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Safe Sprouts.  It is a Matter of Risk Reduction
Sproutnet
International Specialty Supply
August 26, 2001

The last SproutNet stirred up several people to become interested in seed sampling.  It also stirred up more than one grower to consider a class suit action against the FDA.

Personally, I appreciate the efforts of the FDA and other health organizations.  The industry has greatly improved because of their efforts.

The FDA has reason to be concerned.  The outbreaks, with few exceptions, have come from pathogens that enter the sprouting facility on the seed.  There is no sanitizing method that will completely eliminate pathogens from seed all of the time.  Even if your sanitizing method does remove all the pathogens, you still have to worry about who has handled that seed, and where it has been in your facility prior to sanitization.  Seed in not just a problem, seed is the problem that has hounded the industry since the first outbreak.

As an industry, if we want the health organizations to shut up we need to quit having outbreaks.  Yes, I realize that it will take a couple of years without outbreaks to quiet the presses.  Put plain and simple - no outbreaks, no more bad press. 

Sounds easy doesn't it.  Actually, it is. Sprout growers need to quit buying contaminated seed!

About a year ago, while attending a trade show, I was sitting at a lunch table with another sprout grower.  There were about six others at the table as well.  As it turns out, one of them was a seed supplier.  I recognized his name because the company he works for also sales seed to the sprouting industry.  The sprout grower had never heard of the company though.  A conversation struck up that went something like this:

Grower:  "It's always good to find more sources of seed.  Do you test your seed for pathogens?"

Seed Co:  "Oh, absolutely, we always test our seed for pathogens".

Grower:  "Wonderful!  What kinds of seeds do your carry?"

At that point, I realized that the grower heard all they needed to hear.  The company "tests their seed for pathogens".

I had to ask:  "How do you test your seeds for pathogens?"

Seed Co:  "We send a sample off to a lab."

This may have been what the sprout grower wanted to hear, but it told me that the seed company probably didn't have a clue what they were doing. While writing this article I called a nationally known pathogen-testing laboratory.  The lab said that in order to test alfalfa seed for pathogens they need 25 grams of seed for the salmonella test and 25 grams for the E.coli 0157:H7 test.  This is typical of most labs.  If Seed Co. sent a sample to a lab who tests 25 grams, and if the lot of seed were contaminated at .7 cells/kg with one of those pathogens, the likelihood that any of the contaminated seeds would show up in the 25 gram sample is only 1.7%!

However, had he sampled 25 grams from each of the 880 bags, sprouted it, and tested the runoff water, the likelihood of capturing the pathogen from that same lot of seed increases from 1.7% to over 99.9999%.

In other words, Seed Co. did nothing except give the grower a false sense of security.  Even if they had sent a 50-pound sample to this pathogen test lab, the test would have been useless, because they only test 25 grams.  I am not saying that Seed Co intentionally deceived the grower.  They may be trying very hard, or they might just be covering their rear, but what they are doing is useless.

 Until growers become educated on how to purchase well sampled and tested seed, seed suppliers will continue to placate them.  This is only natural.  Many of the growers themselves were guilty of the same thing.  A produce wholesaler would ask them if their sprouts were safe and they would say, "We test all our sprouts for pathogens."  Then the FDA went to the sprout facilities and found a great deal of sprout growers didn't even know how to either test or have their sprouts tested for pathogens.

If you are involved in an outbreak, it will be little comfort to the victims, and probably useless in court, that "your seed supplied said the seed had been tested for pathogens".

Insist on two documents from your seed supplier:

1.  General Procedures.  Get the written procedures your seed supplier uses to sample and test the seed they send you. These are general procedures and are not lot specific.  Then evaluate these procedures!  Just because the seed supplier is a major supplier to the industry does not mean they have the industry at heart.  Make sure the procedures include sampling at least 3 kg of seed, with the largest sample being no more than 30 grams (about two ounces), and that the entire sample is sprouted and the runoff water is tested after 48 hours.

2.  Seed Sampling & Pathogen Testing - Lot Specific.  Get the procedures they actually did on the particular lot of seed you are purchasing.  This should include who did the procedures, and when it was done - An actual name and date!  Don't settle for anything less.  If the seed company did the work they will be delighted you asked. If they didn't do the work, don't financially support them with your business.  Demand properly sampled and tested seed!  The alternative is to properly sample and test the seed yourself, which is a good practice even if the seed supplier does it also.

Seed purchasing is the most important critical control point in your HACCP plan.  An example of the information you should require from your seed supplier (and/or do yourself):

Seed
Seed:  Alfalfa
Lot: 125XCB5
Lot Size: 880 50-pound bags (signature, date)

Sampling
Samples taken: 440 (signature, date)
Sample Size: Approximately 25 grams each (signature, date)
Total Sample: 11 kg (signature, date)

Pathogen Tests
Method:  Sprout production
Time Started: August 21, 2001 8:15 am (signature, date)
Tested:  Run off water (signature, date)
Time Sampled:  August 23, 2001, 9:30 am (signature, date)
Growing Time: 49.25 hours (signature, date)
Salmonella:  Negative (signature, date)
E.coli 0157:H7:  Negative (signature, date)

If you don't know the probability of detection on a particular sample size, ask your ISS sales representative. 

If you do not have paperwork in your hands regarding the specific lot you are buying, that shows your seed was properly sampled and tested, it wasn't.  You have no idea how important, and powerful, that piece of paper is!  It can protect your customers, save your company, and change the industry. 

The seed supplier can't guarantee that there won't be an outbreak with the seed.  However, if there is an outbreak, he can guarantee that he did all the safety steps he said he did for the particular lot of seed you received.  The growers themselves need to be responsible for evaluating the information given to them about the lot to determine if the information is of any value.  The growers are the ones responsible for the end product.  

This does not take an FDA mandate (although one would be helpful).  This takes growers educated in risk reduction and insisting that their suppliers are also. 

I am not advocating anyone replace any of their existing GPM's with proper seed sampling and testing.  I am saying that because nearly all the outbreaks have been seed oriented, seed is the most important Critical Control Point and should be treated as such. 

When all sprouting seed is properly sampled and tested, either by sprout growers or sprout seed suppliers, and all growers are using safe manufacturing procedures, the outbreaks related to contaminated seed will be gone.  So will the bad press.