Update: Beware of Leafy Greens

I wrote recently that the health department is in the process of designating leafy greens as potentially hazardous food. That means they would have to be held at 41 degrees Fahrenheit or colder, seriously complicating things for farmers' market vendors like myself.

I've been reading up on the issue, and I've learned that they're mostly concerned with leafy greens that have been cut rather than leaves that are intact such as heads of cabbage or romaine, or bunches of chard. There's some clarification about exactly what they mean by "cut". Apparently the first cut, detaching the leaf from the plant, doesn't count. One person I spoke to also thought that the regulation would only apply to greens that have been repeatedly cut in multiple facilities but I haven't found anything to support this.

The health inspector I've been talking to sent links to the FDA recommendations to local health departments, and the proposed Washington state changes based on these recommendations. The FDA recommendations use the phrase "ready to eat" multiple times, while the propsed Washington state changes do not. This is important.

Let's put aside for a moment the very important consideration that industrial farms handle their produce in ways that are much more likely to widely spread pathogens than the scale and methods used by small, local farms. A salad mix or cole slaw mix with cut greens that will not be cooked before you eat them is much more likely to make someone sick than a braising mix, which is meant to be cooked. The process of cooking kills pathogens. That's why we're instructed to handle raw chicken with all manner of precautions while cooked chicken is generally regarded as safe.

I've never been someone inclined to get involved in the process of agitating for change. Under "politics" on my Facebook profile I wrote "complacent radical", meaning that I'm very much in favor of dramatic change, but I see my own potential to affect change mainly in terms of just living in ways that are consistent with my ideals. But this new regulation about cut leafy greens is a concrete issue that could have serious consequences, and its really just a matter of sloppy wording.

I sent in a comment form (there's a link for "Issue Submittal Form" in the Washington state document) and I've been contacting market managers and vendors about the issue. I've been encouraged by the fact that several market managers had already learned about it by the time I approached them because an email I sent has been making the rounds.

One market manager said that she'd like to see farmers' market vendors classified as exempt from these kinds of regulations because their production processes are so different from the mainstream industrial paradigm behind most of the difficulties. That's a beautiful thought, but I have a hard time imagining it actually happening. But in the meantime, this matters.