Sprout-Associated Outbreaks – NOP & EU Regulations and US Food Safety - Organic Trade Association
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Sprout-Associated Outbreaks – NOP & EU Regulations and US Food Safety


U.S. organic producers must comply with all food safety and other food regulations in addition to meet the exacting standards of the USDA National Organic program.

NOP recognizes the importance that sanitation plays in the safety of allow foods and allows for sanitizers in crop production and post harvest handling of organic products.

Sprouts have been identified by the FDA as a special problem because of the potential for pathogen growth during the sprouting process. Contaminated seed is the likely source for most reported sprout-associated outbreaks.

FDA requires retail/food service facilities involved in the production of sprouted beans or seeds for sale to implement a HACCP plan. (*).

To date, FDA believes that this outbreak has not affected the U.S. food supply. The FDA is constantly vigilant and consistently takes steps to increase monitoring, as appropriate, in situations such as this, to protect the U.S. food supply.

The U.S. receives relatively little fresh produce from the EU, particularly at this time of year. Due to the short shelf life of most fresh produce and the availability of growing areas in the U.S. and Central America, the EU is not a significant source of fresh produce for this country.

In response to the outbreak in Europe, as a safety precaution, FDA established certain additional import controls. FDA is currently conducting increased surveillance of fresh tomatoes, cucumbers, lettuce and raw salads from areas of concern.


Sprout Production and NOP & EU Regulations

Key areas where contamination may occur is WATER, SEEDS, and MANURE. The organic regulations allow for effective food safety practices in all cases.

Several effective sanitizers and disinfectants are allowed under the NOP.

  • Crops
    • Chlorine materials - residual chlorine levels in the water shall not exceed the maximum residual disinfectant limit under the Safe Drinking Water Act.
    • Peracetic acid - for use in disinfecting equipment, seed, and asexually propagated planting material.
    • Ozone gas—for use as an irrigation system cleaner only.
  • Post Harvest Handling
    • Chlorine materials in accordance with the maximum residual disinfectant levels of the Safe Water Drinking Act
    • Peracetic acid and peroxyacetic acids for use in wash water and/or rinse water according to FDA limitations


EU - There are no direct references to the use of sanitizers in EC 834/2007 or EC 889/2008. The EU list is a closed list and therefore sanitizers are presumed to not be allowed, However, the EU food safety is under the control of Member States - there could be MS derogations as well.


NOP - Requires organic seeds for sprouts, therefore the use of manure during their production is restricted (SEE TALKING POINTS FOR MANURE)


  • Requires organic seeds unless commercially unavailable.
  • Members States to develop and maintain a database of commercially available organic seeds.


NOP requires strict controls of raw manures:

U.S. Organic Standard is very clear and focused on food safety and requires

  • Raw manures to be composted to NRCS standards to destroy pathogens
  • Requires that raw manure must be incorporated into the soil a minimum of 120 Days prior to planting where the edible portion of the crop could come in contact with the soil
  • Requires that raw manures must be incorporated into the soil a minimum 90 days for crops where the edible portion does not come in contact with the edible portion not intended for direct consumption (if feeds etc).  

The EU is focused on environmental contamination (from factory farms):

  • EC 834 Manure and organic material preferably composted from organic production in integrated agricultural systems.
  • EC 889 Allows for cooperation between operations for surplus manure

US Food Safety
In response to sprout-associated outbreaks primarily in the mid-90s, the FDA has issued several instruction and guidance documents to identify the preventive controls that the Food and Drug Administration (FDA) believes should be taken to ensure the food safety of raw sprouts.

The Guidance addresses Seed Production, Conditioning, Storage Transportation, Sprout Production, Seed Treatment, Testing for Pathogens (both seed and irrigation water) and Traceability.

The common practice in the US is to test sprouts for E. coli and Salmonella.

Guidance Documents

Reducing Microbial Food Safety Hazards For Sprouted Seeds 1 October 27, 1999

Sampling And Microbial Testing Of Spent Irrigation Water During Sprout Production 2 October 27, 1999

Letter from California Department of Public Health to Sprout Manufacturers 3 May 1, 2008

Public Meeting: 2005 Sprout Safety - Transcript of Proceedings 4 May 17, 2005

Growing Sprouts in Retail Food Establishments, CFP Issues 02-III-01 and 04-III-012 5 December 2004

Note to Firms That Grow, Condition, Store, or Distribute Seed for Sprouting and to Firms that Produce, Pack, or Ship Fresh Sprouts 6 August 19, 2004

Microbial Testing of Spent Irrigation Water During Sprout Production 7 June/July 2000 (also available in PDF8)

Microbiological Safety Evaluations and Recommendations on Sprouted Seeds 9 May 28, 1999

Safety tips for the consumption of fresh produce and raw sprouts
When preparing any fresh produce, begin with clean hands. Wash the produce under running water just before preparing or eating. This includes produce grown conventionally or organically at home, or produce that is purchased from a grocery store or farmer's market.


  • Buy only sprouts kept at refrigerator temperature. Select crisp-looking sprouts with the buds attached. Avoid musty-smelling, dark, or slimy-looking sprouts.
  • Refrigerate sprouts at home. Refrigerators should be set to maintain a temperature of 40° F or below.
  • Wash hands with warm water and soap for at least 20 seconds before and after handling raw foods.
  • Rinse sprouts thoroughly with water before use. Rinsing can help remove surface dirt. Do not use soap or other detergents.
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