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Perishable Pundit
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Could There Be Common Ground Between The Spinach Crisis And The Cantaloupe Catastrophe?
Might Both Have Been Sourced From Transitional Acreage?

After a weekend of reflection, we have come to think we may have been a little hasty in dismissing the concern raised by Eric Schwartz, President and Chief Executive Officer at Patterson Vegetable Company, in his recent letter to the Pundit that we included in our piece titled, Pundit’s Mailbag — Are Consumers Entitled To Know If Organic Or Transitional Product Is Sold As Conventional?

Eric had raised an issue that has confounded scientists and that is this: One of the greatest challenges in assessing food-safety matters is quantitating risks. Risk is such a personal issue that even among well informed scientists, developing a quantitative consensus is quite improbable. When expanding the process to include the wide diversity of perspectives from the general population, the probability of coming to a consensus is simply impossible.

Which brings us to realize something: Despite intense media attention on the Jensen Farms cantaloupe outbreak, it is somewhat odd that no one has reported anything regarding the organic/transitional or conventional status of the crop. Surely, despite the FDA’s exhaustive report on the packing house, it is legitimate to want to know what type of farming operation supplied Jensen Farms. Was it conventional, transitional or organic?

We’ve tried to get Ryan Jensen to respond to us, without success.

We know the Weston A. Price Foundation claims that “Jensen Farms, producer of the cantaloupes, does not use pesticides,” and the FDA says the cantaloupes are labeled “Pesticide Free”.

At one point, Amy Philpott, known to the industry when she was Vice President of Marketing and Industry Relations at United Fresh Produce Association and now Senior Communications Director at Watson/Mulhern LLC was acting as a spokesperson for Jensen Farms. When news reports hit that a field directly across from a Jensen Farms field had been fertilized with treated human excrement, Amy explained that this didn’t apply to Jensen Farms:

“Jensen Farms uses two types of commercial-grade fertilizer: heat-treated or pasteurized organic fertilizer and phosphorus-based nonorganic fertilizer. Both are approved for use on cantaloupe, among many other crops,” said spokeswoman Amy Philpott.

We should also note that we have heard from other farmers in the area who tell us that the operation was following organic growing practices. So we don’t have a definitive answer, but there seem to be quite substantial indications that Jensen Farms was sourcing product from a transitional operation. If so, this would indeed be a curious coincidence in that it would create an exceptional commonality between the spinach crisis and the cantaloupe crisis in that, in both cases, the product was sourced from transitional ground. 

Of course, and here is the rub, it may not be a coincidence at all. There might be causal links in both situations.

The failure to address this issue in the FDA report may be a case of political correctness run amuck. After all, no matter what the flaws of the packing operation, it still leaves open the question of the source of the pathogen. That typically is product from the field.

There are long term issues here for public health advocates to address and for consumer behavior: When a farm is prohibited — due to organic requirements — from using a mineral fertilizer, as the soils become more and more depleted of nitrogen, the farmer will look for alternatives, including manure.

Is it really unreasonable for an individual to believe that the additional risk of consuming product from a farmer under such pressure is unacceptable?  Are we really saying that the use of manures carries “no additional microbial” risk?  We don’t have good evidence that this dynamic increases risk. It might, however, be that  the rarity of the event causes it to be difficult to replicate in experiments.

Perhaps Eric Schwartz is onto something more substantive than we gave him credit for. The fresh produce industry is responding to a societal pressure to produce organic products that require some practices that may, despite small probabilities — these are all Black Swan events — introduce a possible hazard. 

If reasonable people can agree that a rigid approach to addressing nitrogen deficiencies does add a low probability hazard, and that a less rigid approach would reduce the low probability event even further, how should trade buyers react? How should consumers react, and should they have a right to this information?

One wonders if this point about the source of the cantaloupes was included in the audit report. If it was — and so buyers were aware that a more rigid approach was being practiced — what should have been the response from a trade buyer? Should he consider it to have carried additional risk because it was grown under conditions that restricted the farmer’s options?

Perhaps the idea that consumers should know that the product they are purchasing was grown under constraints, constraints that might have led to the introduction of a hazard, is an idea worth considering.

In other words the idea that organic and transitional product should not be able to be sold as conventional without special labeling may well be an idea whose time has come.

