At five o’clock this morning Eastern time, the Washington Post reported that the Centers for Disease Control and Prevention has linked four more states to the Cyclospora outbreak traced to iceberg lettuce from Taylor Farms de Mexico. Illinois, Kansas, Oklahoma and Pennsylvania join Indiana, Kentucky, Michigan, Ohio and West Virginia. Nine states.

CDC’s own outbreak pages say five. The investigation update was last reviewed July 16 and still reads 1,644 people, five states, 94 hospitalizations, onsets from May 13 through July 13. The map of where people got sick carries the same July 16 stamp and colors in the same five states. FDA’s advisory is titled for a five-state outbreak, is stamped current as of July 17, and lists Indiana, Kentucky, Michigan, Ohio and West Virginia under “States with Cases.” 

The Post has sources and the agencies have a publication schedule. Lena Sun’s story is attributed to two individuals familiar with the investigation. Reuters picked it up and said plainly that it could not verify the report and that CDC could not be reached outside business hours. The Post reported that patients in the four added states may have gotten sick around the same time as those in the original five, and that investigators simply needed longer to determine whether those illnesses belonged to the same outbreak. That is not a new wave. That is the same wave, finally counted.

It is also worth noting that the states got there before the newspaper did, and they got there by watching their own numbers climb. On July 22, two days before the Post story, the Kansas Department of Health and Environment said in its own newsflash that after further investigation it could now confirm some Kansas cases are connected to the outbreaks occurring nationally. Kansas had gone from 55 reported cases on July 15 to 289 on July 22 — more than a fivefold jump in one week, better than 30 percent of them in Johnson County. Oklahoma said it even earlier. The Oklahoma State Department of Health told News 9 in Oklahoma City and News On 6 in Tulsa that multiple Oklahoma cases were linked to Taco Bell and that it was working with FDA to trace them back to the Taylor Farms shredded lettuce. Oklahoma’s own count went from 56 on July 14 to 172 on July 21, and the state health department posted a wrong figure that morning and corrected it the same day.

Illinois is the useful contrast. IDPH reported 408 confirmed and probable cases as of July 21 — 215 acquired domestically, 145 in travelers, 48 unknown, with 31 people hospitalized — after reporting 215 a week earlier. The count nearly doubled in seven days. What Illinois has not done is name a source; the department says no single cause has been identified for the increase. Pennsylvania has not linked its cases either. Two of the four states the Post reports CDC has now added had already tied themselves to this outbreak in public; two had not. Either way, the record was sitting on state websites before it appeared in a newspaper, and it is still not on CDC’s outbreak page.

Here is what the nine states are actually reporting, using each state’s own published count rather than CDC’s outbreak figure. The dates differ because the states update on different days, and three of these numbers are already a week old.

State2026 cases the state itself reportsAs ofIn CDC’s five-state outbreak?Source
Michigan7,664 (160 hospitalized)Jul 23YesMDHHS outbreak page
Ohio1,316 statewide (96 hospitalized)Jul 16Yes — statewide figure not updated since July 16; northwest Ohio alone reported 2,380 on July 23Ohio Capital Journal · Toledo Blade
Indiana684Jul 23YesIndiana Department of Health
West Virginia195 (15 hospitalized)Jul 21YesWV OEPS
Kentucky192 reported / 108 confirmed (7 hospitalized)Jul 15YesKentucky Dept. for Public Health, via WTVQ
Five-state totalabout 10,050CDC counts 1,644 in this outbreak, with 94 hospitalizationsCDC investigation update
Illinois408 confirmed and probable (31 hospitalized; 215 domestic)Jul 21Newly linked per the Washington Post; IDPH itself says no single source identifiedIDPH, via CBS Chicago · WTVO/WQRF
Kansas289 (12 hospitalized; was 55 on Jul 15)Jul 22Newly linked per the Washington Post; KDHE said on July 22 that some Kansas cases are connected to the national outbreaksKDHE · KCTV
Oklahoma172 (12 hospitalized; was 56 on Jul 14)Jul 21Newly linked per the Washington Post; OSDH had already said multiple Oklahoma cases were linked to Taco BellOSDH, via KOSU · News 9 · KSWO
Pennsylvania28Jul 16Newly linked per the Washington Post; state has not linked its own cases, and cyclosporiasis reporting in Pennsylvania is voluntaryPennsylvania DOH, via ABC27 · WESA
Four newly linked statesabout 900Not yet reflected on CDC’s or FDA’s outbreak pagesWashington Post
Nine-state totalabout 10,950A floor, not a total — the reporting dates differ and CDC assumes a six-week lagCDC surveillance

Two things in that table deserve to be said out loud. The first is Pennsylvania. It is now one of the four states newly tied to a national foodborne outbreak, and cyclosporiasis is not on Pennsylvania’s list of reportable conditions — physicians report it voluntarily, a limitation CDC footnotes on its own surveillance page. Pennsylvania’s 28 cases are not a measurement of how many Pennsylvanians got sick. They are a measurement of how many doctors chose to pick up the phone.

The second is Ohio, which is keeping two sets of books. The state health department’s most recent statewide figure is 1,316 as of July 16, with 96 hospitalizations. Northwest Ohio alone reported 2,380 cases on July 23, with 1,074 in Lucas County. A region inside Ohio is reporting nearly twice what Ohio is reporting. On Thursday, at the state’s request, CDC agreed to send disease detectives to Ohio for about three weeks.

A tip of the pen, again, to Lena H. Sun at the Washington Post, who has been out in front of this outbreak for a week and a half and put Taylor Farms in print on July 16, the day before FDA named the supplier itself

The credit belongs further down the masthead too. Almost every number in the table above reached the public through a local reporter, not a federal notice. The Toledo Blade is the only outlet counting northwest Ohio day by day, which is the only reason anyone knows a corner of one state is reporting nearly twice what the state is. WISH-TV in Indianapolis has been reading the Indiana dashboard every afternoon. KCTV in Kansas City caught the Kansas quadrupling. KSWO in Lawton caught Oklahoma’s health department posting a bad number and correcting it the same day. WESA in Pittsburghis the reason I can tell you that cyclosporiasis reporting in Pennsylvania is voluntary. FOX19 in Cincinnati got the disease-detectives deployment out of a county health department, and The Hill’s Nexstar team built its own fifty-state tally out of CDC data, state data and local reporting because no one else had. KBIA in Columbia is why anyone knows Missouri — a state that logs about a dozen cases in a normal year — is at 216. Reporters in Michigan, Ohio, Kentucky and North Carolina have been doing the same work all month.

None of which makes the reporting the problem. The problem is that on a Friday in the eleventh week of the largest Cyclospora outbreak in American history, a mother in Tulsa or Wichita or Harrisburg who wants to know whether her state is part of it has to read a newspaper with a paywall, because the federal pages built for exactly that purpose have not been touched since July 16.

Outbreak notices are not press clippings. They are how the public health system tells people what happened to them and what to stop eating. The Washington Post published the ninth state at five o’clock this morning. CDC’s outbreak page has not changed since July 16.

Every time Taylor Farms turns up at the center of an outbreak, the company says the same thing — this is an isolated event, our branded products are not involved, we acted quickly. So let us put the record in one place. What follows is every Taylor Farms outbreak I can verify from public sources, with the pathogen, the dates, the number of people sickened, and the product. I know these personally, because I represented the people and families impacted.

Then every recall I can verify, sorted by pathogen. Read them together and a pattern shows up that no single press release can explain away.

Pay particular attention to the gap between the two lists. Three of the largest outbreaks on this page — 2013, November 2024, and the 2021 romaine cluster — produced no recall at all. Two more produced recalls that went only to foodservice customers by direct notice, with nothing posted for the public to read.

Outbreaks with Recalls or Not

2009 — Salmonella Typhimurium — shredded lettuce. Shredded lettuce sickened 145 people in the western United States and at least 12 more in Canada. The product was shredded lettuce sold into fast-food and foodservice accounts, and the illnesses pointed at the processing step rather than at any one restaurant. No recall. This is the outbreak nobody remembers, four years ahead of everything else on this list.

June–August 2013 — Cyclospora — bagged salad mix. 631 people in 25 states were sickened. Iowa and Nebraska health officials concluded that the restaurant cases in their states traced to a salad mix produced by Taylor Farms de Mexico, served at Olive Garden and Red Lobster. The Texas cases, a large share of the national total, were never conclusively tied to the same product. FDA inspected the Guanajuato plant that August and produced the environmental assessment that remains the single most-cited document in this company’s history. No recall was issued. Production was suspended; the product already in commerce stayed there.

November 2015 — E. coli O157:H7 — celery and onion diced blend. Nineteen people in seven states were infected, five were hospitalized, two developed hemolytic uremic syndrome and one required a kidney transplant. The vehicle was Costco’s rotisserie chicken salad; the ingredient was the celery and onion diced blend from Taylor Farms Pacific in Tracy, California. Montana’s public health laboratory got a presumptive positive off a retail sample. Taylor Farms Pacific recalled the blend and many other celery-containing products on November 26, 2015, and the recall grew past 155,000 items across Costco, Walmart, Sam’s Club, Target, Safeway, 7-Eleven and Starbucks. FDA’s follow-up analysis could not confirm the organism, and the company has called it a false alarm ever since. Nineteen people were still sick.

November 2021 — E. coli O121:H19 — romaine lettuce. A small cluster, and a telling one. Two Washington cases reported eating romaine at Panera Bread and two Minnesota cases reported eating romaine at Chipotle; the lettuce traced back to Taylor Farms. No recall, and no CDC advisory. The traceback landed and the public was never told.

May 2023 — Cyclospora — Taco del Gnar, Ridgway, Colorado. The Colorado Department of Public Health and Environment and Ouray County Public Health investigated Cyclospora infections among patrons of a single restaurant, with fresh produce implicated and the supply chain running back to Taylor Farms. The public entry does not carry a case count. No recall. A documented single-restaurant Cyclospora cluster is rare, and this one sits three years ahead of the current outbreak with the same parasite and the same supplier.

October–December 2024 — E. coli O157:H7 — slivered yellow onions. One hundred four people in fourteen states, 34 hospitalized, four with hemolytic uremic syndrome, and one dead in Colorado. Sixty-three of 75 people interviewed — 84 percent — reported a menu item containing fresh slivered onions, and FDA’s traceback pointed at the onions served on McDonald’s Quarter Pounders. Taylor Farms initiated a voluntary recall of yellow onions on October 22, 2024 and notified its foodservice customers directly. There was no consumer-facing recall notice. FDA closed the investigation without ever recovering the outbreak strain from an onion, and the Colorado Springs plant drew a Form 483.

