As the industry celebrates its victories on the food safety front, we turn to some thoughts sent by one of the most important voices on the retail side of the business:
My question for the Pundit is this: When it comes to food safety, is the cure worse than the disease? I’m thinking of all the activity that has been stirred up because of the spinach fiasco and the discussions regarding food safety.
I read that Boskovich is now suing Taco Bell over the green onion issue. And now we have the California Tomato Farmers group that will concentrate on food safety.
And we have the California Seal of… I don’t know… whatever it is the seal of!
In any case, here’s my point: The industry focus on food safety is a good thing inherently. In fact, the industry has always focused on food safety. But ever since the spinach problem, the entire food safety issue in produce is constantly in the public discourse. And in many cases, it is turning into a marketing issue.
The fundamental problem that I see with this is that the “food safety battle” is a war that this industry will NEVER win! As long as fruits and vegetables are produced in an open environment, there will always be a risk of another outbreak. And this doesn’t take into account produce grown outside of the United States.
The simple fact is that as long as many fruits and vegetables are consumed raw, the public is always at risk. This is not a new phenomenon, as it doesn’t seem that long ago that we were dealing with the Alar issue. But in every case concerning produce, the public understood that the problem was isolated to a given grower and or geographic location.
While it’s true that the commodity did suffer a short term sales hit, the public generally became comfortable again with the product and sales climbed back.
But all of this media “noise” about what “so and so group” is doing about the food safety issue will keep consumers focused on the issue, and it’s an “Achilles heel” for the produce industry.
The conversation needs to be around “best ag practices,” which help in a number of ways, ONE of which would be food safety. But it also improves quality, flavor, appearance, etc. In my view, all the constant talk about food safety has made a bad situation worse, not better, from the perspective of how the public views our industry. I think two areas of focus should be concentrated on:
- How foodborne illnesses are identified, isolated, and resolved.
- How foodborne illnesses are addressed from a media standpoint
Our correspondent is both experienced and thoughtful and he raises several important points:
- The industry may be setting itself up for a fall.
We have invested enormous effort into things such as the California Leafy Greens Marketing Agreement as the industry’s solution to the problem. Yet, by the very fact that we have “industry-wide solutions,” we tend to tie the industry together from the viewpoint of the consumer.
If we do have another outbreak, for example, on spinach, although companies will immediately argue that they have higher standards than whoever had the outbreak, the very existence of these industry-wide standards will make the problem be perceived as an industry-wide problem. In a sense, our efforts to fashion industry-wide solutions transforms an aberration — the FDA’s decision to universalize the spinach problem — into the norm, in which all future outbreaks will be judged to be an industry-wide failure of standards and inspection requirements.
- All the talk about food safety depresses sales.
There is little question that constant news reports in all media focusing on the safety of produce increases the saliency of the issue in the minds of consumers exposed to the news reports. Consumers do not generally focus on these things the way the industry does, so even if the news reports are positive, the background news consumers hear is likely to simply be the association of produce with foodborne illness. This noise out there operates on both the trade and consumer level.
Foodservice operators designing new items, even today, are likely to use an alternative to spinach — why not? They have no skin in the game of selling more spinach and consumer doubt may depress sales — so if they can put romaine or arugula in that new wrap sandwich, why not do so? Retailers can advertise another item just as well and avoid the issue. Once again, retailers don’t care what spinach sales are — they can promote something else. And on the consumer level, even if there is just a vague sense that there is something still at issue, many consumers will turn to something else.
This is all one reason why getting Fresh Express to join the California Leafy Greens Marketing Agreement was so crucial. If a company representing almost half of the fresh-cut salad industry wasn’t in the agreement, it would have resulted in months of public hearings, hundreds of newspaper articles, etc. By joining, Fresh Express saved the industry from this negative publicity.
- Unfortunately recognizing all this doesn’t really tell us what the real alternative is.
Our correspondent mentions the Boskovich lawsuit against Taco Bell, which we dealt with here. The Boskovich lawsuit is interesting because what it basically alleges is that Taco Bell, in its quest to “resolve” the situation — read get it off the front pages as our letter-writer urges for the industry at large — seized on one product, without confirmatory evidence and with disregard for the reputation of Boskovich, and simply declared it at fault, removed it from its menu and declared the crisis over.
Equally, in the Alar crisis that our correspondent mentions, we could stop talking about the issue very quickly because, very quickly, virtually all apple juice and apple sauce processors pledged to refuse apples grown with Alar. Many supermarket chains pledged to refuse product grown with Alar, most grower regions agreed to stop using Alar, and the EPA voted to ban it but before that could take effect, Uniroyal, the manufacturer of Alar, agreed to stop selling it domestically for food destined for human consumption.