Society has participated in defining the process with organic and transitional, but as it stands now, it is the industry or, more specifically, the individual suppliers, distributors and retailers — as well as the consumer who eats the product of course — that carries all of the risks.  

We need an honest debate regarding this politically incorrect issue.    

Marion Nestle, Organic Facts, And Why The Organic Trade Association's Numbers Don't Make Any Sense

Marion Nestle wrote a piece titled, Jim Prevor on Organics, Crop Yields and Food Politics. We were, of course, flattered to be quoted so extensively by such a thoughtful and eminent scholar.

Yet when we read the piece, we were reminded of how often what seems like differences of opinion are actually differences in regard to facts.

Professor Nestle closed her piece by mentioning a “fact” — here is what she said:

According to the Organic Trade Association, organic sales totaled nearly $27 billion in 2010, and constituted 11% of produce sales. Is this “tiny and insignificant”? I don’t think so.

Now one can hardly fault Professor Nestle for these statistics — she is quoting the Organic Trade Association — a reputable organization. The relevant excerpt from the OTA piece Professor Nestle links to is as follows:

Organic food and beverage sales represented approximately 4 percent of overall food and beverage sales in 2010. Leading were organic fruits and vegetables, now representing over 11 percent of all U.S. fruit and vegetable sales. 
Source: Organic Trade Association’s 2011 Organic Industry Survey

We’ll leave total organic sales to someone else to deconstruct, but we took one look at the produce statistic — “11 percent of all U.S. fruit and vegetable sales” and said that was way off. After all, less than 1% of all US Farmland is certified organic, so where would this 11% come from? In other parts of the report, OTA says that 92.5% of organic produce sales are fresh — 2.8% canned, 3.2% frozen, 1.5% dried — so this almost all is supposedly fresh product.

First off, one should be clear that we are talking dollar sales. The Nielsen Perishables Group has found that organic fresh prices average 80% higher than conventional, so if 11% of sales were organic, that would mean that organic would account for 6.45% of the volume of produce.

Now we’ve seen sales statistics from lots of mainstream supermarkets and few are near that number in volume or dollars. We’ve seen numbers in foodservice distributors and major chain restaurants and those numbers are even less. Even Farmer’s Markets and CSA’s don’t typically reach this number if one is talking about certified organic product as the OTA presumably is. We know the market share for natural food retailers and know that even if their organic percentages were much higher, they wouldn’t add up.

It is not even that the number is wrong; half the number would be way off.

So we called the Organic Trade Association and asked how they got that number. They explained that Nutrition Business Journal, a private publisher that produces various publications, trade shows, etc., that serve the organic and natural communities, did an industry survey on behalf of OTA. This survey was managed and conducted by Carla Ooyen, Director of Market Research at Nutrition Business Journal, with the help of the NBJ staff. They operated under the project direction of Laura Batcha, OTA’s Chief of Policy and External Relations, and Angela Jagiello, Associate Director, OTA’s Conference and Product Development.

In the end, the research product as it related to fresh produce was so unlikely to produce anything approaching accurate numbers that the OTA should be embarrassed for publishing such numbers. New numbers based on the same methodology are due out soon for the 2012 study, and OTA should put a kibosh on them before they publish.

Here, from the OTA’s 2011 Organic Industry Survey, is the “Data Collection” portion of the methodology:

1.2.1 Data Collection

A primary objective of this project was to collect and compile data from the manufacturing community in the organic industry. To maximize the amount of information collected, NBI structured a survey similar to previous OTA surveys to facilitate quantitative assessment and comparison and to assess qualitative issues impacting the organic industry. NBJ distributed the survey and collected the responses through an online survey network. Further e-mails and telephone calls were used to improve response rate and clarify survey responses.

In the survey, NBJ assessed the “universe” of manufacturers in organic products so that survey data could be most effectively modeled into total industry statistics. In other words, traditional statistical modeling usually involves random sampling of defined subcategories (i.e., organic manufacturers between $5-10 million in sales) and conversion to total based on the knowledge of the survey universe. In this case, we used a somewhat hybrid approach, where respondents were not randomly selected, but rather 'self-selected' by their responses and our efforts to make the entire industry aware of the survey. Distinct efforts were made to obtain responses (or as a last resort revenue, product breakdown and sales channel estimates) from the top 100 or so manufacturers and private label brands to maximize the “revenue capture” of the survey database and industry model.

