Much attention has been focused on the Buyers’ Initiative for Food Safety, which was conceived by Tim York of Markon Cooperative and David Corsi of Wegman’s Food Markets — and which we dealt with here. The initiative gained added support when Gene Harris of the Denny’s Corporation expressed support right here. Gene’s addition to the list of signatories means we have the full panoply of retailers, distributors and operators with big names from the buying side supporting this proposal:
Greg Reinauer, Amerifresh, Inc.
Frank Padilla, Costco Wholesale
Reggie Griffin, Kroger Company
Tim York, Markon Cooperative
Ron Anderson, Safeway, Inc.
Gary Gionnette, Supervalu Inc.
Mike Hansen, Sysco Corporation
Gene Harris, Denny’s Corporation
David Corsi, Wegman’s Food Markets
Although we felt the signatories deserved great praise for proactively trying to advance food safety in the trade, the Pundit was skeptical about how the proposal would be received and concerned about its practicality.
To date, no trade association has made any statement concerning the proposal, including whether they intend to meet the deadline the buyers gave, and the buyers have said nothing beyond their initial letter about what will happen if that deadline isn’t met.
We’ve written pretty extensively, including a recent column in PRODUCE BUSINESS magazine, urging buyers to take responsibility for food safety. One difficulty with this particular proposal is that the decision was made to work through our industry trade associations.
This is normally a wise idea but, on food safety, it probably is a bad idea because, truth be told, the growers shouldn’t be involved in setting the standards.
That is a shocking statement, maybe even a little cruel, as the growers are the ones who have to live with the standards, but, inevitably, in the discussions that ensue, the proposals will get watered down as growers fight for their own interests.
It is not just growers; it is true with everything as it is the nature of committees with diverse members that have diverse interests. As an example, Bryan Silbermann of the Produce Marketing Association and the Pundit had a recent discussion on the product produced by a special PMA task force on transportation, specifically trucking. The Pundit found the proposal strong on examples of “best practices” but weak on mandatory requirements or policy changes. Why? Because the solutions to the problems of trucking in the produce industry were solved by a committee of diverse people.
So, you start out with a committee charged with finding a solution to a problem, such as a shortage of trucks willing to haul produce. The very knowledgeable people on the committee identify a cause of the problem, say that truckers are not unloaded quickly and are detained unreasonably. A bright person on the committee then announces a solution: All trucks must be unloaded within two hours of an appointment time or the truck must be paid money for each hour delay beyond that.
That sounds like a triumph: committee given problem, committee identifies the cause of the problem, committee figures out a solution to the problem.
Except, typically, someone says no. The hand goes up, and if they are honest they say it: “No, we don’t have enough warehouse space and we use the trucks as additional warehouse space so that would cost us way too much money.”
And in the end you wind up with a watered-down compromise.
Now this is no big deal on trucking; nobody dies on that issue.
But the exact same process gets involved if growers are sitting in on the negotiations over food safety. And what should be a science-based process gets corrupted by the parochial interests of individual growers. So someone makes a proposal that nobody should grow spinach within 500 feet of a cow, and the guy whose ranch is 400 feet from the cow sets his site on negotiating a change in that requirement not for food safety reasons but because it suits his economic interest.
This is not hypothetical. It is the true story of why the regulators so lacked confidence in the spinach industry that, in the face of the E. coli outbreak, they felt the need to shut down the industry.
The shocking thing about all the food safety action plans being proposed now is that it was only April 25, 2006 — just six months ago — that the Commodity Specific Food Safety Guidelines for the Lettuce and Leafy Greens Supply Chain was published. Yet now we are suddenly told that there are lots of things we should be doing that aren’t included in those guidelines. How is this so?
Well, during the two-year process it took to negotiate this document, it got watered down. In fact, it took TWO YEARS and then only got done because the FDA published a Letter to California Firms that Grow, Pack, Process, or Ship Fresh and Fresh-cut Lettuce, and that letter was pretty overt in warning the industry to stop the delaying tactics:
“…claims that ‘we cannot take action until we know the cause’ are unacceptable. We believe that there are actions that can and should be undertaken immediately to address this issue.”
Obviously, grower/shippers have many technical experts on staff, and we may want to access some of that staff. But there are non-affiliated technical experts as well at universities and consulting firms.
Fundamentally, though, food safety standards should be determined based on science and not under the influence of any particular grower’s economic interests.
Now that the Western Growers Association has announced its desire to see a mandatory food safety regimen imposed, the industry needs two things: An actual plan of what might be included in the mandatory food safety regimen imposed by law, regulation or a marketing order and interim food safety standards that can be used until the legislative and regulatory process runs its course.
Here is where the Buyer’s Group could find its glory in service to the industry. In the initial letter, Point 10 was written as follows:
Due to the urgency of this matter — its current and potential impact on public health — we expect that the major components of this process can and will be accomplished by December 15, 2006. If this is not the case, our options include fast-tracking our own working group to establish a meaningful certification program with objective criteria.
Here’s the Pundit’s suggestion to the buyers: Don’t wait for the deadline to pass. Withdraw the letter to the associations, which can only lead to endless negotiations with grower/shippers and watered-down food safety standards. Instead, create a temporary ad hoc consortium to spearhead the quick development of science-based food safety standards.
In the short term, these will be enforced by buyer demand, hopefully including other buyers who will buy into the plan; in the medium run the plan will be turned over to state authorities in California and federal authorities in Washington, D.C., as the basis for new mandatory regulation.
Because this new initiative will have been developed by buyers without economic interests in farming, it will be perceived as more objective and acceptable to regulators than any plan drawn up by, say, WGA. And because buyers have the ability to act faster than the U.S. government, we can start the process in six weeks, not two years.
Although some grower/shippers may object, anything that quickly rebuilds consumer and regulatory confidence in the system is really in the interest of the whole supply chain, growers included.