November, 2008

Research Perspective and Comments & Analysis

Connecting These Dots Is No Game

Remember as children how we played those connect-the-dots games? Produce safety is a bit like that game, which starts with a grid of dots. While initially the dots don’t seem related or connected, the more you work at it, the more you find everything is eventually connected.

When Produce Marketing Association (PMA) connected the dots together from some of our recent consumer surveys on produce safety, a clear picture of weary consumers emerged.

At the beginning and near the end of the recent Salmonella saintpaul outbreak, we conducted surveys to garner consumers’ perspectives on produce safety after a summer filled with food-safety advisories. On the one hand, we find consumers were more confident in the safety of America’s fresh produce in August than they were in June; on the other hand, surveyed consumers judged the produce industry more harshly than they did just two months earlier. The negative rating of the industry’s handling of the tomato incident more than doubled between June and August.

The main reason given by those who have high confidence in the nation’s fresh produce system is trust in government regulators, the produce industry and farmers. The main reason given by those who have a lack of confidence is the exact reverse — distrust of those same key players. This indicates the challenge we face: for industry and government to reassure those consumers who are tired of the uncertainty and need their trust restored.

Recent indications suggest legislators and regulators are weary, too. We heard it from Congress during food-safety hearings late this summer, including the traceability hearing where I gave testimony. We’ve also heard it from legislators and regulators working on various food-safety proposals.

I’ve said this before and I’ll say it again: We must do an even better job to defend public health and safeguard our products — and must do even more at telling the story about what we are doing and why.

As discussed extensively at PMA’s Fresh Summit just concluded in Orlando, we believe restoring consumer confidence requires an industry-wide philosophical change. It requires that every company in our industry connect the various dots of food-safety responsibility, needs and actions to create not just a food-safety program but a food-safety culture, from top management down to every line worker.

To help us do that, PMA enlisted Dr. Bob Whitaker to join us as chief science officer earlier this year. Bob’s addition greatly enhanced our existing staff’s bench strength and brought the unique perspective of his produce-industry experience to help guide our food-safety efforts.

Bob, for example, chairs the technical committee at the Center for Produce Safety (CPS) at University of California-Davis, the organization PMA helped found to conduct produce-specific food-safety research. Now fully up and running, CPS will this month announce the recipients of its first $1 million in research grants. And Bob also has a wealth of operational experience that is available to share with PMA members worldwide through the presentations he is giving, the audio blogs he’s posting on our Web site (see and the insight he shares one-on-one.

To help us tell our story to the public, the consumers we surveyed told us which messages resonate with them. They told us that they want to hear from the people producing their food, more so than they want to hear from government. They want to know that the same standards apply to U.S. growers when they operate in other countries, that imports are held to American standards, and that we are improving our food-safety inspections and monitoring.

Bob and our staff are also working diligently to tell our story to government agencies and Congress, who often have at best an incomplete — and at worst a naive — understanding of our industry, our capabilities and our needs. We are working hard to correct this and to make our expectations of them known:

(1) Adequate funding for FDA, so it can do the job it has been tasked with; and

(2) Mandatory produce safety regulation.

To restore consumer confidence in the safety of fresh produce, PMA believes that regulation must be risk-based, to give the greatest consumer protection; scientifically proven, to reduce food-safety risks; commodity-specific, to recognize the inherent differences among different products, regions and practices; and that all these points should apply to domestically grown produce as well as imports.

Our future depends upon our ability to connect the dots — to restore relationships — between our industry and two key stakeholder groups, consumers and government. Of course, produce safety is no game; lives and livelihoods are at stake. Unlike the children’s game that only has one winner, everyone wins when all these dots get connected.

Food Safety Requires Mature Thinking

The analogy to a childhood pastime is apt because the weariness legislators, regulators and consumers feel over food safety in the produce industry is an outgrowth of an almost infantile expectation of magic gain with no pain.