Of course, the bias slips in right at the start. If the “primary objective” is to “Compile data from the manufacturing community in the organic industry,” then the survey may provide useful information about organic manufacturers, but the survey will not be useful to compare organic and non-organic market share because the survey will not generally include non-organic manufacturers or at least the non-organic manufacturers are highly likely to be under-represented.

We will assume the word “manufacturers” is broad enough to include farmers and packers. Even so, to generate market share statistics, one needs to have a picture of all manufacturers — organic and non-organic. This survey wouldn’t do that.

Ok, so who did they actually survey?

“…respondents were not randomly selected, but rather “self-selected” by their responses and our efforts to make the entire industry aware of the survey.”

OK, in this case “entire industry” must mean the organic industry, not the fresh produce industry. We know they didn’t advertise the survey on the Perishable Pundit, nor PerishableNews.com’s produce channel. They didn’t run any ads in PRODUCE BUSINESS magazine, nor did they exhibit at The New York Produce Show and Conference — so whatever “efforts” were made in produce were limited.

More broadly, self-selected surveys are pretty close to worthless. One needs to make sure that survey respondents correspond to the general population one is looking to survey. It is especially easy to throw the numbers off if one only markets in a particular community.

Think about doing a survey where the “primary objective is to compile data from the Jewish community”… to promote responses, you advertise in publications geared toward Jewish people, get press releases published there, hand out flyers in synagogues, etc.

Now you might gain some useful information about Jewish people — although you would need to be very careful as certain groups, say younger Jews, may not read the Jewish newspapers or affiliate with synagogues in proportion to their numbers.

What is very clear is you couldn’t possibly use such a survey to compare the percentage of Jews in the population with non-Jews.

So what might be a reasonable estimate of organic market share?

Well the Nielsen Perishables Group maintains a database from scanner data that represents about 62 percent of US food retailers. Steve Lutz is the Executive Vice President at the Nielsen Perishables Group, and he tells us that their data shows that organic accounted for 5.5% of produce department sales for the 52 weeks ending July 30, 2011. This is pulled from scanner data so is much more accurate than survey results.

Once again, this is a dollar figure and the Nielsen Perishables Group has found that organics, on average, are priced 80% above conventional produce. So if 5.5% of sales is organic in dollars, that would translate to 3.1% in volume.

Yet this number is probably way too high as a percentage of produce sales. The Nielsen Perishables Group database is an incredible resource, but it does not include Wal-Mart, and Wal-Mart skews significantly lower on organic sales than mainstream supermarkets, such as Safeway and Kroger. This alone could drop a point or more off the percentage that organic represents.

Then we know that at retail, where consumers can see the organic product and elect to pay more for it, organic has much higher penetration than in foodservice. Sure white tablecloth restaurants use organic sometimes – but that is 1% of the business. Organic is hard to find at McDonald’s.

It is difficult to figure consumer prices in foodservice as the product is not sold independently from the ambiance, service, etc., but if we figure that retail dollar sales are 4.5% — the Nielsen Perishables Group number less a percentage point for the Wal-Mart effect — then with organics costing 80% more, the volume of organic at retail would be 2.6% of the volume.

It is reasonable to think that foodservice is half that percentage. In other words about 1.3% of the produce used in food service is organic. If foodservice accounts for 35% of produce usage, that would mean organics account for 2.15% of the total volume of produce sold in America.

We always like to give people the benefit of the doubt, so we assume that this is all an innocent mistake caused by OTA choosing to contract with a company not really deeply involved in fresh produce to do its research in this area. Though many, less charitable than us, would note that OTA has an interest in exaggerating the importance of the organic industry and that it may have purposely contracted its research out to an organization that produces the Natural Products Expo and similar products and thus has a similar interest rather than to a neutral party.

Surely OTA wants its research to be above reproach. It should consider working with a reputable university-based researcher. Perhaps we should give our friends at the Organic Trade Association the contact info for Ed McLaughlin, the Robert G. Tobin Professor of Marketing at Cornell University. He and his staff have done dozens of these studies for the fresh produce industry and other facets of the food industry. If the OTA is really interested in producing credible research, a staffer can contact Ed right here.

