We received a letter regarding our piece Pundit’s Letter To The Signatories Of The Buyer-led Food Safety Initiative in which we challenged the buyers to insist upon more rigorous standards than are proposed in the current draft Good Agricultural Practices (GAP) document:
Regarding your open letter to the buyer group:
If the buyers were to settle on a set of more rigorous standards would they be the correct standards for other commodities, locations or for next year?
No simple solutions like turn up the heat and leaving the patty on the grill longer exist here.
Normally we get less desirable results the further the decision making is removed from the action.
That does not mean that buyers are helpless to act. Buyers are in the business of creating internal and external incentives. They do it routinely for price, quality and reliability of supply.
Safe production practices are unfortunately more difficult to quantify. Buyers have the task of finding that “measure” and incorporating it into their buyers’ routine.
Addressing food safety unlike; price, quality, reliability or even sustainability or social accountability, is compounded by the fact that success is not measured by the progress of the average supplier. It is the exception that provides the measure of success or failure.
Finding and removing those operations that increase risk is the standard of due diligence. No small task in an industry with a complex supply chain.
How would the buyers confirm the implementation of the new standards throughout their supply chain?
Confirming compliance with safe practices in the fresh produce industry is a data management problem.
— Robert F. Stovicek, Ph.D.
Bob zeroes in on important and relevant questions:
The phrase “the price of liberty is eternal vigilance” has been attributed to Thomas Jefferson but it is Bob Stovicek who points out to us that food safety requires no less.
The attention being paid to lettuce, spinach and other leafy greens still leaves potential problems with tomatoes, melons, green onions and other produce to be dealt with. Rules that apply to Salinas may not make sense in New York state. Science and situations change, and standards have to change with them.
So the institutions set up to keep these standards current and to develop standards for other commodities and places do matter … a lot.
Yet, it strikes this Pundit that these particular GAPs for spinach, lettuce and other leafy vegetables are an important test.
If — with all the attention paid, the industry wide damage suffered and other difficulties — we can’t do this one right, it seems unlikely we will suddenly do other commodities and other places right.
- With all the comparisons to the beef industry, including the Buyer-led Food Safety Initiatives’ call to emulate the Beef Industry Food Safety Council (BIFSCO), it is important to remember that whatever the problem with the beef supplied to Jack-in-the-Box, the proximate cause of that outbreak was insufficiently cooking the burgers. We will have no such simple solutions to produce industry issues.
- Results often do deteriorate the further they get from the scene. However, we would say that if GAP standards are set as minimums and each grower is obligated to perform a HAACP analysis, the worst result would be added expense — some unnecessary testing would be done and some land unnecessarily left fallow. Although inclusion of the idea we ran yesterday, A Suggestion To Improve The Draft GAP, which recommended a risk analysis-driven food safety protocol, might reduce this waste.
- Bob’s way of thinking about the role of buyers is compelling: Buyers are in the business of creating internal and external incentives. They do it routinely for price, quality and reliability of supply. He also is absolutely correct to say that food safety poses special difficulties. Still, the buyer has to decide what to buy. So the buyer will either abdicate this responsibility and say, “We buy only legal product,” or he will assume the responsibility as best he can. Clearly few buyers relish this responsibility on food safety. That is why they punted the job to the associations. After all, they could have just declared new standards on what they would buy.
- The exception being the measure of success is often true today for big operations. Wal-Mart can hire 10 million people and all of them can be happy, if a few hundred or a few thousand are cheated, discriminated against, not paid overtime, forced to work off the clock, that is what makes the front page.
- The complexity of the supply chain is a problem and, in the end, one of the key questions the industry will resolve is whether or not the current lateral trading environment is sustainable. It may well be that asking to be able to buy any produce from anyone and know it is safe is just too high a hurdle. Already in the Draft GAP document there is a deviation from this type of market. At many cases in the GAP it says that if various conditions exist, the land will not be suitable for ready-to-eat produce. It could however be used for regular produce. This means though that no processor can ever fill a short without having the product certified as meeting the ready-to-eat standard.
- Fortunately, the last dilemma isn’t a dilemma at all. Confirming compliance is a snap. You call up Primus or one of a few other reputable firms and ask them to “make it so.” Though it would help if the ultimately adopted GAP did pay more attention to data management and required more than the mere retention of documents.
Many thanks to Bob for sharing his analysis with the entire industry.