November 2024 — E. coli O157:H7 — romaine lettuce. Eighty-nine people in fifteen states, with onsets from November 4 to November 30, 2024. Thirty-six were hospitalized, seven developed HUS, and one person died. CDC and FDA closed the investigation in January 2025 without telling the public which company grew the lettuce. Our own epidemiologist found the common thread among clients who were whole-genome-sequencing matches to one another, and the name came out through federal court filings in April 2025No recall. Fifty of the 89 were in Missouri, most of them from salads catered at a St. Louis high school. Taylor Farms denies every bit of it. In a statement to The Packer, the company said “Taylor Farms product was not the source of the referenced 2024 E. coli outbreak,” maintaining that its raw and finished product testing showed nothing and that tying its products to these illnesses was unfair to the families who got sick. Set that against what the traceback actually found: a single processor sourcing romaine from a single grower, with the lettuce at four of the five points of service running back to the same ranch and the same lot – See FDA Report

May–July 2026 — Cyclospora — shredded iceberg lettuce. The one we are living through. CDC has confirmed 4,173 cases since May 1 and is working to confirm roughly 7,400 more; Michigan alone reported 7,171 cases as of July 22FDA’s traceback converged on a single supplier, Taylor Farms de Mexico, which provided the shredded iceberg lettuce used at Taco Bell locations where sick people ate in Indiana, Kentucky, Michigan, Ohio and West Virginia. Taylor Farms de Mexico recalled all central-Mexico iceberg lettuce on July 17, 2026; the shredded product had gone into 27 states between June 29 and July 16, and Marketside-brand consumer bags were pulled from Walmart stores in 15 states — which is worth remembering every time you hear that only restaurants were affected.

Recalls by Pathogen

Cyclospora cayetanensis

July 17–18, 2026 — shredded iceberg lettuce and iceberg salad, Taylor Farms de Mexico; foodservice in 27 states, Marketside consumer bags at Walmart in 15 states.

E. coli O157:H7

November 26, 2015 — celery and onion diced blend and other celery-containing products, Taylor Farms Pacific; expanded past 155,000 items.

October 22, 2024 — whole peeled, jumbo peeled and diced yellow onions; foodservice customers notified directly, no public notice.

Salmonella

May 2, 2011 — ready-to-eat salad kits containing recalled Six L’s grape tomatoes, Taylor Farms Pacific; about 22,000 pounds on the USDA side.

March 2018 — 3/8-inch diced yellow onions, Taylor Farms California Foodservice; no FDA or company notice was ever posted, only the downstream grocer’s.

August 2020 — diced onions, salads, stir fry and mirepoix, Taylor Farms Texas; Marketside and Taylor Farms brands at Walmart and Kroger in 11 states.

2021 — Taylor Farms brand Maple Bourbon Chopped Kit, 315 g, recalled in Canada; Class 2. A branded consumer salad kit.

Listeria monocytogenes

October 2013 — broccoli salad kits, 5,084 pounds, on account of dressing packets under FDA recall; a companion Taylor Farms action pulled about 5,000 units of broccoli salad across 23 states.

February 11, 2017 — chicken and pork salad products, 6,630 pounds, from the Dallas and Tracy plants.

October 23, 2021 — Taylor Farms Mushroom Stir Fry, 9 oz., Kroger stores in eight states.

February 9, 2024 — Marketside Bacon Ranch Crunch Salad Kit, on the expanded Rizo-López Foods cheese recall.

Undeclared allergens and misbranding

October 24, 2014 — walnuts, Signature Café Broccoli Kale Salad with Chicken, 377 pounds.

May 26, 2016 — wheat and sesame, Wawa Thai style chicken mango salad, 151 pounds.

August 7, 2017 — milk, Taylor Farms Creamy Homestyle Coleslaw Kits, 293 cases.

October 28, 2017 — fish (anchovies), salads with chicken, Taylor Farms Florida, 732 pounds.

August 29, 2018 — egg and wheat, homestyle beef and pork meatloaf, Taylor Farms Illinois, 75 pounds.

May 14, 2019 — Caesar salad with chicken, Taylor Farms Texas, 1,079 pounds.

May 27, 2022 — wheat and egg, Trader Joe’s Lemony Arugula Basil Salad Kit, Taylor Farms Retail.

March 13, 2024 — wheat, Kroger apple walnut with chicken salad bowls, Taylor Farms Pacific, 19,976 pounds.

August 26, 2025 — sesame and soy, Taylor Farms Honey Balsamic Salad Kit, 25 states.

Processing defect

August 9, 2019 — breaded chicken products that may have been undercooked, Taylor Farms Illinois, 342 pounds.

A Note on What Is Missing

This list is not complete, and I want to be plain about why. FDA’s public recall page carries only the announcements a company chooses to make public. The quiet ones — the direct-to-customer foodservice recalls, the low-classification actions nobody writes a press release about — are recorded instead in FDA’s Enforcement Report Database, which is searchable by firm and covers 2004 to the present. Anyone doing this work should run that search under every corporate name the company files under: Taylor Farms Retail, Taylor Farms Pacific, Taylor Farms Texas, Taylor Farms California Foodservice, Taylor Farms Illinois, Taylor Farms Florida, Taylor Farms Tennessee, Taylor Farms Maryland, Taylor Farms de Mexico, and Taylor Fresh Foods. Search one string and you will miss most of them. Meat and poultry recalls sit with USDA’s Food Safety and Inspection Service instead, which is why so many of the entries above point there.

Here is the thing I keep coming back to. The two outbreaks on this page that killed someone — the onions in October 2024 and the romaine in November 2024 — are also the two where the public was never given a recall notice to read. In the first, customers were told and consumers were not. In the second, nobody was told at all until we filed suit.

Three federal maps describe the 2026 Cyclospora Summer. Read in order, they move from what has been established, to what is documented but unexamined, to what nobody has yet explained.

CDC, Where People Got Sick: Cyclospora Outbreak, July 2026 — last reviewed July 16, 2026.

This part is settled. FDA’s traceback investigation identified convergence on a single supplier of iceberg lettuce, Taylor Farms de México, used by the Taco Bell locations where sick people ate before becoming ill. CDC reported 1,644 people infected with Cyclospora and reporting Taco Bell exposure across five states, with 94 hospitalizations and illness onsets running from May 13 to July 13. Michigan analyzed food exposure details from 190 of those cases, and 90 percent reported eating iceberg lettuce. The company announced a recall on July 17. The link from restaurant to supplier to recall is not in dispute.

Taylor Fresh Foods recall notice announced July 17 and posted by FDA July 18, 2026.

Then the same lettuce turns out to have gone much further. The recall notice states that the shredded iceberg product was distributed between June 29 and July 16 in twenty-seven states: Alabama, Arkansas, Connecticut, Florida, Georgia, Iowa, Illinois, Indiana, Kansas, Kentucky, Louisiana, Massachusetts, Maryland, Michigan, Missouri, Mississippi, North Carolina, New Hampshire, New Jersey, Ohio, Oklahoma, Pennsylvania, South Carolina, Tennessee, Texas, Virginia and Wisconsin.

CDC, Surveillance of Cyclosporiasis. Bands read from CDC’s published case-location map.

And this is the part nobody has explained. CDC’s surveillance page reports 4,173 laboratory-confirmed domestically acquired cases since May 1, 2026, plus more than 7,400 additional cases not yet laboratory confirmed, many of them from Michigan and Ohio — roughly 11,600 people across forty-two states and the District of Columbia. The five-state Taco Bell cluster is a subset of that. What accounts for the rest has not been established.

The question worth pressing is whether the distribution map explains the case map. It is not proof either way, but the pattern leans one direction.

Twenty-five of the twenty-seven states that received the recalled lettuce report cases — all but New Hampshire and South Carolina. That is 93 percent, against 74 percent of the states that did not receive it. On its own that comparison proves very little, because with cases in forty-two of fifty states almost any distribution list would overlap heavily.

The stronger signal is where the burden sits. Nine states report 81 or more cases. Eight of the nine received the recalled lettuce: Michigan, Ohio, Indiana, New Jersey, North Carolina, Illinois, Kentucky and Texas. Meanwhile the seventeen states with cases that are absent from the distribution list are overwhelmingly minimal — ten of them sit in the lowest band of one to ten cases, which is roughly what background cyclosporiasis looks like in a normal summer. The heavy states got the lettuce. The states that did not get the lettuce are mostly barely affected.

Two states break the pattern, and both are worth an answer. New York carries between 161 and 300 cases and does not appear on the distribution list at all — the only high-burden state that does not. West Virginia is one of the five states in CDC’s own outbreak map, with confirmed illnesses tied to Taco Bell locations FDA named, and it does not appear on the company’s list either.

Neither gap has an innocent explanation on the public record. Either the product reached those states through a channel the recall notice does not capture, or the two lists were built from different records, or New York’s cases have a different source entirely. Any of those is answerable with documents the company and the agencies already hold: the full customer list behind the recall, the distribution records for the thirty-four product lines the notice does not describe, and the state-level exposure interviews CDC has collected but not published.

Three limits on the comparison, all of which understate rather than overstate it. The twenty-seven-state figure describes the shredded iceberg line only; the recall spans thirty-five product lines, including the Marketside retail bags sold at Walmart, and the notice gives no distribution list for the rest — so the true distribution footprint is larger than twenty-seven, not smaller. The national case map counts all 2026 cyclosporiasis cases, not only those traced to this supplier, so not every shaded state is a Taylor Farms state.

FDA’s table of active foodborne illness investigations currently lists six separate Cyclospora outbreaks running at once. Exactly one has a product attached to it. Reference 1390 is the Taco Bell cluster, where FDA’s traceback converged on Taylor Farms de México and the company pulled its iceberg lettuce from the market. The other five are blanks. Referecne 1392, opened July 22, 72 illnesses, product yet identified. Reference 1385, opened July 8, eight illnesses, product not yet identified. Reference 1384, opened the same day, eighteen illnesses, product not yet identified. Reference 1381, opened June 17, two illnesses, product not yet identified. Reference 1375, opened June 3, eight illnesses — an outbreak FDA now lists as ended, with the investigation still open and the source still unknown. FDA has opened traceback on every one of them and collected samples in some. It has not conducted a single on-site inspection in connection with any of them, and not one has produced a recall.

That matters more than it looks. For this parasite, “not yet identified” resolves to “never identified” about half the time. FDA closed a Cyclospora investigation in July 2025 with 48 illnesses having never identified the product at all and closed another in August 2025 with 69 illnesses that it did manage to trace to parsley. Five open blanks during the largest cyclosporiasis outbreak in American history is not a bookkeeping curiosity. If a second contaminated commodity is moving through the food supply alongside the lettuce, those five files are where it would surface — and right now they are five traceback exercises with no inspections behind them.

In November 2013, after Cyclospora cayetanensis sickened hundreds of people in Iowa and Nebraska, FDA published an environmental assessment of the Taylor Farms de México processing plant at Doctor Mora, Guanajuato. The report closed with recommendations. The second told the firm to determine whether Cyclospora is a reasonably likely hazard in the Guanajuato leafy green growing region and, if it is, to re-evaluate the wash step used on salad mix. Thirteen years later the same region sits at the center of the largest cyclosporiasis outbreak in American history, and no one has produced a document showing that determination was ever made.

Here is what a hazard analysis would have found, had anyone performed one. Two hundred and thirty-five meters from the processing building — roughly eight hundred feet, a three-minute walk — sits Balneario Las Fajanas, a public thermal-water bathing complex with pools, water slides, changing rooms, showers, grills and picnic shelters, open every day of the year. It is the largest concentration of human fecal loading anywhere near that plant. And satellite imagery establishes that it was already built, filled and operating in March 2010, more than three years before FDA and COFEPRIS ever set foot on the property.

March 4, 2010. Taylor Farms de México at center; Balneario Las Fajanas at lower right, pools filled, buildings and mature tree cover in place. More than three years before the FDA and COFEPRIS assessment. Google Earth historical imagery.

That image forecloses the only innocent explanation. Nobody can now say the balneario came later, or that the environment changed after the inspectors left. When FDA and COFEPRIS walked that site in August 2013, a public bathing facility with filled pools stood across the highway in plain view and had stood there for years. The published assessment describes the processing plant and five ranches. It does not describe a bathing complex. 

