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Wash Statement for Hydroponic Lettuce?

raw agricultural commodity RAC ready-to-eat RTE wash leafy greens lettuce hydroponic greenhouse CEA

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Midwest CEA

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Posted 08 September 2021 - 03:06 PM

Curious if anyone has any experience with retail package label language regarding washing for indoor grown hydroponic lettuce and leafy greens. 

 

There seems to be a lack of clarity, both in my company and in the wider controlled environment agriculture community, about whether indoor grown, hydroponic, leafy greens and lettuces that do not have a wash step should be treated as a raw agricultural commodity, a ready-to-eat food, or a hybrid of both categories.  In the market I see language ranging from "triple washed" (typically for outdoor grown product) to "wash before enjoying" to nothing at all.

 

Our indoor grown hydroponic lettuce is not washed.  We currently make a statement on our label "for longest shelf life, please wash before eating."

 

Is a label wash statement required by any regulatory authority? FSMA Produce Safety Rule only requires name and address of the farm is on the label.

 

If a wash statement is made, do you consider it a preventive control? If yes, do you show it in your flow diagram?

 

If a wash statement is not made, why?

 

 



Charles.C

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Posted 09 September 2021 - 06:21 AM

Curious if anyone has any experience with retail package label language regarding washing for indoor grown hydroponic lettuce and leafy greens. 

 

There seems to be a lack of clarity, both in my company and in the wider controlled environment agriculture community, about whether indoor grown, hydroponic, leafy greens and lettuces that do not have a wash step should be treated as a raw agricultural commodity, a ready-to-eat food, or a hybrid of both categories.  In the market I see language ranging from "triple washed" (typically for outdoor grown product) to "wash before enjoying" to nothing at all.

 

Our indoor grown hydroponic lettuce is not washed.  We currently make a statement on our label "for longest shelf life, please wash before eating."

 

Is a label wash statement required by any regulatory authority? FSMA Produce Safety Rule only requires name and address of the farm is on the label.

 

If a wash statement is made, do you consider it a preventive control? If yes, do you show it in your flow diagram?

 

If a wash statement is not made, why?

 

Hi MCEA,

 

I guess this is FDA jurisdiction.

 

afaik they have no specific requirement for RTE labelling. Unlike USDA. Hence the subsequent operational mystifications.

 

Intuitively, one would have thought that ready-to-eat is a reasonably self-defined term. The retail industry has proved otherwise. :smile:

 

(eg ready to cook, ready to heat, and, perhaps, ready to wash ?)

 

PS - IIRC literature dialogs over "to wash" or "not to wash" for RTE vegs have a long and often contentious history. I lost track as to whether there was an agreed conclusion.


Kind Regards,

 

Charles.C


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producelady

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Posted 14 September 2021 - 02:02 PM

I have been searching tirelessly for an answer to this as well! We grow hydroponic lettuce indoors, and do not have a wash step. Our label states "rinse if desired" but we package for a private label as well. They want their label to say "ready to eat" and I can't decide if I should put up a fight about it.



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Posted 14 September 2021 - 02:34 PM

Private label = their problem          just make sure the contract states that they are on the hook for any issues that arise at the consumer level

 

I think the statement about washing to extend shelf is misleading----------consumers will NEVER dry the lettuce enough and it will wilt quicker not slower

 

What does your actual product testing say?  Is there anything present on your particular lettuces that REQUIRES washing?

 

If you can adequately explain to an inspector/auditor/consumer your process and decisions made, there probably isn't a strong argument one way or the other


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