntary food recall of affected products, and the Department of Health and Human Services investigated the particulars of the incident. This outbreak affected retailers and consumers in multiple states and territories. Following the outbreak, the Australian leafy greens industry reported a significant and sustained drop in sales. The small export market was also disrupted. This incident demonstrated that food safety incidents can have significant human health implications. These incidents (even if they occur very infrequently) can also negatively affect the industry’s reputation and its relationship with trading partners. For this reason, the Food Regulation Standing Committee (FRSC) agreed to Victoria undertaking work to: 

examine whether, and to what extent, current farm practices in the production and processing of leafy greens are managing food safety risks, and



assess regulatory and non-regulatory options open to Australian and New Zealand governments to maintain or improve the safety of leafy greens.

This report draws on existing research and data about the leafy greens and broader horticulture sector and consultation with industry representatives, regulators and other experts to answer these questions.

Consultation informing this report Key consultation activities informing this report include: 

a scoping workshop in May 2016 attended by Victorian government and industry stakeholders. This workshop explored contributing factors to the February 2016 outbreak, including factors related to systems, processes, people and the environment



circulation of an issues paper in July 2016. Based on the scoping workshop and research, this paper examined challenges for food safety in the production of leafy greens. The issues paper was circulated to FRSC members and industry stakeholders for comment



further government and industry stakeholder workshops in Melbourne, Brisbane and Adelaide throughout July and August 2016.

Industry stakeholders included people with knowledge and experience in:



growing, harvesting, processing and packaging practices



operating small, medium and large scale fresh produce businesses



industry organisations with state or national horticulture perspectives



technical specialisations in food safety standards, agronomy and research



government food policy, regulation, biosecurity and market access.

Overview of the leafy greens industry in Australia and New Zealand In 2010-11 Australian lettuce production accounted for 4.9 per cent of total vegetable production, with a gross value of $164 million. Production in Queensland and Victoria accounted for 39 and 34 per cent of national production respectively. The production contribution of other states and territories included New South Wales (10 2 per cent), Western Australia (8 per cent), South Australia (6 per cent) and Tasmania (2 per cent). According to the Australian Bureau of Statistics (ABS), 64 per cent of all vegetable growing farms accounted for 98 per cent of the total value of agriculture operations for Australian vegetable industry farms. This means 36 per cent of farms produced only 2 per cent of the national production. These small scale farms each had an estimated value of agricultural output of less than $50,000 per annum.


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In 2009 AusVeg estimated that there were 566 lettuce growers in Australia. New South Wales had the largest number of growers, with over 200 growers (38 per cent of the total number of growers) followed by Queensland 3 with approximately 150 growers (27 per cent) and Victoria with 90 growers (15 per cent). Together, the ABS and AusVeg data suggests that the industry profile in each state and territory is markedly different. Relatively small scale operations dominate New South Wales, whereas the Victoria industry comprises a small number of large farms. 4

In 2015 the New Zealand lettuce production value was estimated at $42 million from 100 growers. New Zealand is currently compiling statistical information on the number of horticulture businesses, businesses growing leafy greens, and the number of these that have adopted industry food safety programs. As explored further in this paper, the industry is non-homogenous in other key respects, including production practices, local climate conditions, participation in food safety programs and supply chains. At the same time, this sector shares features with other horticultural sectors, and the considerations in this paper may be relevant to other horticulture products consumed raw such as rockmelons, sprouts, broccoli, cabbage, snow peas and other salad vegetables. While overall vegetable consumption in Australia falls well short of recommended daily intake, for those that do consume vegetables, there appears to be increasing preferences for healthy eating including preferences for raw foods and fresh vegetables. This has implications for producing safe food, due to the vegetables not undergoing a heat treatment step to kill pathogens. Growth of the leafy greens sector is steady, but the sector reports increasing pressure to reduce production costs to remain commercially viable. The Produce Marketing Association for Australia and New Zealand supports an active group of member fresh salad producers. This grassroots group was first formed by concerned growers in response to food safety incidents throughout 2006 and 2007 in the United States of America and Europe associated with pre-packaged salad products and herbs.

