The Pundit is pleased to publish our first letter from outside of the United States:
I have been reading the Pundit religiously, I find the editorials very interesting and thought provoking — at least to me anyway!
I wanted to just clarify one point in the article, U.S. Spinach Still Banned In Canada, dated October 5, 2006. In the piece you reference an interview with Heather Holland and me, conducted by Mira Slott. Twice in the article, Mira quotes Heather Holland as referring to interactions between USDA and CFIA. The protocol in matters such as these is that CFIA deals with USFDA, which would be the federal body with the most similar mandate and jurisdiction.
Whether we may have stated it erroneously or it was possibly misinterpreted, I just felt it was important to clarify that CFIA was principally speaking with USFDA, not USDA. Ultimately, while CFIA did indeed interface with USDA, and California for that matter, the basis of the ultimate decisions the CFIA made were based upon the USFDA feedback. I wouldn’t want folks in industry down there (In the USA) to possibly think the CFIA decisions were totally rested upon USDA shoulders. To be fair to Mira, we were throwing USFDA, USDA and CFIA around in our discussion.
At this point, it is rather moot as much has transpired since, but I wouldn’t want to convey the message that whatever CFIA decided was the end result of USDA interaction with the CFIA. Having said that, in the longer term, it is important to understand this relationship. Beyond that I feel Mira captured our discussions very accurately.
I also have now the time to read your editorial on the town hall spinach meeting held during the PMA. I was quite impressed, as you outlined many significant points. In my opinion, the USFDA needs to be asked some serious questions, in a manner that promotes transparency and facilitates working relationships between industry and government.
We are finding that there is a need to increase the transparency and sharing of information and communication in order to ensure that all parties have the same knowledge to work with. In this case, FDA shaped the framework for everything that followed, including as previously mentioned, the action by the CFIA in Canada.
One thing I would hope does not get lost is the opportunity and need to have a full dialogue with our two governments — both in the same room, for them to outline exactly how they make their decisions and how they involve other federal departments or state departments in their decision making. I know their priority is public health, and not business and trade impacts, but, the risk exists that useful input from other federal (or state/provincial) agencies that would help them in their decision process is being lost.
Perhaps with that input, they might have been able to minimize the broad negative coverage across the whole US industry, which then forced the CFIA action. These wide-ranging actions have had a negative effect in the Canadian marketplace also, and while this may not be an issue for USFDA, it is important to recognize. It is sometimes difficult to dialogue with governments in these situations due to the misperception that industry doesn’t care about public health, (which we do) and only cares about trade.
Consumer health protection should not be an argument against the need to have frank and open discussions between governments and industries. Hard questions are not meant to question the legitimacy of government responsibility; they are meant to seek answers so that we can solve problems.
Industry absolutely has some key issues to address. We have been working on them for some time, and will continue to do so. I also know we all are concerned about the health of our consumers, and the tragic consequences of this past event. Having said that, the message the mainstream media often leave with the public is that we are a high risk industry with a huge and growing problem.
Consider this…from 1990 — 1999, Canada averaged about 106 reported food borne illness cases per year linked to produce. These cases were associated with a restricted number of commodities (mostly imported). With the average Canadian consuming 4.3 servings of fresh fruits and vegetables a day, between all 33 million of us, that is around 52 billion servings a year. While the number of cases is growing and there may be cases not reported, overall it is still an impressive positive performance. It will be increasingly important to begin to quantify food borne illness in North America in order to better assess our performance and where we need to focus our efforts.
My hope is that we can park all of this and work together for meaningful solutions, so we can avoid, to the best of our collective abilities, this type of situation in the future; not only for the public but also the many innocent industry folks who got hurt badly. But, as you said, this does not mean that there may not be other cases in the future. This is an imperfect world, and the pursuit of perfection is a lofty goal.
I only wish we could gain as much attention from the public and our governments for all of the positive contributions this industry makes to the health of Canadians and Americans. Maybe the governments will help us to get that message across; the one they currently appear to be leaving with the public seems awfully skewed to the negative side of the ledger!
I also just noted the Pundit’s assessment of the recent announcement of CFIA’s opening of the market to US spinach. Notwithstanding the fact that some might feel that it was protectionist, I can honestly tell you with 99.99999% certainty that that was never factored in. The rollout here related to dialogue between CFIA and the USFDA.
All I can say is that it goes back to earlier points for an open dialogue between industry and our governments about this whole episode. Perhaps there can be educational learning opportunities on both sides, so we both can do the correct thing in the future? Industry is responding quickly to this crisis. Industry is always willing to help government make better decisions also, if they are open to it. By no means do I mean to imply that they “erred” in their judgment, but at this time without a better understanding of the processes, protocols and inter governmental cooperation (perhaps even stateside), I am somewhat concerned.
A situation like this should not be a government vs. industry issue. Food safety is our number one objective as an industry. If perceptions within some in government are different, then that view should be corrected, as it is unfair to so many out there. The challenge is how to do the very best job we can to address any and all of the real food safety issues that occur.
Cheers, and keep punditing.
— Dan Dempster, President
Much appreciation to Dan for helping to inform us on this range of issues.
First, apologies for the mix up on the acronym. Through the miracle of modern technology, it is all fixed in the archives.
Second, if the spinach and Nunes lettuce situation taught us nothing else, it taught us the danger that can happen when the NAFTA nations aren’t communicating. Dan’s idea for “…a full dialogue with our two governments — both in the same room…” is a great start.
Third, yes, the industry has to address food safety seriously but, as Dan points out, 52 billion servings a year (in Canada) and 102 reported foodborne illness cases is very safe. It means that massive improvements in industry food safety can only have a modest impact on public health.
Fourth, yes, it would be nice to have our accomplishments praised as quickly and loudly as our flaws are attacked. I always try and remember to do that with my children. It doesn’t always work, so we probably shouldn’t hold our collective breath.
Fifth, these things are always complex. The FDA had a basically ridiculous claim and the CFIA called them on it. That was easier to do at a time of year when other spinach was available than it would have been at a time of year when nothing else was around.