Our piece, Pundit’s Mailbag — Eye-Opening Visit To China’s Garlic Growers, has caused much controversy and brought this letter from a well-recognized force in food safety:
I was fascinated with, though not surprised by, the letter from Roger Niebolt regarding garlic handling in China. As someone who has worked in produce all over the world, I also have many horror stories to tell. But my real purpose in writing is to validate your comment concerning your experiences in the Caribbean and the importance of control.
We in the produce business are all accustomed to the idea of quality control, because quality is what we sell. But we have also grown accustomed to outsourcing our concerns about food safety so that we rely on a certificate or accreditation to assure us of the safety of our products. While this may once have adequately served the purposes of covering our rear ends and facilitating the deal, it is now necessary but insufficient. Anything less than control of our food safety systems won’t do.
Accreditation is well and good. But in many parts of the developing world accreditation and certification are for sale. I have been in food facilities in Eastern Europe that proudly display their ISO Certification documents in the entryway. But when touring the facilities, it became very clear that they could not possibly have completed the stringent ISO requirements of continuous improvement, attention to detail and documentation.
In short, they were filthy and disorganized. They probably purchased their certification. Unfortunately this is all too common in much of the world. Be suspicious of certificates. They are only a piece of paper, and a piece of paper never prevented a food borne illness outbreak. Even when the certificate is legitimate, some certifying organizations, government or private, have little experience with produce food safety and microbiology. Produce really is different, and the microbiological principals that pertain to meat, fish, poultry and other foods often do not hold with produce.
Firstly, and most importantly, know your suppliers. And know their suppliers. Know who they are, how they approach food safety, the level of their commitment to food safety, and their actual food safety practices. Are there staff members with knowledge and training in food safety or is the head of maintenance in charge of food safety? Do they have a living, breathing food safety program, or did they download it off the internet? Visit them and find out.
Secondly, know your food safety partners. What is the education and experience of your auditor? Does your auditing company actually do the audits, or do they outsource the job to somebody they don’t know or control? Do your suppliers’ auditing companies outsource the job? Who is in control and what quality standards are in place within the auditing company? How much experience do they have in the fresh produce business? The same holds true for testing labs. What experience do they have in fresh produce?
Thirdly, invest in food safety knowledge and training. Knowledge and understanding are your best defense. Each time there is a food borne illness outbreak associated with fresh produce we learn new things. We now know that flooded land can be hazardous; that feral pigs in riparian areas can be a risk factor; that feral pigs like to eat grapes and so the proximity of vineyards can be a risk factor; that mixing pesticides in spray water will not kill pathogens in that water; that E. coli can survive in soil for months; that organic produce is not inherently safe simply because it is organic, and on and on.
We may not have been as aware of these things a few years ago, but we are now. If we fail to comprehend and learn from our failures, we will not improve. And lack of improvement is the surest way to lose the confidence of our customers. Shame on us if we repeat our mistakes. Invest in food safety, invest in training your people, and understand the risks in your operation so that you can address and minimize them.
And thanks for mentioning Davis Fresh Technologies in your column. We are now NSF Davis Fresh since we were acquired last year by NSF International of Ann Arbor, MI. We are now a sister company to Cook and Thurber, QAI, and soon another European audit company. This association greatly increases our global reach and the breadth of services that we can provide while maintaining the high professional standards that have always been the source of our pride.
— Devon Zagory, Ph.D.
Senior Vice President
Food Safety & Quality Programs
NSF Davis Fresh
We appreciate Devon’s letter. It echoes a piece we ran in the midst of the spinach crisis entitled, Pundit’s Mailbag — Grower/Shipper Calls Buyer-Led Food safety Initiative Hollow Call To Action, which included this phrase:
Food safety is like flavor; to successfully deliver it you must have commitment and control in an aligned supply chain. The commitment required is to hold food safety (or flavor) as a core value. The control can only be asset-based. The parties involved must have control over the assets necessary to execute daily. These assets are obvious from the shipper standpoint, and from the buyer side it is control over the PO’s.
It is the fact that foodservice buyers often purchase a limited number of items on a contract basis that gives foodservice the opportunity to have an aligned supply chain, and this, by reputation, leads to a safer product. To explore this further, we did a series of interviews with foodservice executives, which you can review here.
The Taco Bell problem last fall demonstrated that even a highly aligned supply chain is no guarantee of safety. Since we had been preaching the benefits of alignment, we were called on this in a letter by Alan Siger of Consumers Produce Co. We responded that the large scale of these operations distort the statistics and, anyway, an aligned supply chain can be aligned for many purposes — to drive costs out of the system, increase flavor, enhance food safety, etc.
So while an aligned supply chain doesn’t guarantee safety — in fact if aligned to reduce costs, it could serve the opposite cause — alignment in favor of food safety seemed the most likely way to produce food safety. You can read the exchange here.
Devon’s letter is helpful because if you want to understand the industry efforts on food safety since the spinach crisis, it is best seen as a battle between aligned supply chains and forces looking to preserve traditional ways of operating.
The whole California Leafy Greens Marketing Agreement is, in fact, a mechanism to allow buyers to purchase from anyone and thus preserve traditional trading mechanisms. Fresh Express resisted signing the agreement before relenting, in part because the vision of the industry Fresh Express preferred was one where buyers sought to align themselves with the companies that have the best food safety practices. Fresh Express had that reputation and so, in theory, would benefit.
The challenge with Devon’s letter is that much procurement is not of that aligned supply chain form. Our interview with Dan Crimmins of Notre Dame illustrated clearly that Notre Dame, along with countless others, was buying through distributors and wholesalers and had no ability to research to the source. He certainly had no ability to audit the auditors.
Even highly aligned supply chains get broken because of crop failure. So we really need an aligned supply chain with an aligned back-up plan.
And how many buyers have this expertise anyway? Should every wholesaler on Hunts Point hire a PhD to send off to fields from New Zealand to the Netherlands? And where will all these food safety experts come from? PMA has been looking for a star for months and hasn’t been able to catch one.
Devon’s report of certifications being sold is, of course, frightening. Though it’s not surprising. The value of a certification can be millions in business, so corruption is inevitable. So what step is the food safety community taking to stop this completely predictable occurrence?
Devon’s urging of buyers to know a lot about suppliers is wonderful — if we are talking about Wal-Mart or McDonald’s. Yet, surely, we need a mechanism by which Notre Dame or a fruit store in Brooklyn can have safe produce as well.
This seems to imply that the focus of government should be on doing undercover work to prevent the sale of certifications as well as preventing counterfeiting — which, as we discussed here, here and here, deceives consumers and the trade.
In other words, Dan Crimmins should be able to get an assurance from a distributor that every raw product he purchases is certified to a set standard such as EurepGAP and that every processing plant is certified to a set standard such as operating to British Retail Consortium standards. And he should know that these certifications mean something.
Devon’s letter is a reminder to the industry that we can’t take representations of food safety for granted. For large buyers with aligned supply chains, Devon lays out a path to food safety. As for the rest of us… this is what deliberations on food safety are really all about.