Curious if anyone has any experience with retail package label language regarding washing for indoor grown hydroponic lettuce and leafy greens.
There seems to be a lack of clarity, both in my company and in the wider controlled environment agriculture community, about whether indoor grown, hydroponic, leafy greens and lettuces that do not have a wash step should be treated as a raw agricultural commodity, a ready-to-eat food, or a hybrid of both categories. In the market I see language ranging from "triple washed" (typically for outdoor grown product) to "wash before enjoying" to nothing at all.
Our indoor grown hydroponic lettuce is not washed. We currently make a statement on our label "for longest shelf life, please wash before eating."
Is a label wash statement required by any regulatory authority? FSMA Produce Safety Rule only requires name and address of the farm is on the label.
If a wash statement is made, do you consider it a preventive control? If yes, do you show it in your flow diagram?
If a wash statement is not made, why?