Here at the Pundit, we have scoured the world looking to learn what we can about food safety from other countries. We have sought information as far as Australia, but a primary focus has been the United Kingdom.
We have spoken with a private processor and to Jo McDonald of the British Retail Consortium (BRC) here. Now we have asked Pundit Investigator and Special Projects Editor Mira Slott to speak with Kaarin Goodburn:
of the U.K.-based
Chilled Food Association (CFA)
Q: Jo McDonald of BRC says the CFA plays a critical role in advancing food safety in the U.K., and serves as a companion to BRC’s post harvest initiatives by addressing field and growing operation issues. What is the organization’s background and purpose?
A: The Association was formed in May 1989 to set and maintain food safety hygiene sectors for the industry to protect consumers. The action came out of lysteria outbreaks in 1988. The government said to the industry unless you sort out food safety problems internally we’ll legislate regarding lysteria. So an association was brought together rapidly.
Q: By whom?
A: The industry had existed for several years. Companies were producing fresh, value-added, ready-to-eat foods and chilled product that required cooking or re-heating, but hadn’t formed a coherent organization. People were working in isolation.
In the retail sector in this country virtually all product is private label. Our members manufacture the products sold at retail. We also have some members from food service but this is not our focal point. It’s the retail prepared food industry. Twelve thousand products are made everyday by our members including direct bagged salads, leaf lettuce products, crudités, stir fry kits, sandwiches, fillings, pizzas, ready meals, meal kits, accompaniments. All chilled prepared foods, not frozen items.
Q: In the U.S., we have value-added, fresh-cut produce products made by processors, some vertically integrated with growing operations, that are members of IFPA now merged with United Fresh. Then, separately, companies that make deli prepared food products like potato salad, carrot raisin salad, pizzas, and other grab & go items are members of the Refrigerated Foods Association. To clarify, CFA members include both sectors?
A: Yes, prepared produce companies (many of which grow their own produce) and further processors are members. Florette (Soleco) is a member, as is Bakkavor, Vitacress, Natures Way Foods, and Del Monte. Listing of our full members can be found here.
We’re not looking at the wholesale world at all; the relatively uncontrolled traded stuff sold on the open market. Anyone can buy it. Green grocers would go to a wholesale market, but that product won’t come from dedicated suppliers.
Q: Is food safety for the wholesale world regulated by the government? Is there evidence consumers refuse to buy at green grocers because they feel chains are safer?
A: Wholesalers are food business operators according to EU law (178/2002) and hygiene and food safety liability rules apply. Safety is largely a matter of perception. There are very few recalls related to ‘green grocers’, possibly since the traceability is not good enough to trace back. However, there is a political drive by a vocal but still relatively small proportion of the population to favor local stores/suppliers/produce, which drives toward green grocers, some of whom have taken the marketing initiative in some cases to capitalize on this and make local sourcing a unique selling proposition. However, few green grocers sell prepared produce — the market is set up around the multiple retailers.
Q: Do any of CFA’s members sell to green grocers as well as to the major retailers?
A: No, not that I am aware of.
Q: Do CFA members have to abide by the organization’s food safety standards?
A: Yes. Membership is linked to adhering to CFA’s food safety guidance and getting accreditation for doing so. This includes main factory standards, best practices guidance, and microbiological guidance to growers. Members have to have audits of their factories. They have to commit to complying with all the other food safety guidelines related to field and growing operations.
Q: So manufacturers have to insure CFA standards are being followed by the growers of their product ingredients?
A: This is a prime purpose of the CFA standards — to be applied by members throughout their supply base.
Q: Do these CFA standards apply outside of the UK?
A: Yes, internationally to raw materials used by members, since microorganisms respect no geographical boundaries!
Q: Do you require members to submit audits of their operations and of the growers they work with?
A: This is built into the approvals system. They would not be able to do business with the major multiples without this.
Q: I had an interviewwith Mark Newton of Florette following the company’s incident with salmonella in watercress it procured from Florida. Mark said that Florette had audited that field in the past, but after the incident was taking additional actions to improve food safety with products sourced outside the country. If a company wasn’t guaranteeing CFA standards with its growers, would they still be allowed to be a CFA member?
A: I saw the interview. If the relevant certification is not maintained (e.g. BRC, International Food Safety), then membership is not possible.
Q: Could you provide CFA’s guidance documents so that our readers can examine the protocols more in depth?
A: Here is the comprehensive guide to microbiological regulation and food safety standards to be implemented. In addition, I’ve appended a top level summary of CFA’s activities in relation to fresh produce since CFA was founded.
Q: Do you think it advisable for U.S. food industry organizations to limit membership based on compliance to a set of food safety standards?
