Thanksgiving this year was salad-less, thanks to a nation-wide romaine lettuce recall on November 20th. And while many Americans were probably more than happy to have more room on their plates for stuffing and gravy, the E. coli outbreak that prompted the recall was rather dire. The Centers for Disease Control and Prevention (CDC) called on consumers to throw away all romaine lettuce following 32 confirmed cases of E. coli bacteria poisoning in 11 U.S. states and Canada.

Recall attention focused on the produce itself, but throwing the lettuce away was merely a temporary solution to our seemingly ever-present food safety issues. If we wish to prevent foodborne illnesses, the real culprit that must be dealt with is deficient agricultural water quality.

This isn’t news to us, though. The water community and Food & Drug Administration (FDA) have been keenly aware of water quality’s role in food safety for over a decade. Produce growers have not been required to test their irrigation water for harmful pathogens, such as E. coli. The result, of course, is that fruits and vegetables are at risk of exposure to contaminated water.

After Congress set food safety as a priority in 2011, the Obama administration’s FDA crafted the Food Safety Modernization Act (FSMA). One of the most important elements of FSMA in terms of foodborne illness prevention is the water quality and testing requirements for agricultural irrigation water. These requirements were set to commence this year, however, the Trump administration’s FDA succumbed to pressure from the agricultural industry, which raised concerns over the price tag associated with the water testing regulations. In keeping with Trump’s platform of deregulation, the FDA suspended the water testing rules for at least four years.

Given what we know about agricultural water quality and foodborne illnesses, it’s appropriate to question whether or not the November romaine lettuce E. coli outbreak could have been avoided if these water testing rules had been enforced rather than deferred.           

“Mystifying, isn’t it?” said Dr. Trevor Suslow, a food safety expert at the University of California, Davis, in response to the deadly Yuma E. coli outbreak that occurred earlier this year. “If the risk factor associated with agricultural water use is that closely tied to contamination and outbreaks, there needs to be something now… I can’t think of a reason to justify waiting four to six to eight years to get started.”

Despite postponement at the national level, some states have made preliminary efforts to improve irrigation water quality. After the 2006 E. coli outbreak that killed three people who ate spinach grown in California’s Salinas Valley, most California and Arizona growers of leafy greens signed agreements to voluntarily test their irrigation water. Unfortunately, the Yuma and Santa Maria E. coli outbreaks of 2018 exemplify the detrimental shortcomings of voluntary testing programs.   

According to an FDA analysis, the FSMA water testing deferment will save growers $12 million annually, which sounds advantageous until it is compared to the cost to consumers which will be $108 million annually in medical expenses.  

The costs are clear. How many more foodborne illnesses must we endure before the FDA prioritizes public health?