What unites the Buyer-led Food Safety Effort, the efforts of the Western Growers Association, the new principles that United Fresh has elucidated and countless efforts by regional, state, commodity-specific and other national groups? One thing: SCIENCE.
The Buyer-led effort explains:
The requirements will be developed with input from and approval by industry research scientists, as well as input from academia and regulatory agencies (whose direction may differ from that of association members).
We recognize the process of developing requirements has and will continue to illuminate areas that require further scientific research; we understand that the initial requirements will be based on current knowledge, but subject to change as science evolves; we expect the associations to have in place a process to keep the requirements up to date based on sound science.
The Western Growers Association is pushing a Marketing Agreement that will require signatories to follow “best practices”:
“Leafy Green Best Practices” or “Best Practices” mean the commodit0y specific leafy green best practices document and the requirements contained therein prepared by industry scientists, reviewed and approved by state and federal agencies, scientifically peer reviewed by a nationally renown science panel and adopted by the Board.
United Fresh is also concerned about the science:
“…a mandatory federal regulatory approach must contain needed scientific flexibility to address specific commodities differently…”
Yet this appeal to science is misplaced. Not only because our scientific knowledge is so limited in these areas, but because, even if we had perfect knowledge, this is mostly a matter of values. It is, in other words, an inherently political choice.
Scientists can help in executing a policy, but the policy itself — the actual choice that must be made — is political; science provides no answer.
This is true in all matters of public safety.
If we make a political decision that nobody should die in an auto accident where a car directly hits a solid concrete wall at ten miles an hour, engineers can design a car that provides that level of protection. We can also tell the engineers that we want 100% survivorship under that test at 20 miles per hour or 30 miles per hour or 75 miles per hour.
But we have to decide, as a polity, what the test should be and what the acceptable outcome is. The engineers can’t tell us whether we “should” have super safe cars that nobody will die in but that will each cost $250,000 and get two miles to the gallon or whether it is a better society to have cheap cars that get great gas mileage and see 50,000 people die on the road each year. The scientists just handle execution.
One of the reasons the food safety issue festers is because we keep thinking we can get a group of scientists together and they can tell us what to do. Without a standard, however, they have nothing to work with.
United’s recent statement included this remark:
“… long-term public trust requires that such standards must be set by the government in an open and transparent process, with full input from industry, academia, consumers and all stakeholders.”
This is the produce industry saying to government: Tell us what you want us to do. Define a standard. We, as the produce industry, can tell you the cost of different options.
Scientists who work with us, when they have the knowledge, may be able to forecast the likelihood of different events. But neither the industry nor scientists who work with us can decide for society as a whole how much of a margin of safety it wishes to pay for.