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August 12, 2026

Without Data, All You Have Is an Opinion  

“Without Data, All You Have Is an Opinion” W. Edwards Deming 

There is a lot of discussion today (rightfully so) about food safety and public health. 

Food safety is a little like the safety features in your car. Most of us don’t spend much time thinking about them when everything is working as intended. But when they’re needed, or when they fail, the value of every investment in prevention, monitoring, technology and safeguards suddenly becomes very clear. 

During food safety events, the focus needs to remain where it belongs: on the people affected by foodborne illness, on supporting patients and their families and on preventing any further harm. But soon, the questions will come, and the most important one will be: What are we willing to do differently to make sure it doesn’t happen again? 

A wise mentor of mine, and my first boss out of grad school, once told me something about foodborne outbreaks that I’ve come to realize applies to almost anything in life: 

“You aren’t judged by what happens; you’re judged by how you handle it.” 

My mentor had experienced a large multistate outbreak firsthand, and while he is unfortunately no longer with us, his voice, and, more importantly, his integrity is still clearly heard and felt in moments like this. 

It leaves me thinking about a difficult question for myself and our collective food industry: How do we quickly turn the events of today into something useful for tomorrow? Not another report that sits on a shelf. Not another round of finger-pointing. Not another temporary surge of attention and investment that fades as soon as the immediate crisis passes. 

How do we learn from what happened, identify what the data could have told us sooner and build systems capable of acting on those signals before people become sick? 

Because Prevention Requires More Than Good Intentions. 

It requires data. It requires monitoring. It requires people willing to share information and ask difficult questions at all levels of the food supply chain. And, ultimately, it requires action. We have spent plenty of time talking about what could be done in food safety before this summer’s outbreaks, and certainly during them. Events like these remind us why the difference between could and did matters so much. 

From Reaction to a Data-Driven Food Safety System 

The path forward does not require a single solution. It requires a food safety system that is better connected through the whole supply chain, more transparent to all stakeholders (including consumers), and increasingly driven by the right type of food safety data, focusing on risk management over compliance and action rather than reaction. 

That means being able to rapidly trace a product when something goes wrong, while investing much more heavily in preventing contamination before it even happens. It means building agricultural water information that can identify emerging risks before they become outbreaks. It means using microbiological testing and surveillance efficiently to understand the residual risks that remain even when preventive systems are working as designed. And it means creating risk-based data systems, particularly for imported foods, that allow downstream stakeholders/customers/regulators to focus limited resources where the data tell us the risk and uncertainty are greatest. 

Five Complementary Pillars.  

Collaboration, Traceability, Prevention, Surveillance, Risk-Based Data Sharing. 

Together these pillars create something we have historically lacked – a more continuous and cohesive picture of risk across the fresh produce supply chain, and the ability to act on that information before an outbreak becomes the signal that something went wrong. 

The objective should not simply be more testing, more regulation or more data. The objective should be better information shared amongst all stakeholders, available sooner, used to make better decisions. When industry and government can see risk more clearly, prevention becomes more targeted, regulatory resources can be deployed more intelligently and interventions can happen earlier. 

Because ultimately, data only has value when we are willing to act on them. It’s time we do. 

A Comprehensive Framework for Fresh Produce Food Safety 

Fresh produce food safety should be built on five complementary pillars: collaboration across industry, rapid traceability to limit the impact of outbreaks, prevention systems that reduce contamination before it occurs, surveillance programs that measure whether preventive controls are working and risk-based data systems that continuously improve both domestic and imported food safety. Together, these elements create a food safety system that is science-based, prevention-focused, cohesive and designed to protect both consumers and the long-term resilience of the produce supply chain. 

Collaboration: Align Stakeholders to a Single Point of Effort and Expertise 

A patchwork of retailer and buyer requirements or certification systems that rely too heavily on checklist-based verification can sometimes impede food safety developments focused on risk-based management. When requirements proliferate independently across buyers/retailers, the intentions are good, but they can divert limited time and resources towards systems that demonstrate compliance better than advancing prevention. The fresh produce supply chain needs a single, open, authoritative point of collaboration that brings together growers, shippers, buyers, regulators, researchers, auditors and food safety subject-matter experts around shared science, validated practices, emerging risks and practical implementation tools.  

This effort should make the best available food safety knowledge accessible to everyone, not only the largest or best-resourced organizations, so that small and mid-sized growing operations can benefit from the same current expertise, data and risk-management guidance. A common transparent, fully accessible collaborative framework would not eliminate accountability or appropriate buyer standards; it would reduce unnecessary duplication, accelerate adoption of science-based practices, and create a clearer pathway for the entire supply chain to learn and improve together. 

Traceability: Protect Consumers and the Supply Chain 

Rapid, lot-level traceability is essential for identifying contaminated food, shortening outbreak investigations, reducing the scope of recalls and preventing additional illnesses. While implementation timelines have been delayed for FSMA 204, the domestic fresh produce industry has largely operated under case-level traceability expectations since implementation of the voluntary Produce Traceability Initiative (PTI) in 2010–2011. These case level data elements are frequently lost as the product moves through the supply chain; this is unfair for consumers and producers. Traceability expectations should apply consistently across domestic and imported supply chains so that critical data is not lost as products move through commerce. 

Prevention: Agricultural Water Intelligence & Infrastructure 

A nationally coordinated agricultural water surveillance program can provide routine monitoring of shared surface waters and high-risk aquifers, creating an early-warning and decision-support system for growers. Today, data like this exist in private, local, state and federal silos and that fragmentation limits the potential impact and preventative value that this data could represent. Shared data, common risk frameworks and targeted infrastructure support can help identify vulnerabilities early and accelerate practical risk-reduction measures. 

Surveillance: Measure Residual Risk 

Microbiological surveillance should be designed to improve understanding of residual food safety risk while minimizing unnecessary market disruption. Domestic surveillance can support continuous improvement, while statistically designed real-time surveillance at ports of entry can strengthen oversight of imported produce before it enters commerce. 

Risk-Based Data Sharing: Focus Resources Where Risk Is Highest, and Reward Suppliers that Contribute the Most. 

The burden of entry (or sale) shouldn’t be one audit certificate, regardless of what food safety standard it meets. Suppliers that have invested in thorough risk characterization and monitoring should be prioritized over those with data gaps and missing information. Standardized, interoperable data-sharing systems can give regulators better visibility into preventive controls, laboratory testing, agricultural water monitoring, GAP verification and lot-level traceability. When validated data demonstrate consistently effective food safety systems, oversight can become more efficient and regulatory resources can be concentrated where uncertainty and risk are greatest.