
Today I fly to New Orleans for IAFP 2026, the annual meeting of the International Association for Food Protection, July 26 through 29 at the Ernest N. Morial Convention Center. It is the largest food safety conference in the world — thousands of microbiologists, regulators, quality assurance directors and academics from more than sixty countries. I am going with one message, and it is about Cyclospora.
Start with the numbers. CDC’s surveillance page, now updated weekly, counted 4,173 laboratory-confirmed domestically acquired cases as of July 21, across 41 states, with 308 hospitalizations. CDC is aware of more than 7,400 additional cases that are not yet laboratory confirmed, most of them from Michigan and Ohio, which puts the national figure above 11,500. The median illness onset is June 26. CDC assumes a six-week reporting lag between onset and reporting, so every one of those numbers is going to grow.
Now the comparison. Over the comparable window last year — May 1 through mid-July — CDC recorded 249 domestically acquired cases. For all of 2025 it had 1,180, with 105 hospitalizations. For all of 2021 it had 1,024. Counting every reported case, including travel-associated illness, CDC’s full-year totals were 2,707 in 2022, 4,200 in 2023, 3,719 in 2024 and 3,955 in 2025. This year’s laboratory-confirmed total, domestic plus travel, was already about 4,940 on July 21. We passed a normal full year in early July with the season still running. Michigan alone has reported 8,176 cases and 160 hospitalizations. Michigan normally sees about fifty a year.
The nine-state outbreak that CDC and FDA have named — the Taco Bell cluster traced to Taylor Farms de Mexico shredded iceberg — accounts for 1,947 of those illnesses and 98 hospitalizations. Add up what the fifty states are reporting on their own dashboards tonight and the floor is somewhere near 14,800. The named recall does not describe the outbreak.
There will be a great deal of good science presented in New Orleans this week on interventions, wash-water chemistry, sanitizer efficacy and process validation. Here is what I have found the published science says about Cyclospora.
Washing does not do it. Ortega and Sanchez wrote in Clinical Microbiology Reviews that washing and sanitizing may reduce but would not be expected to eliminate the risk, and that these practices have been demonstrated not to completely remove oocysts from contaminated produce. The best consumer-level data is a 2021 study in Foods that contaminated raspberries and blueberries with three parasites and washed them three ways. A minute under cold running water removed at least eighty percent of the other two parasites. For Cyclospora on raspberries it removed thirty-nine percent. A vinegar soak or a salad spinner brought that to roughly eighty-five percent. Nothing removed all of it. These oocysts are stickier than Cryptosporidium and Giardia.
Chlorine does not do it, and that is not my opinion. It is FDA’s, in a fact sheet the agency wrote for farmers: chlorine and other common anti-microbial chemical treatments are not effective against C. cayetanensis. The field evidence is thirty years old. In Pokhara, Nepal, an outbreak among British soldiers was traced to drinking water that was chlorinated and filtered and carried a normal residual, and the parasite came through anyway (Rabold, Lancet, 1994). Gaseous chlorine dioxide at 4.1 milligrams per liter for twenty minutes produced no reduction in sporulation at all.
Municipal wastewater treatment is no guarantee. FDA’s own language is that treatment may render the parasite inactive, that conflicting evidence suggests it may remain viable after treatment, and that little conclusive data exists either way. What we do have is this. Cyclospora was detected in wastewater in 1998. Charles Gerba’s group sampled two Arizona treatment plants monthly for a year and concluded that conventional treatment’s ability to remove oocysts is limited. A two-year study in southeastern Georgia found the parasite confirmed by sequencing in nine percent of municipal wastewater sludge samples. Conventional treatment was never designed against this organism and has never been validated against it. That is the accurate sentence, and it is bad enough.
There is no validated kill step for Cyclospora on ready-to-eat produce. The parasite cannot be grown in culture. Heat works — seventy degrees Celsius for fifteen minutes prevents sporulation — and heat also destroys lettuce and raspberries. Every control this industry has built for leafy greens points at bacteria and ends in a chemical intervention. This parasite swims through it. Cyclospora has one reservoir and it is the human gut. When it turns up on lettuce, human feces reached that lettuce or the water that grew it. Nothing that happens after harvest changes that.
