Abstract

The Food Safety Modernization Act (FSMA) includes a time-to-harvest interval following the application of noncompliant water to preharvest produce to allow for microbial die-off. However, additional scientific evidence is needed to support this rule. This study aimed to determine the impact of weather on the die-off rate of Escherichia coli and Salmonella on spinach and lettuce under field conditions. Standardized, replicated field trials were conducted in California, New York, and Spain over 2 years. Baby spinach and lettuce were grown and inoculated with an ∼104-CFU/ml cocktail of E. coli and attenuated Salmonella Leaf samples were collected at 7 time points (0 to 96 h) following inoculation; E. coli and Salmonella were enumerated. The associations of die-off with study design factors (location, produce type, and bacteria) and weather were assessed using log-linear and biphasic segmented log-linear regression. A segmented log-linear model best fit die-off on inoculated leaves in most cases, with a greater variation in the segment 1 die-off rate across trials (-0.46 [95% confidence interval {95% CI}, -0.52, -0.41] to -6.99 [95% CI, -7.38, -6.59] log10 die-off/day) than in the segment 2 die-off rate (0.28 [95% CI, -0.20, 0.77] to -1.00 [95% CI, -1.16, -0.85] log10 die-off/day). A lower relative humidity was associated with a faster segment 1 die-off and an earlier breakpoint (the time when segment 1 die-off rate switches to the segment 2 rate). Relative humidity was also found to be associated with whether die-off would comply with FSMA's specified die-off rate of -0.5 log10 die-off/day.IMPORTANCE The log-linear die-off rate proposed by FSMA is not always appropriate, as the die-off rates of foodborne bacterial pathogens and specified agricultural water quality indicator organisms appear to commonly follow a biphasic pattern with an initial rapid decline followed by a period of tailing. While we observed substantial variation in the net culturable population levels of Salmonella and E. coli at each time point, die-off rate and FSMA compliance (i.e., at least a 2 log10 die-off over 4 days) appear to be impacted by produce type, bacteria, and weather; die-off on lettuce tended to be faster than that on spinach, die-off of E. coli tended to be faster than that of attenuated Salmonella, and die-off tended to become faster as relative humidity decreased. Thus, the use of a single die-off rate for estimating time-to-harvest intervals across different weather conditions, produce types, and bacteria should be revised.

Highlights

  • IMPORTANCE The log-linear die-off rate proposed by Food Safety Modernization Act (FSMA) is not always appropriate, as the die-off rates of foodborne bacterial pathogens and specified agricultural water quality indicator organisms appear to commonly follow a biphasic pattern with an initial rapid decline followed by a period of tailing

  • In the United States, there have been 6 multistate Escherichia coli O157:H7 outbreaks linked to leafy greens between 2017 and 2019, which have caused a total of 497 illnesses and 6 deaths [3,4,5,6,7,8]

  • As part of the Food Safety Modernization Act (FSMA), the FDA proposed an agricultural water standard to define the microbial quality required for any source of surface water applied to the harvestable potion of produce [20]

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Summary

Introduction

IMPORTANCE The log-linear die-off rate proposed by FSMA is not always appropriate, as the die-off rates of foodborne bacterial pathogens and specified agricultural water quality indicator organisms appear to commonly follow a biphasic pattern with an initial rapid decline followed by a period of tailing. If the water does not meet this standard, growers can choose to (i) not use the water source, (ii) treat the water prior to use, or (iii) wait up to 4 days from water application to harvest to achieve microbial die-off at a level compliant with the agricultural water standard This assumes a Ϫ0.5 log die-off per day [22] (a negative die-off rate indicates a reduction in bacterial counts, and a positive die-off rate indicates an increase in bacterial counts). Chase et al [27], inoculated in-field lettuce with the same strains of attenuated E. coli O157:H7 in 2 replicated trials in Salinas, CA, and observed a net reduction of 2.6 and 3.2 log over 10 days This indicates substantial variation in observed die-off between studies. No of inoculation planting to Sample collection plotsb (mo/day/yr) inoculation (days) times (h)c collected per plot Data included per time point in analysisd

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