It is worth setting out what is actually on that property, because the detail matters. The Guanajuato Secretariat of Tourism lists Las Fajanas in its official state guide under balnearios and water parks, at Km 16 of the San Miguel de Allende–Doctor Mora highway, locality of Cruz de la Maza, with state-published coordinates of 21.10266, -100.45159. The state describes thermal-water pools, extensive lawns, parking, water slides, palapas, grills, restrooms, showers, changing rooms and a snack shop, and flags the site as accessible. Other listings add a soda fountain, a store, sports courts and a bar. The operator advertises thermal water held at 40 degrees Celsius and promotes that the facility is open 365 days a year. Admission has climbed steadily — 80 pesos for adults and 40 for children in earlier listings, 100 and 40 after that, 120 and 60 from the first of February, and 150 adults and 80 children from the twenty-third of March. Prices rise like that when demand supports it. The Google listing carries 897 reviews. There is no website; the business runs on Facebook.

Water slides produce high water ingestion, particularly among children. Grills and picnic shelters mean families stay all day rather than an hour, which multiplies restroom use per visitor. Thermal water at 40 degrees means the facility is drawing from a deep geothermal source and moving large volumes of it — and every liter that goes into a pool eventually comes out of one. Where it goes when it leaves is the entire question, and no public listing answers it.

June 14, 2023. The same frame. The balneario is largely unchanged. The Taylor Farms facility is not — note the enlarged processing building, the solar array at left, the formal employee parking, and the trailer yard across the top of the image. Google Earth historical imagery.

Put the two frames side by side and a second argument appears, one that has nothing to do with the balneario. The bathing complex in 2023 looks much as it did in 2010. The Taylor Farms facility does not. The 2010 image shows a moderate plant: one main building, blue-roofed outbuildings, a large unpaved graded area to the north. The 2023 image shows a substantially larger processing building, a solar array along the western boundary, hundreds of employee vehicles in formal parking rows, and a trailer yard holding well over a hundred units. That is not incremental growth. That is a different scale of operation — more throughput, more wash water, more workers, more waste.

One more feature is visible in both frames and deserves attention from someone qualified to identify it. A linear channel runs east to west immediately north of the highway, between the plant and the balneario, and appears to hold water in both images. The 2023 frame also shows a standing water body along that channel southwest of the plant. If that is an irrigation canal or a drainage ditch, it is a surface pathway between the two properties — and surface connection is far easier to establish than aquifer connection. It would also have been visible from the plant yard in 2013. Separately, the 2010 frame shows a dark oval pond immediately southwest of the main building that I cannot find in the 2023 frame. If that was a retention or process-water lagoon, its disappearance during the expansion is a records question worth asking.

Cyclospora cayetanensis has no animal reservoir. Cattle do not carry it, wildlife does not carry it, birds do not carry it. It completes its life cycle in human beings and nowhere else. Every oocyst that ends up on a leaf of iceberg lettuce came out of a person. With E. coli O157:H7 you go looking for a feedlot upgradient of the field. With Cyclospora you go looking for human sewage.

Cyclospora Oocysts are shed unsporulated and non-infectious. They must sit in the environment for roughly one to two weeks at temperatures between about 22 and 32 degrees Celsius before they can infect anyone, which is why CDC says direct person-to-person transmission is unlikely. A sick person cannot hand this parasite to the person beside them. What that person can do is deposit inert oocysts into soil or water, walk away, and leave them to ripen. And northeastern Guanajuato is close to ideal for that ripening: mean daily maximum temperatures at San José Iturbide run from about 23 to 31 degrees Celsius across the entire year, sitting inside the sporulation window in every month.

I want to be careful here, because there is a version of this argument that is wrong. On July 15 the International Fresh Produce Association faulted Michigan’s health department for saying recreational water is not a recognized risk factor, cited three papers for the proposition, and told The Packer that Michigan was defying reputable science. Its consumer FAQ still tells readers that pool chlorine will not kill Cyclospora and that people who swallow pool water are not protected the way they would be from other waterborne illnesses. County health departments in Ohio and Arizona have said much the same thing. The implication running through all of it is that swimmers are catching this. They are not.

The most recent global review of waterborne protozoan outbreaks, published by Bourli and colleagues in the Journal of Water and Health in 2023 and the fifth in a series running since 2007, catalogued 416 outbreaks worldwide between 2017 and 2022. Recreational water and swimming pools were the suspected source in 313 of them — three quarters of the total — and 92 percent of those were CryptosporidiumCyclospora caused three outbreaks in the entire six-year window, and the review lists each one by name: drinking water in Poland traced to travelers from Indonesia, drinking water in South Korea traced to travelers who drank at a church in Nepal, and a British cluster among travelers returning from Mexico whose recorded exposures were fruit, salad vegetables, fresh herbs, bottled water and ice. Not one of them is a pool. Cryptosporidium owns that category, because Cryptosporidium is infectious the moment it leaves the body. Cyclospora is not. A health department urging caution about pools is being careful. A trade association telling you recreational water is a live risk factor in this outbreak is doing something else. It is moving the story off lettuce.

The defensible argument is not that the balneario infected swimmers. It is that the balneario is a fecal loading point into the environmental water system surrounding a ready-to-eat produce plant. And that mechanism is not my invention. It is the express premise of the research the produce industry has been funding for a decade.

The Center for Produce Safety states plainly that it has invested 1.6 million dollars in Cyclospora research since 2014, and that the results confirmed the parasite is endemic in the United States and can be recovered from wastewater and irrigation water, which it calls a significant risk for produce contamination. That is the industry’s own research arm saying the parasite lives in sewage and reaches crops through water. Go one level down and the mechanism gets named outright: a CPS and USDA-listed project led by Charles Gerba, Kelly Bright, Paula Rivadeneira and Walter Betancourt at Arizona was built to determine whether American produce is at risk from irrigation water contaminated by human sewage, and it specifies the sources — faulty and leaking septic systems, compromised sewer pipes, and treated wastewater effluent discharged into surface waters used to irrigate food crops. The USDA National Agricultural Library listing carries the identical framing. Faulty septic near produce ground is not a theory I am floating. It is a funded federal research question.

The surveillance results tell you where the parasite actually is. A two-year study in a Southeastern Georgia growing region, published in the Journal of Food Protection and funded through CPS, sampled municipal wastewater sludge, on-farm portable toilets, irrigation pond water and spent packinghouse dump tank water. The parasite lives in human sewage, reliably. And an unconfirmed molecular positive on agricultural water is a known published artifact — precisely what happened at the border in July, and why that false positive proved nothing about whether the lettuce was contaminated.

Treatment does not solve it. Kitajima, Haramoto, Iker and Gerba sampled two Arizona wastewater treatment plantsmonthly for a year, detected Cyclospora in wastewater with a purpose-built assay, and concluded that conventional treatment is limited in its ability to remove protozoan oocysts and cysts. That is a functioning municipal plant. A rural recreational facility is not going to do better. Nor is any of this new: Sterling and Ortega reported in Emerging Infectious Diseases that Cyclospora oocysts were recovered from sewage lagoons beside an endemic area of Lima, and that water from those lagoons irrigates pasture, corn, and elsewhere in the city, vegetable crops. That was 1999.

Straight-line distances computed from published coordinates. The processing plant is at 21.10634° N, 100.45266° W.

Taylor Farms will argue it cannot control what its neighbors put into the ground. That argument fails on the 2013 record. FDA told Taylor Farm, in writing, to determine whether Cyclospora is a reasonably likely hazard in this growing region, and if it is, to re-evaluate the wash step. A hazard analysis worth the paper it is printed on would have identified a public bathing complex eight hundred feet from the intake — a bathing complex that the satellite record now proves was sitting there, pools filled, three years before the inspectors arrived. The failure here is not that the balneario is there. The failure is that the federal government said look, and thirteen years and one record-breaking outbreak later, no one can show that anybody did.

Mexico’s health secretary, David Kershenobich, told reporters Tuesday that his government has found no evidence that the outbreak sickening thousands of Americans began on a lettuce farm in Guanajuato. He said Mexico is taking precautions anyway, and its food-safety agencies, Cofepris and Senasica, say they are running preventive inspections and traceability checks in the state. It is a careful statement, and a defensible one on its own terms. It is also the newest verse in a song that has played for two weeks: Taylor Farms says it was less than one percent of the iceberg supply, the produce trade groups say the case rests on interviews, and now a national government says no laboratory result points its way. Every one of them is standing on the same fact — that no sample of the lettuce has tested positive for the parasite. For this parasite, that fact means almost nothing.

Here is why. Cyclospora cannot be grown in a laboratory — there is no culture, no animal model, no way to multiply it and confirm it the way a lab confirms Salmonella or E. coli. Detecting it means finding its DNA on the produce itself, and the produce is lettuce: it is eaten or thrown away within days, while the people who ate it do not fall sick for a week and are not counted for a month or more. By the time investigators know an outbreak exists, the lots that caused it are gone. Contamination is patchy, too — a clean twenty-five-gram sample says nothing about the leaf beside it. So, a negative test is not evidence of a safe field. It is evidence that the evidence was eaten. The one positive sample the FDA did announce, from Taylor Farms de Mexico lettuce, it retracted two days later as a false positive. The absence that remains is not exoneration. It is the ordinary condition of a Cyclospora investigation.

What investigators have instead is the thing that actually breaks these outbreaks open: sick people and a supply chain. Sixteen hundred and forty-four of them. That is how many people across five states — Indiana, Kentucky, Michigan, Ohio and West Virginia — caught Cyclospora after eating at Taco Bell, with illnesses starting between May 13 and July 13 and ninety-four of them hospitalized. Sixteen hundred strangers in five states do not share a rare parasite by coincidence. They shared a restaurant. Michigan interviewed one hundred ninety of its Taco Bell patients, and ninety percent had eaten the iceberg lettuce; the FDA then traced that lettuce back through the chain, and it converged on one supplier — Taylor Farms de Mexico, in central Mexico. That is the evidence, and it is the part the minister’s statement steps around. A positive lab sample would be welcome, but it is not required and never has been. As NBC noted this week, a positive test is not necessarily needed to name a source. What names it here is 1,644 people and one farm at the end of every thread.

And 2013 is the part the statement left out. The same Guanajuato facility — Taylor Farms de Mexico — was the source of a Cyclospora outbreak that sickened more than six hundred people across twenty-five states, traced to salad mix served at Olive Garden and Red Lobster. There was a no-evidence-yet posture then, too, and stepped-up border screening, and a company that pulled far more product than the implicated lot. No one wanted to be the answer. Eleven years later the answer was the same place.

The count is not waiting for anyone’s certainty. CDC now reports 4,173 laboratory-confirmed domestic cases since May 1 and says it is aware of more than 7,400 additional cases not yet confirmed — many of them in Michigan and Ohio — for a national total above eleven thousand five hundred across forty-one states, with three hundred and eight people hospitalized. Michigan alone reported 7,171 cases on Wednesday, up six hundred in a single day. The states themselves add up to a little more; below is where each one stands tonight, with the source for every number.

