August, 2009

Research Perspective and Comments & Analysis

Keeping Produce Safer

This time of year, we don’t need research to remind us that food safety is top of many minds — consumers, government and our own. Nonetheless, we’ve got plenty of it. PMA members recently rated food safety as the top issue facing the industry. Meanwhile, new surveys by The Hartman Group for PMA’s Consumer Research Online underscore that consumers’ produce buying habits hinge on their confidence in the safety of our products.

When it comes to food safety, our industry has broad needs — from working with government to conducting applied research, from teaching the basics to cultivating a culture of food safety throughout your company. Let me touch on some of these briefly.

We’re continuing to reach out to the federal government, from the Food and Drug Administration and U.S. Department of Agriculture to Congress and the White House. Our goal is to inform them about our industry, to consult with them to aid and speed produce-related illness investigations, and to ensure any produce-specific food safety requirements they may consider are risk-based, science-based, commodity-specific, and apply to domestic and imported produce alike. The recent recommendations of the White House Inter-Agency Work Group on Food Safety show that the Obama administration is taking notice of our industry’s needs — though the devil is always in the details that must still be worked out.

We’re also working to connect members to current information, ideas and research. That’s a key objective of PMA’s Chief Science Officer Dr. Bob Whitaker: taking the best insights from the world of science and making them understandable and applicable to the real world in which the industry operates daily. Bob has hit the ground running in his first year. In addition to his work with Congress and the agencies, he is also leading numerous industry education events, such as Fresh Connections, the Foodservice Conference and Fresh Summit in October. He will also lead a new series of food safety symposia we launched in July. You can listen in and comment on his audioblog at, stay informed through our food safety Web page, and join the conversation and hone your food safety capability at our educational sessions.

When it comes to research, I believe our most valuable investment has been in creating the Center for Produce Safety (CPS) at the University of California at Davis. PMA has donated over $2.5 million to cover CPS’s formation and operations for four years. Taylor Farms committed $2 million for initial research, and additional support came from University of California and the California Department of Food and Agriculture (CDFA). Bonnie Fernandez-Fenaroli was hired as executive director in March 2008. Past PMA chairman Tim York of Markon Cooperative chairs CPS’s board on which I also serve.

Formed with the goal to answer our industry’s fundamental food safety questions, CPS has marched forward with incredible speed in its first 18 months under Fernandez-Fenaroli’s leadership. With the help of PMA’s Dr. Bob as chair of the CPS Technical Committee (a group of top industry, government and university scientists), CPS quickly defined its research priorities and awarded its first grants by November 2008. By June 2009, additional industry financial support had increased CPS’s research war chest to $3.5 million.

As of July, CPS has issued $1.1 million in research grants to fund 11 produce-specific projects. Meanwhile, CDFA recently committed to providing a portion of a state specialty crops grants program to CPS; those awards will be announced in September.

Research is the first phase of CPS’ work; it will also help translate those findings into actionable, ready-to-use solutions to prevent or minimize vulnerabilities, to be delivered via a research clearinghouse, education and outreach activities.

CPS’s support is critical to our industry’s vitality; our industry’s support of CPS is critical to its success. By supporting CPS, our industry gains access to actionable research, training and outreach programs to translate research from the world’s best scientists into real-world business practices to enhance the safety of the foods we produce.

Some might not think that applied research in the field has a direct correlation to confidence in the minds of our consumers. Yet it is clear that the proactive role taken by industry and government to kick-start this vital research is precisely what the consuming public expects us to do. I know from countless conversations and study that the public is assured when it sees an industry searching for answers to unknowns and looking to prevent problems, problems that undermine their confidence and our livelihoods.

Last month I wrote that “enhanced traceability is as fundamental as insurance to manage your other business risks.” I can’t say it strongly enough: research into what causes contamination of produce and what solutions are available is an insurance premium we must pay forward — the complex reality of today’s food safety environment demands it.

No Absolutes In Food Safety

Whether the issue is governmental regulation or buyer procurement specifications, one point on which the industry is agreed upon is that requirements motivated by a desire to enhance food safety should be science-based. This makes perfect sense as the alternative is that such regulations or requirements will be based on superstition, political demagoguery or a desire to one-up competitors. This would mean a massive investment in meeting regulations and requirements that will do little or nothing to enhance food safety.

This quest for science-based standards has an Achilles heel however: We simply don’t know much about an awful lot related to food safety.

What is the migration rate of E. coli 0157:H7? What is the risk, if any, that filth flies can transmit E. coli? If we want to reduce the frequency of pathogen contamination by 20 percent, how great an increase in buffer zones will accomplish this?

We just don’t know the answers to these and many other questions, which makes a science-based standard problematic to detail and implement. For years, consumer advocates criticized the industry — and not without reason — for using this desire for science-based standards as an excuse to do nothing. It wasn’t really until the spinach crisis of 2006, when the FDA shut down the industry, that many in the trade realized that action simply had to be taken, even based on imperfect knowledge. This change in attitude ultimately resulted in the California Leafy Greens Product Handler Marketing Agreement.

The Produce Marketing Association (PMA) deserves much credit for recognizing that this was, at best, a short term mechanism. Gathering the best and brightest in a room and writing metrics is sometimes the best we can do, but it would be much better if these experts had real data to draw on in developing food safety metrics.

It is obvious that in fostering the Center for Produce Safety, PMA hit a sweet spot of industry need. Although there were various private efforts being conducted to advance food safety science related to produce, notably a substantial one by Fresh Express, many companies and organizations have known they needed to do research but found the organizing of the process difficult.

Now the Center for Produce Safety is handling this arduous process for many produce commodity groups. The end result will be better research, done more efficiently.

Unfortunately, this still leaves two important problems: First, although the Center for Produce Safety has worked hard to fund relevant projects that can provide actionable information within a relatively short time frame, good research inevitably raises more questions than it answers.

This means that the need for funding will be ongoing and, although insights gained from the research can be continuously incorporated into our food safety efforts, it will be years before we can realistically hope to know enough to address — in a scientifically rigorous way — many of the food safety requirements buyers and government will look to establish.

Second, whatever the state of our scientific knowledge, a search for a science-based food safety rule is a kind of chimera, a shining city on the hill that we can never live in. Here’s why: Safety, in food, automobiles, airplanes, buildings — almost all of life — is not a matter of a simple on/off switch or yes/no indicator; there is a continuum and selecting a place along that continuum is, inherently, a values-based decision, not a matter of science.

So though effective research organized by the Center for Produce Safety may one day tell us that for every 10 feet we increase a buffer zone we reduce the likelihood of pathogen contamination by 1 percent, no research can ever tell us whether that means buffer zones should be 10 feet or 1,000 feet. That is a values-based decision and, in our society, one that will be made by the polity.

Just look at cars. We actually have a great deal of knowledge of physics and the force of moving objects, and we know how to build cars that will protect the occupants at a crash of 10 miles per hour or 100 miles per hour. The fact that there are still fatalities in auto accidents is not a function of our limited scientific knowledge; it is a function of our balancing many societal desires — such as for both safety and economy — in the regulations that control car production.

There may be some irony in our thirst for knowledge about food safety. Because we know so little, everyone can pontificate on what standards they would like to see imposed. If we ever actually come to understand what will solve the problem, those same folks will have to deal with the real costs of implementing their plans. It may yet turn out, in produce, as in everything else in life, trade-offs are par for the course, and absolutism in food safety is an extremism like any other.