LETTER REGARDING UNPASTEURIZED JAMBA JUICE

September 3, 2025

To:

Mr. Joe Levitt, Director, Center for Food Safety and Applied Nutrition, FDA
Dr. Morris Potter, Director, Food Safety Initiative, CFSAN, FDA
Mr. Jim Waddell, Food and Drug Branch, California State Dept. of Health
Dr. Jeff Farrar, Food and Drug Branch, California State Dept. of Health

Dear Gentlemen,

With over 150 stores in 9 states (Arizona, California, Colorado, Oklahoma, Oregon, Hawaii, Idaho, Minnesota and Washington), Jamba Juice is one of the largest franchised chains of juice smoothie storefronts in the United States. Most of Jamba Juice's ingredients are pasteurized with the exception of their orange juice, wheat grass juice, carrot juice and lemon juice, which are juiced at the storefront.

In recent interactions with the City of Saratoga Planning Commission, the Manager of Quality Control at Jamba Juice sent the attached letter as a followup to discussion as to whether they should be required to post the FDA warning language at their juice bar in Saratoga. While the letter indicates the company has an understanding about reducing the potential for contamination in unpasteurized juices, several points within the document call into question whether they have the latest juice safety information.

1) Jamba Juice indicates that "bottled" products require pasteurization because "of the time allowed for bacteria to proliferate and reach dangerous and unhealthy levels." Because very low doses of foodborne pathogens in unpasteurized juice are sufficient to bring on lifethreatening illness, consumer concern and most public health concern has been focused on contamination and its prevention. Most unpasteurized juice is kept refrigerated after juicing because lack of refrigeration brings on spoilage, not increased numbers of pathogens; indeed, with the exception of Listeria, most foodborne pathogens are not expected to grow significantly under refrigeration.

2) Jamba Juice indicates "Fruit such as ripe oranges do not have the tendency to fall to the ground and do not pose the same risk..." as apples. Yet, repeated outbreaks of Salmonella in unpasteurized orange juice indicate a route for fecal contamination of orange juice components, whether via the orange, water or ice. Three of the top five outbreaks in the United States are from Salmonella contaminated, unpasteurized orange juice. Worldwide, the outbreak with the largest number of identified cases or contamination was that of unpasteurized orange juice outside of Sydney, Australia in February, 1999. This consistent appearance of Salmonella in orange juice does not support Jamba Juice's theory that merely because oranges might not be picked up off the ground, orange juice would be safer.

3) Jamba Juice indicates that it is testing its carrots for Salmonella. As a result of the Sun Orchard outbreak, the FDA has recently proposed a new form of Salmonella testing of which Jamba Juice may not be aware. It would be wise to ensure that Jamba Juice is using enrichment methods for testing both Salmonella and E. coli O157:H7 in its wheatgrass as enrichments methods are presently considered more accurate in identifying small quantities of potentially lethal pathogens.

4) Jamba Juice states that it uses sanitizers for cleaning equipment and blenders. Yet, according to many studies, sanitizers are better at reducing organisms than eliminating them. It would appear that cleaning the blenders with a high temperature dishwasher could be superior.

5) The company argues that, with respect to their product, "in a sense, it is the closest thing to actually eating the fruit or vegetable itself." Yet, they point out that they sanitize their equipment only once a day, and therefore, the health risk of a glass of unpasteurized juice put through such equipment is more proportional to that of sampling bacteria from the dozens of pieces of fruit that have passed through it than it is to sampling the bacteria of a single piece of fruit.

Jamba Juice has taken some steps to reduce microorganisms in their storefronts, but they are only one of many unpasteurized juice smoothies companies across the country. As S.T.O.P. has indicated in multiple comments to FDA, this segment of unpasteurized juice sales is growing dramatically. State and federal health departments have done very little to educate these companies about the real risks associated with unpasteurized juices. Please be sure to specifically invite Jamba Juice and its competitors to any further educational meetings. It is critical that all of these companies receive accurate education and information about:

• the virulence of pathogens,
• the sources and causes of outbreaks,
• risk analysis,
• the latest and most accurate testing mechanisms,
• and the difficulty of eliminating pathogens with sanitizers.

It is also critical that consumers receive adequate warning from their government to counter marketing information provided by unpasteurized juice companies. Without such warnings, the only message consumers hear is that unpasteurized juices served at juice bars are safer than other unpasteurized juices and are healthy and nutritious meals for everyone.

Sincerely,

Laurie Girand
Advisory Board Member

Attachment: 7/13/99 Letter from Steve Marko, Manager of Quality Control, Jamba Juice to Mayor Jim Shaw, City of Saratoga