Joelle Mosso of Western Growers has written that this summer’s Cyclospora response exposed three major gaps in our public health system — risk communication, national surveillance, and FDA’s handling of imported risk. I have spent twenty years suing the produce industry, and I am going to say something that will surprise people on both sides: she is largely right. On surveillance and imports she is closer than most of the public health commentary I have read this month. However, on risk communication she has identified a real problem but reached for the wrong remedy. The remedy she needs is sitting on a shelf with a 2028 date on it.

Take her surveillance point first, because it is the most important thing in her piece. Mosso argues that restoring what existed before July 2025 is not enough, and that we need a network capable of showing where infectious oocysts actually are — which waterways, which wastewater systems, which environmental conditions and regions create elevated risk. That is exactly right, and more ambitious than anything anyone in government is currently proposing. Putting Cyclosporaback on FoodNet’s mandatory reporting list, after CDC cut the required pathogen list from eight to two, is the floor. Environmental monitoring of surface water and wastewater is the ceiling. We built wastewater surveillance networks for a virus in eighteen months during a pandemic. We can do it for a parasite that has been sickening thousands of Americans every summer for years.

She is right on imports too and this outbreak proves the point. When contamination enters through a foreign supplier and the public message is essentially “be careful with fresh produce,” the foreign supplier is not the one who pays. The grower in Salinas who did everything correctly pays. FDA’s foreign supplier verification program has been a paper exercise for a decade. The lettuce came from central Mexico. Somebody in the United States bought it, and whatever verification obligations attached to that purchase stopped none of this.

Now her third point, where I part company — not with the diagnosis, but with the cure. Mosso objects to vague warnings that cast suspicion across an entire food category, and she is completely right that they are destructive. They frighten people away from vegetables they ought to be eating, they punish growers who did nothing wrong, and they leave sick people no better informed about what actually hurt them. But the answer to a vague warning is not a quieter warning. It is a faster and more specific one. And specificity is not a communications skill. It is a records problem.

Watch how this outbreak actually resolved. Illnesses began May 13. FDA and CDC issued broad Cyclospora advisories with no source, which is precisely the category-wide suspicion Mosso is complaining about. Then the Washington Post reported on July 16 that the supplier was Taylor Farms, and the next day FDA and CDC confirmed the traceback had converged on Taylor Farms de Mexico. The instant that name appeared, the vague-category problem evaporated. Every other iceberg grower in America was cleared by that one piece of specific information. Two months of undifferentiated suspicion ended the moment somebody could say whose lettuce it was.

So why did it take two months? Because tracing a head of lettuce from a taco back to a field is still, in 2026, largely a manual exercise — investigators interviewing thousands of sick people, then chasing paper invoices backward through distributors and processors one company at a time. There is a fix for that, and it is already federal law. FSMA Section 204, the Food Traceability Rule, was finalized in November 2022. It puts leafy greens on the Food Traceability List, requires lot-level records at every critical tracking event, and — this is the part that matters here — requires a company to hand FDA those records in a standardized electronic format within twenty-four hours of a request. Twenty-four hours, not eight weeks.

It was supposed to take effect January 20, 2026. In August 2025, FDA proposed pushing the compliance date out thirty months to July 20, 2028, citing how much time industry needed. In November 2025 Congress made it binding, directing FDA not to enforce the rule before that date. The single tool most likely to have compressed this outbreak’s two-month mystery into a two-day answer was scheduled to be operating six months before the first person got sick, and instead it will not be enforced until the summer of 2028.

That is the whole argument, and I would like Western Growers to make it with me. If the industry genuinely wants public communication that names a supplier instead of smearing a commodity, the industry has to want the traceability that makes naming possible. You cannot ask for precision and simultaneously ask for another three years before the records requirement bites. Notably, Walmart did not wait — it began requiring standardized traceability data from its suppliers in August 2025, ahead of any federal deadline, because a retailer with real exposure understands that lot-level records are self-defense. The growers who invested early are the ones who get exonerated fastest when the next outbreak hits. The ones who lobbied for delay will spend the next outbreak in the same undifferentiated cloud Mosso is objecting to now.

Here is a process I can get behind. If Western Growers wants to call for congressional hearings into how this outbreak happened, I will stand next to them and say so. I have testified before Congress, and I know how easily a hearing becomes theater. This one does not have to be. There are four questions with actual answers, and every one of them is embarrassing to somebody.

First: how did a human parasite get onto a field of lettuce in central Mexico, and what did the American company buying that lettuce know about the water and the sanitation? 

Second: why did it take from May 13 to July 17 to name a supplier, and what specifically slowed the traceback? 

Third — and this is the one nobody wants to touch — the government has now attributed 1,644 illnesses to Taco Bell and Taylor Farms. CDC’s own count is 1,645 laboratory-confirmed cases across 34 states with more than 5,100 additional reports still awaiting analysis, and the states themselves are reporting far more; Michigan alone was at 4,312 as of July 16. So, the official explanation covers a fraction of the sick. Where did everyone else’s parasite come from? That question will die quietly the moment the news cycle moves on unless somebody with subpoena power asks it out loud.

Fourth: what did the DOGE cuts do? Not as a partisan talking point — as a factual record built under oath. What happened to FDA’s investigative capacity, to CDC’s outbreak response, and to the state and local health departments that do the actual interviewing, after the funding and staffing reductions of the past two years. What was the practical consequence of taking Cyclospora off FoodNet’s required reporting list in July 2025. Whether a fully staffed system would have named this supplier in June instead of the middle of July, and how many of the people who got sick between those two dates would not have. Somebody at CDC and FDA knows the answer to that. Ask them under oath and put it in the record.

Mosso closes by saying the produce industry has an important role but cannot solve a systemic environmental and public health problem alone. That is true and I would not ask it to. But it cannot be a shield either. Cyclospora is a human parasite. It does not come from cattle or deer or birds. It reaches lettuce through human waste — contaminated irrigation water, or fields where the people cutting the crop lack a clean toilet and a sink within a reasonable walk. Wastewater monitoring will tell us where the parasite is circulating. It will not put a handwashing station at the end of a row, and it will not tell an investigator which lot went to which restaurant. Those two things are the industry’s job, and they were the industry’s job in 2013, when this same subsidiary was tied to a Cyclospora outbreak that sickened 535 people in 19 states through salad served at Olive Garden and Red Lobster and the lettuce too came from Mexico.

So here is my offer. I will back Mosso on environmental surveillance, on import controls, and on the proposition that vague advisories hurt innocent people. I will say publicly that Western Growers is right about the public health system, because it is. In exchange, I want the produce industry to stop treating the Food Traceability Rule as a burden to be deferred and start treating it as the fastest available cure for exactly the communication problem it is complaining about. Move the date back. Build the systems now. And call for the hearings — loudly, by name, to the committees that fund these agencies. The people I represent — the ones who lost fifteen pounds and six weeks to a taco — do not care which institution failed them. They care that thirteen years after Olive Garden, people are still sitting on a toilet with explosive diarrhea.