When Bryan explains the industry must “do an even better job to defend public health and safeguard our products,” this can only mean we must be prepared to put safety ahead of other interests. If this means making our farms less productive by, say, putting in large buffer zones or making our operations more capital-intensive by insisting on drip irrigation or incurring higher labor costs to monitor more compressed trapping, then the cause of food safety justifies these higher expenses.

Yet, we are somewhat troubled. Although we have heard hundreds of regulators and legislators at state and national levels speak to food-safety issues related to produce, we cannot recall even one who urged consumers to prepare for higher prices that will be necessary to justify the investment in food safety.

Everyone treats food safety as a “free good,” ignoring the tradeoffs to design and operate a growing, packing and transport system. Just as a car can always be designed to be heavier, have a stronger bumper, etc., so can we always test the water supply more frequently or put traps closer together.

That is why the call of the national produce trade associations for government regulation really begs the question: What would that regulation be? In a sense, we already have government regulation. It is against the law right now to sell adulterated food products.

It is highly likely any attempt to regulate specific horticultural practices will founder on this reality: FDA has given no indication it has come to peace with any acceptable level of foodborne illness in the way the National Highway Traffic Administration has come to peace with automobile accidents.

This means FDA will look to avoid the kind of specific regulation that could potentially lead to its being blamed for a future food-safety outbreak. So we will never get a regulation that actually tells us what to do.

No regulation ever says something like: “Fields must be fenced with a wire mesh fence with an aperture not to exceed 2¾”. The fence shall extend from six inches below the ground up to six feet above the ground.” Why? Because if an animal manages to get through the aperture or burrow below or jump over the fence, FDA would get blamed for an outbreak.

So we will wind up with vague admonitions that come out something like: “Fields should be adequately fenced to guard against unacceptable animal intrusion.”

If regulation is unlikely to solve the problem, what about our “telling the story about what we are doing and why”? Alas, this form of communication is also problematic. Yes, we have to tell our story to regulators, and PMA’s addition of Dr. Bob Whitaker to its staff gives needed credibility to that effort, but speaking directly to consumers about food safety is as likely to do as much harm as good.

Of course, produce companies and the industry at large should have copious information available on Web sites for consumers motivated to study the issue. But there is no good research indicating raising these issues actually reassures consumers. One suspects it is just as likely to raise doubts as to reassure.

As to Bryan’s desire that “every company in our industry connect the various dots of food safety responsibility,” we couldn’t agree more that the key to food safety is the corporate culture. However, the odds are not good “every company in our industry” is going to do anything, much less something as profound as changing its corporate culture.

What we could do is work on changing the industry incentives. The goal should be to prevent a food-safety culture from becoming dysfunctional. This inevitably means a focus on the buyers.

If buyers focus on getting the lowest price, producers will focus on driving costs out of the system. If buyers focus on something else — food safety, quality, flavor, whatever — producers will focus on achieving that goal.

The key to making the cultural shift is to move away from minimum compliance standards and toward a cultural imperative to always be safer.

Right now most retailers establish a minimum standard. This may be rigorous or it may be lax, but the very existence of this standard removes food safety from the day-to-day conduct of most buyers. In other words, if a retailer requires its California leafy greens be produced by a member of the California Leafy Greens Marketing Agreement (CLGMA), the buyer doesn’t even engage in discussions with firms that don’t meet that standard. But the day-to-day business probably focuses on price — as food safety is off the table.

If a producer wants to charge more because he exceeds the CLGMA metrics, the retail buyer has no directive to pay more for more food safety.

Some would argue it makes no sense to go beyond minimum standards as such standards are not “science-based,” but the truth is the industry is in debt to PMA and Taylor Farms for initially funding the Center for Produce Safety, as we desperately need good science in this area. For now, we have virtually no hard “science” to rely on. We just don’t know core issues, such as the migration rate of E. coli 0157:H7, so we can’t say how big a buffer zone should be.

The challenge for the industry then is how to prevent our ignorance from becoming an excuse to do nothing.

Children require a clear path, thus the success of connect-the-dots games. Adults have to deal with ambiguities, imperfect knowledge and hard tradeoffs. By doing all this well, the industry can merit the trust of the consumer.