Food Safety Case Study: Dole Fresh Vegetables

“Do I have to wash my salads?”

That’s the one question consumers ask Dole more than any other when it comes to food safety. The answer, according to www.dole.com, is no.

“Dole Salads are thoroughly washed in purified water and are sold ready-to-eat,” according to the site. “As a result, it is not necessary for you to wash the salad prior to eating. Nevertheless, rinsing your salad again will not damage the lettuce or vegetables in any way.”

This is just one way Dole reaches out to its consumers to share the company’s food safety practices – and works to ensure food safety from the field to the dining room table. Openness and honesty to consumers about how the company deals with food safety is one of the most important aspects of Dole’s overall quality assurance and food safety program, said Eric Schwartz, president of the fresh vegetables division of Dole. The Web site even allows people to take a virtual tour of a fresh-cut salad processing plant.

Dole also prints “800” numbers on the products, so consumers can call with questions or comments. One area that’s especially important is using point-of-sale materials to inform consumers about the products they’re buying. Dole currently is working on putting out some new point-of-sale materials.

But proper food safety practices don’t lie solely on the shoulders of the end user and the processor. The middlemen – retailers and foodservice operators – play a big role, too.

“We take the retailers and foodservice operators through training about cross contamination and protecting the cold chain – protecting the cold chain is the most important,” Schwartz said. “Once it leaves our hands, (retailers and foodservice operators) are controlling the product until it gets to consumers.”

Dole’s own employees – some 11,000 of them – all go through annual training on the company’s food safety practices. Training covers all aspects of the company’s Good Agricultural Practices and HACCP programs, which form the foundation of all food safety practices for Dole.

“We take them through basic food safety and hygiene training, and we take them through our good agricultural practices so everybody’s had exposure to that,” Schwartz said.

Dole has a food safety department, which is run by a director of food safety. All quality assurance and food safety programs run through that person.

There also are people in the food safety department assigned to the raw product side of the business – people who are overseeing food safety in the fields.

“They’re developing SOPs (Standard Operating Procedures), doing audits, spending time in the fields making sure SOPs are being followed; they’re testing well water,” Schwartz said. “They are making sure the agriculture side is following GAPs.”

Though Dole doesn’t employ any part-time workers, the company does use labor provided by contractors. And to make sure everyone understands and is invested in food safety, the labor contractors go through the company’s food safety training as well. Everyone is required to wear the appropriate attire, including gloves, hairnets and the like.

To keep team members on their toes, and as added training, Dole does mock recalls once a year.

These unannounced, in-house recalls are “very intense,” Schwartz said, and give everyone involved a chance to make sure they know the company’s processes and procedures.

“And we can go back and do a post-mortem to see how to make it better the next time around,” he said.

Crisis Communications

But even with the most stringent policies and practices, contamination can occur somewhere in the channel. On Oct. 1, 2005, Dole Fresh Vegetables announced it was working with the Food and Drug Administration and the Minnesota and California departments of health in an investigation of a mid-September E. coli outbreak in some of the company’s products in the Minneapolis/St. Paul area.

The first thing the team at Dole does when something like that is brought to its attention is notify its customers – the retailers and foodservice establishments that could be affected.

“We keep on file, which we update periodically, a key contact sheet for retailers and foodservice operators,” Schwartz said. “We already had a traceability system set up a couple of years ago, so we do a search for the product so we can notify – within a couple of hours – anyone who received that product.”

In the case of the E. coli outbreak, the salads in question were past their use-by dates, so Schwartz said that he wasn’t expecting to find anything still on the shelves.

“But you still want to go through that process,” he said.

When an outbreak does occur, one thing is inevitable: media attention.

Schwartz is one of Dole’s designated media spokesmen, of which there are several throughout the organization. Everyone who is designated to speak in crisis situations goes through intense training on working with the media. Dole takes its spokesteam to a third-party location where working journalists bombard them with questions. And all of it’s recorded.

In crisis situations, there will be a lot of journalists asking a lot of questions and looking for a lot of answers.

“There are a lot of people looking for that one ‘gotcha’ sound bite,” Schwartz said.

The training for the Dole team tries to recreate this scene to prepare them for anything. And they can take the tapes with them to watch and refresh what they learned at the training sessions.

“It’s a very intense and humbling experience, but it’s very good training,” Schwartz said. “For anyone who doesn’t do this, I would strongly recommend it.”

Throughout the investigation into the September outbreaks, Dole stayed involved with the FDA. The company revisited all of its internal procedures and looked at what could have gone, and where.

“It wasn’t a total surprise FDA didn’t find any direct connections,” Schwartz said. “But that doesn’t mean we’ll stop looking.”

Schwartz said there are two schools of thought on this situation. One is if the FDA found nothing wrong, the company being investigated can stop looking. The second is continuing to look at processes and procedures to make sure the company is doing all it can do to stop future outbreaks before they happen. Dole follows the second school of thought.

“The first step is to make sure there weren’t any holes in your program,” Schwartz said. “We’ve gone through processes with the FDA to make sure everything we said we were doing, we were doing. We re-audited our processes. We want to work concurrently with the FDA.”

Schwartz couldn’t comment on some of the specifics of the September outbreak because of ongoing investigation and litigation.

“We’re still at somewhat of a disadvantage because the information is still in control of the state and FDA, and they will not release (information) until their investigation is done, which can take years,” he said.

The way companies respond to food safety issues and conduct food safety practices can affect the whole industry. While the fresh-cut category hasn’t really seen any long-term damage from the Dole outbreak – or similar situations – that doesn’t mean it hasn’t affected consumers’ perceptions.

“The whole industry wears the good or the bad with what happens with one operator – we all wear the tag,” Schwartz said. “It’s really important that everyone takes food safety seriously from a proactive stand.”

Staying Active

One important aspect of Dole’s overall food safety and quality assurance program is being involved in the industry – something Schwartz said every processor should do.

“We’ve got a lot of folks involved with these trade associations and government agencies so we can keep up on the regulatory issues,” Schwartz said.

Working closely with government agencies not only helps individual processors, it helps the industry.

Dole participated in a pilot HACCP program with FDA. FDA came into the company’s Soledad, Calif., plant and worked with the Dole team to look at HACCP programs as they applied to fresh-cut produce.

“Our intent was that FDA had best practices from other food industries, but we had experience in bagged salads,” Schwartz said. “We took the best practices from other industries and married that with what we think are the best practices from the salad industry.”

FDA plays an important role in setting guidelines and regulations for fresh-cut processors. Schwartz said he fully agrees with FDA’s recent involvement in the fresh-cut industry – specifically with the letter it issued to the California lettuce and leafy green industries and the guidelines it recently put out for fresh-cut produce. The one thing Schwartz said he would have liked to see was a more general letter. The one FDA issued last fall was directed at the Salinas, Calif., industry.

“As we try to bring industry-wide solutions, we need to make sure this comes across like an industry challenge because it really is,” he said. “It doesn’t matter where the problem is because the industry wears the black eye.”

Schwartz said he wasn’t all that familiar with the new lettuce coalition formed by different industry associations, but he said it’s something he’s following.

While industry organizations can serve as a good clearinghouse for best practices, Schwartz said they play a big role in regulatory issues.

“(Organizations) can be a voice on the regulatory side because there does need to be a balance,” he said. “There has to be a check and balance so regulations that come out are based on sound science and not on pressure from consumer groups or emotions.”