A: I’m not sure that is legally allowed in the U.S. I believe it is in conflict with U.S. anti-trust laws to restrict membership like that even though doing so is in the consumer interest.
Q: Do retailers belong to CFA?
A: Our members are manufacturers. No retailers allowed. This is a private space for the food manufacturing sector in this country.
Q: In the U.S. many retailers, such as Kroger, Safeway, etc., own food manufacturing plants. Even more operate commissaries where they cook prepared foods. Some prepare in-store products such as cut fruit or deli salads. Is there overlap sometimes?
A: Major retailers are not preparing these foods in store — the hygiene requirements set out in the Best Practices Guidelines for the Production of Chilled Foods are challenging enough (e.g. segregation) for a manufacturer, let alone a shop. Major retailers are not growers or packers of these foods in the UK.
Q: Why no retailers as members?
A: We have a lot of openness in our meetings, freedom to express issues, a forum to exchange information and experience. No one is competing on food safety brands. Retailers rely on the technological expertise of growers. This has been a great change in the last 15 years — retailers working with suppliers on food safety rather than just mandating it.
The retailers don’t own the fields. Suppliers have the ultimate responsibility for food safety. CFA wants a private space for manufacturers. There are other organizations for retailers. We don’t want commercial issues to cloud our purpose. We don’t want to get sidelined in working out food safety. Retailers have the ultimate decision, but in regard to technical expertise they count on manufacturers to have safety in place; there is no guarantee they will be in business otherwise.
Q: Do the retailers go along with the food safety guidelines set by CFA members? Do they find these sufficient?
A: Tesco bought copies of our micro guidance for growers for their supply base. Other retailers incorporate our food safety standards into their supplier requirements, a cross pollination type of approach.
We’re working with retailers, and speaking with retailers on microbiology and other issues. We’re all very close but we have this private space for manufacturers at CFA.
Q: You say manufacturers are ultimately responsible for food safety? Are you talking about ethical and/or legal culpability? What responsibility do retailers have here? Do UK retailers have more at stake if there is a food safety outbreak since most of their product is private label?
A: Under European law both suppliers and retailers as business operators carry legal responsibility for food they sell.
Responsibility for food safety in UK law lies with the manufacturer and some is shared with the brand owner. The manufacturers are culpable ultimately because they are the ones producing and packaging the product. Here if something goes wrong, generally the retailer name goes on the recall notice. Sometimes the manufacturer name goes on as well, but often the retailer brand name is what is prominent and recognizable to the consumer.
It changes everything if you put your name on a product. It means it’s your product; it meets your standards and you are confident in your supply chain.
We have a totally different retail market here with four or five big retailers in control of the market. In the U.S. you have big names, but also local chains, more ma and pa operators, a much more fragmented system than we have here. In the U.S. you won’t be able to set up dedicated growing bases and supply bases as easily as here.
Q: In the U.S. there is much discussion about containing food safety problems by developing a more efficient and accurate traceability system. Is this less of an issue in the U.K because of your concentrated supply chain?
A: We have instant traceability when a food safety problem is discovered, with the ability to check back quickly to which field the product was grown, when fertilizer applied, what pesticides, what the weather was like when harvested, the water used, etc. All information relevant to food safety is logged in. The reason we do not have big issues here is because of built in traceability, supplier assurances, dedicated bases, all controlled from the seed onward. All growers in these dedicated supply chains have to comply with the same field standards.
Q: What if there are supply/demand issues, weather problems, etc., and retailers need to supplement or replace product from other sources? Are all these sources complying with the same food safety standards? Aren’t there instances that break the dedicated supply chain?
A: While we hope to see local UK product on the shelf, importing is something that is done all the time. If there’s a problem related to dreadful weather, for example, retailers make sure product is brought in from pre-approved sources. They have contingencies, plans built in to prevent food safety breaches. It’s a matter of reputation.
penalties for food safety breaches in the U.K. are extremely high; for one hygiene failure it can cost the company an equivalent of $40,000 U.S. in fines. But this pales into insignificance compared with the real penalties — reputation loss, negative media coverage and potentially the loss of ability to stay in business.
Q: The media’s coverage of food safety issues in the U.S. produce industry has escalated since the spinach E. coli crisis hit last September. What impact does the U.K. media play?
A: Media covers everything related to food safety very heavily here. We’ll get the same kind of coverage as what happened with the spinach crisis for smaller food safety issues here. It’s all tracked by the media. Food safety is a really high profile issue in this country.
Everybody goes down if a mistake is made by even the most insignificant company in the market. At the CFA, we don’t deal with freely traded commodities. All food comes through a controlled supply chain.
