We’ve been focused lately on the plans of the National Restaurant Association to address produce-based food safety issues. Most recently right here.
There are some real concerns:
- Although the industry has been working for months on a new Good Agricultural Practices document and has both kept NRA specifically informed about the progress of this effort and has posted that document in numerous places to encourage feedback, the NRA has provided no feedback.
- This lack of feedback is troubling because one presumes that if the scientists who work for NRA or its members had substantive critiques of these draft GAP documents, they would point them out so that the industry could revise the GAP documents.
- Yet NRA has said they are going to announce new standards that its members require of suppliers. But if it has no scientific or substantive critique of the industry draft GAP, then any new standard would be superfluous, just a way of being “safer than thou” by demanding arbitrarily higher standards.
- Whatever it is that NRA is ultimately going to suggest to its members, the timing seems off. The plan is to present new standards at a conference at the end of March, but this is too late to have any influence on the Salinas season. This seems problematic in two senses: First, the mere publication of new standards at that moment will doubtlessly be picked up by the consumer media who, just as predictably, will point out that the current production does not meet these new standards. This means that consumer demand will take a blow as consumer media report sub-standard food safety practices. Second, NRA would be putting its own members in a situation of enhanced liability as these restaurants would be compelled to buy product — the only product available — that did not meet the new NRA standards. If there should be an outbreak, the NRA members would be utilizing ingredients their own association had warned might be unsafe.
There is some talk that NRA has changed plans and now is thinking of just unveiling draft requirements at the conference. But NRA is being mysterious and is unwilling to confirm that to be true.
In any case, nobody should be holding back on food safety ideas to sell tickets to a conference. If NRA or the Food Safety Leadership Council, which is drafting the NRA proposals, actually has concerns, they should be discussing them with the people working on the draft GAPs right now. The whole point is to discuss these things before positions harden. The minute NRA “unveils” something at a conference, it has something to defend — and defensiveness won’t produce food safety.
The sad part about all this is that NRA actually has a big role to play in food safety… and its energy focused on produce is really a tail-wagging-the-dog scenario.
Sure inputs are an issue and NRA has a perfect right to look to defend its member’s interests in a good quality safe supply of food.
But the real win in reducing foodborne illness at restaurants is not on the supply side at all. As the FDA wrote in FDA Report on the Occurrence of Foodborne Illness Risk Factors in Selected Institutional Foodservice, Restaurant, and Retail Food Store Facility Types (2004):
The data presented in this report indicate that the same risk factors and data items identified as problem areas in the 2000 report remain in need of priority attention. This indicates that industry and regulatory efforts to promote active managerial control of these risk factors must be strengthened. In all facility types, the Out of Compliance percentages remained high for data items related to the following risk factors:
- Improper Holding/Time and Temperature
- Poor Personal Hygiene
- Contaminated Equipment/Prevention of Contamination
Put another way, the big risk at restaurants is not unsafe inputs. It is what they do with the food once they get it — improper storage, workers who don’t wash their hands, dirty equipment, etc.
Now NRA’s Educational Foundation does have a great program called ServSafe that is designed to help with all this but, unless a municipality requires it, it is strictly voluntary. And in many cases, even where it is required, there is no refresher course ever required.
What if the NRA made a “Code of Conduct” for its own members that required each operating unit have a ServSafe-certified manager on duty every minute that facility is open? Further, what if to be certified required continuing education every two years?
Then consumers could look for the NRA membership logo as a reason to prefer to dine at NRA-member restaurants.
Initially NRA might take a membership hit but, over time, as consumers recognized the meaning of the NRA logo, more restaurants would see real value from being an NRA member.
One thing is certainly true: Assertive actions to improve restaurant operations are far more likely to pay off in reducing foodborne illness than anything NRA will do with the produce supply chain.