August, 2008

Research Perspective and Comments & Analysis

Citizenship, Courage and Character

In 1910, former President Theodore Roosevelt delivered a famous commentary on citizenship, courage and character. Speaking on the duties of citizens, Roosevelt defined the standard by which he felt men should be judged, discounting bystanding critics and naysayers in favor of “the man who is actually in the arena” and who “spends himself in a worthy cause.”

Today, our industry finds itself in the arena facing a serious food-safety crisis as federal agencies linked some tomatoes — and most recently some hot peppers — to a foodborne illness outbreak involving Salmonella saintpaul. As of July 8, more than 1,000 people in 40 states and Canada had been sickened, including a cancer patient who died after contracting salmonellosis.

The victims span all ages, from less than one year old to 99. The actual toll is much, much higher; for every recorded illness, the U.S. Centers for Disease Control and Prevention (CDC) estimates 38 unreported ones, bringing the actual count to about 40,000 victims. That is a staggering amount of human suffering, and all the signs point to fresh produce as the cause.

This outbreak may well be a breaking point for our key stakeholders, and it certainly presents a point of change for us all. Like Roosevelt’s man in the arena, our industry has strived valiantly to ensure the safety of the foods we produce. Yet despite our enthusiasm and devotion to our craft, we continue to come up short in the eyes of those who matter the most to our future: our customers, regulators and legislators.

Our research indicates this outbreak has dealt yet another weakening blow to consumer confidence in our industry. Awareness of produce food-safety issues is nearly universal among the nationally projectable sample of 500 consumers we surveyed — with most volunteering the Salmonella outbreak specifically. Nearly two-thirds say they are avoiding all tomatoes, and a third of those avoiding red rounds and plums report they aren’t substituting anything — a loss not just for the tomato category but for the entire produce department. Nearly half of all those surveyed say they will wait a few weeks to a few months before purchasing tomatoes again, during which time many growers’ seasons will come and go. Meanwhile, consumer confidence in the overall safety of all fresh produce has fallen yet again.

At the same time, in the United States, federal legislators and regulators have taken note of this — yet another serious produce-related foodborne illness outbreak. It will be only a matter of time before legislation and/or regulations are proposed — and not just for tomatoes. While we have profound issues with this investigation, we must also agree that profound change is needed in our industry.

While we welcome the increased communications with industry that the U.S. Food and Drug Administration (FDA) and CDC have provided, we also disagree with aspects of their investigations and public communications. Produce Marketing Association (PMA) has worked through its daily agency contacts at the staff level, including FDA Food Safety Chief Dr. David Acheson, to ensure our industry’s voice is heard and the agencies are mindful of the heavy toll this has taken on our industry. In addition, PMA and United Fresh Produce Association (UFPA) have twice requested a meeting with Health and Human Services Secretary Michael Leavitt to discuss necessary improvements.

Yet we cannot fault the agencies’ commitment to protect public health because that is a commitment that our industry shares wholeheartedly. And frankly, we will have lost the right to lay blame if one of our foods did indeed cause yet another illness outbreak — the largest on record. Nor should we protest too loudly, because each of us knows a potential weak link somewhere in our supply chain that may have contributed to this or another such outbreak.

Simply put, it is time for our industry to do more to safeguard our foods and to protect the consumers who put their trust in us to provide safe, wholesome, delicious food — every bite, every time. Food safety is not just a plan on a shelf or passing an audit; it must become an intrinsic part of our culture, ingrained in our daily work, infused in every step we take from field to fork. As a result, we must redouble our efforts to gain mandatory food-safety regulations covering domestic and imported items so that everyone is on a level playing field and our consumers can have greater confidence in us and the fresh fruits and vegetables we supply them.

Nearly 100 years after Roosevelt’s commentary, our industry faces a turning point in our global citizenship. I know our industry has the courage and character that he envisioned to spend ourselves in this worthy cause, so that we and our customers can know victory.

The Strenuous Life

What did Theodore Roosevelt think was the kind of citizenry that would produce national greatness? He answered that in another speech, entitled The Strenuous Life, in which Roosevelt explained his position: “I wish to preach, not the doctrine of ignoble ease, but the doctrine of the strenuous life, the life of toil and effort, of labor and strife; to preach that highest form of success which comes, not to the man who desires mere easy peace, but to the man who does not shrink from danger, from hardship, or from bitter toil, and who out of these wins the splendid ultimate triumph.”