A working group of about a half dozen companies started food safety hygiene guidelines, officially launched in December of 1989. It was not just enough to have standards, but to show they were being complied with, so a system of auditing was instituted.
Q: How do CFA food safety guidelines and audits relate to what BRC does? Are CFA field requirements/audits comparable to post harvest initiatives through the BRC?
A: On the field side, we have a national scheme, EurepGAP, and our own CFA standards/microbiological guidance for growers, and we harmonize with retailers on that. We bring it all of it together and make the most sense of it and provide a common approach to catch everybody.
Q: Tell us more about your auditing procedures. In the U.S., suppliers can be inundated with audits from different customers, which can lead to duplications and unnecessary costs. The BRC created common standards and auditing procedures to address this issue. Does CFA do the same on the field side?
A: When we researched the audits concept originally (for factories), we asked what became of The European Food Safety Inspection Service (EFSIS) to establish itself. Now EFSIS is an international auditing company, which grew out of our working group in 1989. EFSIS was formed by Campden & Chorleywood Food Research Association and The Meat and Livestock Commission working together quite independent of anybody to audit the standards we wrote. CFA was committed from the outset to the whole concept of chilled food manufacturing hygiene and audits and accreditation.
Q: Is this auditing going back to the fields?
A: Here we have several levels of auditing. There is auditing done by local authorities looking at the legal aspects — that’s government monitoring, then third party audits people pay for against CFA standards or other standards. There are the company’s own internal audits all the way to the fields as well. Then there are the customer audits and retail audits. So you really have four tiers of auditing.
Q: That doesn’t sound like you’re consolidating auditing procedures, if anything quite the contrary.
A: We go through cycles from where we were 15 years ago. Once we set up auditing, a few years later we had a big auditing boom, where a man and his dog said, ‘I’ll audit’. Who audits the auditors when there are so many audits going on here? Then these divergent approaches were sewn together through BRC. Largely their members, the retailers, had been doing their own thing, asking for different things, and then third party audits were turning up, plus internal, plus government auditing. The retailers pooled together for BRC standards and general principles.
Separately there are long standing efforts to get more focused on food safety in the produce industry and assure produce hygiene standards. The National Farming Union has helped get more food safety measures in place. Food safety is a national theme and it relates to EurepGAP. You don’t get there overnight. You have to carry people with you; it’s the classic buy in from the top or you won’t get anywhere.
Negative publicity is a real business killer; that’s a real driver. You don’t want to see any problem in any part of world. If a UK consumer reads about a food safety problem with produce in another country, they figure it is dangerous in this country too.
Accreditation auditing started out with factories, and then in the last decade or so started focusing on the field. I remember a trigger point was a Chicago lady dying from red leaf lettuce around 1995. We started to ask questions. What can you do to lettuce to make sure it’s right in the field? If it’s ready to eat raw, it’s got to be right in the field.
Q: Can you really guarantee elimination of bacteria and pathogens in the field with so many variables? Growers in the U.S. feel the emphasis has become too weighted to field issues and processors/manufacturers need to take more responsibility. Some argue the only kill step for deadly pathogens infiltrating fresh, uncooked produce is irradiation.
A: Retailers in this country don’t want to do irradiation because of consumer resistance. There is a lot of pressure in this country to do things completely naturally. Consumers are not willing to eat irradiated food knowingly. There are different attitudes with GMOs here too. Consumers are quite sensitive in the U.K. compared to some other member states in Europe. There has been talk about irradiation for the last 20 years, but it hasn’t come to be because there would be an outcry here. In the UK, we have never had an E. coli outbreak with produce. We haven’t had to resort to irradiation because we have effective food safety measures.
If a pathogen gets in or on the leaf, there is no magic ray gun to kill it. In this country people don’t want to eat irradiation, so the solution is not getting the pathogen on the food in the first place. Yes, there are a huge amount of variables in the field and that’s the challenge.
Q: But you believe the challenges in the field are surmountable?
A: If something has gone wrong with produce, it’s probably something avoidable. You won’t get a single bird causing an outbreak. It seems to be something far more avoidable; contamination of irrigated water or a field in the valley with cows above you. It’s the big stuff that seems to go wrong. Is your field in the right place? We don’t have anything here like your produce fields adjacent to cattle. You just can’t allow ready-to-eat crop in proximity to cattle. It’s a basic problem. It’s wrong.
We had a rare salmonella found in leaf product years ago. The traceability was so good the grower could go back to the field lot number. At first he couldn’t find anything wrong there. But at night he saw lizards crawling around in the fields. The solution was to make the crop less attractive to lizards, drawing the pests away from the crops by making the surrounding environmental area more attractive than the lettuce.
