Now we have received a statement specifically dealing with fresh produce. Bob Martin of Rio Farms has been working with a group of California producers looking to outreach to the industry, including the buying segment:
The (Not So) Hidden Agenda Behind the Term “Sustainable Production”
Over the last several weeks a growing group of concerned agriculturalists have been meeting with one common goal, to determine California agriculture’s role in the nationwide sustainability draft standards discussion.
As it stands now, “sustainable agriculture” in the current national standards draft ultimately means that a producer that signs onto the program with the ultimate goal of certification, will eventually become an organic producer on any acreage used to grow sustainable products. More and more buyers are requesting that their suppliers produce commodities utilizing sustainable measures. My questions are:
- Do they truly understand the meaning of that term in these draft standards, and
- Why can’t conventional as well as organic producers qualify for this certification?
Scientific Certification Systems wrote the ANSI standards and the Leonardo Academy is facilitating the process. Further development of the program begins in Ohio in May of this year, and the goal is that by 2010 the final sustainability standards will be in place. This set of standards will more than likely supersede any standards put forth by other certifying agencies, akin to National Organics Standards.
It is our goal to convince the decision-making committee that sustainability should include conventional and organic producers of vegetables and salad items.
As we made our way through the standards document, we became more and more aware that if the final standards compare to the draft standards as written, only a few producers would qualify to place a stamp on their product that reads ”produced in accordance with ANSI standards for sustainable agriculture”.
We honestly feel that much of the concept behind this document is good and should be the driving force for the protection of the environment, the economy (including social issues) and product integrity as time and technology allows. It would truly be unfortunate to see the major goals of the “sustainability concept” go down in flames because, as now written, either you’re in (with the agreement to become an organic producer) or you’re out! There is no incentive to become just “a little bit pregnant”!
The way we currently see it, there needs to be multiple levels of sustainability.
One level may well include producing organically. But there should also be a level that allows conventional production methods with the caveat that certain high standards of methodology be attained. There are economic, environmental and social benefits to both organic and conventional growing methods. Let’s create a document that takes into account the positive aspects of each.
We encourage your readers to log on to this site. The document is 127 pages long, but you don’t have to read too much of it to understand the incredible pressure it places on our industry.
Read the conformance requirements in section 3.0 for producers and handlers. It will lead you to section 6.0 (mandatory prerequisite requirements for producers and handlers).
In section 22.214.171.124, titled “Pesticide Phase-Out”, you will find more details on pesticide requirements for sustainable growers.
One might read into this section the possibility of permanently allowing certain pesticides if “alternative controls” are not found.
It is scary to think that some obscure committee, which is possibly made up of members heavily weighted towards organic production, will make that decision when they believe that everything can be produced organically. Members of all facets of food and fiber production need to be at the table discussing the future of the term “sustainability”.
It is sad to say that this pressure on agriculture is occurring well after pesticide manufacturers have begun producing tools that are more target-specific and less hazardous to the environment. The days of the “non-specific legacy” pesticides are rapidly waning. (More reason to allow conventional production to become part of the sustainable family!)
We have rapidly experienced the demise of durable goods production in this country due to rising costs stemming (in part) from regulatory issues that are not imposed on products imported into the U.S. Luckily it is much tougher to take our rich, productive farmland and climate and move them to China and Taiwan… or is it?
We have the ability to continue feeding the growing masses. We can’t allow this sustainable trend to remove that opportunity.
We are asking that major buyers join forces with us in this effort so their shelves won’t lack for product after demanding sustainable production methods.
Bob Martin and the producers group have identified the key problem. ANSI will wind up accepting some standard called “sustainable” — buyers, wanting the label, will demand “sustainable” product and the whole industry will collapse.
It is actually much worse than that. Consumers and the consumer media will want “sustainable” product, and they will pressure retailers to offer it.
Yet none of these people will have any real idea what is in the standards or what it means to endorse them.
There are two very big problems with this draft standard. One is substantive and the other is procedural:
On the substantive side, all sustainability standards are an attempt to balance the economic, environmental and social responsibilities of the sector involved — yet this particular one places almost no emphasis on economic viability. This is a crucial flaw. Sustainability, inherently, must be sufficiently profitable to enable a business to attract capital. It is not sustainable if it makes you go out of business.
Beyond that this draft provides no basis for the way in which these three responsibilities — economic, environmental and social — are balanced other than the prejudices of the people who happen to be on the committee. No responsibilities are defined in a way that allows us to challenge the definitions.
Without definitions, it becomes impossible to judge whether any action will actually encourage or impede any particular goal. The least controversial things — say the use of soy-based ink rather than petroleum-based ink — become highly complex when you start considering the environment down in Brazil where they are cutting down trees to grow all that soy.