The food safety of horticulture products While this work has focused on leafy greens, in many instances the evidence and issues are more broadly relevant to other horticulture products. Microbiological data available from Australian and New Zealand surveys suggests there is a low level of 5,6 contamination on fruits and vegetables. Since January 2006, there has been over 600 food recalls in Australia with 189 due to microbial contamination. Eighty four of these recalls occurred in the government regulated meat (including poultry) and dairy sectors, for Salmonella, Escherichia Coli and Listeria microbial contamination. During this period, there have been 15 food recalls for microbiological contamination in the fruits, vegetables and 7 herbs category. The products in this category recalled due to Salmonella were mainly sprouts , fresh parsley and dried herbs. As recently as July 2016 there was a Salmonella outbreak linked to rockmelon produced in the Northern Territory.

The regulatory context The Australia New Zealand Food Standards Code (the Food Standards Code) sets out compulsory primary production and processing standards. With the exception of sprouts, the Food Standards Code does not contain standards for the primary production of horticulture products. In 2013, Food Standards Australia New Zealand (FSANZ) proposed a primary production and processing standard for horticulture. The aim of the proposed standard was to create a regulatory standard to strengthen food safety and traceability throughout the horticulture supply chain. Following consultation, FSANZ determined not to progress the standard. The reasons for not progressing the proposal included: 

a lack of uniform support for a horticulture primary production and processing standard



the adequacy of existing industry led practice. An estimated 70 to 80 per cent of horticultural produce in Australia is grown under a food safety scheme that contains measures to control identified risk factors


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

a need to better understand industry profile and practice and its relationship to food safety risk



the broader issue of ensuring through-chain traceability for all commodities needs to be addressed. In 2014, FSANZ commenced an examination of traceability requirements for all industry sectors and supply chains.

FSANZ undertook to further investigate food safety initiatives in horticulture in collaboration with the horticulture 8 industry and government with a view to developing a non-regulatory approach. NSW is the only Australian jurisdiction that has state-based food safety requirements for plant product industries. The requirements are part of the Plant Product Food Safety Scheme (the Safety Scheme). The Safety Scheme 9 relates to the processing of fruit and vegetables, but does not cover primary production activities. New Zealand requires horticulture growers and packhouses to be registered under the Food Act 2014. The Act takes a risk-based approach and horticulture growers and packhouses are classified as National Programme 1 (low-risk). They are required to show how they manage hazards and follow simple good agricultural practices, to 10 produce safe and suitable food. 11

Australian governments have issued a range of non-binding guidelines to assist the fresh produce sector. The Fresh Produce Safety Centre has also issued Guidelines for Fresh Produce Food Safety. These guidelines provide support for businesses to identify food safety hazards in production, processing and handling of fresh produce. The guidelines identify supply chain hazards and outline best practice for managing the risks. They include recommendations about minimum periods between application of manures and harvest and provide a simple decision tree to help growers identify ‘high risk’ crops.


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Opportunities to deliver better food safety outcomes in the production of leafy greens There are three key elements that work together to support food safety in the production and processing of leafy greens. 

evidence about risk profile. A robust evidence base enables industry and government to better target investment and maximise the effectiveness of food safety efforts.



guidance and oversight. Easy to understand, fit-forpurpose guidance materials and external oversight can support the sector to adopt best practice food safety measures. To be most effective, guidance and oversight depends on the availability of robust evidence and a culture within a business to learn and continuously improve food safety practices.



food safety culture. A strong food safety culture supports a business to make decisions based on the best evidence and maximise the value of guidance and oversight to inform continuous improvement. Good food safety culture requires leadership commitment, a capable and supported workforce, and appropriate systems, tools, technology and infrastructure.

evidence about risk


food safety culture

The available evidence and stakeholder consultation does not identify serious systemic or sector-wide food safety issues in these three areas. However, there are opportunities to deliver better food safety outcomes through work in each of these areas. Options for bi-national and jurisdiction-level work in relation to each of these areas are considered below.

Evidence informing food safety in the production and consumption of ready-to-eat leafy greens Existing evidence suggests that production and consumption of leafy greens means that they carry an elevated risk in comparison to other horticulture products, but actual contamination and related foodborne illness is rare. However, there is limited evidence about particular risks and hazards throughout the supply chain, and the effectiveness of particular management strategies. Not enough is known about how risks and hazards interact, and the best approaches to deal with this complex interaction. Changes in consumer behaviour have implications for food safety practices on-farm and throughout the supply chain. Accurate and relevant evidence about the risk profile of products throughout the supply chain would support industry and governments to more effectively intervene to ensure food safety, and would provide a benchmark for the effectiveness of efforts to manage and improve food safety. Assessment of research and consultation indicates the key findings as outlined below.