It’s a simple basic ecology. Basic hygiene, but dealing with it on a big scale. The hazards you’re talking about are not complicated. Waste from an animal on to the field is straight forward. We don’t have wild boar roaming around our crops. You need to know what’s out there, what your hazards are and then get rid of them. If you have standards that are clear and simple enough to follow. If the requirements are too complicated and convoluted people won’t do them.
Q: Do you think the Leafy Greens Marketing Agreement addresses the issues?
A: I haven’t seen the final standards, but the drafts of proposed requirements appeared to be so arbitrary. Watching what has been going on with food safety matrix in the U.S. from across the pond has been appalling. One proposed standard of 20 feet separating crop from animals may have been related to the turning circle of the tractor but has nothing to do with food safety. The set of standards for manure use doesn’t seem stringent enough either.
Q: I understand you are putting the finishing touches on updated CFA guidelines. How different are the new measures from what is currently in place?
A: The core guidelines are the same. We’re just updating bits. We’re still writing up whole sections on micro standards, which we’ll be sorting out in meetings in two to three weeks, and we’ll have the final version out by the end of the year. There are some adjustments due to legal definition changes. For example, ready-to-eat is now legally defined. In addition, the guidelines now reference European microbiological criteria regulations that came into effect. There is still a minimum of 24 months to applying fresh raw manure in land before you can drill or grow plant crop. There are all kinds of things about treating manures. This is quite extreme compared with what guys are doing in the states.
We have restrictions related to animal grazing and crop development. There must be a 12 month gap between cattle entering a field and crops being allowed to be grown there. Other strict safety standards relate to seed production and storage, the field and its history for the last five years of use, including adjoining sites, hazardous waste, animal production, sewage, mining, flooding etc. treatment of farm yard manure compost and other materials, animals and birds, field margin requirements. Water irrigation standards. Equipment and vehicles, water systems.
We have a multi-pronged approach here to make sure things happen correctly in the field. People don’t sell cooked lettuce. There is not a particular challenge with accepting and doing things right here; Investments in your systems, in growers, making sure the supply chain is controlled, to have a massive commitment to food safety in the field, that it really means something.
There are a huge number of variables you’re dealing with. If you don’t try to do your best in tracking and logging all relevant information on irrigation water, quality issues, the basics, and following up with audits, you’re leaving yourself quite open to things going wrong and an inability to do the proper traceability.
Growers are really passionate. People have known for decades that produce carries risks with it. I’m afraid we’ve had to look across the Atlantic to see them rise with any great regularity.
If irrigation water is coming from wrong place or being compromised or likely to be compromised because it is in the same locality of a cow, do something about it. No wonder there is less consumer confidence.
Q: There is much discussion here about the government’s role in food safety. What about in the U.K.?
A: The government here is only waking up to what we’ve done. The systems are in place here. The standards are internally measured here. It’s not just a matter of luck we haven’t had outbreaks like September last year in the U.S. I’ve researched E. coli O157 infection rates from food and they are 12.4 times higher in the U.S. than in the U.K.
We’ve never had an E. coli O157 outbreak related to produce in this country. Indeed many of the salmonellas have been imported, and many through the wholesale chain that is not part of our dedicated supply base.
It is a matter of cost and effort to minimize risk. If you’re dealing with a high value salad, there is no reason not to put effort into it. When you get to the wholesale market where value is lower, traceability is more difficult. Sometimes you can’t nail the supplier or market it came through and the problem is lost in the ether.
We’re ahead of the game in regulatory requirements beyond HACCP. HACCP in the field is not a mandatory requirement in Europe. It’s too complicated, politicos say, but we do it. Europe has a bigger population than the U.S. now; with a wide range of countries and economies. Suppliers to UK major multiples are at one end of the spectrum, a small grower in relatively undeveloped economies like some of the new member states on the other. When dealing with European legislation, it’s not as if everyone is supplying Tesco, Sainsbury and Marks & Spencer.
Instead of talking about the need for international standards, let’s sort out local problems in our fields and get them fixed. You can’t get the pathogens off once they’re there. We have to deal with the basic things going wrong in the field causing most of the outbreaks.
Q: So you would find the argument that fields will always be dirty or you can’t control birds flying over the field to be superfluous to the crux of the problem?
A: You can’t get the pathogen off the plant once it’s there. There are basic things going wrong in the field causing most of the outbreaks. Talking about E. coli O157 in bird poop sidetracks the issue. OK, if you have a flock of seagulls nesting in your crop deal with it, but we’re not talking about shooting down one bird. We went through three years or so of birds flying overhead arguments, but it’s just a red herring. Let’s concentrate on the big, basic stuff. It’s going to cost you, but what’s the cost of not doing it right?
