In December 2025, there was a tragic shark attack in the Monterey Bay of California. An experienced open-water swimmer had a fatal interaction with a shark, leaving bystanders, friends and community traumatized. As someone who has been amazed by sharks my entire life, I think often about how these organisms have so eloquently evolved, fine-tuning function and necessity into every biological detail.  In the news coverage that followed, details have emerged at just how respectful this swimmer was when entering the space of these creatures – they knew they were the outlier and the object out-of-place in the ocean environment. The event is tragic, but it is a known (albeit small) risk for those who venture into the beauty and mystique of the ocean. 

This tragedy offers an important parallel for environmental monitoring in fresh produce food safety. Like the swimmer in the ocean, we are outliers in the environments where food is grown and processed. We insert our production systems (often simplified monocultures of the crops we grow) into ecosystems shared with other organisms, diverse food webs and both biotic and abiotic forces. Even when we control our operations, we remain dependent on and constrained by the broader systems in which we operate. 

So, in a world where we can expect no less than to cohabitate with other organisms, especially those that make their home in soil and plant systems, why would we ever expect encounters to be infrequent?  

I think about this a lot – in reading reports about how to design EMPs, in visiting producers who have questions or issues in their plants and fields, reviewing scientific journals on Listeria and Salmonella research, discussing companies’ EMP results and in hearing about recalls and outbreaks in mainstream media about the inherent risk (and described failures) of certain categories of food. Nothing from these activities implies that they are rare, nor that they solely originate from the failures of people managing them. Many companies go above and beyond in terms of seek and destroy, and they still seek and find quite often. Does this mean they are failing? Quite the contrary, they are exhibiting the exact behavior we wish to promote – proactive design and action to monitor their environment for optimized risk management. 

So why then do so many articles, conversations and legal cases frame EMPs findings as failures when observations are found? Doesn’t this reinforce the opposite behavior we seek? A well-designed EMP should have positives – in certain environments, many should be expected, and the lack of positive observations is suspect. The number of positive findings is not the important piece of a program. As with many things, it is the context around them, what they represent, what was done about them and the overall story that a cumulative data analysis can show.   

Too often, the story we speak about when discussing EMPs with many positive findings is that there are failures and inadequacies in the program – truants in manufacturing that knowingly or negligently are failing. Unfortunately, these failures do happen, just like encounters with rare sharks occur in the ocean. But just as we acknowledge sharks exist in the ocean, we should also expect and promote building EMP systems that find the targets, that applaud those who put the effort into really characterizing their environment or risk. A robust EMP program and the results it would find should not be viewed as failures or regulatory or legal liabilities. We should be promoting building EMPs that robustly identify when Listeria (or other pathogens) come into facilities and applaud those whose programs are able to keep the encounters as transient versus resident in the production environment.