The Owner-Operator Independent Drivers Association (OOIDA) appreciates the opportunity to speak about conditions within the fresh produce industry that directly effect the safety of the products shipped for human consumption.  Our more than 151,000 members operate over 240,000 trucks nationwide.

An integral part of the supply chain is transportation.   Small business truckers and their drivers are the overwhelmingly dominant providers of fresh produce transportation.
Focusing fresh produce safety narrowly on E.coli contamination clearly misses other significant entry points of foodborne pathogens that intuitively are implicated in fresh produce safety.

The agricultural industry attempt to thwart significant regulatory oversight through voluntary “best practice” guidelines related to food safety should be viewed with great skepticism.  “Best practices” have been well known for many years but economic considerations have trumped meaningful implementation.

An expose carried by Dateline NBC on March 25th exposed poor conditions at a wholesale produce market in LA and was not shocking to most produce truckers.  We’ve been forced to live with filthy conditions in this industry for decades.  OOIDA had described similar conditions in our comments opposing an industry pushed Marketing Agreement with the California Department of Food and Agriculture.  That agreement is to set voluntary “best practices” related to leafy green vegetables.   Unfortunately, CDFA ignored input questioning the wisdom of this approach and their responsibility to consumers.  They simply rubber-stamped an industry public relations initiative.

Unsanitary and unsafe practices related to handling and shipping fresh produce is not limited to California.  It is a nationwide problem.  Significant numbers of shipping and receiving facilities around the country could have just as easily been highlighted by reporters and hidden cameras.

The lack of sanitary bathroom facilities and hygienic conditions in which to work is all too common in the fresh produce industry.  Produce truckers are exposed regularly to bathrooms lacking running water, soap, and towels.  Portable toilet facilities that are only given scant attention are common.  These are often so filthy drivers prefer to stand beside their trucks and relieve themselves.  Even when modern, clean facilities are available; we’ll be denied their use because of deeply seated animosity against drivers.

Many shippers and receivers within the fresh produce industry exhibit a callous disregard for cleanliness and sanitation procedures.  The idea of maintaining a clean and sterile environment to minimize microbial contamination is given short shrift when compared to economic considerations.

 Much fresh produce is intended to be eaten in its raw form; minimizing human handling should be an obvious strategy to minimize potential microbial contamination associated with too much human contact.  A common practice within the produce industry that is counterintuitive to minimizing excessive human contact places either the truck driver or a surrogate unloader he hires in the position of being responsible for manually restacking palletized produce onto other pallets. We call this fingerprinting a load and coupled with unsanitary toilet and working conditions this without a doubt introduces disease causing pathogens to the food supply. (Lack of testing for hepatitis).  This practice is purely economic in origin, transferring warehouse costs to the trucker and compromising food safety.

The use of recycled used pallets, wet or stained with animal blood, residue of previous chemical shipments and bug infestations is another practice that compromises fresh produce safety.

Improper loading of refrigerated trailers in violation of manufacturer specifications related to proper air circulation for proper cooling is very common.

Last year’s outbreak of E.coli in spinach and the subsequent voluntary recall left many small business produce truckers with the financial responsibility to find dumping facilities for the rejected product.  It is a common industry practice to evade financial responsibility by leaving truckers “holding the bag” when dealing with recalled product.  We are their dumping ground.

The lack of any mandatory assigned responsibility by the FDA during a recall indirectly allows rejected, rotted, or contaminated produce to enter the food supply chain.  Produce truckers facing large financial losses are under economic pressure to find the quickest dumping solution.  Dumping product at the back of a truck stop or along a highway is not uncommon.  Produce truckers have found that giving produce away to the general public is an effective method to extricate oneself from this Pandora’s Box.  In a post 9-11 world, this is a recipe for disaster that will never contain any inadvertent or purposeful contamination of fresh produce.

The produce industry has exhibited a historical lack of responsibility when dealing with the men and women charged with safely and efficiently hauling America’s fresh produce.  It is hard to image a solution to fresh produce safety without intervention at the highest level of government.

The Owner-Operator Independent Drivers Association (OOIDA) is the national trade association representing the interests of small-business trucking professionals and professional truck drivers. OOIDA was established in 1973 and is headquartered in the greater Kansas City, Mo. area. The Association currently has more than 149,000 members from all 50 states and Canada.