Products have different food safety risks depending on a complex interaction of factors There is a range of interactions between crops, pathogens and production systems. Some products, activities and production systems are inherently more risky than others. For example soil culture where crops are exposed to weather events and animal waste products has different risks from hydroponic systems where the environment is more controlled. The plant structure and the leaf surface also influence how easily pathogens may be removed during processing, which in turn affects the risk profile of the final product. Mature whole lettuce is a more robust plant, so it is less likely to be damaged and has much longer harvest periods. Baby leaf products and on-farm practices for producing these products carry higher risk because they are more fragile and the potential sites of 12 physical damage on the leaf might increase the risk of pathogens entering its internal structure.


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Multiple governments have assessed the food safety risks relating to production and processing of leafy 13,14,15,16 greens. These risk assessments highlight the complexity of the food safety risks for ready-to-eat produce, noting that risk factors may vary with crop, production system, geographic setting, cultivar, plant development stage and pathogen (some variants of pathogens can stick to leaf surfaces and/or penetrate leaves better than others, even within a species). The complex interaction of crop, pathogen and production systems and consumer behaviour means there is no one-size-fits-all production practice that will effectively deliver safe products. The food safety of leafy greens instead requires a dynamic approach to risk assessment and mitigation.

The evidence base for food safety in the horticulture sector is underdeveloped In November 2015 the Fresh Produce Safety Centre (the Centre) published a report on gaps in current fresh 17 produce food safety knowledge in five key areas. 

fresh produce microbial contamination levels



agricultural water



organic inputs and composting



the storage environment and transport



interaction of sanitisers and fungicides.

This report identified key priority research areas including: 

collecting data to provide a clear view on the level and type of fresh produce microbiological contamination in Australia and New Zealand. This will help focus industry effort on managing key risk areas.



understanding the potential for pathogen transfer from agricultural water to produce surfaces, including improved information on water quality risk assessment, testing, water source management. This will help growers identify water use risks.



data about types of manures used in Australia and New Zealand composts. This will enable an improved assessment of the pathogen types and effectiveness of composting treatments in reducing food safety risk to an acceptable level.



a review of sanitiser and fungicide use patterns in Australia and New Zealand produce industries. This will assist in prioritising which produce types or sanitiser and fungicide use patterns need to be evaluated for compatibility.

In 2016, the Centre received Australian Research Council (ARC) funding over four years to support food safety research. Individual research projects are currently being scoped for approval. This research will contribute to addressing the current underdeveloped evidence base for food safety risk and effective risk management.

Attitudes and behaviours about food preparation have implications for food safety Consumers in Australia and New Zealand have a high level of trust in the safety of locally produced food. At the same time, consumers and food businesses increasingly prepare and consume traditional foods in non-traditional ways (for example, raw or lightly cooked). Consumers’ growing preferences for healthy fresh vegetables in 18 convenient ready-to-eat formats is driving retailers to fill this demand. Products may be sold or on-sold with the appearance of being ready-to-eat in instances where growers or wholesalers act on the assumption that users will further wash, cook or otherwise treat a product. Effectively ensuring food safety depends on growers and other parts of the supply chain being aware of and responding to trends in consumption. It also depends on consumers being informed about production practices and the implications for how food is prepared to protect health. There is limited evidence about whether, and how, consumer behaviour is informed by knowledge of how fresh vegetables are produced and intended to be consumed. Similarly, there is limited evidence about whether growers take changing preparation and consumption trends into account in their assessment and implementation of food safety practices.


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Guidance and oversight of food safety practices Industry standards and guidelines help growers identify, assess and control food safety hazards in complex production and processing systems. Standards and guidelines, whether mandated by government or under industry-based food safety programs, provide assurance to customers that individual suppliers meet quality parameters, including food safety. Strong and clearly demonstrated industry-wide adoption of good food safety practices increases the reputation of the industry. There is no primary production and processing standard for general horticultural products produced in Australia. In contrast, the United States of America and Europe have government-mandated standards for the production of horticulture products. The evidence and stakeholder consultation, as considered by FSANZ in 2013-14, and in the preparation of this paper, does not suggest that reconsideration of a mandatory standard is warranted for this sector. In the absence of mandatory standards and government oversight, industry has adopted voluntary food safety programs. Limited participation in food safety programs, inconsistent interpretation of standards and treatment of audit as an administrative formality together limit the effectiveness of existing guidance and oversight. Assessment of research and consultation indicates the key findings as outlined below.