Marketing Gone Wild: The Use And Abuse Of Food Safety ‘Certifications’

The produce industry has come to work so hard on food safety. This is seen collectively through institutions such as the California Leafy Greens Marketing Agreement and the Center for Produce Safety.

It is also true on an individual company level. Anyone who has been involved in the produce trade for an extended period has seen an enormous increase in attention and commitment on food safety issues, especially following the Spinach Crisis of 2006.

But each company and the industry as a whole has to make sure the marketing efforts don’t get ahead of themselves. Particularly, those who offer seals or indicias or who use them in their marketing have a responsibility to make sure that these are not misused to imply things that are not justified..

We check out a lot of industry web sites and we find these seals are often misused.

Many are at fault and sometimes these situations are inadvertent, caused by web designers handed a bunch of logos and not understanding. But in the end, every company has a responsibility to not exaggerate its food safety credentials.

One web page we looked at, from a substantial company that has actually been the focus of food safety concerns, offers an example of the problem more common than would be desirable. As part of its webpage, the company has a bunch of logo graphics and corresponding type. Here are the words:


• Global Food Safety Initiative (GFSI) Compliant

• Safe Quality Food (SQF) Certified

• Primus Certified

• Produce Marketing Association Gold Circle, Advancing Food Safety Certified

• United States Customs-Trade Partnership Against Terrorism Cooperative

The most obvious and most egregious problem here is the use of PMA’s Gold Circle in this fashion.

Gold Circle is a terrific program through which PMA member companies so inclined can donate an extra $1,000 to support food safety and consumer communication efforts. It is a very industry-minded thing to support, and any company that supports it deserves a hat tip.

It is not, however, in any way, a “certification” of anything. All it means is a company donated $1,000. That is it. PMA doesn’t inspect companies. PMA has no idea if a firm’s food safety program is good or not. All this means is the check didn’t bounce.

To imply that this is a certification is to deceive.

Obviously this company should change its web site. Other firms should check theirs, and PMA should issue a reminder to all other Gold Circle members about the appropriate use of this logo. It is fine to use it to demonstrate that a company is supportive of industry food-safety efforts — but it should not imply certification by PMA.

Besides protecting the integrity of the logo, if PMA does not act to stop these types of claims, one day someone will sue PMA, claiming it was complicit in the implication that PMA had certified this company in some way and thus had liability. That risk is not worth $1,000.

This may be the most egregious example, but most of these types of claims are too broad.

Primus-certified? What in the world does that mean? Primus does have a Platinum Supplier program, and one if its benefits is allowing use of the Primus logo — but this company is not listed on the Primus web site as a Platinum Program member. More importantly, though, what is the implication a buyer or consumer – this is an open web site — should draw from this? That if one buys from this company, every box has been certified in some way by Primus? We doubt that is true as the company whose website we took this from sells many products from many different places. In all probability the company buys “shorts” from other shippers and terminal markets. Even if the company does not and all its product is certified, the obvious question is certified for what? Primus will certify product to be organic. It has a pesticide-certification program, GAP, GMP, PrimusGFS, etc.

SQF-certified? It is even less likely that every box sold has SQF certification in this diverse company.     

GFSI isn’t a certification at all, and the company whose website we drew this from is known to have, in at least some cases, required that suppliers do only standard GMP audits, not GFSI audits.

In fact of all these claims of “certifications,” the only one we could endorse would be the claim that the company is certified as a partner in the United States Customs-Trade Partnership Against Terrorism Cooperative, which is actually a claim that applies to the company, not the product.

The truth is that these kinds of certifications mostly apply to specific fields or specific plants for specific things. They typically don’t apply to companies at all.

This may be a distinction without a difference if one is a fresh-cut processor and all the plants are certified the same way and there is a requirement that all growing operations be certified the same way, or if one is a grower/shipper/packer and all the fields are certified the same way and the packing house is certified one way.

But for most, these logos should be used specifically and in a limited way: “Our company supports industry food-safety efforts by contributing to PMA’s Gold Circle campaign to advance food safety.”

“Our fresh-cut facility in Los Angeles is certified annually by Primus Labs to meet the Global British Retail Consortium standard.”

