Now that the “cantaloupe crisis” has passed – though not without significant costs to the trade and a horrid death toll of 30 – it is important to reflect on lessons learned. We wrote extensively about the cantaloupe crisis and you can see those pieces here.
We have received an important letter from the leadership of two organizations at the forefront of industry food safety efforts.
Many of the scenarios regarding industry food safety efforts have revolved around the question of audits and what is reasonable for the world to expect from audits. So we were very pleased that this joint letter was from two men involved with innovative efforts to use audits successfully as part of food safety programs:
Jim, thank you for your very thoughtful analysis of the tragic Colorado listeria outbreak. We felt it was appropriate for us to take a moment to share what we’ve learned over the last five years of our programs’ existence. First, an audit and score are only one piece of any overall program. A comprehensive program should instill a culture of food safety that permeates throughout an entire operation.
And, to your point, Jim, that really begins with a rigorous set of industry-wide standards developed through a transparent and inclusive process. Verifying compliance comes next through announced and unannounced audits. In the case of both the California Tomato Farmers and the California Leafy Greens Marketing Agreement, those announced and unannounced audits are mandatory for our members and conducted by USDA-certified government auditors, not private auditing companies.
We want to be clear that we are not saying our auditing systems are perfect, and we are constantly working with USDA to refine and improve these systems. But, what we are saying is that our members strongly believe that the government auditors are ideally positioned to conduct effective and independent food safety audits, as neither the buyer nor the seller hires them directly. The auditors report only to their government supervisors. Most importantly, if these auditors identify an imminent health risk during an audit, he or she is required to inform local, federal or state health authorities of the situation.
Another aspect of a comprehensive program is a system for handling corrective actions. For both CTF and LGMA, any member who does not pass every facet of the audit must take corrective actions to not only correct violations but to enact measures to prevent their reoccurrence. Follow-up audits validate these corrective actions.
In some cases, we have been criticized for allowing members to “retake the test” until they pass. That’s not accurate. We require necessary improvements in their food safety practices with all employees and contractors focused on achieving across-the-board compliance. Again, this helps create a culture of food safety throughout an operation.
For members who fail to achieve 100 percent compliance, they are decertified from the programs and buyers are informed. For LGMA, buyers are notified directly of the decertification action and the company’s name is posted on the LGMA website. CTF customers have on-line access to audit history and compliance. This level of transparency is also a crucial element of a food safety program.
For any food safety program to be successful, it must evolve. And to do that we must listen to what our customers are saying – constantly. Jointly, our members have conducted food safety tours for buyers, and we have personally met with customers to hear how we can do better; we have attended food safety summits, seminars and meetings throughout the country.
And what we’ve heard is that buyers want rigorous industry-wide standards, quality auditors inspecting operations and they want transparency — but they also want continuous improvement and refinements in each of those areas. Both of our programs are working hard to deliver these attributes to buyers. As the Perishable Pundit has already pointed out, the next step in the evolution of food safety in the produce industry is for procurement divisions to recognize and accept these comprehensive systems.
California Tomato Farmers
President and CEO
California Leafy Greens Marketing Agreement
We appreciate this letter and think it important as it raises eight key points:
1) AN AUDIT IS NOT ENOUGH
We received so many calls from consumer media suggesting that the idea that a firm passed an audit and yet still had a food safety issue was somewhat incredulous. This incredulity makes no sense as almost all food safety outbreaks involve audited firms because the vast majority of industry volume is audited by somebody for something.
Obviously if a firm or its employees do food safety just to pass an audit, they will not do a lot of important things when the auditors aren’t watching. Therefore the game is clearly to change people’s motivations from “passing the test” to “doing the right thing.”
2) INDUSTRY-WIDE STANDARDS PROPERLY DEVELOPED
A prerequisite for any successful audit scheme is that the standards against which the audit are done must be meaningful and acceptable. This letter argues that they best be industry-wide standards as well.
There are many reasons to think this point is true. Most notably that it creates a level playing field for producers and for retailers. Many producers in the world don’t want to stint on food safety, but they feel compelled to avoid costs because their competitors don’t incur them and buyers will still accept the product.
Many retailers would prefer to always buy the best stuff produced under high food safety standards, but competitive retailers buy cheap stuff and consumers accept the product thus creating competitive pressure to both buy and sell cheap.
3) ANNOUNCED AND SURPRISE AUDITS
It is an open secret in the industry that people prep when they know the auditor is coming. This is not so terrible as it gives a moment in time for everyone to take stock and make sure everything is up to snuff. It is, however, obviously not sufficient.
Although true “surprise” audits are rare — and we note that Ed and Scott use the term “unscheduled” in their letter — the fact that an auditor might show up at any time is useful in keeping people on their toes and in building a food safety culture.
4) USDA-CERTIFIED GOVERNMENT AUDITORS
This is a controversial point. Do government auditors produce better food safety outcomes than private auditors? The research on this subject is scanty. It is not obvious to us that if the CLGMA, for example, chose to hire Primus auditors that the audits would be worse or that food safety would decline.
Still, one can see the appeal. The government is somewhat of a neutral standard whereas different people have different opinions about different auditing organizations. The image of people denying access to government officials seems less credible than denying a private business, and the assumption is that the government auditor will have job security and thus be willing to be tough whereas a private auditor may have fears about being displaced — although there is a lot of political theory about how private interests capture regulatory bodies and bend them to their will.
5) CORRECTIVE ACTION
One of the big flaws with audits is that the corrective action mechanism is deeply flawed. Although some companies use audits as self-assessment tools and work hard to make sure they are doing everything right, the Jensen Farms cantaloupe situation clearly shows the need for an automatic mechanism to force corrective actions.
The requirement that everyone score 100% on an audit is a good start. Completely aside from the substance, the requirement to get 100% is a way of building a culture that says that compromises on food safety are not acceptable.
Of course, we are still not certain this is enough. Many of the flaws identified in Colorado were not the subject of an audit. For example, there was no requirement to have a pre-cooling facility. Buyers still can’t look at an audit, see the producer got 100% and assume that nothing else can be done. That is not often the case.
What happens if someone fails an audit or gets a low score or gets comments? This needs to be immediately communicated to all buyers and be available to all prospective buyers. So many buys today are program buys that run through continuous replenishment models. Audits must be circulated in such a way that a computer will stop these programs as result of a problem.
7) CONTINUOUS IMPROVEMENT
Obviously, audit metrics can’t remain static as science advances. Note, though, that the Europeans and programs such as GFSI seem to prefer stability over continuous improvement.
None of this, of course, matters if it doesn’t impact the behavior of the actual buyer.
These are all more than valid points for consideration but it is worth noting that both of these organizations, California Tomato Farmers and California Leafy Greens Marketing Agreement, have several advantages. As state-focused organizations, they have a relatively homogenous environment to consider and they both have a concentrated industry to support their efforts.
The California cantaloupe industry does not have the same structure — government auditors, etc. — but it has had few food safety issues.
And neither the CLGMA or CTF would have protected their industries against a problem with leafy greens or tomatoes from Colorado.
The Leafy Greens effort was expanded to Arizona and there is an effort afoot to make it national.
Maybe the real lesson of the Cantaloupe Crisis is that since such food safety outbreaks affect everyone in the business, the mechanisms we use to deal with them need to encompass not only the large well capitalized players but smaller more regional players — like Jensen Farms in Colorado.
Many thanks to Ed Beckman and Scott Horsfall for weighing in on such an important industry issue.