Food Safety Requires Mature Thinking
By Jim Prevor, Editor-in-Chief, Produce Business
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.