De Ann Davis, senior vice president of science at the Western Growers Association, published a piece on August 31 arguing that FDA outbreak communication is itself a food safety tool and needs to work better. I missed it when it came out. It deserves a reply, because I agree with most of it, and the places where I do not are where the next outbreak will be won or lost.
One thing first. Davis told the Guardian in August that growers have collected shipment data voluntarily for more than a decade and that Western Growers supports the Food Traceability Rule. That put growers on the record on the other side from the retail and foodservice associations that lobbied for delay. Nothing below changes my respect for that.
Where we agree, and it is most of it
Her framework is close to what I have asked for all summer. Every advisory should say what is confirmed, what is reasonably suspected, what is unknown and what would change the agency’s view. As soon as the evidence permits, the FDA should name the commodity, product form, brand or supplier, country and growing region, distribution channel and dates, and when those details are unknown, say so. Corrections should be time-stamped and pushed through the same channels as the original. After the hazard passes, the agency should publish root-cause reports that tell growers, importers and retailers what to change.
She is right that the July 17 naming of Taylor Farms de Mexico was the moment the response started working. It gave restaurants and shoppers a target, and it told everyone else what was not in play. The FDA’s outbreak page still carries that history. She is also right that the FDA should be the hub that separates confirmed outbreaks from concurrent clusters and background surveillance. North Carolina said on July 17 that its increase did not appear connected to the Taco Bell outbreak. That was careful work by a state health department, and no federal page set it beside the national count and explained how the pieces fit.
Where I part company, gently
The first is Michigan. Davis faults the July 4 Michigan advisory for listing produce from past Cyclospora outbreaks, including salad mixes, cilantro, basil, raspberries, snow peas and green onions, when no source had been identified. She calls that a missed opportunity for the FDA, and on that point I agree. The fix is a federal voice, not a quieter state. A health department watching its case count climb with no named food owes the public something, and the history of the parasite was the evidence it had.
The second is what the FDA can honestly say is not implicated. Davis wanted the agency to say this summer that domestic leafy greens had not been implicated, and her September 15 follow-up goes further, arguing that the risk from domestically grown produce is meaningfully lower than from imports. On the history she has a point, and the FDA’s own Cyclospora action plan says most domestically acquired outbreaks have been tied to imported produce. Now look at this year’s arithmetic. The CDC’s case data page, updated September 15, counts 19,883 confirmed domestically acquired cases from May 1 through August 31. The federal outbreak linked to Taylor Farms de Mexico closed at 12,883. That leaves 7,000 confirmed cases with no food named by any agency.
Davis poses three good questions in that follow-up: where the illness was acquired, where the product was grown and where the contamination occurred. For those 7,000 people the second and third answers are blank, because no agency has said what they ate. An advisory that clears a category before the evidence does is its own kind of imprecision, and it is the kind that gets people sick.
The third is her proposed verification hold. Davis wants preliminary laboratory results with public and commercial consequences verified before release whenever consumer protection does not require immediate disclosure. After the FDA announced a positive lettuce sample on July 18 and called it a false positive on July 19, I understand why. The same correction said the epidemiological and traceback evidence still supported the recall. People were protected by the epidemiology, not by the sample. A verification step is reasonable if it has a clock measured in days and the agency says publicly that a result is pending. Without a clock, verify first becomes announce later.
The cost of imprecision is real
I hold an economics degree, and I do not wave these numbers away. Western Growers estimated $125 million in short-term wholesale losses to California strawberry growers after the 2022 hepatitis A outbreak tied to imported berries. An International Food Information Council survey in mid-August found that among adults who had heard about this summer’s outbreak, 30 percent said they had stopped eating lettuce entirely in the previous month. Fewer vegetables on American plates is a public health cost, and Davis is right to say so. Precision is the answer to it. Precision, though, means naming, and naming sometimes means naming somebody you would rather not.
What precision requires
Two things, and Western Growers is in a position to help with both.
The first is traceability. Supplier, growing region and dates, the second item in Davis’s framework, come from records. Section 780 of last November’s continuing resolution barred the FDA from spending money to administer or enforce the traceability rule before July 20, 2028. I made this argument in July when Joelle Mosso of Western Growers wrote about the Cyclospora response, and it has only gotten stronger since. Western Growers already supports the rule. If it said out loud that Section 780 should be unwound, that would carry weight with Congress that my saying it never will.
The second is naming. On September 10 the FDA closed CORE investigation #1382, an E. coli O157:H7 outbreak with 14 sick, naming romaine lettuce as the source and no grower or processor. The FDA’s investigations table is where that closure lives, in a single line. The 89-person romaine outbreak from late 2024 closed the same way. Under Davis’s framework, if traceback reached one grower, the advisory names the grower. I would like to know whether Western Growers will say so when the grower is a member. That is the hardest version of the question, and it decides whether consumers learn which lettuce or only that it was lettuce.
Davis closed her September piece by asking industry, academia and public health to work together on fact-based context before the next Cyclospora season. I am in. Traceability draws a line. It says what everything else is. Without the line, fear prices the whole category, and the whole category pays.