Which leads us to these questions:

• Precisely how great can our citizens be if they cringe in horror at the infinitesimal risk of a pathogen on a tomato or jalapeño?

• Do we not have a public interest in ensuring that the citizenry is educated in such a manner they are able to evaluate risk?

Obviously, pathogens are bad and should be minimized or eliminated. If FDA knows of a specific producer who is pouring pathogen-laced produce into the system, it should stop that producer. But the issue is whether FDA ought to bankrupt hundreds or thousands of people by banning crops in the hope of obtaining infinitesimal benefits when FDA does not know the specific source of an outbreak.

If we have “come up short in the eyes of those who matter most to our future: our customers, regulators and legislators,” we have to ask if our food-safety shortcomings are a result of failures in food safety or failures in honest communication.

Many of these issues first came to prominence in the 2006 spinach crisis. This was in some ways unfortunate as the issue there was bagged product being sold to consumers with a marketing promise that it was “ready to eat.” Obviously, marketers who wish to make such promises take on special responsibilities.

However, a typical farmer who grows produce in the dirt has the items rained on in the field where they may also come into contact with animals and humans. The typical farmer is going to grow product that will sometimes have pathogens on it.

If we do not state this loudly and clearly at every opportunity, we are setting up the industry for unreasonable expectations. There is always in the produce supply a “base level” of pathogens.

That consumers panic upon our discovering a pathogen is not surprising, especially when public-health leadership runs around screaming “fire.” But as Dr. Michael T. Osterholm, the distinguished public-health expert from Minnesota, has pointed out: “For every numerator, there is a denominator.” For public-health authorities to induce panic rather than place things in perspective is simply reprehensible.

There may well be regulation of the produce industry, and we are fortunate that Bryan and PMA and other associations will work hard to make that regulation reasonable. But the meat industry already has regulation, and this is a banner year for E. coli 0157:H7. The poultry industry has regulation, and there is more Salmonella in chicken each year than there is in fresh produce each decade.

Regulation may make people feel “something is being done” — if the regulation is administered wisely, it may even help a bit. But regulation doesn’t resolve the fundamental questions. One can always test water or soil more frequently, always put traps closer, always provide more training, etc.

In fresh produce, where we have no “kill step” such as pasteurization, food safety expenditures are a simple continuum, and a regulatory requirement to stop at some particular place on the continuum will not guarantee safety, even if universally followed.

I do not “fault the agencies’ commitment to protect public health,” but I balance it with the rights of consumers to live freely and of producers to produce their products. Public health is a value, but not the only value, and if the actions taken in the name of public health are down to the third and fourth decimal place in impact, moderation is reasonable to expect.

Risk is endemic in life. Walk outside and you might get hit by lightening; drive a car and you might have a crash; eat a rare hamburger and you might get E. coli 0157:H7; sample a raw milk cheese and suffer the risk of Listeria. But it is not the purpose of public-health authorities to make our lives risk-free.

Do we have flaws in our industry regarding food safety? Absolutely. The core problem is cultural. Buyers are too quick to abandon food-safety requirements to achieve other goals — say a “locally grown” or “winter import” program — and food-safety standards at buying organizations are “minimums.” In addition, buyers have no incentive to pay extra to get product above that firm’s required standard.

This cultural problem is very difficult to fix, but well worth the attempt.

The public-health authorities also contribute to the problem. Although irradiated hamburger can be purchased at retailers such as Wegmans, the proposal to allow irradiation for the purpose of killing pathogens has wallowed in FDA’s in-basket for almost a decade. Put another way, the very serious food-safety problem of produce is not serious enough to prompt action on technology that could make a difference.

While we look to improve both our industry and public-health infrastructure, Bryan is right to remind us of Theodore Roosevelt. When we tell the population there might be some infinitesimal risk in consumption of a jalapeño, we can remind the citizenry that our national character depends on its having the intestinal fortitude to, in Theodore Roosevelt’s words, “not shrink from danger.”