State2026 cases reportedPart of the Taco Bell outbreak?Source
AlabamaNo 2026 count publishedNot reported as part of the outbreakCDC
Alaska5; 3 travel-relatedNo – AK DOH: no link to the outbreakAK DOH / Epoch
Arizona19Cases reported; not in clusterAZ DHS / Epoch
Arkansas26 year-to-dateUnder investigation for outbreak linkAR DOH / Epoch
California41 provisional (Jul 14); CDC lists 97No – CDPH: no local acquisition identifiedCDPH
Colorado150; 4 hospitalized; 8 of 120 domesticNo – CDPHE: not part of the Midwest outbreakCDPHE / Epoch
Connecticut35 (up from 19 in 2025)Links its cases to the national outbreakCT DPH
DelawareNo 2026 count publishedNot reported as part of the outbreakCDC
Florida106No – FL DOH: seasonal disease Florida sees yearlyFL DOH / Epoch
Georgia11–30 domestic since May 1; CDC lists 71No – GA DPH: no Georgia-specific clusterGA DPH / Epoch
HawaiiNo 2026 count publishedNot reported as part of the outbreakCDC
IdahoNo 2026 count publishedNot reported as part of the outbreakCDC
Illinois277 (Jul 16); 23 hospitalized; CDC lists 87No – IDPH: higher than average, no single causeIDPH / TODAY
Indiana327 total; at least 47 tied to the outbreakYES – fifth Taco Bell outbreak state; daily updatesIN DOH / Epoch
Iowa57; about half domesticNo – IA HHS: not connected to national investigationsIA HHS / Epoch
Kansas55 (Jul 15); 37 domesticDomestic cases rising; no Kansas source foundKDHE
Kentucky192 (Jul 15); 108 confirmed; 7 hospitalizedYES – Taco Bell outbreak state; weekly updatesKY DPH / Epoch
Louisiana1–10Not declared part; not in clusterLA DOH / Epoch
MaineNo 2026 count publishedNot reported as part of the outbreakCDC
Maryland69; some travel-relatedNo – no common link identifiedMD DOH / Epoch
Massachusetts18 (normal seasonal amount)No – MA DPH: not affected by the Midwest outbreakMA DPH / Epoch
Michigan7,171 (Jul 22); 102 hospitalized (Jul 16); 23 out-of-state pendingYES – leads the outbreak; 2,408 new cases in the week to Jul 18MDHHS
Minnesota41 since May 1No – MDH: no increase over expectedMDH / Epoch
MississippiNo 2026 count publishedNot reported as part of the outbreakCDC
MissouriNo 2026 count publishedNot reported as part of the outbreakCDC
MontanaNo 2026 count publishedNot reported as part of the outbreakCDC
Nebraska49No – NE DHHS: none related to the wider outbreakNE DHHS / Epoch
NevadaNo 2026 count publishedNot reported as part of the outbreakCDC
New Hampshire1–10Cases reported; not in clusterNH DHHS / Epoch
New Jersey46 (May 1–Jul 11); within typical rangeNo – NJDOH: no clusters or outbreaksNJDOH
New MexicoNo 2026 count publishedNot reported as part of the outbreakCDC
New York517 (May 1–Jul 13) incl. NYC; CDC lists 539No – NYSDOH: not a major deviation from the normNYSDOH / Epoch
North Carolina307 (Jul 14); 13 hospitalizedNo – NCDHHS: does not appear linked to the Taco Bell outbreakNCDHHS
North DakotaNo 2026 count publishedNot reported as part of the outbreakCDC
Ohio1,316 statewide (Jul 16); 96 hospitalized. Northwest Ohio alone reports 2,029 (Jul 20)YES – Taco Bell outbreak state; state updates weeklyODH / Toledo-Lucas
Oklahoma57; 6 hospitalizedPart of the national outbreak; no Oklahoma sourceOSDH / Epoch
OregonNo 2026 count publishedNot reported as part of the outbreakCDC
Pennsylvania28; reporting is voluntaryNo – mostly travel-relatedPA DOH / Epoch
Rhode Island4 since May 1Cases reported; not in clusterRI DOH / Epoch
South CarolinaNo 2026 count publishedNot reported as part of the outbreakCDC
South DakotaNo 2026 count publishedNot reported as part of the outbreakCDC
Tennessee11–30Investigating; not in clusterTN DOH / Epoch
Texas68 (Jul 13); 15 hospitalized; all domesticMeets CDC case definition; no source identifiedTX DSHS
Utah1–10No – UT DHHS: not related to the wider outbreakUT DHHS / Epoch
VermontNo 2026 count publishedNot reported as part of the outbreakCDC
Virginia37 through Jul 4; CDC lists 61No – VDH: no evidence of a Virginia outbreakVDH
Washington27 since May 1; 5 domestic or possibly domesticNo – WA DOH: not associated with other statesWA DOH / Epoch
West Virginia195 (Jul 21); 15 hospitalized – nearly tripled since Jul 13YES – Taco Bell outbreak state; updates Tuesdays and FridaysWV Dept. of Health
Wisconsin61 (May 1–Jul 15); 11 domesticNo – WI DHS: no common food item identifiedWI DHS / Epoch
WyomingNo 2026 count publishedNot reported as part of the outbreakCDC

A word on the counts. Where a state publishes its own figure I used it, because state health departments are closer to the illnesses and update more often; where CDC’s own state table differs materially, I noted both. Update cadence is uneven — Michigan and Indiana post daily on weekdays, West Virginia Tuesdays and Fridays, Ohio and Kentucky weekly — so any national total is a blend of numbers of different ages, and sixteen states publish no 2026 count at all. The roughly 11,350 these fifty numbers add to is a floor, not a ceiling.

So, Mexico is right that there is no laboratory evidence its lettuce made anyone sick. It is right the way a supplier is right when it points to a clean test, and the way a trade group is right when it says the case rests on interviews. In a Cyclospora outbreak the laboratory almost never arrives in time, and everyone who has worked one of these knows it. The evidence here is sixteen hundred people who ate at the same restaurant, thousands more who are sick, and a paper trail that keeps arriving at the same farm in Guanajuato — the same farm as 2013. I have been doing this since 1993, and I have never once watched a positive lettuce sample rescue anyone. The people are the evidence. They always were.

Nearly twelve thousand cyclosporiasis cases have now been reported to the CDC this summer — 4,173 confirmed in the laboratory as domestically acquired, and more than 7,400 more still awaiting the analysis that would confirm them, many of them in Michigan and Ohio. Michigan alone counted 6,571 as of July 21, with 102 hospitalizations and, so far, no deaths. Officials call it likely the largest outbreak of this parasite in the country’s history. As the count climbed, every corner of the produce and grocery world that speaks for itself put out a statement. Some of those statements have quietly changed since. Here is the whole map, group by group, with links so you can read each one yourself and check my work.

GroupWhat it saidStill says it?Where it landed
IFPAJuly 15 statement: epidemiology alone, without a physical sample, isn’t proof; faulted Michigan for dismissing water; put itself on record against delaying the traceability ruleYes — and the July 15 original still sits, dated, beneath the softened July 19 updateAged best, and the only group to correct itself in the open
California/Arizona LGMAJuly 15 statement: lettuce a “leading suspect,” Cyclospora historically tied to imported produce, and a note that CDC cut national Cyclospora surveillance in 2025No — replaced July 16 under a new byline; the imported-produce and surveillance-cut lines are goneWarmer tone, but the original survives only on the Wayback Machine
FMICyclosporiasis backgrounder: confirms the recall, links FDA and CDC, states the confirmed-versus-probable gap accuratelyYes — revised in place, with a visible date stampBest consumer communication of any group; also the loudest voice for delaying the very rule at issue
National Grocers Association“What Independent Grocers Should Know”: operational guidance for member storesYesUseful, but tells grocers there is no retail recall — there is one; and it applauded the traceability delay
Western GrowersJoelle Mosso’s essay naming three gaps: risk communication, national surveillance, and imported-produce oversightYesThe most substantive critique from inside the industry — right on two of the three
National Restaurant AssociationNothingSilent — while Taco Bell, an operator and not a trade group, spoke twice and early
Fresh Produce Association of the AmericasNothingSilent

Start with the group that comes out of this best. The International Fresh Produce Association — the trade body that speaks for the whole supply chain — put out a sharp statement on July 15 through its chief science officer, Max Teplitski. Its core claim was that a survey of what sick people remembered eating, without a contaminated sample to match it, is a lead and not proof. I have spent thirty years arguing the other side of that in court, and I still think the epidemiology here is strong. But IFPA did something the others did not. When it softened the statement on July 19 — dropping the tougher lines about Michigan and about jobs — it left the original sitting right there on the same page, dated and signed, beneath the new version. You can read both at once. That is what a correction is supposed to look like.

Now the one that troubles me. The California and Arizona Leafy Greens Marketing Agreement, which speaks for the lettuce farms, also posted on July 15. That first version called lettuce a leading suspect, argued that Cyclospora has historically been tied to imported produce rather than domestic greens, and — to its credit — noted plainly that CDC had cut national Cyclospora surveillance in 2025 after federal budget reductions. That last point is mine too; it is the whole reason we cannot count this outbreak. The next day the page was replaced under a different byline with a warmer, more sympathetic message, and both of those lines were gone. The tone improved. But the original now survives only on the Wayback Machine. A statement you have to dig out of an internet archive is not a statement the public can still hold you to.

LGMA’s newest word came in a July 20 webinar with food-safety scientist Jennifer McEntire, formerly of IFPA. Her headline was blunt and, on the science, correct: “testing is not the answer.” Current methods for finding this parasite on a leaf are too unreliable to lean on. She is right that you cannot test your way to prevention. I would only add the other half of that truth: you cannot test your way to innocence either. When a supplier waves a clean sample, remember that a negative result on a parasite this hard to detect proves almost nothing — which is exactly why the people who ate the lettuce, not the lab, are the evidence in an outbreak like this.

FMI, the grocery-industry association, wrote the clearest consumer material of anyone. It confirms the recall, links the federal notices, and states the gap between confirmed and probable cases honestly. I will praise it without hedging — and then note the thing that sits awkwardly beside the praise. FMI has been the most forceful voice in the country for delaying the food traceability rule that would make outbreaks like this traceable in the first place. Both things are true at once, and readers deserve to know both.

The National Grocers Association broke a longer silence with practical guidance for independent stores. It is useful, with one real problem: it tells grocers to reassure customers that there is no broad retail recall. There is one. The recall reached bagged Marketside iceberg and shredded lettuce on Walmart shelves in more than a dozen states, and federal officials are telling shoppers to throw it out. NGA also applauded the thirty-month delay of the traceability rule as too hard on smaller grocers. I understand the burden; I would ask them to weigh it against the count in Michigan.

Give Western Growers credit for the most serious piece of thinking from inside the industry. Joelle Mosso named three gaps — risk communication, national surveillance, and the way the country handles imported risk. I wrote back to say she is right on two of the three. On surveillance and on imports she is closer to the mark than most of the public-health commentary I have read this month. Where we part is her call for quieter, more careful warnings; the cure for a vague warning is a faster, more specific one, and that requires traceability, not restraint.

And then the silences. The National Restaurant Association has said nothing about an outbreak that ran through a fast-food chain, even as reporters asked. The Fresh Produce Association of the Americas, which speaks for importers of exactly this kind of Mexican produce, has said nothing either. The silence is more glaring because Taco Bell — an operator, not a trade group, and the one with the most to lose from talking — pulled the lettuce and said so twice, ahead of the federal advisory. When the restaurant on the corner outruns the associations built to speak for the industry, the associations should notice.

