Explore this issueApril/May 2018
During the 1970s in the U.S., sprouts became popularized as a healing food by people such as Adele Davis (Let’s Eat Right to Keep Fit) Frances Moore Lappe (Diet for a Small Planet), and Ann Wigmore (The Sprouting Book: How to Group and Use Sprouts to Maximize Your Health and Vitality). Increasingly, consumers have been exploring the relationship between highly processed foods involving nutrient depletion and chemical additives, and many long-term degenerative diseases. There is a growing interest in eating a healthy diet rich in sprouts, wheatgrass juice, berries and other primary foods. By “primary food,” I mean a food carrying all the nutrients it needs to get started on life; the seed or berry receives from the mother plant the highest quality nutrients available to ensure the survival of its species.
When the seed is first planted and begins to sprout, the nutrients burst forth and nutrients, including phyto- (plant) chemicals, which are known to have various healing properties, are often present at much higher concentrations than in the full-grown plant. For example, broccoli, radish, kale, and other plants in the Brassica family have a phytochemical (sulforaphane) at many times the level found in the broccoli branches, that has been shown to protect against a range of maladies, including cancer.
Not only are sprouts high in phytochemicals, they are exceedingly high in naturally occurring microorganisms. In the past, bacteria have often been seen as inherently undesirable, to be minimized or eliminated entirely. However, there is a growing realization that the human body exists in a complex relationship with countless types of microorganisms that are crucial not only to good health, but to our very existence.
My husband, Bob, and I have been sprout growers since 1976. I first got involved in the Massachusetts Department of Food and Agriculture, Promotional Advisory Committee, in the early 1980s. The offer of a federal/state marketing grant led me to contact other Northeast sprout growers. We set up a sprout association to both promote sprouts and solve some of our quality problems in conjunction with the University of Massachusetts Amherst plant pathology department (pathogens in those days were the bacteria that spoiled sprouts). This association led to the formation of the International Sprout Growers Association (ISGA). Our regional, national, and international involvement in the sprout industry followed from there.
In the late 1980s, CDC’s epidemiology began to identify illnesses related to consumption of sprouts and other vegetables, and suddenly we were involved with a new kind of microorganism, that made people sick. The ISGA formed a Technical Review Board and, among other projects, began work on our Code of Practice for the Hygienic Production of Sprouted Seeds and Beans.
The FDA released sprout grower guidance for growing safe sprouts in 1999. The guide basically consisted of three recommendations: treat seed with an effective disinfection process, test all production batches for pathogens of concern with hold-and-release pending negative test results, and maintain a clean and sanitary operation.
Through the ISGA, sprout growers became involved in forming a Task Force with the Institute for Food Safety and Health. A group of growers, professors, and related industry members began work with government on the Sprout Safety Audit, which I co-chaired with Tong-Jen Fu, PhD, research chemical engineer at FDA.
After a year of work on the audit, followed by beta testing with three sprout companies, the USDA suggested converting the audit to a format listing not just the requirements of an audit, but also the procedure, verification, and corrective action for each requirement. Permission was granted by the United Fresh Produce Association to model a Sprout Grower Packer Operations Safety Standard on the Harmonized GAP Standards. Interested parties, such as Whole Foods and Sysco Corp., joined in on conference calls for the next year of conversion from Audit to Standard.
In 2016, FDA codified the growing and handling of all produce (the FSMA Rule) with a special section addressing (some of—I’ll get back to this) the unique qualities of sprouts. Upon issuance of the final Rule, the Task Force went into its third revision of the “Standard” to incorporate the appropriate elements for the applicable FSMA regulations (Produce Safety Rule, Sanitary Transport, and Intentional Adulteration). The Task Force will evaluate need for a fourth revision when the 2017 Draft FDA Guidance for Sprout Operations is finalized.
Concurrent with the development of sprout safety standards by industry and regulatory, in 2003 the Food Marketing Institute developed a Safe Quality Food (SQF) audit, within the framework of the Global Food Safety Initiative, which has become the primary food safety standard for many of the larger retailers.
Recently, SQF created a draft Sprout Module, using the language of the Sprout Standard. At the same time, due to budget concerns, the USDA has tabled the next round of beta testing and auditor training for their Sprout Safety Audit until they see more interest from growers, or industry QA, for a less expensive, thorough audit, based on the Sprout Safety Standard. Contact Ken Petersen, branch chief of specialty crops inspection division, Audit Services Branch, USDA-AMS, at email@example.com if you are interested in pursuing this option.
During the summer of 2017, the FDA released its Draft Guidance for Sprout Growers, a 123-page document with details appropriate to specific kinds of sprouting equipment (more or less costly to growers depending on the type of equipment they use) and in some cases containing unclear or insufficient scientific or statistical rationale for the specific recommendations given. Although the sprout industry and the public were given the opportunity to comment on both the FSMA Rule and the Guidance, the process of deliberation and decision does not involve further sprout grower input, and will at some point be published as “final” Guidance.
Back to FSMA, there are several areas where regulators have codified practices for the sprout industry that are based on “the way things have been defined” and not on a scientific questioning of the applicability to the unique qualities of sprouts. For example, FDA classified sprouts as “Time/Temperature Control” for safety. It is expensive to growers and retail stores and ignores one of the most promising characteristics of sprouts. From the earliest guidance in 1999, the FDA has suggested sampling and testing of sprout irrigation water (SIW) for Salmonella and E. coli O157:H7, at about 48 hours from planting of every batch of sprouts grown (see graph).
Notice that the population of bacteria on the sprout increases from about 3.6 log cfu/g at the start of sprouting (about 600 cfu) to about 9 log cfu/g (100 million cfu) in 24 to 48 hours, after which it shows no further growth, and possibly a slight decline in population. Every experiment we have seen tracking normal or pathogenic bacterial growth in sprouts has almost the identical growth curve.
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 firstname.lastname@example.org.
Sanderson, with her husband Robert—who assisted in this article, are the owners of Jonathan Sprouts, Inc. since 1976. Reach her at email@example.com.