The Chefs Collaborative has decided to oppose efforts to take the standards of the California Leafy Greens Marketing Agreement national. It is not really surprising — the organization defines itself this way:
Chefs Collaborative works with chefs and the greater food community to celebrate local foods and foster a more sustainable food supply. The Collaborative inspires action by translating information about our food into tools for making knowledgeable purchasing decisions. Through these actions, our members embrace seasonality, preserve diversity and traditional practices, and support local economies.
So, as you can see, a priori the organization has already decided — without evidence — that locally grown foods are always better.
So this is the letter the association sent to its membership of chefs:
If you depend on and value the local growers that bring their diverse range of fresh, leafy greens to your restaurant, we encourage you to educate yourself about the proposed USDA national Leafy Green Marketing Agreement and sign onto a letter to the USDA to voice your concern before the December 3 deadline for public comment.
While Chefs Collaborative supports efforts to improve food safety overall, we feel that the agreement would be better served if it were tailored to the processing issues that led to last year’s e-coli outbreaks traced to bagged spinach. Unfortunately, the proposed agreement is a one-size-fits-all policy that could adversely and needlessly affect small-scale growers.
We hope you’ll consider signing the letter to the USDA prepared by CAFF (Community Alliance for Family Farmers, the organization leading the opposition to the proposed marketing agreement). You can click here to sign the letter and voice your concern about the potential negative impact on local growers and the availability of fresh, leafy greens.
This is a critical issue for small-scale growers across the country. CAFF says that the Leafy Greens Marketing Agreement enacted in California this summer will hurt family farms if it becomes mandatory in the state or nationwide and that the Marketing Agreement model is already serving as a template for other states, like Arizona, to follow suit. Please see below for more information.
Thank you for your commitment to promoting local, sustainable food.
Executive Director, Chefs Collaborative
In some ways the letter is shocking. For example, it asserts — once again without evidence — that a better food safety solution would be “…tailored to the processing issues that led to last year’s e-coli outbreaks traced to bagged spinach.”
Thus the Chefs Collaborative decides for itself what the FDA, USDA, CDFA and the whole industry cannot — what “led to” last year’s outbreak.
In fact, despite the letter placing blame on “processing issues,” we know that E. coli 0157:H7 doesn’t spontaneously generate on stainless steel, so at some point it was brought in from the field.
The truth is that the Chefs Collaborative is not facing reality. It has fallen for propaganda put out by the Community Alliance with Family Farms or CAFF. In fact, at the bottom of its letter, the Chefs Collaborative put this paragraph:
Read on for more background…
The USDA national Marketing Agreement being proposed is based on the model of the California Leafy Green Marketing Agreement (LGMA). The LGMA, already enacted in California, is the result of the leafy greens industry’s reaction to last year’s e-coli outbreaks traced to bagged spinach. According to CAFF, since 1999, 98.5% of the reported California sourced leafy green E. coli 0157 illnesses have been traced back to the pre-cut, processed, bagged salad that the industry calls “fresh cut”.
The proposed “one-size-fits-all” regulation will also apply to the small-scale independent growers we value working with. Included in the proposed rules are practices that will harm sustainable agricultural practices, like discouraging the development of microbial life in the soil and discouraging wildlife on the farm and any vegetation that could harbor wildlife. We invite you to visit the CAFF website for more information.
Both CAFF and the Chefs Collaborative have fallen victim to a statistical chimera. Fortunately, even when a pathogen is present on produce, most people either do not get sick or get sick only in the sense of having uncomfortable gastro-intestinal symptoms. They do not go to the doctor, they do not go to the hospital… they have “food poisoning” or the “24-hour bug” and then get better. Many times, even though they are supposed to report it, even when people do go to a doctor, if the patient is going to make a full recovery, the doctor doesn’t bother to report the illness.
Thus, it is only a tiny portion of the people who get sick from food who ever wind up becoming known to the state health departments or the Centers for Disease Control and Prevention in Atlanta.
What this means, of course, is that only massive outbreaks are ever identified. Stalin said, “One death is a tragedy; a million is a statistic.” In produce it is that only when we get large numbers of people sick can we identify and trace back the outbreak. Local growers, who lack the technology, the food safety personnel, the HACCP plans, the third-party audits, in all probability sell produce disproportionately affected by pathogens.
But a large producer gets 30,000 people sick and with massive publicity we can identify 300 sick people.
A thousand small growers may, in a thousand separate incidents, get 30,000 people sick, but we never can trace back the problem, because a typical grower gets only three people sick and, on average, less than one goes to a hospital or doctor.
Remember that our trace back system starts with a survey — sick people come into the hospital and are asked questions. If we have hundreds, we can note disproportionate consumption of spinach or Taco Bell. But if one sick person comes in, he is just a guy who ate spinach or went to Taco Bell.
CAFF also asserts the problem is strictly with fresh-cuts. One point is that this is also a statistical quirk. It is far easier to trace back to a packaged item with a bar code than to bulk product.
Beyond this, CAFF is comparing apples and oranges. Now fresh-cuts may have issues, but the choice is not eating fresh-cuts or bulk produce. If the processor doesn’t cut the lettuce it does not mean we serve consumers the whole head.
We have to compare the danger of processing at a fresh-cut facility with the danger of processing at a restaurant. We have zero evidence that processing spinach, romaine or head lettuce in a restaurant produces a safer product than a world-class processing facility. The recent findings of a scientific panel, that Consumers And Foodservice Operators Should Not Rewash Fresh-cut Produce, hinged on the likelihood of cross-contamination:
The risk of cross contamination from food handlers and food contact surfaces used during washing may outweigh any safety benefit that further washing may confer.
Though the study did not deal with buying raw product and processing it in the restaurant, by implication, the risk of dirty hands, dirty surfaces, etc., are not insignificant.
One reason we have so lauded the Nucci Scholaship for Culinary Innovation is that the produce industry desperately needs to reach out to chefs. As we pointed out in Pundit sister publication, PRODUCE BUSINESS, in a piece entitled Foodservice And Food Safety:
We now have a situation in which reputable distributors spent millions in rigorous food-safety audits and the best chefs prefer their produce delivered in wood crates with the earth still upon them.
This is romanticism, but food safety requires HACCP plans, Good Agricultural Practices, expertise, water testing, soil samples and other tests. Our best chefs must insist the local growers they wish to buy from conform to good food-safety standards.
There is nothing magic about “small farms” that makes their produce safe. We can understand CAFF’s position because it represents small farmers who don’t want to have things like large buffer zones or inspectors on their property because it is very expensive.
The Chefs Collaborative, though, should advocate for the restaurant patrons and demand the safest possible product from growers small or large. That should be the ante to get into the supply game.