So far this is a story about the groups that speak for the industry. But the company at the center of the outbreak has been speaking for itself, too — and it has done the quiet-edit trick more brazenly than any association here. The credit for catching it belongs to Bloomberg’s Jessica Nix and Kristina Peterson, who on July 21 lined up the dates and called what they found a slow-walk. The recall window ran June 29 to July 16 — weeks after the first illnesses began in mid-May. By the time Taylor Farms’ lettuce came off the shelf, the contaminated product had already been eaten.

Watch the statement itself. Taylor Farms’ first version, on July 17, opened with concern for the sick and — this is the sentence that matters — acknowledged that FDA’s traceback pointed to a specific central-Mexico farm, which it called less than one percent of the U.S. iceberg supply, and said it had pulled all of the region’s iceberg. Over the next forty-eight hours the company rewrote that statement at the same web address, with no version note. The sympathy slid from the first paragraph to the fourth. A grievance against FDA rose to the lead. And the acknowledgment that the traceback pointed at its own farm simply vanished. It is the same edit-in-the-dark I faulted LGMA for above, performed by the company with the most to lose.

That vanished sentence may be the most important one in the whole outbreak, and here is why. Taylor Farms wrote it on July 17 — before any product sample was ever reported positive. It is the company’s own admission, in its own words, that the recall rested on FDA’s traceback and the epidemiology, not on a lab result. Which is why the false positive the company spent the following Sunday turning into a demand for an apology changes nothing. In a Cyclospora outbreak the victims ate the evidence months ago; a clean sample proves nothing, and Taylor Farms had already conceded as much in writing before the sample existed.

And none of it happened in a vacuum. The New York Times reported, and a Taylor Farms spokeswoman confirmed, that on July 16 — the day before the recall — company executives met with White House and FDA officials to complain about what they called shortfalls in the agencies’ outbreak response, challenged the finding that their lettuce was responsible, and worked to distance the company from the illnesses — while conceding they had only been contacted in the days just before the recall, after investigators had been chasing this outbreak for weeks. The Times also reported the company had been staffing up in Washington, hiring a former Trump White House personnel official. Then, on July 20, FDA answered in public: the false positive does not change the overwhelming epidemiological data, and the traceback continues to converge on Taylor Farms locations — plural — in central Mexico, not the single small farm the company had named on July 17 and unnamed by July 19.

Step back, and every one of these statements is circling the same hole. No one — not the growers, not the grocers, not the agencies — can catch a contaminated leaf before it ships, count the people it sickens, or trace it back to the field fast enough to matter. That is not bad luck. Over the last fifteen years this country took apart the three tools built to do exactly those things, one after another, and this outbreak walked straight through the space where they used to be.

Start with the one almost no one remembers. For a decade the U.S. Department of Agriculture ran the Microbiological Data Program — the MDP — which did the single thing none of the systems above can do now: it went out and tested the produce itself. From 2001 to 2012, on a budget of about five million dollars a year, it pulled more than 120,000 samples of high-risk fruits and vegetables off shelves across 42 states, screened them for pathogens, and when it found one it told FDA, CDC and the states right away. In 2010 and 2011 alone its findings drove twenty-three produce recalls, fifteen of them tied to real human illness. It was, in plain terms, the country’s early-warning radar for contaminated produce — the one program that looked at the lettuce instead of waiting for the patients.

Then it was gone. The program was zeroed out in the Obama administration’s 2013 budget, defended by USDA as work that fell outside its marketing agency’s mission, over the objection of Congresswoman Rosa DeLauro. And Food Safety News reported at the time that the produce industry’s own paid lobbyists had pushed to end it — the trade group leading that effort was United Fresh, which in 2022 merged into the International Fresh Produce Association. The same house that helped switch off the radar is the one now, in this outbreak, calling for surveillance to be rebuilt. I do not raise that to score a point. I raise it because IFPA is right that we need it back, and it is better positioned than anyone to help undo what its predecessor helped do. Bring the MDP back, or something like it, and someone is once again testing the produce before it reaches a taco.

The second tool went dark just last year, and it is the reason you keep seeing two different numbers for this outbreak. On July 1, 2025, the CDC cut its foodborne-illness surveillance network, FoodNet, from eight pathogens down to two — it kept Salmonella and E. coli and made Cyclospora, along with CampylobacterListeria and three others, optional to report. The agency’s own explanation was money: the funding had not kept up. That is why Michigan alone now counts more cases than the CDC has laboratory-confirmed in the entire country, and why the states’ tallies and the federal one keep telling two different stories. We are living through an outbreak the national system is no longer built to count. And here let me be just as fair in the other direction: you cannot lay FoodNet at the produce industry’s feet. No lobbyist killed it. It was a budget decision at CDC, made under a different administration than the one that ended the MDP — which is exactly the point. Across fifteen years and both parties, foodborne-disease surveillance has been treated as the easy thing to cut. Fixing FoodNet — restoring the full list of pathogens and the money underneath it — is the fastest way to at least see clearly the outbreak we are already in.

The third tool is the one still salvageable, because it wasn’t killed — only shelved. FSMA Section 204, the Food Traceability Rule, puts leafy greens on a list and requires lot-level records a company must hand over electronically within twenty-four hours. It was supposed to take effect this past January. It now sits with a 2028 date on it, pushed there with the produce and grocery industry’s blessing.

The sharpest proof of what that last rule would buy came from IFPA’s own scientist. Asked by The Packer on July 15 how full traceability would have changed this outbreak, Teplitski reached for the cilantro that investigators had wrongly floated before the Fourth of July. With the rule in force, he said, you could establish in an afternoon whether a given lot of cilantro went into a given salsa, which kitchen received it, when, and where else it traveled — then line that up against the map of who got sick and rule cilantro out fast.

The rule, he said, “would’ve helped to eliminate cilantro as a suspect within hours.”

Read that again, because it is the whole argument in one sentence. Teplitski wants the traceability rule so the industry can clear an innocent product in hours. I want the same rule so investigators can name a guilty one in hours. It is the same twenty-four-hour records requirement doing both jobs — and his industry lobbied to delay it to 2028. On the science of this parasite, IFPA has been the most honest voice in the room. The next honest thing it could do is spend its considerable weight in Washington getting the one rule that would end the guessing put back on the calendar. I would stand with them if they did.

Catch it, count it, trace it. The Microbiological Data Program could have caught this lettuce. FoodNet could have counted the sick. The Traceability Rule could have found the field. We dismantled the first, defunded the second, and delayed the third — and then acted surprised at an outbreak from a source no one can name. Two of those three failures the produce industry had a hand in. The honest response now is not to relitigate the blame but to put all three tools back, and the industry groups in the table above are the ones with the weight in Washington to do it.

Until then, the count in Michigan climbs by the hundreds each morning, the source of most of those cases is still officially unnamed, and the industry’s statements about it are, in a couple of cases, no longer the statements it first wrote. I have tried to keep this record straight and fair, and to hold myself to the same standard I am asking of everyone else: when the facts move, you correct in the open and you leave the original where people can find it.

The Secretary of Health and Human Services said today that this outbreak is “under control.” I would like that to be true. Here is what the states reported while he was saying it.

Michigan added 2,408 new cases in the week ending July 18. The three weeks before that were 71, then 498, then 1,331. That is not a curve bending down. That is a curve that has doubled in each of the last three weeks, and Michigan’s own total went from 6,148 on Monday to 6,571 today, with 23 more out-of-state cases waiting to be referred somewhere else. West Virginia went from 69 cases on July 13 to 195 today, with 15 hospitalized — nearly triple in eight days. CNN put it plainly this afternoon: the epidemiological curve has not yet slowed.

An outbreak is under control when new cases stop appearing. Not when a recall is issued. A recall is an action taken; control is a result observed. The Secretary described the first and called it the second.

There is a second problem with today’s statement. He said the source has been identified, citing extensive forensics. But FDA spent Sunday night withdrawing the only positive lettuce sample it had as a false positive. The traceback still points at Taylor Farms de Mexico, and FDA is right about that. But there is a difference between an epidemiological conclusion and a confirmed source, and the government is now claiming the second while holding the first. That is exactly the kind of overstatement that gets thrown back at investigators later.

He also said the criticism about surveillance cuts is invalid, and that FoodNet reductions were only for redundant surveillance. CDC made Cyclospora reporting optional in 2025. Six of the eight pathogens came off mandatory reporting. Whether you call that redundant depends on whether you ever intended to count this parasite. We are now two and a half months into a season in which nobody can say how many people are sick, and the Secretary’s own department publishes three different numbers.

Those numbers are worth laying out, because they are the heart of it. CDC’s outbreak investigation page says 1,644 people who reported eating at Taco Bell have been reported by five states, with 94 hospitalizations and illness onsets running from May 13 through July 13. CDC’s health advisory separately says 1,645 lab-confirmed domestically acquired cases across 34 states, with 141 hospitalizations. And CDC’s surveillance page says it is aware of more than 5,100 additional cases awaiting analysis, plus another 440 travel-associated cases. Meanwhile FDA’s outbreak table carries the iceberg lettuce cluster at 1,644 and four other open Cyclospora investigations alongside it.

Add up what the fifty states themselves are reporting and you get roughly 10,750. CDC concedes the point in its own words: it is aware that states are likely to report higher counts than its data reflects. The federal number is not wrong. It is just months behind, and it is the number the Secretary used to tell the country this is handled.

One more thing, and it is not a small one. Ohio’s health department reports 1,316 cases statewide as of July 16. The Toledo-Lucas County dashboard, covering only the northwest corner of that state, reports 2,029. A region inside Ohio is reporting more cases than Ohio. Both numbers are real; they come from different reporting systems that count different things on different days. That is the condition of American foodborne disease surveillance in the middle of the largest cyclosporiasis outbreak this country has ever had. Under control is not the phrase I would use.

Below is where all fifty states stand tonight, with the source for every number.

