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Efforts To Minimize Food Safety And Sustainability Conflicts Laudable But Don’t Resolve Conflict

Jim Prevor’s Perishable Pundit, March 5, 2010

One of the biggest battles that produce growers have had to deal with is how to wrestle with the competing values of food safety and environmental concerns. Actually it is more than just competing values; it is competing and often contradictory instructions from multiple buyers and multiple governmental agencies.

Now comes word that there has been an effort to resolve this dilemma:

Report finds that Co-management approach on farmland
is optimal path to ensure safe produce and ecological health

The Nature Conservancy recently produced Safe and Sustainable, a report for Georgetown’s University’s Produce Safety Project, which was developed with support from more than 35 expert advisors representing many facets of the agricultural industry — from small and mid-scale growers to shippers and buyers — as well as government agencies, environmental non-profits, the legal world and academia.

The report sheds light on the causes and consequences of food safety practices in California’s Central:

• What’s happening on farms today

• What’s driving these changes

• And, the best path forward

Farmers and landowners in California’s Central Coast are recognized leaders in natural resource conservation efforts. However, new food safety requirements are putting enormous pressure on some growers to reverse more than 20 years of resource conservation investments. Yet, throughout the development of the report, growers stated their continued commitment to produce safe food, their desire to be excellent stewards of natural resources, and their belief that they can do both well — if food safety programs allow them to effectively integrate resource conservation practices.

“Our goal in preparing Safe and Sustainable was simple: to bring the best available information — and the right mix of people — together to address critical challenges to protecting our food supply and the environment.” said Christina Fischer, Monterey Project Director for The Nature Conservancy in California. “Producing safe and nutritious fruits and vegetables is essential for public health. So too are grower’s efforts to safeguard natural resources such as clean water, clean air, and healthy ecosystems. Success means that growers have what they need to do both well.”

The Report is titled Safe and Sustainable: Co-Managing For Food Safety And Ecological Health in California’s Central Coast Region. The forward explains the effort:

The goal of writing Safe and Sustainable was simple: to bring the best available information — and the right mix of people — together to address critical challenges associated with protecting our food supply and the environment. In researching and writing this report, one thing became clear: we must pursue both food safety and environmental goals in tandem. Producing safe and nutritious fruits and vegetables is a critical component of public health. So too are growers’ efforts to safeguard natural resources such as clean water, clean air, and healthy ecosystems.

Throughout the development of this report, produce growers have resoundingly stated their commitment to produce safe food, their desire to be excellent stewards of natural resources, and their belief that they can do both well — but only if food safety programs effectively integrate resource conservation goals. Today, growers overwhelmingly report being pressured by what appear to be conflicting demands. However, as detailed in this report, we believe “comanaging” for food safety and ecological health is not only possible, but in fact represents the optimal path forward.

We owe it to growers and consumers to work together to provide a framework that makes this a reality. This joint effort has resulted in a long and thorough process. More than 35 expert advisors contributed directly to the drafting of this report, representing many facets of the agricultural industry — from small and mid-scale growers to shippers and buyers — as well as government agencies, environmental non-profits, the legal world, academia, and other related organizations and interests. The research and writing process built extensive networks of cooperation and learning to produce this in-depth report. The project was further advised by top scientific experts in the fields of microbiology, wildlife biology and veterinary science who are engaged in groundbreaking work to define sources of contamination in fresh produce, as well as processes of contamination.

We encourage policy makers and industry leaders at every level to read Safe and Sustainable and consider its findings. From legislative offices to corporate boardrooms, it is essential to pay close attention to the research and “on-the-ground” realities represented here. The decisions we make now regarding managing food safety and our natural resources may impact our nation’s health and prosperity for generations to come.

Sincerely,

Timothy York
President
Markon Cooperative

Christina Fischer
Project Director
The Nature Conservancy

Gail Raabe
Agricultural Commissioner
San Mateo County

The overall conclusion of the report:

Growers report yielding to tremendous pressure from auditors, inspectors, and other food safety professionals to change on-farm management practices in ways that not only generate uncertain food safety benefits, but also create serious environmental consequences. Many growers and a wide consortium of regional experts believe that “co-management” for food safety and environmental protection represents the optimal path forward, albeit one that faces several key obstacles.

The report itself speaks more about co-management:

Co-management has been defined in this report as an approach to minimize microbiological hazards associated with food production while simultaneously conserving soil, water, air, wildlife, and other natural resources. It is based on the premise that farmers want to produce safe food, desire to be good land stewards, and can do both while still remaining economically viable. Many Central Coast stakeholders are currently working towards co-management but it is not yet a mainstream approach, and they face many challenges from the various food safety programs they often must accommodate to sell their produce. Success in instituting a co-management approach will require those involved in both food safety and ecological health management to increase awareness of each others’ concerns and to adjust standards and guidelines accordingly.