Q: Aren’t there means short of irradiation to combat pathogens in the processing plant. For example, some U.S. manufacturers are instituting more sophisticated washing systems.
A: Beware of red herrings and relative importance of solutions. What does chlorine wash really do? Adding more and more doesn’t get the product any cleaner. If you go above a certain level of chlorine it doesn’t make a difference. It doesn’t kill more bugs. More sophisticated research on how pathogens are attaching to the leaves is needed. Chlorine washes do nothing past a certain point. All they do is keep the water clean but they’re not going to eliminate a dangerous pathogen embedded in the leaf.
Spending money on chemicals in food washes is not productive. Chlorine is an issue in the U.K. Retailers here don’t want chlorine to be used any more in washing. There is radical off-the-wall stuff going on with the benefits of washing. This is not a critical control point. Keep handling to a minimum and do the right thing in the field. There is no spontaneous salmonella in a factory. Fields are dirty, but there is a difference between soil and crap. Organisms in the soil are not the pathogens that come from the back of an animal. It is time to put effort into dealing with and controlling the bleeding obvious.
Ms. Goodburn’s forthrightness is refreshing, but on the key question about the relative food safety of fresh produce in the U.K. and the United States, the jury is still out. Yes, as Ms. Goodburn points out, she “… researched E. coli O157 infection rates from food and they are 12.4 times higher in the U.S. than in the U.K.,” but international comparisons are very difficult. If for no other reason than that every country has its own mechanisms for identifying outbreaks.
Remember, it wasn’t until post 9/11 funding for PulseNet that we suddenly discovered we had all these problems in the U.S. — we don’t really know what would be found in the U.K. or Australia or anyplace else if they operated under the same detection systems we do in the U.S.
There are other factors that also make direct comparisons difficult. Traditionally produce was not perceived as a food safety threat because it typically went rotten before it became dangerous. It is the growth of modified atmosphere packaging that lets product look great even if pathogens are growing on it that contributes to our problems. In the geographically much smaller U.K. market, shelf lives are shorter and modified atmosphere packaging is much less common.
And, of course, the prevalence of different pathogens in different countries is probably different as well.
It is also true that whatever the standards, there is some doubt about how they can reasonably be implemented in a worldwide supply chain. When inclement weather hits, a new source of supply is needed — fast — and, doubtless, CFA members try to buy from good and reputable companies, but they just won’t have the time to make sure the particular field they are buying from was audited to CFA standards.
There are some key points that Ms. Goodburn makes that do resonate:
- One of the problems in the U.S. is that retailers are hesitant to constrain their supply chains to achieve food safety. And under U.S. law, the manufacturer is typically liable for any problems, not the retailer. But start to label everything under the supermarket’s name and the dynamic shifts. The press coverage would always highlight Wal-Mart or Costco or Safeway or Kroger over some unknown manufacturer. It creates a totally different incentive for retailers.
- An integrated supply chain is really the key to traceability. If we want traceability, it is difficult to achieve it if one buys on the spot market.
- Focus on the big issues. Yes, one bird flying over a field might, theoretically, do some damage. But why don’t we take care of the big issues, such as proximity to cattle, instead of using the small things as reasons to not do anything.
- The California Leafy Greens Board should consider inviting people like the CFA to sit on the panel developing new and updated metrics. They have no conflicts of interest and can speak the truth.
At the same times some things in our conversation with Ms. Goodburn raise some troubling issues:
- This group operates only for suppliers to the multiples; it creates a kind of bifurcated food safety system. Shouldn’t all produce sold be grown and processed to the same standard?
- Do the consumers appreciate all this work? On the one hand, we are told of this exhaustive process to obtain food safety, then we are advised that British consumers increasingly want “Organic Boxes” of produce just pulled from the earth, locally grown without any of these standards.
- Opposition to irradiation, to chlorine and other things seems not to be scientifically based. Does an organization lose credibility by pandering to popular prejudice as opposed to trying to educate consumers.
- Is it really true that once the pathogen is on the produce, it can’t be removed? Improvements in E. coli performance of the meat industry are built around changes in central processing plants. Isn’t it more feasible to think we can develop effective processes at our few fresh-cut processing plants, where we have food safety experts on site and we can do testing and monitoring, as opposed to at hundreds of thousands of fields all across the word?
In any case, it is always helpful to hear how things are done elsewhere, and we thank Ms. Goodburn and the Chilled Food Association for so generously sharing their time with us.