A significant minority of the sector do not participate in industry-based food safety programs There are multiple voluntary industry-based food safety programs and associated standards that can apply to the production of leafy greens. Of the nine most used food safety programs, seven cover Good Agricultural Practice for primary production activities. Of these, five include a requirement for a Hazard Analysis and Critical Control Point (HACCP) plan showing the systematic assessment and control of hazards. All are third-party audited, at initial certification, and then periodically to maintain certification. There is a component of self-assessment and reporting against standards. Food Standards Australia New Zealand (FSANZ) indicates between 70 and 80 per cent of Australian produce is 19 grown under an industry-based food safety program. Other research suggests that for some sectors, 20 participation in industry-based food safety programs is even lower. While segmented data is not available, it is assumed that a significant minority of leafy greens are not produced under a certified food safety program. These products may be sold through wholesale markets and supply the food service sector and fresh produce retailers such as greengrocers. A small proportion of produce may also be sold in farmers’ markets and direct to public at the farm gate. Growers who do not participate in industry-led food safety programs miss out on the benefits of improved understanding of food safety risks in their production systems, information about process improvement and innovation opportunities, independent assurance (and the concomitant market access benefits), and raising staff awareness about the value of food safety and how they can contribute. In 2014 the FSANZ horticulture working group determined that this gap can be progressed through a collaborative approach involving the horticulture industry and government to develop, as appropriate, targeted 21 guidance, codes of practice, education materials and training.

Inconsistency in interpretation and implementation of standards and guidelines results in inconsistent risk management Interpretation and implementation of standards and guidelines varies between and among growers, on-farm food safety officers and auditors. This variation means that some growers exceed expectations to effectively manage food-safety risks. However, others may not effectively manage risk as a result of misinterpreting a standard. On-farm, multiple employees are involved in production and processing, and knowledge of standards and guidelines can vary between different employees and roles. Individual auditors may vary in their assessment of compliance, which creates confusion about which practices are compliant and effective. The existence of multiple voluntary food safety programs and non-mandatory guidelines can further contribute to uncertainty about best practice. In 2008, a group of fresh salad producers developed the Salad GAP (Salad Good Agriculture Practices) food safety standard that has now been included within the Freshcare Standard. The group believed collaborating on projects such as Salad GAP, they would begin to develop a unified approach to essential pre-competitive issues, 22 such as food safety.


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In May 2016 Horticulture Innovation Australia commenced work to improve consistency of horticulture standards and auditing processes. Major grocery retailers and the horticultural industry have agreed to streamline fresh produce safety requirements. A pilot of the new program will take place in the coming months, with the full 23 standardised food safety initiative expected to begin by the end of the year.

The value of audits is limited if they are treated as administrative formalities Audits can be useful to highlight areas for improvement and confirm good practice. External audit against a food safety program is also often a threshold requirement for market access. Compliance with food safety standards is typically assessed through a combination of self-assessment and regular external audit and inspection. There is very limited use of ad hoc ‘unannounced’ monitoring as part of external audit and self-assessment. Because the audits are annual one off planned events and closely linked to market access, sometimes producers treat them as administrative formalities. Growers may place a higher value on ‘passing’ than ‘learning’ from the audit.