A retired FDA food safety director said the quiet part out loud this week. Mark Moorman, until recently the director of FDA’s Office of Food Safety, told CNN that investigators have never definitively identified the cause of a Cyclospora outbreak. Not one, in thirty years. Asked whether anyone is obliged to look, he was blunt: no law or rule requires a farm to test its irrigation water or its produce for this parasite. It is voluntary, and he said FDA does not have that lever. He suggested the big buyers could pull it — he named Kroger, Food Lion and Costco — and that Congress could write the requirement and fund the research. In the same piece Jennifer McEntire, the microbiologist, put the mechanism plainly. “Water is number one,” she said, and the open question is how human waste gets into it. Her candidates are the ones you would expect. Waste emptied from portable toilets. A septic tank that leaked. A sewer that overflowed after heavy rain.
One disclosure before the next paragraph. My firm represents people sickened in this outbreak, and we have filed cases naming Taylor Farms entities as defendants. The record below is public either way. You should still know where I sit.
And the 2013 investigation found something worth sitting with. Goodman reports a detail from FDA’s investigation of the 2013 Cyclospora outbreak traced to salad mix from Taylor Farms de Mexico: when investigators pulled the medical records of harvesting workers, they found antidiarrheal medications and the combination antibiotic used to treat cyclosporiasis. No diagnoses were recorded in the records FDA inspected, and those drugs are prescribed for other things, so it proves nothing on its own. But the plant is at Doctor Mora, in Guanajuato — the same facility at the center of this summer’s outbreak. And roughly eight hundred feet from that processing building sits Balneario Las Fajanas, a public thermal-water bathing complex with pools, slides, showers and changing rooms, open every day of the year and listed by the state of Guanajuato’s own tourism office. Google Earth imagery shows it built and operating in March 2010, more than three years before FDA and COFEPRIS conducted their environmental assessment at the plant. That published assessment covers the processing facility and five ranches. Its second recommendation told the firm to determine whether Cyclospora is a reasonably likely hazard in that growing region and, if so, to re-evaluate the wash step. Thirteen years later, no one has produced a document showing that determination was ever made — and the whole of this post is the reason the wash step was never going to be the answer.
None of this is news to the government, or to the industry. In 2021 FDA released a Cyclospora Prevention, Response and Research Action Plan, written by a task force the agency created in 2019. In 2023 the National Advisory Committee on Microbiological Criteria for Foods delivered FDA a full report on Cyclospora cayetanensis in produce, with sections on preventive measures, surrogates, the maintenance and conveyance of wastewater, and prevention in food. That report states that the oocysts are resistant to many of the common chemical treatments used against bacterial pathogens in the produce production environment and in agricultural inputs, agricultural water among them. Its subcommittee was co-chaired by Peggy Cook and by Max Teplitski, now the chief science officer of the International Fresh Produce Association. None of the science in this post is contested. It has been sitting in a federal advisory committee report for three years.
Which is why the fix is upstream, and it is not mysterious. Treat the water. FDA says so in the same fact sheet: in regions where cyclosporiasis is endemic, microfiltration, ozone or ultraviolet treatment may be necessary to decrease the parasite in irrigation water. Read the footnote listing which regions those are and you find a roster running from Bangladesh to Zimbabwe with Puerto Rico sitting in the middle of it. The data behind the interventions is real, with one caveat that matters: because the parasite cannot be propagated in a laboratory, most of this work uses a poultry coccidian, Eimeria acervulina, as a surrogate. Ozonated water acidified with citric acid inactivated ninety-three percent of sporulation in that surrogate. Ultraviolet light at 222, 254 and 282 nanometers each cut sporulation and produced close to a three-log reduction in its infectivity. Zero-valent iron sand filtration — tested on actual C. cayetanensis oocysts rather than a stand-in — retained ninety-seven percent of them.
