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Letters Bring Broader Issues To Surface

Jim Prevor’s Perishable Pundit,
November 15, 2007

The new joint produce association letter to the Food Safety Leadership Council (FSLC) is much better than the one sent by WGA, yet we confess that we suspect all this letter-writing is counterproductive. Letters tend to freeze positions in place and limit the freedom of negotiation. They create public records and put people on the defensive.

We wish Publix had called its top vendors to discuss the matter before sending out a letter, and we suspect that a few well placed phone calls by WGA might have arranged for a meeting without publically embarrassing anyone.

The FSLC letter also raises some broader issues that the produce industry needs to reflect upon:

Minimum Standards

Throughout the battle to get the California Marketing Agreement passed, anyone who objected because they thought their standards were superior to those in the metrics was told not to worry, that these are minimum standards and anyone is free to exceed them.

Did we really mean that?

The flavor of the joint association letter is no, we did not mean that. Certainly the letter identifies some specific problems but there is no sense that just solving those problems would satisfy the production side associations.

The association letter says this: “…this must be a scientific discussion committed to mutual industry efforts to develop and agree on best practices to serve our consumers, not to create a bifurcated food safety system with different groups setting separate and unilateral requirements.”

Yet, of course, accepting the Leafy Greens Metrics as minimum standards means precisely that there could be multiple standards. Not only a bifurcation but a trifurcation and on and on of the market.

In fact there are already multiple standards. Everyone who has wanted to export to British retailers for years has wrestled with higher standards. Selling to Darden or Jack-in-the-Box or McDonald’s has also long involved different standards.

It would be reasonable to seek reassurance that the Food Safety Leadership Council standards are supplemental to the California Leafy Greens metrics, but there is no basis either in industry practice or in the promises made to pass the California Marketing Agreement to prevent either producers or buyers from adding supplemental standards.

All Commodity/All Geography Standards

Yes, the California Leafy Greens Agreement has gotten a lot of play and it has been expanded to Arizona. Many other commodities, including Florida tomatoes, California tomatoes, California strawberries, watermelon, etc., as well as states, such as New Jersey, have had various efforts to enhance food safety.

Bottom line, though, the Food Safety Leadership Council is doing the industry a favor by pointing out that, in most of the country, on most commodities, the emperor has no clothes.

Yes, detailed metrics developed for each commodity and customized to each growing area are the gold standard, but we still don’t even have commodity-specific guidance for critical items such as green onions. From the FDA:

The FDA instituted a Produce Safety Action Plan in 2004….

As part of the plan, the FDA has provided technical assistance to help industry develop food safety guidance for five commodity groups: cantaloupes, lettuce and leafy greens, tomatoes, green onions, and herbs. The guidelines for cantaloupes, tomatoes, and lettuce have been finalized and are available. With FDA assistance, industry work on guidances for herbs and green onions is ongoing.

“Produce safety is the number one priority in CFSAN right now…”

So, with produce safety the number one priority, a major outbreak in spinach that caused an unprecedented industry crisis, and three years of work to establish guidelines — we still don’t have GAPs on 40% of the high risk items.

At this rate, the fact that the produce association letter correctly points out that “produce food safety demands a commodity-specific approach” becomes less relevant as the industry shows absolutely no ability to produce these documents in a timely manner.

Yes, hopefully, in meeting with the Food Safety Leadership Council, the Council members will recognize and respect the work that has been done by the produce trade. Just as important, the produce trade needs to realize that there is an obligation to extend the rigorous scrutiny that lettuce and leafy greens in California have gotten, to the rest of the country and the rest of the list of produce items.

Mandatory, Federal Regulation

First United called, then PMA and United jointly called, for mandatory, federal regulation of the industry. And absolutely nothing has happened. No legislation has been drafted, no bill introduced, no one is being urged to contact their legislators to get it passed, we are not attempting to get an amendment to the Farm Bill to get it through.

Well if we believe this is necessary, it must surely mean we believe that without it our food safety is less certain and secure.

Why should The Walt Disney Company care about our political weakness? If we can’t unify and get it passed, well, that is not a good reason for Disney to not demand its customers be made safer.

The Food Safety Leadership Council standards apply to spinach grown in New Jersey — that is more than can be said for the California Marketing Agreement.

It is easy to blame people who are doing things we might prefer they not do — but we have left ourselves vulnerable on this matter by not moving ahead aggressively with a national plan.

And the dirty little secret of our industry is that we haven’t moved ahead because many growers who have not been implicated in a crisis really don’t want to.

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