The report notes several food safety issues that may impact the success of co-management. These issues remain the primary areas of concern expressed by stakeholders involved in the co-management process and addressing them may be critical if significant progress is to occur. Focused discussion with a wide range of stakeholders undertaken as part of this case study indicates concern about the role of liability, private corporate food safety standards, potential implications of national food safety standards, value-added processed produce, and insufficient scientific information.

Many of these challenges remain controversial and unresolved, and recommending solutions to them lies beyond the scope or intent of this report. Nevertheless, it is critical to understand stakeholder concerns in order to move forward with co-management efforts. These same issues are also important to consider for development and implementation of food safety programs to be applied in other regions or nationally.

This is all very similar to the work that the California Roundtable on Agriculture and the Environment has done. In December of 2009, the group published Guiding Principles for National Food Safety Programs for Produce. Tim York of Markon and Chris Fischer of the Nature’s Conservancy were both involved in that project as well. In correspondence sent to the Pundit, Tim York described the effort this way:

The CRAE group is a broad group of multiple stakeholders in diverse sectors of California agriculture. Several of us that are involved in CRAE — Chris and Chris’ boss (TNC), Hank Giclas, myself, also were involved in the development of this new “Safe and Sustainable” report.

The CRAE information is a good example of how different folks, different ideas/agendas (can you really picture WGA and Nature Conservancy and National Resources Defense Council agreeing on anything?), can indeed find common ground (tell that to the Republicans and Democrats).

The CRAE effort came to a consensus because it avoided the typical approach of the environmental advocates, which is all too often, to get the EPA to hold some hearing at which growers are dragged up and put in impossible positions.

It also succeeded because the environmental advocates were, for the moment, happy to see some “progress” being made. Its framework has been useful as the FDA got exposed to some of these ideas during its listening sessions on the proposed National Leafy Greens Marketing Agreement.

The CRAE Principles are strong and will certainly win much support:

Guiding Principles for National Food Safety Programs for Produce

December 2009 — Protecting public health by ensuring the best available food safety practices is important to everyone — produce growers, processors, retailers, the regulatory and environmental communities, consumer advocates, and the general public. The e coli outbreaks in Fall 2006 highlighted a clear need for improved food handling practices for leafy green vegetables.

Various responses, including industry-led Leafy Green Marketing Agreements, numerous individual corporate food safety programs, newly introduced state and federal legislation, and intensive new monitoring and research are underway. These efforts reflect the priority the agricultural industry and society as a whole place on acting quickly to address this critical issue. However, some of these efforts could prove counter-productive if they are not science-based, transparent, focused on the highest risk factors, integrated with other public health and safety programs — and ultimately effective.

At the farm-level in particular, addressing food safety and resource conservation concerns in a coordinated manner is essential to ensuring a safe, affordable, and sustainable US-grown food supply. In support of this goal, the members of the California Roundtable on Agriculture and Environment recommend that current and future efforts to improve food safety be consistent with the basic principles described below in order to enhance the nation’s safe and reliable food supply while protecting other social values. These principles are equally relevant to industry-led, legislative and governmental agency efforts, and are intended to provide guidance both to existing and newly emerging food safety programs and requirements.

10 PRINCIPLES FOR SAFE AND SUSTAINABLE PRODUCE

1. Science-based metrics: To ensure that food safety requirements effectively address actual sources of pathogenic risk, to prevent accidental incorporation of counterproductive measures, and to avoid unintended consequences to public health and safety such as impacts to water or air quality, food safety programs and requirements must be subject to rigorous review by agricultural and regulatory experts as well as experts in environmental sciences and natural resource conservation.

2. Adaptability: Substantial scientific gaps remain regarding the processes by which produce contamination may occur throughout the supply chain. Food safety programs and requirements must include robust processes for timely review and 2/3 incorporation of new science and data as it becomes available, to ensure that the best available science is applied to risk reduction activities.

3. Transparency and participation: Food safety programs and requirements should be developed, updated and maintained through a transparent and participatory process, including the early and full participation of appropriate stakeholders, such as producers, scientists, conservationists, agencies, consumers, etc., to ensure that programs are science-based, focused on known risks, and compatible with other public health and safety efforts. Whenever possible, food safety programs should actively address barriers to cooperation among scientists, agencies, growers, produce industry representatives along the supply chain, auditors, resource conservation organizations, insurance companies, and others.

4. Comanagement of food safety and environmental goals: Given the close association between ecological health and the health and safety of human communities, it is critical that both food safety and natural resource protection activities on and near farm fields be considered together. Food safety programs should be developed in a manner that considers and minimizes impacts to ecological health, and resource conservation measures should be carefully calibrated to minimize any increase in risk of pathogenic contamination of harvested crops. This concept of ‘comanagement’ for food safety and ecological health is essential to the long-term sustainability of both agriculture and ecosystem services critical to human communities, and should be incorporated into any food safety program and/or legislation.