The ‘less visible’ supply chain and weaknesses in traceability may carry risks for effective incident management The ability to trace a food back through a supply chain enables incident investigation to accurately identify sources of contamination. This in turn facilitates provision of targeted and accurate information about 24 contaminated products. Inadequate traceability hinders swift and precise identification, correction and containment of the source of an incident, and misses the opportunity to address specific and systemic contributing factors. This may also result in industry-wide rather than targeted food recall, with a higher economic and reputational cost to the sector. Growers participating in the food safety standards certification schemes are required to have traceability in place if they are supplying to processors captured by government food safety traceability regulations. The requirement for traceability is incorporated in the industry Freshcare standard and is required by the major food retailers in Australia. Other industries such as cattle, pork, dairy and recently sheep and goats in Victoria require traceability of an animal from the farm to the processor. However, growers supplying via other pathways through wholesalers or wholesale markets to food service or greengrocers are not currently required to have traceability. This includes the small proportion of products sold in farmers’ markets, direct to public at the farm gate or on the roadside. The lack of explicit traceability requirements for horticulture was raised during the consultation around the proposed primary production and processing standard for horticulture. FSANZ has commenced work to review the traceability requirements for all food commodity sectors and supply chains. A recurring theme identified in collaboration with regulators and industry is the importance of reliable, relevant, and readily and rapidly accessible information for traceability during emergencies and recalls. Inefficient record-keeping systems, human errors in data recording during batching/formulation and shipping, and inconsistent information from suppliers can all lead to complications in traceability and the ability to identify and retrieve implicated products. Stakeholders have indicated to FSANZ that there is very little guidance and it is generally up to the individual companies to determine the best way to meet the requirements. FSANZ’s initial work is focused on looking for a framework that is broader than specific food/product categories, facilitates better definition and alignment of data requirements across the food supply chain and enables information to be shared quickly and accurately between local, state and commonwealth agencies. Following discussions with the Global Food Traceability Centre, FSANZ’s current work is gaining a better understanding of * † the Critical Tracking Event /Key Data Elements (CTE/KDE) framework for providing data for internal traceability as well as connecting supply chain partners. FSANZ proposes to release a discussion paper at the end of 2017 describing the framework and seeking commodity, industry sectors, and associations to pilot the tool.

* †

Critical Tracking Events (CTEs) establish the processes and path of a product through the supply chain. Key Data Elements (KDEs) are the standardised pieces of data that document and record each CTE.


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Embedding a culture of food safety Consistent production of high quality products that are safe for human consumption is most effectively achieved when a solid evidence base and good external guidance and oversight is coupled with a strong food safety culture. Research about organisational culture and change, and its application to the food industry (particularly in the 25 26 work of Yiannas and Jespersen ), suggests that reorienting organisational culture toward new values requires deliberate effort at every level and aspect of a business’s operations. For a business to embed a strong food safety culture it also needs: 

strong leadership and commitment to food safety by owners and managers



a capable and informed workforce who are recognised and rewarded for good practice



business systems to support risk identification and management



technology, tools and infrastructure that support food safety.

FSANZ has recently commenced work to better understand and support effective food safety culture. National discussions have commenced between government and industry on the role of food safety culture and the drivers and barriers around implementing and maintaining a strong food safety culture throughout the food supply chain. The FSANZ approach and progress on this work is described in Appendix A. Assessment of research and consultation indicates the following key findings.

The commercial value of food safety is not recognised Food safety is one of many competing priorities in a farm’s business operations. Many farms are small to medium-sized businesses with limited resources. Many businesses are family owned 27 and run. Commercial operations have multiple areas of focus: financial management, facilities and equipment, employment, and contractual pressures around continuity of supply. These operating pressures mean food safety is one of many considerations. It can often be understood as a cost, requiring investment without apparent commercial advantage. The leafy greens market is highly competitive. Growers experience pressure to keep production costs as low as possible. They balance the commercial value of investing in adequate food safety risk management with the cost of mitigating against these risks. For example, chicken manure is an inexpensive source of nitrogen. However, unless adequately treated, chicken manure carries an increased risk that produce will be contaminated. Treated chicken manure is more expensive. Employing and upskilling staff with food safety expertise can improve management of food safety risks but also requires investment. Businesses must balance this value against the salary cost. The justification in a small to medium sized business for this type of expenditure is extremely difficult. Growers are removed from the ultimate human health consequences of contamination events. For example, a contamination event on farm may not result in an identifiable food contamination outbreak until the product has been purchased and consumed. Even then the product may not be traced back to the farm. This lack of proximity can reinforce a culture of ‘out of sight, out of mind’ in the absence of strong leadership and commitment to change. Fluctuating customer specifications or demand, and changing weather and other hazard conditions, further complicate growers’ ability to invest in consistent, strategic food safety risk mitigation.