Claiming lots of “certifications” that don’t exist or are easily misinterpreted indicates a company is less concerned about food safety than marketing food safety. Nothing good can come of that, and owners of these trademarks should be vigilant in preventing their misuse.

FDA, Stealth Recalls, Public Health And Other Interests

We thought our piece, Food Safety, Recalls And Why Consumers Don’t Always Need Notification, was fairly persuasive. We didn’t, however, persuade the person we addressed it to. That was Phyllis Entis, a microbiologist who had published a piece titled, 114 Tons of Spinach Recalled By Stealth. In that piece, she asked a question:

…I cannot understand the rationale behind NOT publicizing a Class I Hazard recall of a ready-to-eat item of produce that may be contaminated with a potentially lethal pathogen.

Would anyone care to explain this to me?

We tried to explain various reasons why in that particular situation the product probably never reached consumers and so the FDA saw no reason to publicize the recall. For example, we noted that the spinach was sold in 30 lb. totes and this probably meant that it was sold to processors who were able to pull the product before it hit retailers.

We must have done a poor job of stating our case, because Ms. Entis responded with another piece, this one titled, FDA and Stealth Recalls. Ms. Entis went out and researched other recalls that had not been publicized by the FDA and noted that these were not sold in totes as in the original issue. As such she critiqued our comments this way:

I was taken to task for my February 9th stealth recall ‘rant’ by Jim Prevor of the Perishable Pundit in his February 15th item, “Food Safety, Recalls And Why Consumers Don’t Always Need Notification.” What were his gripes, and how do they stack up in light of what I have found?

Prevor theorized that the E. coli O157:H7-contaminated spinach was not destined for direct retail sale; therefore, he concluded, there was “…no need to notify consumers.”

But, USDA’s Food Safety and Inspection Service routinely publicizes recalls of products that are destined strictly for the institutional market. Why should FDA not do likewise?

Prevor also suggests that the recall was not publicized to avoid worrying or confusing consumers, who would not differentiate between the recalled (curly) spinach from Texas and the unaffected (flat leaf) baby spinach from California and Arizona. He concludes that avoiding a public announcement was the responsible path, to prevent crushing “countless farmers and processors”.

Sorry, Jim, but how does that justification extrapolate to the “Branded” products I’ve cited above — especially those that were sold in retail-sized packaging bearing lot number identification and/or expiration dates?

Finally, Prevor ends his article with the following statement:

“One suspects that the decision to not announce recalls when the announcement would not enhance public health is motivated by the desire to protect another value: Maintaining viable farms, industries, jobs, etc.”

Interesting. I always thought that the primary responsibility of FDA was to protect public health.

Although the original comments related to a specific situation with spinach packed in totes, the real issue is whether consumers will benefit from knowing of a recall.

The typical reason why consumers might not benefit from a recall: If the product never reached consumers, there is nothing for consumers to do.

Very often product is sold and shipped long distances. Sometimes a recall can happen before the trucks even reach the warehouse of a customer. Other times, the product reaches the warehouse but is never distributed to stores.

It is hard to understand anyone objecting to the lack of notice in these situations.

Our example with the totes was simply to say that with product going to processors, such a recall is often easier because there are fewer customers and more of a time lag since product has to be processed.

So when Ms. Entis asks, “…how does that justification extrapolate to the “Branded” products I’ve cited above — especially those that were sold in retail-sized packaging…” the answer is actually very clear and simple. If product is caught — be it retail packages, foodservice packages or totes for processing — BEFORE THE PRODUCT IS SOLD TO CONSUMERS, there is no need for any consumer notification.

In other words, if California Farmer Smith is selling to New York Retailer Jones and during transport the product is recalled and turned around or disposed of in St. Louis, what would possibly be gained by issuing a recall notice to consumers?

We agree with Ms. Entis that the primary responsibility of the FDA is to protect consumer health, but that doesn’t mean it should exercise its responsibilities in a way callously indifferent to the interests of others, including workers who need jobs and farmers who need to sell their crops.

Sure, if the FDA thinks the public health will be served by announcement of a recall, then it should announce it; no arguments here. If, however, the FDA thinks that no public health interest is served by such notification because the product was all caught on a truck or in a warehouse, why cause panic and lead consumers to shy away from healthy produce? It just wouldn’t make any sense.

