Reducing the Unique Risks in Sprouts

The FDA guidance document recommends that spent irrigation water be sampled from each production lot or batch, described as “sprouts from a single lot of seed that were started at the same time in a single growing unit (i.e., a single drum or rack of trays).” Generally, 1 liter of water is recommended for sampling spent irrigation water, collected as the water leaves a drum or trays during the irrigation cycle. Pooling from different production batches is discouraged since any pathogens present may be diluted with samples that are not contaminated. In addition, if a presumptive positive is found in a pooled sample, the sprouter would need to either discard all batches represented by the pooled sample or retest each individual batch in order to determine which is/are contaminated.

Hurdles and Solutions

Other types of sprouts present a challenge in recommending a best practice for testing. Some types of sprouts are commonly irrigated for less than 48 hours, and if microbiological testing is performed, results may not be reported to the sprout producer prior to the product entering the food supply. In such a case, a sprout producer may instead sample the sprouts themselves, rather than the spent irrigation water. The concern in this case is that detecting a low level of contamination present in the sprouts is challenging.

The recommendations in the two FDA guidance documents, along with other resources, including documents from international scientific bodies, international regulations, training material, etc., relating to best practices for sprout safety are currently being evaluated and used to develop a core curriculum by the Sprout Safety Alliance (SSA), a public-private alliance between stakeholders from the food industry, academia, and federal, state, and local food protection agencies. The SSA was created by the FDA in cooperation with Illinois Institute of Technology’s Institute for Food Safety and Health in 2012 to enhance the sprout industry’s understanding and implementation of best practices for improving sprout safety. The SSA aims to develop a core curriculum and training program for stakeholders in the sprout production community for improving sprout safety and understanding the requirements outlined in the FDA Proposed Rule on Standards for Produce Safety.

Under FSMA

Sprout producers will likely need to adhere to the appropriate requirements in the Proposed Rule covering fresh produce safety under the FDA’s Food Safety Modernization Act (FSMA), and in particular, in the specific section on sprouts (FDA, 2013). The proposed requirements include using a scientifically valid method to treat seeds immediately prior to sprouting in order to reduce pathogens that may be present on the seeds. The FDA also proposes that sprout producers perform environmental testing for Listeria spp. or L. monocytogenes, and test spent irrigation water or sprouts for Salmonella and E. coli O157:H7. In each case, a written sampling plan must be prepared and include considerations of when, how, where, and what to sample, and for spent irrigation water testing, how much sample to collect.

The SSA is working with sprout producers, academic researchers, and other stakeholders to develop best practices for sampling so sprout producers large and small can benchmark their current practices, and strive to improve their practices surrounding sprout safety. Mock sampling and testing plans are expected to be part of the SSA training program, in order to assist the sprout industry, and particularly the small sprout producers, with developing their own individual plans.

Raw sprouts will continue to have safety concerns due to the inherent issues surrounding their growth, which also promote the growth of any pathogenic bacteria that may be present. Testing sprout spent irrigation water for bacterial pathogens has long been known to be an effective tool, amongst others, that can be used to improve the safety of sprouts.