Water treatment is already mandatory. It is just aimed at the wrong organism. The California and Arizona Leafy Greens Marketing Agreements, which cover better than ninety percent of the leafy greens grown in this country, require growers who use surface water for overhead irrigation to treat that water in the twenty-one days before harvest. Then read what the requirement asks for. An EPA-registered antimicrobial, validated and verified, with success measured by generic E. coli. That is chlorine-family chemistry, selected for bacteria and scored by a bacterial indicator — the exact chemistry FDA says does not work on this parasite. The mandate exists and it points at the wrong organism. Microfiltration, ozone and ultraviolet are required of no one. And the field at the center of this outbreak is in Guanajuato, which no LGMA metric reaches at all.
Test for the right thing. FDA states plainly that testing for generic E. coli and fecal coliforms will not identify C. cayetanensis. Human-specific markers will. That same Georgia study found the human fecal marker HF183 in thirty-three percent of irrigation pond samples. If your irrigation water carries a human sewage signal, you have a Cyclospora exposure whether or not anyone ever finds an oocyst. The Center for Produce Safety has spent more than $1.6 million since 2014 establishing that this parasite is endemic in the United States and recoverable from wastewater and irrigation water, and it published a Cyclospora resource page this week collecting the literature on agricultural water monitoring and mitigation. The industry funded the finding. It needs to act on it.
Write the parasite into the rule that already exists. The pre-harvest agricultural water rule became final on May 6, 2024 and requires covered farms to conduct an annual systems-based assessment of their water — the system, the practices, the crop, the environment, and adjacent land uses including sewage. The only numeric microbial criterion in Subpart E is generic E. coli, the same indicator FDA says will not identify this parasite. For leafy greens and berries the rule should name Cyclospora outright, and the Foreign Supplier Verification Program should require importers to document treatment that works on protozoa rather than chlorination that does not.
Fix field sanitation. OSHA’s standard has required agricultural employers to provide one toilet and one handwashing station for every twenty hand laborers, within a quarter mile, since 1987. Operations with fewer than eleven workers are exempt outright. Inspectors are thin on the ground. Workers paid by the piece and worried about their immigration status do not file complaints. For an organism whose only reservoir is a human being, that exemption is the hazard.
And count it, trace it and test for it. Cyclospora came out of FoodNet last July. The Food Traceability Rule that would have put lot-level records in FDA’s hands within twenty-four hours was supposed to be in force this January and now cannot be enforced before July 2028. The methods to watch for this parasite in wastewater have been published for more than a decade. CDC built a National Wastewater Surveillance Systemthat takes data from about fifteen hundred sites and covers roughly half the country. It reports SARS-CoV-2, influenza A, RSV, mpox and measles. Cyclospora is not among its targets, and it is not on the academic WastewaterSCAN panel either. Meanwhile a diagnostics company watching its own clinical panels reported national positivity jumping from one or two percent to ten or twelve this spring. Frank Yiannas, who ran FDA’s foods program under two administrations and is a past president of this association, told POLITICO this week that the federal response is approaching a catastrophic level of mismanagement and should get an independent review. He has been proposing an NTSB-style board for foodborne outbreaks since last November. Restore the Microbiological Data Program, which for eleven years pulled high-risk produce off the shelf and tested it, and which the industry lobbied to death in 2012.
A tip of the pen. The Moorman and McEntire interviews and that 2013 record are Brenda Goodman’s reporting for CNN. She has been on this story for weeks. It was also her July 20 piece that carried Frank Yiannas on the withdrawn laboratory result — he called it unfortunate and consequential, warned that consumers would wrongly read a false positive as proof the recall was unnecessary, credited FDA for disclosing the error promptly, and then said the thing that matters: “transparency alone is not enough.” The agency still owes the public a root cause for the laboratory failure and the corrective actions that follow from it. Goodman went and asked the people who actually ran these investigations the one question the trade press has spent a month stepping around — how does human waste get into the water in the first place — and got them to answer on the record. It is the piece I wish had run three weeks ago.
See you in the “Big Easy.” I will be in New Orleans Sunday through Wednesday. If the honest sentence is that we cannot make contaminated lettuce safe, then the whole of the answer is keeping it from being contaminated — and what we require today is aimed at a different organism.






