Competition is a barrier to businesses sharing information about food safety The ability to produce high quality and safe products can be a point of differentiation in a competitive market. Growers can further maximise profitability by adopting cost-effective food safety approaches. Growers can be reluctant to share information about effective, economical food safety approaches with their competitors. Other primary production industries such as the dairy industry have been able to overcome this pressure by recognising that food safety is not a commercial differentiator for an individual business but rather an industrywide risk to be managed. Dairy Australia recognises this in their strategic plan to assist in protecting and promoting the industry. Managing supply chain food safety and integrity issues is a component in their strategic 28 program deemed worthy of investment for their members.


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Processors as accumulators of producers’ product may be in a strategic position to provide a platform for information sharing about food safety with growers. This may include the provision of valuable feedback on product quality issues that may affect food safety such as damaged leaves or heavily soiled product. Wholesale market authorities may be in a similarly valuable position for information sharing with growers regarding food safety for products entering supply chains such as for the food service sector and greengrocers.

Availability and uptake of relevant, timely and useful information, education and training is limited An effective food safety culture is one in which everyone understands their specific food safety responsibility. Education and training across the workforce is therefore a necessary precursor to all staff contributing to food safety. Between growers, and even within each farm, food safety knowledge, experience and capability varies. Employees bring a diverse range of experiences and expectations about food safety and the way in which farm practices contribute to food safety. Some farms and workers have excellent experience, expertise and capacity. Others may not develop or maintain a basic level of food safety risk management. Within some farms, some workers may not have the knowledge and skills to contribute to good practice or to mitigate food safety risks. There are few professional development opportunities such as courses and professional networks for on-farm food safety officers. There is also limited food handling training for other staff, such as pickers and packers. Training is difficult to access and is generally not delivered on the farm. Growers in the horticulture sector commonly rely on training from food safety management standards providers such as Freshcare and their 29 auditors. A workforce that increasingly comprises untrained, casual and itinerant workers is a challenge for traditional high-cost, time-intensive training delivery. 30

Existing guidelines, such as those published by the Fresh Produce Safety Centre contain accurate information about fresh produce food safety. However, the level of detail, length, format and language of these guidelines can limit the accessibility and usefulness. Some horticulture sectors have developed industry-specific training approaches. The Queensland ‘Yellow card’, ‘Melon card’ and ‘Mango card’ provide online pre-employment farm health and safety inductions for banana, melon and mango farm workers. A card is provided to farm workers as proof they have completed the farm safety 31 32,33 training. This approach could be adapted to food safety training.

Tools, technology and infrastructure are available but not always utilised or adapted for food safety purposes There may be an opportunity to enhance the identification and management of food safety risks with technology. On-farm data collection systems for crop management provide accurate data on crop history that may be adapted to enable growers to conduct a risk assessment at harvest. These tools combine ease of access through portable devices with the collection of farm data, such as: 

site characteristics



weather data



crop health



inputs



yields



chemical withholding periods.

Adoption of these tools varies across the industry. Workshop participants indicated that technology to assist with crop management used in combination with produce traceability can help mitigate the risk of overlooking hazards during production and processing. Uptake of this technology is low in the industry and there is value in further development and adaption of these tools for food safety risk management purposes.


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Conclusion The risks of foodborne illness are not limited to one jurisdiction. Food supply chains cross borders and as such it is important that governments, industry and businesses work individually and collaboratively to understand and manage risks in primary production and processing systems across jurisdictions. Industry and governments have already commenced work to address current weaknesses in the existing evidence base, guidance and oversight and food safety culture of the leafy greens sector. The Food Regulators Standing Committee will provide leadership by encouraging and monitoring existing and new efforts to maintain and improve the food safety of leafy greens. As this work leads to a more sophisticated understanding of the factors that enhance or threaten food safety of leafy greens, governments and industry can critically reflect on the effectiveness of existing efforts, and may wish to: 

develop benchmarks measures and targets for improvement of the food safety of leafy greens



consider further regulatory and non-regulatory interventions to address residual and emerging issues in the production of leafy greens



examine the relevance of issues in the production of leafy greens to other horticulture products.