This proposed standard leaves enormous ethical, economic and environmental questions on the table: If all production adopted this standard, what would the yields be? Would we feed the world? Or would people starve? Or would we expand production and destroy the rain forest to grow sufficient crops to feed everyone? What would be our vulnerability to insects, fungus and other problems?
Now we could all sit down and have a vigorous discussion on these issues. Unfortunately, the process has been fixed.
If you read the Frequently Asked Questions document, you find astounding things:
Q. Who selects members of the Standards Committee?
A. The Leonardo Academy is solely responsible for the selection of Standards Committee members, based on applications received.
Q. On the list of experts consulted, why apparently have no national “mainstream” agriculture and commodity associations been consulted in developing the draft standard?
A. The draft standard was developed with extensive input, but clearly a much wider net must be cast in the development of the final standard. Agriculture and commodity associations are among the many stakeholders invited to participate in the development of the ANSI standard.
The Standards Committee is the one with the power to accept or reject things. That Committee is chosen in the most undemocratic way possible — by the personal predilections of the people at some organization in Madison, Wisconsin.
Then, though they invite the elected boards of directors of industry organizations to “participate,” they don’t give them a vote and they don’t bring them in at the beginning of the process, only at the end.
On this basis, none of these organizations would want to lend credibility to this effort. Why work hard if some arbitrarily chosen committee ignores you?
The stacking of the deck goes beyond the individuals selected for the Committee; it goes to the heart of its makeup. The FAQ says this:
Q. How do you define stakeholders? What stakeholder groups will participate in the development of the standard? Where do government representatives and academic researchers fit in?
A. The Leonardo Academy constitution approved by ANSI recognizes four stakeholder “interest groups” that must be equally represented in the establishment of standards — producers, users, environmentalists and general interest. For the purpose of this agriculture standard, these groups would be interpreted as follows:
- Producer — representative of entity that produces or supplies goods (growers, shippers, packers, farmer organizations,)
- User — representative of entity that uses goods (retailers and restaurants, food service companies, product handlers, processors, distributors, and manufacturers).
- Environmentalist — individuals and representatives of organizations focused on preserving and improving the environment
- General Interest — anyone not in the above categories (government representatives, labor groups and representatives, academic scientists, consumer groups, other interested parties).
Note that this stakeholder definition is not widely accepted; it just happens to be in The Leonardo Academy constitution.
Note the inclusion of 25% of the seats on the board for “Environmentalists.” This Pundit bows before no man in his love for the environment, but “environmentalists” is just a special interest group. There is zero logic in setting aside seats for people who happen to favor the environment over other interests. Why not 25% of the seats for those who favor economic development? This is simply the bias of the particular people and organizations running this project.
It is really quite despicable. Instead of sitting down and saying they want to work together to build a more sustainable world, the forces behind this effort just want to steamroll anyone who would disagree with them.
We found a press release on the Leonardo Academy web site which you can see here claiming they were soliciting for stakeholders to join the process. But we are pretty well-read in this industry, and we can state unequivocally that nobody ever called the Pundit to ask if we might promote the availability of seats on this Committee. Nobody sent us a press release. It all means nobody was trying very hard to do any stakeholder engagement. It sounds like the fix was in.
In fact the process used here was in direct violation of ANSI requirements that call for openness, balance, consensus and due process:
Accreditation by ANSI signifies that the procedures used by the standards body in connection with the development of American National Standards meet the Institute’s essential requirements for openness, balance, consensus and due process.
The agriculture organizations that sent the letter have a pretty good strategy. Turn to ANSI, point out the abandoment of ANSI standards to engage stakeholders and encourage everyone involved to narrow the standard into a kind of “organic plus” so organic growers who want an additional certification can get that. In the meantime, the broader industry can work on a new sustainability standard that really involves all the stakeholders.
Western Growers, United Fresh and PMA are all now on the issue and it will require major efforts to stop this from coming out horribly wrong.
We’ve been working for two months now on a Sustainability Conference for the industry. We’ve had fantastic feedback from Sydney to London and all across North America. Our first survey is going out next week. If you are interested in the field and want to participate in the conference as a partner, as a sponsor, as a member of the steering committee, as a speaker or an attendee, there is still time. Please let us know right here.
As we write this, the Pundit is getting ready to leave for the Cornell University/United Fresh Executive Development program. Our part of the program is to focus on “critical industry issues” as they arise. The only problem is we have to pick the issues months in advance. Last year, we focused on Food Safety. This year: Sustainability as a Strategic Imperative. Good call.