Our piece, Got Produce? Schnuck’s Mike O’Brien Tries To Add “Balance,” brought this commentary from a principal at a search firm focused on food, agribusiness and the life sciences:
Regarding this quote from the letter Mike O’Brien submitted to the Perishable Pundit:
“I don’t know for a fact whether PBH has impacted produce consumption because I don’t know what the results would have been had they not been around.”
With all due respect, it sounds like the government telling you they can’t show the benefit of their expensive and burdensome regulation, but who knows what the situation would be without it?
We appreciate Mr. Medero’s weighing in on the issue and, indeed, we think he points to a key issue regarding any consideration of a generic promotion order for fresh produce: If it was to pass, how would we evaluate whether it was a success or a failure?
To us, Mike O’Brien’s comment deserves praise for its candor. Neither Mike, nor anyone else, can state definitively if the work and money spent by the Produce for Better Health Foundation has increased consumption because there is no control group, not exposed to PBH, to compare against.
Now whether this lack of ability to ascertain success or failure leads one to say, “keep going,” or “cancel the program,” seems to be mostly a matter of personal disposition.
To us, the past is the past… the bigger issue is what are we doing to ensure that this much larger generic promotion program is created in such a way that success or failure can be verified.
To put it another way, if it were to pass and then in three years or five years we had to vote to renew the program or cancel the program, on what basis would we determine if the program had succeeded or failed?
Part of our disappointment at the proposal for a new generic promotion program is that it provides no metrics for any future evaluation.
In fact, as Mr. Medero’s letter alludes to, the future is very predictable: When the time comes to vote to renew the generic promotion program, the advocates will urge a ‘yes’ vote. They will do this no matter what the state of consumption. If consumption has gone up, they will claim, without any evidence, that it was their program that brought about the increase in consumption.
Should consumption be flat or have fallen, the advocates will claim, once again without any evidence, that the situation would have been much worse without their program.
This is not a very business-like approach to an expenditure that over the next five years would involve $150 million!
At an absolute minimum, we need good studies done of what consumption can be expected to be in the absence of a generic plan and then we need legitimate, third-party academic projection of how this plan is expected to alter these numbers.
If the projections don’t show improvement sufficient to justify the program, that is an excellent reason not to proceed with the program.
If the program proceeds, at least we will have established metrics against which its success or failure can be assessed.
Many thanks to Fred Medero and Kincannon & Reed for helping us think through this important issue.