State2026 cases reportedPart of the Taco Bell outbreak?Source
AlabamaNo 2026 count publishedNot reported as part of the outbreakCDC
Alaska5; 3 travel-relatedNo – AK DOH: no link to the outbreakAK DOH / Epoch
Arizona19Cases reported; not in clusterAZ DHS / Epoch
Arkansas26 year-to-dateUnder investigation for outbreak linkAR DOH / Epoch
California41 provisional (Jul 14); CDC lists 97No – CDPH: no local acquisition identifiedCDPH
Colorado150; 4 hospitalized; 8 of 120 domesticNo – CDPHE: not part of the Midwest outbreakCDPHE / Epoch
Connecticut35 (up from 19 in 2025)Links its cases to the national outbreakCT DPH
DelawareNo 2026 count publishedNot reported as part of the outbreakCDC
Florida106No – FL DOH: seasonal disease Florida sees yearlyFL DOH / Epoch
Georgia11-30 domestic since May 1; CDC lists 71No – GA DPH: no Georgia-specific clusterGA DPH / Epoch
HawaiiNo 2026 count publishedNot reported as part of the outbreakCDC
IdahoNo 2026 count publishedNot reported as part of the outbreakCDC
Illinois277 (Jul 16); 23 hospitalized; CDC lists 87No – IDPH: higher than average, no single causeIDPH / TODAY
Indiana327 total; at least 47 tied to the outbreakYES – fifth Taco Bell outbreak state; daily updatesIN DOH / Epoch
Iowa57; about half domesticNo – IA HHS: not connected to national investigationsIA HHS / Epoch
Kansas55 (Jul 15); 37 domesticDomestic cases rising; no Kansas source foundKDHE
Kentucky192 (Jul 15); 108 confirmed; 7 hospitalizedYES – Taco Bell outbreak state; weekly updatesKY DPH / Epoch
Louisiana1-10Not declared part; not in clusterLA DOH / Epoch
MaineNo 2026 count publishedNot reported as part of the outbreakCDC
Maryland69; some travel-relatedNo – no common link identifiedMD DOH / Epoch
Massachusetts18 (normal seasonal amount)No – MA DPH: not affected by the Midwest outbreakMA DPH / Epoch
Michigan6,571 (Jul 21); 102 hospitalized (Jul 16); 23 out-of-state pendingYES – leads the outbreak; 2,408 new cases in the week to Jul 18MDHHS
Minnesota41 since May 1No – MDH: no increase over expectedMDH / Epoch
MississippiNo 2026 count publishedNot reported as part of the outbreakCDC
MissouriNo 2026 count publishedNot reported as part of the outbreakCDC
MontanaNo 2026 count publishedNot reported as part of the outbreakCDC
Nebraska49No – NE DHHS: none related to the wider outbreakNE DHHS / Epoch
NevadaNo 2026 count publishedNot reported as part of the outbreakCDC
New Hampshire1-10Cases reported; not in clusterNH DHHS / Epoch
New Jersey46 (May 1-Jul 11); within typical rangeNo – NJDOH: no clusters or outbreaksNJDOH
New MexicoNo 2026 count publishedNot reported as part of the outbreakCDC
New York517 (May 1-Jul 13) incl. NYC; CDC lists 539No – NYSDOH: not a major deviation from the normNYSDOH / Epoch
North Carolina307 (Jul 14); 13 hospitalizedNo – NCDHHS: does not appear linked to the Taco Bell outbreakNCDHHS
North DakotaNo 2026 count publishedNot reported as part of the outbreakCDC
Ohio1,316 statewide (Jul 16); 96 hospitalized. Northwest Ohio alone reports 2,029 (Jul 20)YES – Taco Bell outbreak state; state updates weeklyODH / Toledo-Lucas
Oklahoma57; 6 hospitalizedPart of the national outbreak; no Oklahoma sourceOSDH / Epoch
OregonNo 2026 count publishedNot reported as part of the outbreakCDC
Pennsylvania28; reporting is voluntaryNo – mostly travel-relatedPA DOH / Epoch
Rhode Island4 since May 1Cases reported; not in clusterRI DOH / Epoch
South CarolinaNo 2026 count publishedNot reported as part of the outbreakCDC
South DakotaNo 2026 count publishedNot reported as part of the outbreakCDC
Tennessee11-30Investigating; not in clusterTN DOH / Epoch
Texas68 (Jul 13); 15 hospitalized; all domesticMeets CDC case definition; no source identifiedTX DSHS
Utah1-10No – UT DHHS: not related to the wider outbreakUT DHHS / Epoch
VermontNo 2026 count publishedNot reported as part of the outbreakCDC
Virginia37 through Jul 4; CDC lists 61No – VDH: no evidence of a Virginia outbreakVDH
Washington27 since May 1; 5 domestic or possibly domesticNo – WA DOH: not associated with other statesWA DOH / Epoch
West Virginia195 (Jul 21); 15 hospitalized – nearly tripled since Jul 13YES – Taco Bell outbreak state; updates Tuesdays and FridaysWV Dept. of Health
Wisconsin61 (May 1-Jul 15); 11 domesticNo – WI DHS: no common food item identifiedWI DHS / Epoch
WyomingNo 2026 count publishedNot reported as part of the outbreakCDC

A word on the counts. Where a state publishes its own figure, I used it, because state health departments are closer to the illnesses and update more often. Where CDC’s own state table differs materially, I noted both — and it cuts in both directions. CDC lists more cases than the state does in New York, Colorado, California, Georgia and Virginia, and far fewer in Illinois. Nobody’s numbers agree with anybody’s.

Update cadence matters too, and it is uneven. Michigan and Indiana post daily on weekdays. West Virginia updates Tuesdays and Fridays. Ohio and Kentucky update weekly. CDC’s national figures have not moved since July 13. So any national total, including mine, is a blend of numbers of different ages. Sixteen states still publish no 2026 count at all.

Roughly 10,750 is a floor, not a ceiling. It mixes domestic and travel-associated illness in the states that do not separate them, it counts only people sick enough to see a doctor who ordered the specific test that finds this parasite, and it omits sixteen states entirely. CDC says the true number is likely higher. On that, the Secretary and I and CDC all agree.

What FDA actually wrote about Taylor Farms de Mexico in 2013, what FDA wrote about Taylor Farms Colorado in 2024, and why both were opened only after people were already sick.

And, although I looked, I could not find other FDA inspection reports – I assume they exist?

Taylor Farms has told the public this week that FDA “has not identified a single positive product test result for Cyclospora.” That is true. It is also the same thing the company and the agency were able to say in 2013, and again in 2024. Two federal documents explain why that sentence has never meant what the company wants it to mean.

Where this Cyclospora Outbreak Stands

As of today, CDC counts 1,644 people infected with Cyclospora who reported eating at Taco Bell across five states — Indiana, Kentucky, Michigan, Ohio and West Virginia. Illness onsets run from May 13 through July 13, 2026, with 94 hospitalizations and no deaths. That is the confirmed cluster, and it is the smallest number in this story. Nationally, CDC reports more than 1,645 laboratory-confirmed domestically acquired cases since May 1 and is aware of over 5,100 additional cases still awaiting the work needed to confirm them, against 249 cases reported nationally by this same point last year. Cyclosporiasis has now been reported in 34 states.

The state figures are far larger. Michigan reported 6,571 cases on July 21, an increase of 423 in a single day, with 102 hospitalizations. Northwest Ohio has reported more than 2,000. Michigan officials have said this is likely the largest outbreak of its kind in United States history, and a state that normally sees roughly fifty cases a year is the epicenter. Michigan also did the exposure work that broke the case: investigators analyzed food histories from 190 of the CDC-confirmed patients and found that 90 percent reported eating iceberg lettuce at Taco Bell.

On July 17, FDA’s traceback investigation identified Taylor Farms de Mexico as the single supplier of the shredded iceberg lettuce served at the implicated restaurants, and the company recalled all iceberg lettuce sourced from central Mexico, product that had gone to 27 states, including Marketside-brand bags sold at Walmart. Then came the detour. On July 18, FDA reported that a sample of Taylor Farms de Mexico shredded iceberg, collected during targeted import surveillance, had tested positive for Cyclospora. On July 19, FDA retracted it, saying that because of the complexity of detecting this parasite, its laboratory experts had re-reviewed the result, concluded the finding did not represent true amplification, and should be treated as a false positive. There are no confirmed positive product samples in this outbreak.

The company moved immediately. Its July 19 statement opens with the line “Today, FDA apologized to us,” and states that FDA has not identified a single positive product test result for Cyclospora. FDA answered publicly the next day: the false-positive sample does not change the basis for the investigation or the overwhelming epidemiological data supporting the recall, and traceback and outbreak data continue to converge on shredded iceberg lettuce from Taylor Farms locations in central Mexico. Health officials said they had offered no apology. FDA’s guidance is unchanged: do not eat the recalled lettuce.

The determination stands, and it stands on what these cases almost always stand on — epidemiology and traceback, not a laboratory hit on the food. That is not a weakness in the case. It is the ordinary condition of a Cyclospora investigation. The incubation period runs a week or more, diagnosis takes weeks longer, and lettuce is perishable. By the time anyone knows to look for the product, the product is gone. The victims ate the evidence in May.

Which is exactly why the two federal documents below are worth reading in full. Both were written after outbreaks in which the pathogen was never recovered from the food, and both show what investigators found when they finally walked into a Taylor Farms facility.

Document One: FDA Environmental Assessment, November 2013

The Cyclospora Outbreak – 631 Sick

In the summer of 2013, cyclosporiasis sickened 631 people across 25 states. Iowa and Nebraska accounted for 239 of them. Epidemiologic and traceback work by the two states, CDC and FDA linked bagged salad mix supplied by Taylor Farms de Mexico, in Doctor Mora, Guanajuato, to Olive Garden and Red Lobster restaurants owned by Darden. A separate 278 cases in Texas were traced to cilantro from Mexico. The cause of 126 illnesses across 22 states was never determined. The implicated salad mix was iceberg lettuce, romaine, green leaf, red cabbage and carrots.

What FDA did

Taylor Farms de Mexico suspended production and shipment to the United States on August 9 and notified FDA on August 12. FDA began work that same day and stayed through August 19, alongside CDC and five Mexican agencies — COFEPRIS, SENASICA, SAGARPA, CESAVEG and the Guanajuato state health authority. The team assessed the processing plant and five ranches: three identified by traceback, plus two more added during the assessment. The plant was not running while they were there.

The timing problem, stated by FDA itself

The last Iowa or Nebraska illness onset was July 2 — more than five weeks before the assessment began. FDA put that sentence in the introduction of its own report.

The findings

No significant source. No significant route of contamination. Employees, restrooms, plumbing, the wastewater treatment plant, harvest crews, field sanitary facilities, irrigation systems and growing fields were each judged “not likely” to be sources — and every one of those conclusions carries the qualifier at the time of the assessment. FDA’s bottom line was that it could not determine how, or at what point in the supply chain, the salad mix became contaminated.

The wash step

The one process point FDA flagged was the washing of the combined salad components in recycled wash water. The firm held free chlorine at a 10 ppm target and used phosphoric acid to keep the pH at or below 7.0. In the same passage, FDA noted that Cyclospora resists halogen-based sanitizers including chlorine, that the infectious dose is estimated at 10 to 100 sporulated oocysts, and that micro-filtration — which can eliminate the parasite from water — is defeated by the turbidity of recycled salad wash water and is therefore not used anywhere in the cut salad industry.

The testing

Roughly 835 product, water and environmental samples were analyzed across FDA, CDC and the company, including more than 269 human fecal samples collected from on-ranch sanitary facilities. All were negative except one: FDA sample 744382, the recycled wash water, came back inconclusive because turbidity inhibited the BAM method. Taylor Farms de Mexico also ran its own parallel assessment covering the processing facility and 30 ranches — 793 samples, all negative.

That distinction matters. “Everything tested negative” is not what the record says. The one sample taken at the exact point FDA identified as the plausible amplification step could not be read at all.

Three details that never made the press

Ranch E. FDA added this ranch to the assessment after reviewing the company’s own irrigation water testing records and finding a fecal coliform positive from drip irrigation tape. The result was 200 MPN/100 mL. It triggered nothing. The firm’s rolling mean-average system did not fire because follow-up samples were negative, and 200 sits just under the company’s own single-sample action level of 235. The crop remained harvestable for salad production.

The prescriptions. FDA tabulated fourteen harvest-crew medical visits inside the outbreak window. Loperamide, an antidiarrheal, was dispensed on June 26, July 3, July 10 and July 24. Trimethoprim-sulfamethoxazole — which FDA notes in the report is effective against Cyclospora — was given on March 6 and twice on August 7, both August doses flagged in the table as near expiration and “chosen for economic reasons.” The company doctor said he had not suspected a parasitic infection. No diagnosis was recorded by the firm for any employee illness.

