All You Want to Know About Sprouts

This is interesting because there is a strong implication that, if the sprouts pass their SIW pathogen test at 48 hours, after any pathogens on the seed will have had the opportunity to multiply by 6 log cfu/g, the risk that the sprouts might be contaminated is greatly reduced. If undesirable organisms are present at significant levels in sprouts, these organisms would have been detected in the routine, every-batch SIW testing that has become standard good manufacturing practice for sprout production, and would not have reached the consumer.

(Note that these graphs are measuring sprouts that are continuing to sprout in ideal growing conditions, 20-30 degrees Celsius, for up to 84 hours). This research gives a high level of confidence that the sprouts, subject to this procedure, are safe to consume.

There is also an implication that any cross-contamination with pathogens onto the sprouts, after the sampling, will not have significant growth, even under the most ideal conditions for growth. This is where the Time/Temperature Control is questionable, and not based on sufficient research. There has been some initial, promising research in this area.

Another implication from the growth curve of bacteria on these graphs is the possibility that healthy bacteria inoculated on the seed before sprouting may out-compete pathogens that might be present on the seed from prior contamination. Some research into competitive exclusion with friendly bacteria as a preventive pre-sprout step has good indicators. Sprout grower associations, universities, and the FDA are continuing to pursue this line of investigation, which would save sprouts from harsh pre-sprout sanitation steps that kill pathogens but almost always show re-growth during the first 24 to 48 hours of sprout growth.

The maintenance of a healthy sprout industry depends on every grower having access to relevant, affordable and up to date good practices and third-party audits. An industry standard, backed by an audit (unlike the Rule) can be easily updated to newer or better procedures that can save costs, be simpler for growers to use, and produce better quality product.

Industry needs government to distribute best practices, research expensive and sound scientific improvements, and regulate industry with some threat of consequence for slacking. Although we have worked together quite well over the years, we feel that there are a number of areas in the FSMA Rule as it applies to sprouts, and in the Draft Guidance, that did not adequately involve the sprout industry. To name a few: developing a mandatory seed supplier seed testing protocol; reviewing the scientific basis of the value of “Time/Temperature Control” for safety; the statistical rationale for defining an entire seed lot as “contaminated” following a single positive SIW test; the evidence for determining the best time in a watering cycle to collect the SIW sample; and the ongoing uncertainties around estimating treatment efficacy, resulting from the lack of a standard protocol for treatment research studies.

I hope that the FSMA Rule is not considered to be a “Final Rule,” and believe that a further cooperative effort with the sprout industry could be beneficial in developing more effective and practical regulations.

There are valuable opportunities here, which can lead to significant improvements in sprout safety, and help increase confidence in sprouts as a safe and uniquely nutritious food. For more information on sprouts, and on some of these research opportunities, please contact the ISGA office at [email protected].

Sanderson, with her husband Robert—who assisted in this article, are the owners of Jonathan Sprouts, Inc. since 1976. Reach her at [email protected].