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National Restaurant Association Soon
To Unveil Its Own Food Safety Plan

Jim Prevor’s Perishable Pundit, March 1, 2007

It was inevitable that the National Restaurant Association would want a place at the table for its views on food safety to be expressed.

Way back in November, we reported in NRA Forms Produce Safety Working Group that NRA had convened a secret committee to develop new food safety standards for the produce industry. Now, as we detail below, NRA is ready to unveil its plan this March at a special Food Safety Conference it is hosting.

Donna Garren, Vice President, Health and Safety Regulatory Affairs for the National Restaurant Association, used to work for United Fresh Produce Association. She warns us that NRA’s standards will be seen by the produce industry as “very conservative,” and we will find similarities to the requirements being made right now by Fresh Express and many top foodservice companies.

Many thanks to Donna Garren and the National Restaurant Association for explaining their position today:

Donna Garren
Vice President, Health and
Safety Regulatory Affairs
National Restaurant Association
(NRA), Washington, D.C.

Q: When NRA formed the Produce Safety Working Group in November, you told us the goal was to have more stringent food safety standards written by first quarter 2007. Where do you stand in this effort?

A: We set the date for a produce safety conference in March [agenda with speakers here, overview info here, and press release here], and at that time we intend to share with the produce industry what our requirements will be for vendors to handle produce through the supply chain. What elements, GAP, HACCP programs we need to see implemented, including more specific directives on the evaluation of water, soil management, animal control; all these things that would promote safe handling.

Q: In the food safety recommendations you’ll be announcing, do they apply strictly to leafy greens or have you done GAP metrics for other commodities as well? When we first talked in November, you mentioned the initial focus would be on leafy greens and tomatoes.

A: Broadly, it will cover all produce.

Q: How do these requirements compare to the other industry proposals and government regulations being developed?

A: In reviewing this document, the produce industry would assess what we put forth as very conservative. We need to be sure we put the necessary regulations in place. We require conservative actions to make sure elements are controlled, and there needs to be validation to insure food safety and necessary verification to our members that indeed the requirements are taking place.

Q: Are the recommendations science-based or just conservative? In other words, if the industry GAPs say you need 400 feet from a compost station, for example, and you recommend a greater distance, is it because the committee has a science-based reason for a different distance?

A: Throughout the recommendations, it will encourage risk assessment to identify risks and measures to control these — basically management of food safety systems.

Q: Have these standards and the reasons behind them been shared with Western Growers Association, United Fresh and the people drafting the GAPs? If so, what has the response been?

A: They have not been shared with produce organizations yet.

Q: Have you worked in any way to coordinate your food safety proposal efforts with other organizations in the industry including Western Growers and United Fresh?

A: We really are in the finalizing stage of this draft. There will be elements weaved in to our recommendations of what the produce industry has developed. Elements will not be foreign to government and fresh-cut industry guidelines. We will be adding new language based on the documentation out there.

Q: Are you concerned there could be conflicting messages, duplication of efforts, or confusion because of the variations of standards on the table?

A: There may be argument from the industry that there’s a lot out there. If you look at Western Growers and United, and even FDA for that matter, the recommendations they put forth add meat to the bone of the original GAP documents and stiffen guidelines to address the leafy greens situation.

Anything we will put forth is going along with that process, adding more specifics to that broad recommendation. We don’t look at it as tons of different recommendations. We consider our role as providing more clarification and more specifics.

Q: I suppose the industry at large will have to wait until NRA’s food safety conference at the end of March to learn those specifics. In the mean time, would you say there are some comparisons to tough food safety protocols of companies like Fresh Express?

A: Looking at our document, you may see similarities with the stringent requirements used at Fresh Express and other companies with a similar commitment. We want to be sure to raise the bar on food safety.

Q: Will the requirements you are proposing include finished product testing?

A: There will be mentioning of testing both at the field level and at the processing plants. There will be soil and water amendments and final product testing recommendations for companies proceeding down that path. If final product testing is pursued, options covering that area will include what pathogens should be looked at and identified.

Q: You sound very vague here, using words like ‘options’, and phrasing like, ‘if final product testing is pursued’. Are you suggesting that final product testing as well as other standards are a choice?

A: These are recommendations. It will be up to individual companies working with vendors to require they adhere to them. Member companies will determine how their vendors should proceed.

Q: Are these standards new? Are they higher than what top foodservice operators such as Darden, McDonald’s and Jack In The Box are doing right now?

A: Our recommendations would be in line with conservative approaches already being used by many foodservice companies.

Q: During the formation of the working study group back in November, you mentioned there were 20 different companies involved, representing the much larger membership at casual dining chains, QSRs and restaurant companies. Could you tell us now who the key task force members are?

A: We generally don’t give out information on who has been active. Of the major chains in the industry, there is a commitment of a broad membership for us to pursue a leadership role in the supply chain.

Q: Are there specific concerns for foodservice that are not relevant in retail? Does foodservice require different standards than retail?

A: Retail and foodservice industries have a shared goal of improving the safety of produce.

Q: Is NRA concerned about liability issues? For example, if NRA comes out and says X should be the standard and there is another outbreak, might NRA be liable? And in another sense, has NRA considered restricting membership to those who follow the food safety standards NRA says are needed for food safety and protecting consumers?

A: The document developed will be recommendations and a resource available to our members. Our legal counsel will review it prior to completion.

We like Donna Garren and have often exhibited at the NRA Convention, but this really startles:

Q: Have these standards and the reasons behind them been shared with Western Growers Association, United Fresh and the people drafting the GAPS? If so, what has the response been?

A: They have not been shared with produce organizations yet.

NRA has the right to make any recommendations it thinks wise to its members, but the way NRA is handling this matter is not right. NRA has refused to make these proposed standards available to the produce industry associations working on developing the Good Agricultural Practices standards for leafy greens.

This makes us feel that more industry politics than food safety sincerity is involved here. If NRA has technical people — and its members have some of the best in the world on staff — that have suggested higher standards are required for food safety, then the association has a moral responsibility to get those recommendations into the hands of the committee drafting the GAP standards as soon as possible.

It would be morally grotesque to hold back this valuable information, and the names of the technical experts endorsing it, so they can be unveiled at a conference. Every day people are planting crops, every day people are processing crops. If NRA’s experts think the draft GAPs are too lax, they should speak out today.

Suppose someone gets sick or dies and that could have been prevented with prompt sharing of NRA’s technical advice. The Board of Directors of NRA should rethink this at once.

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