The carrot ranch. A single ranch in Sonora supplied 100 percent of the carrots in the implicated salad mix. It was never assessed. The harvest season had ended.

The four recommendations

1. Assess the Sonora carrot growing environment before the next carrot harvest.

2. Research whether Cyclospora cayetanensis is a reasonably likely food safety hazard associated with the Guanajuato leafy green growing region — and if it is, have Taylor Farms de Mexico re-evaluate its salad mix processing procedures to control cross-contamination at the washing step.

3. Use the company nurse’s home visits to encourage symptomatic workers to submit stool samples for Cyclosporaanalysis.

4. Fix the ranch handwashing faucets, none of which were hands-free.

Taylor Farms de Mexico resumed production and shipment to the United States on August 25, 2013, after FDA reviewed a sampling plan.

Document Two: FDA Form 483, Taylor Farms Colorado, Inc., issued December 18, 2024

The E. coli Outbreak – 104 Sick

E. coli O157:H7 in slivered onions served on McDonald’s Quarter Pounders. One hundred four confirmed cases across 14 states, 34 hospitalizations, four cases of hemolytic uremic syndrome, and one death in Mesa County, Colorado. Onsets ran from mid-September through October 21, 2024. Taylor Farms recalled the yellow onions on October 22. FDA later stated that the outbreak strain was never found in onion or environmental samples, and that epidemiologic and traceback evidence showed the recalled onions were the likely source. McDonald’s stopped sourcing from the Colorado Springs plant indefinitely and re-supplied roughly 900 restaurants.

The scale of the inspection

Eight days on site: October 28, 29, 30 and 31, and November 4, 5, 7 and 12. Nine FDA investigators signed the form, including a designated National Expert and an Acting Branch Chief. The facility is Taylor Farms Colorado, Inc., 890 N Newport Road, FEI 1783599, and the form was issued to President Christopher M. Hallee. This was not a routine visit.

Observation 1 — the sanitation preventive control was never implemented

The hazard analysis governing slivered onions, dated October 23, 2024, did not identify a preventive control for recontamination by environmental pathogens. The food safety plan that management said covers all processed vegetables at that location — including the onions — carries the product description “Diced Tomatoe.” Slivered onions are exposed to the environment from the peel step through finished packaging, with no lethal treatment anywhere in between.

Production rooms were held at temperatures that would support the growth of Listeria. FDA listed twelve separate non-food-contact locations that tested positive for Listeria spp. between March 20, 2023 and June 14, 2024 — drains, floors, production lines, employee high-traffic areas — plus pooling water near a cutting area that was positive on January 26 and January 30, 2024. The corrective action procedure did not address how recurrence would be prevented. Follow-up testing was not consistently completed; a January 28, 2024 positive produced a follow-up test that was also positive.

And the verification method the plant used to check its own hazard measures the amount of soil on a surface. As FDA put it, that method “is not designed to identify Salmonella and Listeria” — the two organisms the plant’s own food safety plan names as the hazards requiring a sanitation control.

Investigators found biofilm and large amounts of food debris present after the firm’s completed post-operation cleans. On November 5 the firm entered “Pass” at 5:51 a.m. and again at 5:54 a.m. on food contact surfaces that FDA concluded should have been marked “Fail.” A customer complaint from September 23, 2024 documented the consequence: a green-pepper-only finished product arrived containing onions.

Also observed: apron parts inside the handwashing sink, with ties touching the basin and then the hands of employees handling food; employees sanitizing gloved hands after touching insanitary surfaces and returning to ready-to-eat food without ever removing gloves and washing, which management described as common practice; a hose spraying near exposed spin baskets; food particles in the crevices of equipment welds; trapped water and food debris in pitted food contact surfaces; white cutting boards used for ready-to-eat lettuce and celery, severely discolored with deep cracks and crevices; and a torn carrot-line belt with a piece that would come into direct contact with ready-to-eat food before packaging.

The line that ran in every news account: production employees handling ready-to-eat produce and food contact surfaces were not observed using any of the handwashing sinks in the facility.

Observation 2 — the records did not exist

The pre-operation cleanliness check documents for September 24 and October 5, 2024 were missing. The PCQI-trained individual signed off on all preventive control monitoring records in the production packets for both days and did not note the missing records. No corrective action report was generated.

Observation 3 — operations not run under conditions minimizing contamination

Knives stored fully submerged in sanitizing solution were removed and used immediately to chop ready-to-eat produce, without the air-drying step the chemical manufacturer’s own label requires. During production on November 4, an item removed from sanitizing solution measured over 200 ppm against a 50 to 200 ppm range for food contact surfaces, was not air dried, and could transfer that solution to ready-to-eat lettuce. Slicers were sprayed and put back in use within minutes.

And production employees mix their own chemical recipe. It is used as a “reclean step,” scrubbed onto food contact surfaces when checks fail, before the surface is retested. The employee performing the reclean on November 5 said he mixes it routinely. The firm could not locate the source of the recipe, and management could not provide a manufacturer label or any chemical representative’s statement that the mixture was designed for that use.

The classification

FDA classified the inspection VAI — voluntary action indicated — meaning no administrative or regulatory action followed. Taylor Farms has cited that classification publicly as vindication, alongside the observation that no illnesses were linked to the specific conditions FDA wrote down. Both statements are accurate. Neither addresses what the nine investigators saw.

What the Two Documents Show Together

Both were opened because people were already sick. Neither is a routine inspection. In 2013, FDA arrived five weeks after the last illness onset, at a plant that had voluntarily stopped running. In 2024, FDA arrived a week after the recall. Nine investigators and eight days in Colorado Springs; a five-agency binational team and eight days in Guanajuato. That level of federal attention is what a body count buys.

Neither found the pathogen. No Cyclospora in 2013. No outbreak-strain E. coli in 2024. Both times the case rested on epidemiology and traceback. Both times the company said so publicly. That is the identical posture Taylor Farms holds today. It was not an exoneration in 2013, it was not one in 2024, and it is not one now.

What each document did find was a control the company had written down and had not operated. In 2013: a wash step FDA identified as the plausible amplification point, running chlorine against an organism FDA said in the same paragraph resists chlorine, and an irrigation trigger set at 235 that a 200 sailed straight under. In 2024: a hazard analysis that omitted the hazard, a food safety plan labeled for the wrong vegetable, twenty months of Listeria positives with corrective actions that did not correct, a verification method incapable of detecting the organisms it was meant to verify, and pre-operation checks signed “Pass” on visibly dirty equipment. Different pathogen, different hemisphere, different regulation — the same failure mode. The paper system exists. The physical system does not follow it.

And the 2013 recommendation is the one that matters this month

FDA told Taylor Farms de Mexico to determine whether Cyclospora is a reasonably likely food safety hazard associated with the Guanajuato leafy green growing region, and if it is, to re-evaluate the wash step. That was November 2013.

It is now July 2026. Same subsidiary. Same Guanajuato region. Same parasite. Iceberg lettuce. And by the state health departments’ own counts, more than ten thousand people.

There is one question someone should answer. Was that research ever done, and what did it conclude? If it was done and it found that Cyclospora is a reasonably likely hazard in central Mexico, then the wash step should have been redesigned in 2014. If it was never done, the company left FDA’s central recommendation sitting on the table for thirteen years, and this outbreak is the second invoice for it.

Sources

FDA, “Environmental Assessment: 2013 Cyclosporiasis outbreak in Iowa and Nebraska — Findings and Recommendations,” November 2013

FDA Form 483, Taylor Farms Colorado, Inc., inspection of October 28 – November 12, 2024, issued December 18, 2024

Eighty-nine people in fifteen states got sick in November 2024. Thirty-six of them went to the hospital. Seven developed hemolytic uremic syndrome, which is the polite clinical way of saying that a child’s kidneys shut down. One person died. On January 15, 2025, the CDC and the FDA closed the file, recorded the vehicle as romaine lettuce supplied by a “common supplier,” and said nothing else. No processor. No grower. No point of service. The public notice the agencies had issued for every comparable romaine outbreak going back to 2010 was simply never issued for this one.

I wrote about that silence at the time and called the post “CDC and FDA — Romaine Silent.” I have now spent a year and a half on the other side of it, and the outbreak has become the clearest illustration I have of why transparency is not a courtesy the government extends to consumers when it is convenient. It is the thing that makes everything else — choice, accountability, deterrence — possible.

Start with what secrecy actually purchased. Because my firm represented families in several states whose infections were whole genome sequencing matches to one another, our staff epidemiologist did what the agencies would not publish: she found the common denominator. It was Taylor Farms romaine. In April 2025 we filed suit, and the company answered with a flat denial — its product was not the source, and any reporting connecting it to those illnesses was dangerous and irresponsible. That denial was only available to them because the FDA’s own traceback summary had been released with nearly every name that mattered blacked out under the (b)(4) exemption. The processor was a gray box. The grower was a gray box. The ranch, the distribution centers, the brokers, the lot codes — all gray boxes. A company cannot be contradicted by a document nobody is allowed to read.

I stayed on the agency, and in stages it took the boxes off. What had been hidden was this: Taylor Farms of California in Salinas was the sole processor, and the FDA’s summary says it supplied all the romaine available at every point of sale during the timeframe of interest. Anthony Costa & Sons of Soledad was the single grower. The records also named Andre’s Banquets and Catering of St. Louis as the caterer at the center of the largest cluster — three events over November 6 to 8, 2024, including a marching band banquet and a Veterans Day luncheon at a high school, with twenty-two illnesses from that one point of service. 

None of that is a trade secret. A harvest date is not a proprietary formula. The identity of the company that processed lettuce that killed somebody is not confidential commercial information. It is the basic factual record of a public health disaster, and the only thing the redactions accomplished was to hand the responsible companies a period of deniability they had not earned.

If this were the first time, I would call it a lapse. It is not the first time, and I can trace the same habit across my entire career because I have been on the receiving end of it since the beginning. In the 1993 MMWR that described the hamburger outbreak that made me a food safety lawyer, Jack in the Box is called “Restaurant A.” In medical journals it still is. In 2010, two concurrent Salmonella outbreaks sickened 155 people in twenty-one states, and in 2011 a Salmonella Enteritidis outbreak sickened sixty-eight more across ten states — both attributed by the CDC to a “Mexican-style fast food restaurant chain, Restaurant Chain A.” I worked the elimination publicly, matching chain footprints against the ten outbreak states, and reporters at Food Safety News called every candidate. The name finally came out in February 2012, not from the CDC, but from a document the Oklahoma State Department of Health released after the agency let a deadline pass without telling the state what to do. It was Taco Bell. 

In 2025 the mystery company was “a common supplier.” Last week, in the Cyclospora outbreak still going on, the FDA’s own recall notice listed the brands as “CV, JB, Mark and more” — internal customer codes, not brands, which no shopper has ever seen on a bag of lettuce. Restaurant A, Restaurant Chain A, a common supplier, CV and JB. Four decades of the same redaction in different clothes.

What is striking about the Taco Bell episode is that the agency said out loud why it was doing it. The policy, as described at the time, weighed public health against the business concerns of firms that could be hurt by bad publicity, and officials explained that the outbreak was over and that they wanted to keep relations with the chain cordial while it cooperated. I wrote then that this has it exactly backwards, and I have not moved an inch since. If a company will help find the source of an outbreak only in exchange for permanent anonymity, that tells you what its commitment to safe food is actually worth. Cooperation purchased with secrecy is not cooperation. And the government does not exist to protect a company’s bottom line from the consequences of selling food that hurts people. The reputational hit is not a bug in transparency. It is the point of it.

