We’ve been harping on the importance of sustainability and social responsibility as an issue for the fresh produce industry to wrestle with for some time. The issue has now reached a point where attention is not only important, but urgent. As such, we dedicate this entire issue to the controversy now enveloping the industry in relation to sustainability standards.
We have written many pieces, such as Michael Pollan’s Sustainability Arguments Unsustainable In Context Of Economics, and we have given many presentations on sustainability, including a seminar at PMA in Houston where we unveiled the preliminary results of an exclusive research project we’ve been conducting comparing and contrasting consumer attitudes toward sustainability in the United States and the United Kingdom.
Here at the Pundit, we also published an important letter from Tim York of Markon Cooperative asking the industry to take a lead on this issue. The letter was in a piece entitled, A Call For An Industrywide Sustainability and Social Responsibility Initiative:
I read with interest your recent piece on sustainability and appreciate the opportunity to share some thoughts on the challenges our industry faces.
Sustainability — which some define as balancing the needs of society, the environment and economics — is a trend with traction. When Markon thinks about it, we consider not only the evolving demands of our customers (today and into the future), but our responsibility for economic stewardship. If the produce industry dismisses or even moves too slowly toward adequately addressing sustainability, it will do so at its own peril — exposing vulnerabilities in our social policies (e.g. labor), the environment (e.g. water usage) and economic viability.
As consumer awareness about sustainability — with all its various definitions — has increased, food retailers and foodservice buyers have begun to develop sustainability programs. If our experience with food safety is any indication, grower-shippers will at first be asked to describe their activities in specific areas (for example, related to hiring and labor policies, pesticide use, water use, etc.) then eventually be asked to implement a patch-work of programs as additional buyers jump into the fray. Some of these programs will be based on that buyer’s unique definition of sustainability, some based on a competitive differentiation strategy, and others on even shakier ground.
If we let this phenomenon play out on its own, we are likely to see a proliferation of standards rivaling what we saw in food safety — arguably, with even less efficacy in accomplishing the stated goals. Dueling standards for sustainability in the buyer community isn’t sustainable — by any definition of the word — and may do nothing to advance the industry.
There is an alternative, and last year’s progress in food safety provides a model. We saw the collective industry work together, perhaps as never before, and create a common standard for a sound food safety program and independent verification, the California Leafy Greens Marketing Agreement.
Inspired by that collective action, we believe a meaningful sustainability program must include specific, measurable and verifiable criteria. True, the task of developing systems to credibly define, measure and monitor sustainability may be too large for most individual foodservice and retail companies. A more practical strategy lies with one or more of the major trade groups investing resources in the development of basic industry metrics. Such metrics would enable us to wring out inefficiencies across the supply chain and meet meaningful goals in sustainability while still affording companies the opportunity to create competitive advantage with “green” products and services.
Our Buyer’s Coalition, in cooperation with the Food Safety Leadership Council participants, and partnership with grower-shipper companies, may be an alternative approach. However, absent a uniting crisis like the one we faced last fall, we may lack the impetus to join forces and set aside our perceived competitive advantages.
Absent some cooperative effort, individual buyers (including Markon), third-party auditors, and others currently working on sustainability will impose their demands on the produce industry. Moreover, we can imagine a scenario in which food safety and sustainability are treated as discrete initiatives when in fact they should be viewed holistically — as complementary steps toward a healthier industry.
Maybe it’s wishful thinking, but I’d rather see us collectively take the initiative now, while it’s still possible to create sustainability metrics that dovetail with food safety best practices — and together move the industry forward ahead of consumer or regulatory scrutiny.
— Tim York
Tim’s clarion call has turned out to be prescient, as the sustainability issue is being co-opted by people who choose to define sustainability in a manner that comports with their ideological predispositions, rather than engaging in vigorous debate on what principles should guide an understanding of sustainability. Specifically, these people have basically proclaimed that only organic agriculture is sustainable. This is a proposition that is, to put it mildly, highly debatable.
What has happened is that the American National Standards Institute (ANSI) coordinates the development and use of voluntary standards. An organization called the Leonardo Academy, which declares itself to be “The Sustainability Experts,” is an ANSI-accredited standards developer. Sometimes the Leonardo Academy provides “ANSI process administration” for standards being developed by other organizations.
