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Pundit’s Mailbag —
Food Safety And Lake Wobegon

Jim Prevor’s Perishable Pundit, February 15, 2007

Mark Beeler of Watsonville Produce must be a pretty sharp guy. Dominic Muzzi, owner of Watsonville Produce, has credited Mark, along with Matt Cuzick, as being instrumental in the opening this past November of a fresh produce processing plant in Yuma, Arizona. The plant is called Red River, and is owned by Watsonville Produce, Metz Fresh and outside investors.

The facility got extra play because someone was thinking and used a newly enhanced Small Business Administration 504 Guaranteed Loan Program to help fund the project. It turned out that Red River was the first project to apply and the first to be approved. You can read about it here.

In addition Mark is no stranger to the Pundit, having written us to argue for the use of irradiation as a food safety tool right here.

Today, Mark sends us a brief, but pointed, note in regards to our piece Fresh Express Declines To Sign California Marketing Agreement:

I don’t like the feeling I get from this article that anyone who signs the agreement has a substandard food safety program. Are all the signers now the second class producers?

— Mark Beeler
Watsonville Produce

The California Department of Food and Agriculture (CDFA) claims it now has over 90% of the California production of spinach, lettuce and other leafy greens as signatories to the California Marketing Agreement. Here at the Pundit, we have not been able to duplicate the department’s math and, for some odd reason, the CDFA has refused to explain its methodology even to a State Senator.

Still, if the department is even close, it means that the signatories will represent not a “second class” group of producers but the overwhelming mainstream majority of the industry.

In fact, processors that decline to join but purchase product will almost certainly wind up purchasing product from signatories to the agreement and, in fact, being a signatory doesn’t restrict anyone from adding additional food safety systems. The food safety systems could be added to meet the requirements of Fresh Express or to meet the requirements of Costco, Tesco, Darden or McDonald’s or those of some other buyer.

The way it has been structured, however, when one signs on, one is signing on to a Marketing Agreement and the decision one makes in electing to sign on is not merely that one is willing to commit to follow these minimum food safety standards, but also that one wants to be part of the marketing effort associated with the Agreement. Take a look at the text from the California Leafy Green Products Handler Marketing Agreement:

ARTICLE VII
ADVERTISING AND SALES PROMOTION
Pursuant to Food and Agricultural Code section 58889, the Agreement may advertise and promote consumer recognition of the Official Mark and its meaning.

ARTICLE VIII
QUALITY IMPROVEMENT AND EDUCATION PROGRAM
Pursuant to Food and Agricultural Code section 58893, the Agreement may engage a program of educating the public and producers concerning the Best Practices.

The implication here is, clearly, that it is contemplated that the Agreement will advertise, promote and educate both the trade and the consumers about “ the Official Mark and its meaning” — and what are they going to say about the Official Mark?

No ads have been written but, one supposes, they will say it is “your assurance of safety” or “your assurance that fresh produce has been grown in accordance with the best practices to make sure your family can eat healthy produce with peace of mind” or some other such thing.

Yet, none other than today’s correspondent, Mark Beeler, told us in his letter regarding irradiation:

We all know that everything we do in the field and processing shed that the government or buyers demand will not stop the next E. coli outbreak. The current system, and for that matter what I have heard regarding a future system, are not designed to be fail safe.

This is absolutely correct. So, not being fail safe, we recognize that food safety efforts are on a continuum so there probably is no bright line between first and second class food safety programs. One guy puts the traps 100 yards apart, another says 75 yards; a third says 50 yards and still another says 25 yards.

At no point does anyone have business saying consumers are now “safe” — though we believe the more vigilant we are, the better the chances of safe product.

The truth is that even before the latest draft GAP standards, eating spinach, lettuce and other leafy greens was quite safe. To the best of our knowledge, over a decade the industry produced over a trillion servings of these items and, although the numbers are slightly hazy, there were less than ten fatalities.

Eating these products — under the old standards — was significantly safer than driving a car or flying in an airplane.

So, in this sense, anyone who will meet the new, more stringent draft GAP standards has a fantastic food safety program that will be astoundingly safe. Yet, because it is a continuum of food safety, any program ever adopted, no matter how stringent, will probably have someone who will consider it a good idea to be a little stricter.

The dilemma for the produce industry is that the company that is doing a stricter standard happens to be the largest player in the ready-to-eat salad business.

If the guy with tougher standards was a niche player who grows all his salad ingredients in a greenhouse and charged triple the price, it could be dismissed as an exotic situation not applicable to large mass marketing or feeding America healthy food.

When it is the biggest player, it raises issues as to whether the industry is truly doing all it can to ensure safe food.

The bottom line is that food safety is one attribute of this consumer product. Low cost, convenient packaging, a trusted brand and many other things make up the total consumer offer.

Many would like to remove food safety from those considerations, but because we do not use irradiation or some other “kill step” that allows us to draw a bright line and say “this product is now safe” — it is always going to be expected that some companies will have better food safety programs than others.

Garrison Keillor of the radio show, The Prairie Home Companion, would speak of his fictitious home town this way: Welcome to Lake Wobegon, where all the women are strong, all the men are good-looking, and all the children are above average.

Alas, the produce industry is not Lake Wobegon, and this means that every company in the industry cannot have an above average food safety program.

Many thanks to Mark for sharing his concerns.

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