So in the Alar situation, the industry could quickly move on because the allegations about Alar being carcinogenic in humans quickly became moot. Nobody was using Alar anymore, so it became a backbench issue for food scientists and public policy wonks to debate over.
In the spinach/E. coli 0157:H7 case, however, the industry didn’t have this option. We never discovered a “cause” for the problem that we could “eliminate” as Boskovich is alleged to have done with green onions and as the industry did with Alar.
Without that golden bullet to kill the problem, we had no choice but to slug through long public investigations and discussions. Indeed, if there should be another outbreak — and we would be foolish to think there won’t ever be — we might find that our problem was not being public enough.
For example, the metrics adopted by the California Leafy Greens Marketing Agreement Advisory Board were supposed to be vetted by a group of independent scientists. Yet the Western Growers Association has never revealed their names.
We actually have no proof they were vetted at all. If they were we don’t know what conflicts these experts might have had or what recommendations they made that were not approved.
None of this may matter. But if there is another outbreak and someone dies, Bill Marler, the noted plaintiff’s attorney on foodborne illness cases, will surely find out who was on that board, what conflicts existed and what recommendations were not accepted. And the reputational harm to the industry from electing to keep secrets will be astounding.
- The question of food safety as a marketing issue is an important one, but it is also most problematic.
Because there are no bright lines between safe and unsafe, many companies will elect for moral or marketing reasons to exceed standard industry practices. In many cases, these practices will cost money or require labeling. How can companies explain those labels — on, say, irradiated product — or explain the higher price on product grown or processed to higher standards if they don’t to some extent “market” the value of what they are doing? One supposes we could urge people to restrict such marketing to the trade but that just shifts the issue to retailers.
How can they voluntarily pay more than market prices for product grown or processed to a standard higher than industry norm when food safety is concerned if they can’t market that fact? Or if someone else, such as the producer, doesn’t market to consumers to explain the value of these higher priced items?
Of course part of the dilemma might be resolved if companies could just be less clunky in their marketing. Emily Dickinson said, “Tell all the Truth but tell it slant — Success in Circuit lies”.
When the old Pan American Airways, popularly known as Pan Am, advertised, it used the slogan, “The World’s Most Experienced Airline.” Not a word about safety in that slogan, yet to a consuming public still nervous about air travel, it was a slogan that said Pan Am was the airline most likely to keep you safe.
- There are many virtues to tying food safety with other quality attributes.
This is why, until recently, people rarely had a title with “food safety” in it. Most titles were usually referred to as quality assurance, with the knowledge that food safety is an integral part of quality. The increased prominence to food safety titles is, in part, a form of marketing in which companies tell trade buyers and the public that they are focused on this area.
But it also is a way of emphasizing to the employees themselves what the company is focusing on. It also is a recognition that, although food safety is served by following general good ag practices, there are many specific things done in pursuit of any individual goal — be it flavor or sustainability or food safety — that would not be done in pursuit of general good practices.
Still, from an industry marketing standpoint, it is probably a good idea to tie all these things together as much as possible.
We are reminded of many programs we’ve given over the years on shrink reduction. We have always found that an excessively single-minded focus on reducing shrink has negative effects. People under-order and increase out-of-stocks, people reduce SKUs and thus decrease variety offered to customers, people order green bananas and thus don’t have product shoppers want for quick consumption.
So we always recommend a focus on general good operating practices to achieve the optimal level of shrink reduction compatible with maximizing sales and profits.
Here, we can recommend an emphasis on general good ag and manufacturing practices but intrinsic in those practices we need a far higher emphasis on food safety as a value that is not easily trumped by other values.
- Because food safety is not absolute, a focus on the process of identification and communication is crucial. When our correspondent suggests that we should focus on two priorities — How foodborne illnesses are identified, isolated, and resolved, and How foodborne illnesses are addressed from a media standpoint —he is suggesting that because we have no definitive “kill step” to prevent foodborne illness, we need to look carefully at what we can control.
To some extent, with its call for mandatory regulation, United Fresh is moving in this direction. Because our foodborne illness outbreaks last year occurred among large, reputableorganizations with food safety programs, it is difficult to believe that an FDA regulation would have much effect on food safety. What it might have an effect on, though, is the way regulators react to an outbreak.
In a highly regulated arena, such as the meat industry, FDA, USDA and others have a strong incentive to minimize the impact of an outbreak so that their stewardship of the meat food safety system is not questioned. In produce, the incentives are the opposite.
By bringing the industry under a regulatory regimen, the goal is to switch the incentives of regulators as much as to improve food safety.
And the media feeds off what the FDA and other regulatory authorities do. As long as they are holding press conferences announcing danger, there will be a strong media reaction. If they hold press conferences announcing a limited aberration in an otherwise strong system, the media reaction will be quite different.
Many thanks to our correspondent for his thoughtful letter.