5. Risk-based approach: Different crops, regions, levels of processing, methods of consumption (e.g. cooked versus raw) and/or seasons of production may have inherently different levels of risk for pathogenic contamination and/or human health impacts. These varying levels of risk must be better understood and incorporated into food safety programs in order to ensure effective risk reduction and to avoid unnecessary costs and impacts. Efforts to enhance food safety should concentrate on appropriate points of risk along the whole supply chain, from ‘farm to fork,’ similar to Hazards Analysis and Critical Control Points (HACCP) procedures in other industries.

6. Accessibility for all producers: The nation’s agricultural production includes tremendous diversity of scales of production, farm typologies, harvest methods, and marketing mechanisms. Food safety programs should incorporate flexibility to ensure sustainable implementation by all producers. In particular, the needs and limitations of small- and mid-scale farms and diversified farms must be taken into account.

7. Efficiency and harmonization with existing requirements: Producers report widespread concerns regarding multiple, conflicting criteria between various food safety programs and requirements, as well as conflicts between food safety and natural resource protection goals and obligations. Food safety programs should 3/3 work to harmonize with one another, as should auditing efforts. Furthermore, measures should be aligned with existing standards for production, such as organic standards, and natural resource protection such as soil, air and water resources critical for longterm agricultural sustainability. Likewise, natural resource conservation programs and activities should be designed and implemented in a manner consistent with best practices for onfarm food safety.

8. Clarity and specificity: Standards must be clearly worded and reasonably specific, in an effort to minimize subjective interpretation by auditors, producers and others, that may unduly increase costs and undermine ecological health. Including precise and explicit definitions of standards, as well as appropriate training for auditors and others engaged in program implementation as described below, are essential to avoid ambiguity and the potential for misinterpretation.

9. Education: Food safety programs should have high-quality complementary mandatory educational or certification programs targeted toward auditors and other program implementers, which aim to build consistency and accuracy in audit efforts and also help growers understand and comply with standards. Such efforts should also integrate training in resource conservation practices to ensure that environmental goals are not undermined. Likewise, natural resource conservation professionals, consumers and supply chain partners should be provided with opportunities to understand and incorporate food safety concerns.

10. Technical assistance and programs: To the extent practicable, all food safety programs should incorporate the availability of technical assistance to ensure that the full spectrum of operation types have the training and resources necessary to effectively implement requirements.

We have nothing but praise for people who do the hard work of trying to solve industry problems, and the conflict between environmentalism and food safety is a real problem.

Alas, having read the results of all these efforts, we confess that we think they fall short.

They may be useful on the margins… urging people, for example, when they have differences to look to science to justify their actions. Unfortunately, the real difficulties arise precisely when the science is unclear or nonexistent or when the science is clear but values are in conflict.

We can say that if there is a riparian area near a field, that rather than stripping it clean to clear out any critters around, we should look to science to see if there is any known benefit to clearing those areas.

But the science is not clear, the studies are few and, inevitably people have to make decisions with imperfect information. Most of our efforts to deal with food safety issues are like this — estimations made to improve our odds of not having an outbreak.

Even if we had perfect information, though, it would not often lead to some kind of value-free answer.

Suppose we found that by clearing all riparian areas, we could reduce the number of deaths due to food safety problems in the next 20 years by two people.

To some the answer would be clear: Start clearing the areas. Human life is precious and if we can avoid the loss of a single human life, we ought to do it.

Yet, to others, the answer would be the opposite, and equally clear. Don’t clear the areas. Two people over 20 years? Horrid to be sure, but you don’t deprive millions of animals of habitat for such a small benefit.

And this dispute wouldn’t change much if the numbers changed, because there are real differences in values, and these approaches, well meaning as they may be, won’t change that.

There also are differences in interests. Although buyers may care about the environment, the farms are far away, and someone getting ill as a result of a purchase in their store or restaurant is a completely different level of concern. Most buyers will be absolutists on food safety, happy to demand fences or buffer zones or traps as long as there is any possibility it would help prevent a death in food purchased from their store or restaurant.

Co-management is a lovely idea and, sometimes, it can even work. But to a certain extent, co-management is not so much a solution to the conflict between food safety standards and environmental protection as it is a way of assuming away the conflict. Read again the definition used in the report:

Co-management has been defined in this report as an approach to minimize microbiological hazards associated with food production while simultaneously conserving soil, water, air, wildlife, and other natural resources. It is based on the premise that farmers want to produce safe food, desire to be good land stewards, and can do both while still remaining economically viable.

That premise reminds one of the poignant closing line of Ernest Hemingway’s The Sun Also Rises. Spoken while inside a taxi, Lady Brett Ashley laments what could have been… or what she wants to believe could have been… and the war-wounded and impotent Jake Barnes gives the subtle goodbye to a relationship that could never have been more than a beautiful dream:

“Oh, Jake,” Brett said, “we could have had such a damned good time together.”
Ahead was a mounted policeman in khaki directing traffic. He raised his baton. The car slowed suddenly pressing Brett against me.
Yes,” I said. “Isn’t it pretty to think so?”

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