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March 2, 2021 

Dear Western Growers Board of Directors and Members:

I am writing today in support of Western Growers’ Collaborative Data Sharing Project, which 

looks to leverage insights from preharvest sampling and testing data that many leafy greens 

growers are already collecting. The ultimate goal is to convert data into information that will 

help growers and regulators prevent produce contamination and reduce the potential for 

outbreaks of foodborne illness. 

The importance of collaborating to harness and democratize data streams to protect the food 

supply is a key element of two important documents released by the FDA last year: the New Era 

of Smarter Food Safety Blueprint and the 2020 Leafy Greens STEC Action Plan. 

We recognize that most of your members operate under the premise that food safety should not 

be a competitive issue, and it’s in this spirit that the industry has worked over the years to 

address the issue of recurring outbreaks of foodborne illness associated with romaine lettuce and 

other leafy greens. This project speaks to your commitment to continue to work collaboratively, 

so that the entire sector can further strengthen the safety of leafy greens. 

Data-Sharing Project

Many leafy greens growers already conduct preharvest product testing to verify that preventive 

safety measures have been effectively implemented and to meet buyer requirements. The 

Western Growers Association data-sharing project looks to use preharvest product and water 

sampling data trends, in a trusted and secured manner, to allow all of industry to gain insights 

regarding the relative risks of pathogen contamination. The platform is a digital system that will 

allow for the collection of sampling information such as sampling patterns, collection 

timeframes, target organisms, and results. 

It is our understanding that the sampling data will be aggregated and anonymized to preclude 

attribution to a particular grower yet empower industry and public health officials by 

democratizing insights. In addition to allowing everyone to get smarter and safer together, this 

approach may also reduce duplicative verification and surveillance sampling. 

The information that growers submit will be maintained by Western Growers in a private 

database. However, in the spirit of private-public data sharing, a report containing aggregate data 
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will be provided to FDA. We would encourage that aggregate data also be shared with others to 

allow for a meaningful analysis of the data and trends by all stakeholders. 

This is a voluntary program, but high-levels of participation will help industry and public health 

officials identify trends in contamination of leafy greens, which would then help prioritize

research, training and outreach. 

Using Data to Enhance Preventive-Oriented Food Safety Actions

We believe that increased sharing and analysis of data could help identify trends that may be 

contributing to contamination and inform our understanding of when and how contamination 

occurs, while potentially allowing both government and industry to maximize resources spent on 

these efforts. 

This project is very much in line with the goals set forth in two recently released FDA initiatives. 

The New Era of Smarter Food Safety Blueprint outlines our plans to create a more digital, 

traceable and safer food system, speaks to the importance of utilizing new data streams to 

enhance food safety, strengthen preventive approaches, and support innovative production 

technologies. In addition, the Leafy Greens STEC 2020 Action Plan stresses the importance of 

sharing data to avoid a duplication of efforts as we work to address gaps in our knowledge of the 

factors on farms and in facilities that can lead to contamination. 

It can’t be overstated how important data is to the safety and security of our food supply. We at 

FDA hope that the leafy greens community sees the value that this program can bring to the food 

industry as a whole as we look to implement the New Era of Smarter Food Safety. FDA looks 

forward to continuing our work with Western Growers to help ensure that leafy greens, which

are an important contributor to a healthy diet for many Americans, are safe for consumers to eat 

and serve to their families. 

 Sincerely,

 

Frank Yiannas 

Deputy Commissioner 

Food Policy and Response