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Pundit’s Mailbag — Responsibility To
Provide Clarity

Although we are always pleased to receive letters filled with praise for our work here at the Pundit, we also value letters that criticize our positions.

Very often we find that the written word is limiting, and we sometimes need to restate our case to be clearer. We think we need to clarify a point after receiving this blunt assessment from an important grower:

After reading your articles regarding food safety and the LGMA, I am convinced that your comments have little foundation in basic fact. The reporting is irresponsible, and you should make a better effort to engage people and learn what is really going on.

All of the meetings of the LGMA are public and available for your participation. In addition, WGA has spent considerable time in vetting the metrics with people from all areas of the industry and deserves praise for their efforts.

I hope that you correct some of your misstatements in the future or do a better job of reviewing them before putting them out.

— Bardin Bengard
Bengard Ranch
Salinas, CA

Bardin’s letter seems to be, most particularly, a response to our piece, Consensus From Unknown Experts Leaves Cause To Err On Side Of Caution . In this piece we raised two points:

First, we questioned whether there actually is a consensus in favor of the metrics that have been adopted by the California Leafy Greens Marketing Agreement.

Second, we repeated our call for the California Leafy Green Handler Marketing Agreement to develop a more transparent procedure for the development of the metrics.

In his note, Bardin correctly points out that the meetings of the California Leafy Green Handler Marketing Agreement are public. He also points out that WGA has spent much time vetting the metrics with many people — something that is doubtless true.

We also agree fully that the development of these metrics was an enormous task and that the people who did the work should receive praise for their efforts. In fact, we actually gave an award, The Perishable Pundit’s Unsung Heroes Award, to Hank Giclas of WGA, as well as to David Gombas and Jim Gorny, both of whom were working for United at the time, for taking on the yeoman’s task of putting all this together.

However, despite agreeing fully with Bardin on all these points, we think we were trying to make a different point.

The fact that the California Leafy Green Handler Marketing Agreement Board holds open meetings is not really the point because the board does not draft the metrics. As per the Marketing Agreement:

“Leafy Green Best Practices” or “Best Practices” means the commodity specific leafy green best practices document and the requirements contained therein, prepared by industry scientists, and reviewed by state and federal agencies, scientifically peer reviewed by a nationally renowned science panel and adopted and/or amended by the Board.

So, very specifically, the board is not supposed to develop the metrics or “Best Practices” document. It is merely supposed to “adopt” and/or “amend” them.

There is really no dispute that the metrics were “prepared by industry scientists” and they have certainly been “reviewed” — though that word is different than “endorsed” — by the government. Whether they have been “scientifically peer reviewed by a nationally renowned science panel” is uncertain.

It seems reasonable to ask basic questions, such as who serves on this “nationally renowned science panel,” and merely showing the metrics to some smart people and asking their opinion is a very loose definition of “peer review”.

We have asked pretty obvious questions:

Who is on the panel?

Who appointed the panel?

Do the appointees have conflicts of interest?

What specifically was the panel charged with doing?

Did the panel unanimously endorse the metrics?

Were panel members given an opportunity to file “Minority Reports” recommending changes or improvements to the metrics?

We raised these issues six months ago because we want the industry to succeed. It is not that anyone has to tell the Pundit this information; the problem is that if it is not public, then we can expect exactly what we saw the last two weeks as you see here, here and here from the Food Safety Leadership Council — people who don’t believe in the process the industry has gone through and, therefore are going to make their own process.

Bardin makes the difference of perspective clear when he writes “WGA has spent considerable time in vetting the metrics with people from all areas of the industry.” We believe this, we even think it is important, but we kid ourselves at our own peril if we don’t recognize that most of the world does not consider WGA or people from “the industry” to be credible when it comes to assessing food safety practices for the industry. They see it as the fox guarding the hen house.

One way to deal with this reality is to simply leave it to FDA. An underlying assumption when first United and then United and PMA called for mandatory, national, uniform regulation was that only an FDA-imposed metric, enforced on a national level, under mandatory conditions, would satisfy consumer advocates, regulators, etc.

Since WGA, presumably representing the voice of western agriculture, has been trying to avoid the FDA route, we have spilled our ink — or electrons as the case may be — to plead that the case for the metrics be both so strong and so transparent that if Disney or the Center for Science in the Public Interest or a Congressman questioned the trade’s actions, we could throw down on his desk the report from this “nationally renowned science panel” and prove at an instant that 30 of the most prominent names in food safety science thought enough of this document to unanimously endorse it as the state of the art in food safety.

We also noted that in the industry association joint letter, it went beyond even saying that this one peer-review panel had endorsed the metrics; the letter claimed that the metrics, as written, reflect an “…expert consensus among industry, academia and government…”

We simply asked the question that you can be sure the QA people at Disney, McDonald’s, Avendra, Publix, Wal-Mart or Darden are going to ask. Namely, who makes up this consensus?

See, to us in the produce industry, if we have the Grower Shipper Association of Central California, Western Growers Association, United Fresh and PMA — we feel like we have a consensus. Yet we asked the obvious — if we don’t have on board the Food Safety Leadership Council companies — Wal-Mart, Disney, Publix, Avendra, Darden, McDonald’s — what kind of consensus can we have?

These aren’t trivial companies; these are important, world-class companies. As a collective, the produce industry can stand here and curse them if we want, but it seems to us more useful to question ourselves. Are we conducting the kind of transparent and persuasive process that persuades the QA people of organizations such as these that our food safety efforts are world class?

We also threw out the names of two academic experts on food safety, Dr. Michael T. Osterholm, Ph.D., M.P.H. and Director of the Center for Infectious Disease Research and Policy, University of Minnesota, and Michael Doyle, Director of the University of Georgia Center for Food Safety. These names may not resonate much with most people who grow, pack, buy or sell fresh produce. Yet they are very important people in the field. There is really no question that they would be asked to serve on any “…nationally renowned science panel…” the industry would put together.

Yet, in the article, we pointed out some good reasons to believe that they would not be part of this alleged “consensus” on the metrics. Namely that Dr. Osterholm consults for Fresh Express and, as indicated in this article from USA Today, Fresh Express has adopted the same one-mile buffer zone that the joint association letter and the WGA letter condemn and that Dr. Doyle still won’t eat bagged salads!

We really do appreciate Bardin’s letter. It serves as a great reminder to the whole industry to not assume that the whole world is on the same page. We in the industry, especially producers and marketers of leafy greens, have watched the CMA be born, grow and spread to Arizona. Many, not so close to the issue, are much less informed.

Back in March 2007, when NRA decided to put aside any standards from the Food Safety Leadership Council and adopt the industry’s Leafy Greens metrics, we published an article entitled NRA Adopts Leafy Greens GAP Metrics. The piece included a note we received from a very important produce industry executive who was speaking about the mostly Quality Assurance group in the room:

I sat there shaking my head. First at the total ignorance about the CMA.

I think for most of the people in that room, it was the first time they have ever heard of the Marketing Agreement. Where have these people been? Why were they not hanging on every decision that was being made about the CMA? Why were they not engaged in the process? Why were they not telling their buyers that they needed to force suppliers to sign the MA? Where was National Restaurant Association in the process? Why is there such ignorance amongst their members? PMA and United sent dozens of e-mails, and every produce trade publication covered it extensively.

As far as the Pundit goes, Bardin can be assured we already work hard and will redouble our efforts to understand the situations we confront as an industry.

Many times, however, things that seem so clear to us in the produce industry don’t seem that way to those outside the industry. Part of our job is to help move the industry out of our comfort zone to confront some of these realities.

Many thanks to Bardin for helping us think through this difficult issue.

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