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Appendix A: Food Standards Australia New Zealand work on food safety culture FSANZ’s work to support the development of food safety culture includes: 

developing a national food safety culture toolkit (assessment tools and guidance)



revising Safe Food Australia to provide further context and contemporary information on the Food Safety standards



establishing a food safety hub to centrally locate all food safety information on the FSANZ website



hosting a government and industry Food Safety Culture Forum – Drivers, Challenges and Opportunities on Friday 19 August 2016 at Old Parliament House Canberra to discuss the role of food safety culture and the drivers for, and barriers to, implementing and maintaining a strong food safety culture throughout the food ‡ supply chain. It was agreed to establish a government-industry partnership with FSANZ as coordinator.

The work will be undertaken during 2016, and reviewed in December 2016 to determine 2017 commitments resulting from Food Safety Culture Forum. A set of tools has been developed by FSANZ for use by government and industry, but primarily aimed at food businesses. These resources will be presented in different formats e.g. website resource, downloadable templates, printed materials e.g. survey forms, checklists, workbooks etc. Tool 1 – Identifying the food safety culture in your business This tool assists a food business with an initial food safety culture ‘health check’. It helps identify areas for improvement and provides a way for management to seek feedback from employees. It is recommended that this tool is used prior to the other tools. This tool can also be used as a self-assessment tool by small food businesses (for example, owner operators with no other staff), in place of the more comprehensive tool 4. Tool 2 – Shaping food safety culture in your business This tool emphasises that for a food safety culture to be successful it needs to be led from the top - that is, food safety culture needs to be embraced and practiced by the company managers. This tool guides senior staff through a four step culture change process on how to strengthen a business’ food safety culture. The tool uses a series of checklists that outline a range of simple leadership practices and examples that can be used to develop, shape and strengthen the food safety culture in a food business. Tool 3 – Measuring food safety culture – with matrix The matrix describes elements that make up a food safety culture. The left column describes a very poor food safety culture (termed reluctant compliers). The right side describes an ideal food safety culture (food safety champions), with three other columns in-between. This can help identify where a business sits in a schematic framework, and can help identify areas for improvements. This matrix can be used by both food businesses and regulators and complements the assessment tools (tools 4 and 5). Tool 4 – Self assessment tool for food businesses This self-assessment tool enables the owner or business manager to provide staff with the opportunity to provide anonymous feedback via the use of the tool’s questionnaire. The owner or business manager can then see which food safety culture category the staff perceive the food business to be in and can also identify opportunities for improvement to the food safety culture of the business. Tool 5 – Assessment tool for possible use by auditors and food regulators This tool is intended to complement the existing tools used by auditors or food regulators (e.g. audits, assessments) to enable them to assess the food safety culture within a food business and to assist in identifying opportunities for improvement. The FSANZ food safety webpages are being updated and consolidated as part of a food safety hub. This will include a separate section on Food Safety Culture, where the resources will be available for download. It is ‡

Currently working on refined purpose statement (around “we want to do it better”) and conversation streams. One of the first tasks will be looking at other sectors who have gone through a culture change (e.g. Qantas, Air NZ) where there is a focus on showcasing pride in their delivery and service.


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anticipated that the website will be live before the end of 2016. FSANZ is promoting the term Know, Do, Follow through, as part of food safety culture. This terminology is used throughout the tools and promotional items developed by FSANZ.

Know

Step 1

Do a health check of the food safety culture

Do

Step 2

Shape the food safety culture

Follow through

Step 3

Track and improve the food safety culture


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References 1 In this paper ‘leafy greens’ is broadly defined to include all green leafy vegetables primarily consumed in uncooked form, for example: lettuces, rocket, spinach, watercress, kale, parsley, basil. 2

Thompson, Zhang (2012), Australian vegetable growing farms: an economic survey 2010–-11 and 2011–-12, ABARES Research report 12.11 prepared for Horticulture Australia Limited, Canberra, December, Available at: http://data.daff.gov.au/data/warehouse/9aab/9aabf/2012/avfesd9abri20121127/AustVegGrwFrmEcoS urvey_1.0.0.pdf , accessed 17 August 2016 3

AusVeg (2011), Lettuce [online], Available at: http://www.ausveg.com.au/resources/statistics/vegetable-spotlight/lettuce.htm, accessed 13 July 2016 4

