No Absolutes In Food Safety

By Jim Prevor, Editor-in-Chief, Produce Business

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.