A Tip of the Pen to Gina Shaw for “Invaders From Planet Lettuce” – and My List for Making Sure 2026 Does Not Happen Again

A tip of the pen to Gina Shaw, whose piece in the October issue of Infectious Disease Special Edition, “Invaders From Planet Lettuce,” asks the right question: how did produce become the vehicle that makes so many of us sick? It is the clearest explanation I have read of why this summer’s Cyclospora season was the largest ever recorded in the United States, and it is written for the doctors who must diagnose it. It deserves a wider audience, especially among the people who can do something about it.

Shaw lays out the scale. By CDC’s early September update, more than 18,000 laboratory-confirmed cases had been acquired in the U.S. since May 1, with thousands more awaiting confirmation, against 1,180 in all of 2025. Most trace to the outbreak linked to iceberg lettuce from Taylor Farms de Mexico, which FDA closed at 12,883 illnesses, 570 hospitalizations and two deaths. Michigan alone reported more than 14,000 cases, in a state that saw 50 the year before.

Her sources, Dr. David Freedman of the University of Alabama at Birmingham and Dr. Craig Hedberg of the University of Minnesota, explain why this one got so big. Cyclospora used to ride in on raspberries, basil and cilantro, foods most people eat rarely or in small amounts. This time it rode in on lettuce, which about 80 percent of Americans eat in any given week, served through a fast-food chain. As Dr. Freedman put it, “Now the lettuce is bringing it to us.” Industrial processing then does the rest: millions of heads mixed in one plant, so a few bad ones contaminate thousands of bags. And the parasite survives for weeks in soil and water and shrugs off chlorine washes.

Then Shaw describes a system under strain. The outbreak hit a year after CDC made FoodNet surveillance optional for Cyclospora and five other pathogens. Case reports piled up faster than short-staffed health departments could interview patients, which slowed the search for sources. Michigan pulled people from other programs to keep up. And unlike Salmonella or E. coli, there is no real-time genetic fingerprinting for Cyclospora, so investigators could not always tell whether a patient belonged to the big outbreak or one of the smaller clusters. Her table of open FDA investigations as of late September is sobering on its own: sprouts, raw milk cheese, jalapeños, eggs, infant formula and a long run of outbreaks with the food listed as unknown.

Shaw ends with Dr. Freedman’s warning that preventing a repeat in 2027 will take more inspection and mitigation of at-risk produce, and more people to do it, than we have now. I agree. So here is my list, focused on the food that made so many of us sick this summer: leafy greens.

What needs to be done about leafy greens

1. Unwind the traceability delay. FDA’s Food Traceability Rule covers lettuce, spinach and other leafy greens, and it was supposed to take effect in January 2026. Compliance was pushed to July 2028, and Congress wrote the delay into law. The Safe Food Coalition has asked Congress to rescind it. It should. In the meantime, every grower, processor, distributor and restaurant chain handling leafy greens should comply now. This summer, perfectly good lettuce was plowed under because nobody could say quickly where the bad lettuce went.
2. Fix the water in the fields and the plants. In 2024 FDA replaced numeric water testing with “systems-based” assessments. For a crop grown close to the ground and eaten raw, that is not enough. We need enforceable numeric standards and routine testing for pre-harvest water on leafy greens; parasite testing in irrigation and wash water in the growing regions where outbreaks have occurred; processor wastewater controls (FDA found Cyclospora in a Taylor Farms de Mexico wastewater tank, and Taylor Farms promised water testing there in 2013); and research money for a wash or treatment step that actually kills parasites on lettuce without destroying it.
3. Break up the batches and test before it ships. Shaw’s sources explain how a single plant mixing millions of heads lets a few bad ones contaminate thousands of bags. Processors should limit how much product from different fields and growers is commingled on one line or shift, keep lots small enough to trace and recall precisely, and test finished product by lot, holding each lot until results come back negative, using FDA’s validated methods for the pathogens of concern, including Cyclospora. Testing will not catch every contaminated bag, but small, held lots shrink an outbreak when one gets through and give investigators a lot number instead of a guess.
4. Keep cattle away from lettuce. Setbacks between animal feeding operations and leafy greens fields, and the canals that irrigate them, should be required by rule, not left to buyer guidance. The 2018 Yuma romaine outbreak traced back to irrigation canal water near a large feedlot, and the Salinas Valley outbreaks that followed pointed to cattle on adjacent land. We keep finding the same source and keep acting surprised.
5. Hold imported greens to the same standard. Lettuce grown in Mexico for U.S. buyers should meet the same water, setback and sanitation requirements as lettuce grown in California and Arizona, enforced through the Foreign Supplier Verification Program and backed by on-site FDA inspections.
6. Verify sanitation on the farm. Toilets, handwashing, worker health and water at leafy greens farms supplying U.S. buyers should be checked by auditors who are not paid to pass. Training is not verification.
7. Rebuild the trip wire. USDA’s Microbiological Data Program sampled lettuce, spinach and other produce in commerce for about $5 million a year and triggered dozens of recalls before it was killed in 2012. Bring it back, with leafy greens at the top of the list. It is the cheapest insurance the produce industry will ever be offered.
8. Count the sick again. In July 2025, CDC made FoodNet reporting optional for Cyclospora and several other pathogens. The largest Cyclospora outbreak in history arrived a year later, on a food 80 percent of us eat every week. When the vehicle is that common, every day of delay means more people sick. Restore full FoodNet surveillance, fund the state and local labs and epidemiologists who interview the sick and find the source, and pay for real-time Cyclospora genotyping so investigators know which cases belong to which outbreak.
9. Agree on data sharing before the next outbreak. A standing protocol, worked out now among leafy greens growers, processors, fast-food chains and grocers, for handing shipping, sourcing and test data to CDC and FDA within hours, not days.
10. Publish root cause analyses and solve the unsolved. FDA has promised a report on the lettuce outbreak. Every leafy greens outbreak should get one, published promptly and in full, and the four other Cyclospora outbreaks this year that still list the source as “not yet identified” deserve an explanation of why.
11. Stop rolling back FSMA. The Produce Safety Rule is the floor for every leafy greens farm in the country. Every “burden” removed in the name of deregulation was a tool someone needed this summer.
12. Name the firms, publish the consignee lists and let FDA sample where the evidence points. I have drafted three FDA citizen petitions that go straight at how leafy greens outbreaks are handled: one asking FDA to stop treating the identity of outbreak-implicated firms as confidential, so people know which lettuce to throw out; one asking it to publish retail consignee lists in Class I recalls, as USDA has done for meat and poultry since 2008, so people know which stores sold it; and one asking it to use its communicable disease authority to require sampling at animal feeding operations implicated in multistate outbreaks, so investigators can finally test the cattle next to the field.

The cheapest outbreak

Gina Shaw’s headline calls it the rise of foodborne illness. It does not have to keep rising. None of the items on my list requires new science. Most require money, will and the willingness to make the people who grow, process and sell our leafy greens do things differently. Dr. Freedman is right that whether we can get it done before next summer is the big question. The 2027 growing season is about six months away. The cheapest outbreak is the one that never happens.