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Van der Linden, Inge, Avalos Llano, Karina R., Eriksson, Markus, De Vos, Winnok H., Van Damme, Els J.M., Uyttendaele, Mieke, Devlieghere, Frank (2016) Minimal processing of iceberg lettuce has no substantial influence on the survival, attachment and internalization of E. coli O157 and Salmonella, International Journal of Food Microbiology, [online], Available at http://dx.doi.org/10.1016/j.ijfoodmicro.2016.07.029, accessed 22 August 2016 13

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https://www.foodstandards.gov.au/.../proposals/.../P1015%20Horticulture%20PPPS%2, accessed 22 August 2016 14

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Insider FMCG (2016), Healthy trends drive Australian food consumption. Available at : https://insidefmcg.com.au/2016/03/29/healthy-trends-drive-australian-food-consumption/, accessed 22 August 2016 19

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Department of Economic Development Jobs and Transport and Food Standards Australia and New Zealand (2016) On-farm food safety practices survey of strawberry growing in Victoria. Available: http://www.foodstandards.gov.au/science/surveillance/pages/isccomponent1.aspx, accessed 8 July (This estimate is similar to findings from a Victorian Department of Economic Development Jobs, Transport and Resources survey of Victorian strawberry growers. The survey found 56 per cent of farms had one or more food safety programs in place and the remaining 44 per cent had no food safety program. When farm size was considered, 26.7 per cent of small farms and 78.6 per cent of large farms had food safety programs, respectively.) 21

Food Standards Australia New Zealand (2014), Abandonment – Proposal P1015 Primary Production & Processing Standard for Horticulture pg13, Available: http://www.foodstandards.gov.au/code/proposals/Documents/P1015-Hort-PPPS.pdf , accessed 22 August 2016 22

Food Standards Australia New Zealand (2008), Supporting Document 3 - Review of Food Safety Systems in Australian Horticulture Page 48 Salad GAP – Version 1.1 (September 2008). Available: http://www.foodstandards.gov.au/code/proposals/documents/P1015%20Horticulture%20PPPS%201C FS%20SD3%20FS%20systems.pdf, accessed 29 August 2016 23

Horticulture Innovation Australia (2016), Global-first agreement with retailers to benefit horticulture growers [Media Release], Available: http://horticulture.com.au/global-first-agreement-with-australianretailers-to-benefit-horticulture-growers/, accessed 18 August 2016 24

Welt, Blanchfield (2012), Food traceability [PDF] International Union of Food Science and Technology, Available at: http://iufost.org/iufostftp/IUF.SIB.Food%20Traceability.pdf, accessed 17 August 2016


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Central Markets Association of Australia (2015) Horticulture Code of Conduct – Review Submission, [PDF], Available at http://www.agriculture.gov.au/SiteCollectionDocuments/agfood/horticulture/code-conduct/submissions/central-markets-association-of-australia.pdf, accessed 12 July 2016 28

Dairy Australia (2013), Dairy Australia: Strategic Plan 2013-14 to 2015-16 [PDF],ages Available at: http://www.dairyaustralia.com.au/Industry-information/About-Dairy Australia/~/media/Documents/Industry%20overview/About%20Dairy%20Australia/Strategic%20plan/S trategic%20Plan%2013-16_web.pdf , accessed 19 August 2016 29

Department of Economic Development Jobs and Transport and Food Standards Australia and New Zealand (2016) On-farm food safety practices survey of strawberry growing in Victoria pg21. Available: http://www.foodstandards.gov.au/science/surveillance/pages/isccomponent1.aspx, accessed 8 July 2016 30

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Food and Agriculture Organisation of the United Nations (2013), Code of hygienic practice for fresh fruits and vegetables (CAC/RCP 53-2003) [PDF], Available: http://www.fao.org/fao-whocodexalimentarius/shproxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FSta ndards%252FCAC%2BRCP%2B53-2003%252FCXP_053e_2013.pdf, accessed 6 July 2016 (For example, this recommends personnel associated with growing, harvesting should be aware of Good Agricultural Practices (GAPs), good hygienic practices, their role and responsibilities and have necessary skills and knowledge.) 33

Food Standards Australia New Zealand (2011) Supporting Document 1 Information Paper pg 9. Proposal P1015: Primary Production & Processing Requirements for Horticulture. Available: http://www.foodstandards.gov.au/code/proposals/pages/proposalp1015primary5412.aspx, accessed 22 August 2016


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