Pundit’s Mailbag — If Wishes Were Horses, Then Beggars Would Ride — Wishing For A Better Way To Feed The Planet

Our piece, Organics, Crop Yields And Feeding The World, brought many responses including this letter from one active in the organic industry.

I think the most efficient way to respond to this article is to offer this link which debunks the idea that GMOs and large scale agriculture are the answer to feeding the world’s population: How to Feed 7 billion of Us Without ruining the Planet.

I’ve been eating organic food since the 1970’s and work for a company which has seen rapid growth in its fourteen year history.  Great civilizations such as the Romans, Mayans and even our own great nation, during the “dustbowl” years, have come to decline and/or extinction simply by losing topsoil, often by mono-crop farming which strips vital nutrients from the ground.   One of the most important aspects of organic farming has to do with the composition of that precious and often overlooked item — dirt.

If we do not revisit how and why we grow food (i.e., for consumption by cows in feedlots, for production of by-products for unhealthy processed foods such as High Fructose Corn Syrup, or for processing into ethanol) and how and what we consume, there will be no answer to feeding 7 billion mouths.

—Ronni Blumenthal, Vice President of Administration
Global Organic Specialty Source
Sarasota, Florida

Ronni is passionate and engaged, and so we appreciate her letter. Interesting enough, Steve Savage is also very concerned about soil. He has developed an intriguing idea that the problem is closely related to the fact that much cropland is leased rather than owned by farmers. You can see his thoughts here.

Although theoretically, property owners have an incentive to only lease to people who will preserve their asset, the information costs of doing so may be prohibitively expensive. If so, his focus may be right on target. If a Libertarian is told that fishermen are exhausting the fish in the lake, his answer would be to give ownership of the lake to someone who will then have a strong interest in sustaining its fish stocks.

Some of Ronni’s pleas, though passionate, don’t seem supported by the law. For example, monocultures may be bad, but the national organic standards don’t block them.

When we turned to the article with which she linked, we did so with enthusiasm, but confess that we found it less than helpful. Here is the “to-do list” that will let us feed 7 billion people without ruining the planet:

On the bright side, Foley’s team of researchers concluded that we can indeed produce enough food and do so in a way that both minimizes environmental and climate damage while treating water as the precious resource it is. We will, however, have to make a few adjustments to our approach to agriculture. The to-do list is surprisingly short:

• Close agricultural “yield gaps” — the difference between the most and least productive regions — while minimizing farming’s environmental footprint

• Stop agricultural expansion into sensitive areas, such as rainforests

• Stop wasting so much food

• Eat less meat and put less food (i.e. ethanol) into our gas tanks.

The first wish seems to us a contradiction in terms. First everything can’t be made equal because some places are better environments to grow things than other places. To the extent we can equalize things, the reason the top productivity agriculture is that way is because it uses plenty of high technology — GMOs, chemicals, tractors, etc. This clearly would not be acceptable to these authors from an environmental standpoint.

The second wish may be a good idea, but it certainly does nothing to increase food production.

The third wish is admirable. Who, after all, is in favor of “waste”? But from a public policy perspective, what could this possibly mean? How will we stop this?

The fourth wish suggests one useful thing — we have long said that federal subsidies for ethanol made no sense. But the same article explains that only 3% of food goes to “biofuel, fiber and seed production” combined. That includes cotton clothes, etc., so ethanol is only a tiny use of the total worldwide food supply.

As far as “eating less meat” goes, the world seems to be going in the opposite direction. Growing middle classes in formally underdeveloped countries are wanting to eat more meat. This trend will overwhelm even diligent efforts by Americans and Europeans to eat less meat, and there is little sign that the mass of westerners are very interested in dramatically changing their lifestyles either.

To us, all this reads not so much like a solution on how to feed the population of the world as it is a kind of lament that we have to. It is almost as if it those impoverished people in Africa and Asia should just keep practicing subsistence agriculture and not get all uppity and want to have lives like us.

We know Ronni is a very nice person and doesn’t think that way, but the implications of the policies being urged by the author of this article are very close to that.

Many thanks to Ronni Blumenthal and Global Organic Specialty Source for weighing in on this important issue.

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