There is a further cost, and it is the one consumers never see happening. Naming a company is not only about stopping today’s illnesses — in most outbreaks the food is long eaten before anyone knows the source. It is about building a track record, so that a school district, a distributor, a restaurant group, or a mother in the produce aisle can see which firms keep turning up in the same sad story. That ledger only exists if somebody writes names in it. Taylor Farms’s entry would read: the 2013 Cyclospora outbreak traced to salad mix from its Mexico operation, the 2015 celery-and-onion mix tied to E. coli in Costco chicken salad, the 2024 slivered onions behind the McDonald’s Quarter Pounder outbreak that sickened more than a hundred people and killed one, this romaine outbreak, and now the Cyclospora outbreak of this summer. Four of those five entries exist because an agency, a court, or a reporter published a name. The romaine entry exists because this lawyer pried it loose eighteen months after the funeral.

I have heard the rest of the arguments too, and I have answered them one by one: that bad publicity is unfair economic harm, that the agencies cannot risk a tomatoes-then-peppers mistake, that surveillance is too underfunded to finish the job. That last one is not an argument at all. It is a confession, and the answer to it is to fund the work rather than redact our way out of admitting it is not getting done. As for the sky falling, we already ran the experiment: USDA has named contaminated-meat manufacturers for twenty years and the retailers who sold the product since 2008, and the beef industry’s trade secrets are still intact. I asked back in 2012 whether the 1993 outbreak happens at all if the 1982 one had carried McDonald’s name instead of a letter of the alphabet. I still do not know. Neither does anyone else, which is rather the problem.

Here is the part that has stayed with me longest. When the government declines to write the record, the regulated company writes it instead. I watched that happen again this month. In the middle of the Cyclosporaoutbreak now sickening more than ten thousand Americans, Taylor Farms’s public statement was rewritten on the same web address inside of about forty-eight hours — no version history, no correction note. Concern for the sick moved from the first paragraph to the fourth. The company’s grievance against the FDA moved to the lead. And the sentence acknowledging that the agency’s traceback pointed at a specific farm simply disappeared. That is what a record looks like when its author has an interest in the outcome. It is exactly the record consumers are left with whenever the agency holding the traceback data decides the names belong behind gray boxes.

I would put the principle as plainly as I can, and it has not changed since I was a young lawyer reading about Restaurant A. When people are hospitalized and someone dies, the public’s interest in knowing who grew and processed the food is at its highest and the commercial interest in anonymity is at its lowest. Redaction practice in cases like this one inverts that balance completely, treating the company names as the secret most in need of protecting when they are the single most important thing the public is entitled to know. In every one of these fights the name came out eventually — through a reporter, a state records officer, a FOIA request, or a lawsuit. Never once through the agency that had it first. The families at that Veterans Day luncheon should have been able to read it in a government notice in January 2025, in plain text, with no gray boxes at all.

There is something to do about it, and it is sitting at the FDA right now. In February, Stop Foodborne Illness filed a citizen petition asking the agency to stop treating a company’s name as confidential commercial information and, failing that, to disclose it anyway under its own statutory duty to keep food safe. The petition is right, and I said so at the time. Its argument is straightforward: the Trade Secrets Act protects sales figures and proprietary processes, not the factual identity of a firm that sells food to the public, and the D.C. Circuit has held that a company name is not commercial information in and of itself. The agency can grant it tomorrow with a memorandum — no rulemaking, no years of waiting. I would ask for one thing more. The petition speaks of the consumer-facing company, and in the 2024 E. coli outbreak, there was no such thing: the lettuce moved from a grower to a processor to a distributor to a caterer and onto a banquet plate with no brand on it anywhere. Disclosure has to reach the processor and the grower too or produce outbreaks will keep ending in gray boxes for the simple reason that nobody’s logo was on the bag. The petition’s own lead example is the outbreak in this post, and the child it describes is my client — Colton George, nine years old, eighteen days in the hospital, nine days of continuous dialysis and five more of intermittent, five transfusions, still seeing a nephrologist. His father spent months trying to learn the name of the company that sold the lettuce that did that to his son. He should not have had to.

On Sunday I graded every trade association in this outbreak on what it said and on how it handled being overtaken by events. I need to start by grading myself, because a paragraph of mine came apart within hours of publication. I wrote that there was a positive lot and that it was detained, and that we had gone from first naming a supplier to laboratory confirmation in seventy-two hours. That is not true. FDA has since concluded that the July 18 result on Taylor Farms de Mexico shredded iceberg does not represent true amplification and should be treated as a false positive. There has never been a confirmed positive product sample in this outbreak. I wrote about the retraction the same night, but I did not go back and fix the sentence, and that is on me.

It matters most because of who I used it against. I said Max Teplitski of the International Fresh Produce Association had claimed no contaminated product had been identified and that his claim was overtaken within two days. It was not overtaken. It is true today. He is entitled to hear me say so in the same place I said the opposite.

What has not changed is everything that was actually holding the case up. Michigan analyzed food-exposure details from 190 people who ate at Taco Bell and ninety percent of them ate iceberg lettuce. Traceback converged on a single supplier. FDA said on Sunday that the corrected laboratory result does not change the basis for the investigation or the overwhelming epidemiological data supporting the voluntary recall, and it went further on Monday, calling the epidemiology and traceback evidence very strong and saying that traceback and outbreak data continue to converge on shredded iceberg from Taylor Farms locations in central Mexico. An FDA official explained why the lab work is so thin and gave my own argument back to me better than I make it: with the time this takes and the epidemiology that has to happen first, the product may already have been eaten or thrown away, which turns testing into a chasing game. The word FDA is still using is implicated. The recall stands, and on Monday Taylor Farms said it will stop sourcing central Mexican iceberg for the rest of the growing season. As for the apology the company announced, an FDA official told Newsweek there was no official apology — the agency notified the company of the corrected result and explained how such a result can happen. However, my sentence about the positive sample was still wrong.

And Teplitski was half right about something else, which I should say now rather than after somebody makes me. His July 15 statement argued that patient recall explained at most about half the cases. FDA said Monday that of more than two thousand people interviewed — 2,025 of them in Michigan — many did not report eating lettuce at a chain restaurant, though lettuce showed up on the questionnaires again and again whether or not fast food did. He was right that the Taco Bell interviews do not explain everyone. But look at where that leads. It does not shrink this outbreak, it enlarges it. It means the five-state Taco Bell cluster is a subset of something bigger, that lettuce is showing up in the food histories of people who never went near a Taco Bell, and that the honest count is now above eight thousand across those five states with Michigan alone past six thousand one hundred. 

Now to the reason I am writing again. On Sunday evening at 8:15 p.m. Eastern, IFPA updated its statement. Same web address. But the new text sits above a horizontal rule and the entire July 15 original sits below it, each one separately dated and separately attributed to Teplitski. Nothing was deleted. Nothing was quietly rewritten. A reader arriving today can see exactly what the association said before, what it says now, and to the minute when it changed its mind.

Hold that against the rest of the week. LGMA took down the truest paragraph any trade group wrote about this outbreak and left no trace at the same URL, and as of this morning its page still says nothing about the retraction, or about anything else since July 16. Taylor Farms overwrote its own statement, moving sympathy for the sick from the first paragraph to the fourth and dropping its acknowledgment that FDA’s traceback pointed at a specific farm. FDA, by its own account, removed the sample information from its July 18 update rather than striking it through. Three parties edited the record. One party corrected it. The one that corrected it is the produce association whose founding board chair was the CEO of Taylor Farms. Credit where it is owed.

Here is what I missed the first time, buried in the last paragraph of the original that IFPA had the nerve to leave standing. IFPA writes that it has long been a champion of end-to-end traceability, that IFPA and its members are on the record against continued delays with the implementation of the Traceability Rule, and that it has offered technological solutions that would bring the entire supply chain into compliance. On Sunday I wrote that I could find no evidence IFPA lobbied for the delay. That was an understatement. The largest produce trade association in the country is on the record against the delay, in writing, twice, during the outbreak, while the rule it wants is sitting on a shelf.

So let me take them at their word.Today is July 20, 2026. Congress set July 20, 2028 as the date before which FDA may not enforce the Food Traceability Rule. Two years, to the day. FSMA 204 requires lot-level records producible in twenty-four hours, and leafy greens are on the list, and compliance was supposed to begin this past January. Instead, FDA published a recall notice in the middle of the largest Cyclospora outbreak in American history with no lot codes and customers identified only as CV, JB, MARK, MKTSD, PK, SUB, SY and TF. IFPA’s own consumer FAQ explains why that is intolerable better than I can: one bag of salad can combine lettuce from several growers in different states or countries, washed and packed at a single facility, and once commingled there is no way to tell whose product is in the bag.

IFPA has a government relations shop, a lobbying budget north of a million dollars a year, and a political action committee. I have a blog that no one reads. IFPA can move that date and I cannot. Ask Congress to repeal the non-enforcement rider and put the January 2026 compliance date back where it was, and say so with the same specificity you used when you told Michigan its epidemiology was not robust enough.

One association that was silent on Sunday is not silent now. The National Grocers Association has published guidance for independent grocers, and it is current through the retraction, plainly written, and useful — it tells retailers what the parasite is, what FDA has and has not confirmed, and to stay in contact with their suppliers. That is more than most produced this month and I am glad to see it.

But there is a sentence in it that has to be fixed today. NGA tells its members to reassure customers that there is currently no broad retail grocery recall associated with this investigation. That is not right. The Taylor Farms recall includesMarketside Iceberg Salad and Shredded Lettuce sold at Walmart across fifteen states with best-if-used-by dates running into August, and CDC is telling retailers and consumers to throw recalled lettuce out or take it back to the store. An independent grocer reading NGA’s page could reasonably conclude there is nothing on their shelf to check. There is. And I would note, without making more of it than it deserves, that NGA is one of the organizations that applauded the thirty-month delay of the traceability rule, arguing it fell hardest on smaller grocers. Smaller grocers are exactly the members who cannot afford to guess whether a recalled bag is in the cooler. Correct the sentence and then ask yourselves whether the rule you opposed is the one that would have answered the question for them.

And now the part I want people to watch for, because it started within a day. A radio station in Michigan — in the state with six thousand sick people — reported the retraction as good news: a routine supply-chain surveillance program, advanced sequencing confirming no active parasite, proof of the rigorous multi-tiered protocols that catch threats before they reach a plate, and relief for regional growers. Nearly every clause of that is wrong. The sample was not routine; it was taken because of this outbreak. Nothing was confirmed clean; a test was found unreliable and withdrawn, which is not the same thing. And no protocol caught anything before it reached a plate, because more than eight thousand people had already eaten. That is the story this becomes if nobody says otherwise, and by August it will be the version people remember.

The scorecard from Sunday needs a correction, a concession and an addition. The correction is mine: there is no positive product sample and there never was. The concession is that Teplitski was right about that and half right about the interviews, and the half he was right about should frighten all of us, because it means we cannot account for where the rest of this outbreak came from. The addition is NGA, which showed up late and got one sentence badly wrong, and IFPA, which published a new version and left the old one standing — more than the grower group, the supplier, or the government managed. There is now an offer on the table from a trade association that says it wants the same traceability rule I want. I am taking them up on it. 

Want to put me out of business? Move the date.