In this case, Scientific Certification Systems, “in consultation with numerous stakeholders,” has authored a draft standard with the rubber stamp of the Leonardo Academy. In this context, there has been an ongoing process that has resulted in this draft standard.
As soon as the draft was published, the outcry began. A group of 30 agricultural organizations sent a letter:
January 31, 2008
Mr. Michael Arny, President
1526 Chandler Street,
Madison, Wisconsin 53711
Dear Mr. Arny,
We are writing in follow-up to our conversation on January 17th with Anne Caldas of American National Standards Institute (ANSI) to express our concern about the process used to establish the proposed American National Standards Institute Draft Standard for Sustainable Agriculture for Trial Use. We understand the Leonardo Academy’s desire to generate and harmonize sustainability standards. It is unfortunate, however, that this standard with its important implications for American agriculture was processed in this manner. We are concerned that the ANSI process has not been followed and that this may have already led to irremediable defects in terms of ANSI’s ability to receive approval. Stakeholder concerns and the controversial nature of the standard make procedural issues of utmost importance.
- It equates organic practices with best agricultural practices, a conclusion that would be soundly rejected by many in the scientific community and an issue that will provoke intense debate between the organic and conventional agricultural communities.
- It rejects the use of biotechnology, perpetuating scientifically unsound and overly precautionary approaches that have been rejected by many governments, including our own, and which have provoked significant trade concerns.
- It requires that producers follow organic processes rather than achieving specific results that can be objectively and metrically validated as sustainable, making it unsuitable for the very sectors of agriculture that would be impacted.
- It requires agriculture to engage in discussions of carbon emission standards that are well beyond the technological knowledge and capability of most of the participants likely to be engaged in this standards process. Carbon emissions standards are the proper focus of climate change discussions and regulatory guidance processes, which have just begun.
- It applies to biofuels, which are also the subject of many other standard setting efforts, including the International Standards Organization (ISO) and the Roundtable on Sustainable Biofuels. Food and agriculture stakeholders are also participating in other initiatives including legislative discussions. We believe that the ANSI process is not being followed and we would like to highlight several concerns.
- The draft standard for trial use was not notified to “materially affected stakeholders” prior to its adoption for trial use by the Leonardo Academy.
- The draft standard has not since been notified effectively to materially affected stakeholders both domestically and internationally.
- The standard’s stated purpose is to define sustainable agriculture. However, the draft standard as written clearly pertains to “sustainable organic agriculture” only and does not meet the definition of “sustainable agriculture” as defined in law by the 1990 Farm Bill. Therefore, had it been notified as a standard for “sustainable agriculture”, it would have been misleading and inaccurate.
- Because the Leonardo Academy has demonstrated that it has little knowledge of or experience with the broad range of stakeholders that will be affected by this standard, we are concerned that the process it is following will not accurately reflect the balance or scope required by its rules and by ANSI’s.
- We are concerned that the Leonardo process will not garner sufficient input to ensure that this standard is credible, particularly since Leonardo has not established a group composed of government experts.
We encourage the Leonardo Academy to narrow the scope of this standard to organic agriculture and work with other ongoing standard setting efforts. We believe that the inevitable years of intense debate on irresolvable conflicts that this standards process will provoke can and should be avoided.
American Farm Bureau
American Seed Trade Association
American Soybean Association
American Sugar Alliance
Animal Health Institute
Biotechnology Industry Association
California Association of Wheat Growers
California Citrus Quality Council
California Dried Plum Board
California Grain and Feed Association
California Grape & Tree Fruit League
California Pear Growers
California Seed Association
California Warehouse Association
California Tree Fruit Agreement
Del Monte Foods
Florida Fruit and Vegetable Association
Grocery Manufacturers Association
Lodi-Woodbridge Winegrape Commission
National Association of Wheat Growers
National Cattlemen’s Beef Association
National Corn Growers Association
National Cotton Council
National Oilseed Processors Association
National Sorghum Producers
North American Millers’ Association
United Soybean Board
U.S. Rice Producers Association
United States Soy Export Council
USA Rice Federation
cc Mr. Joseph Bhatia, Presiden
Ms. Anne Caldas, Director
Procedures and Standards Administration
American National Standards Institute
25 West 43 Street, 4th Floor
NY, NY 10036
Now we have received a statement specifically dealing with fresh produce. Bob Martin of Rio Farms has been working with a group of California producers looking to outreach to the industry, including the buying segment:
The (Not So) Hidden Agenda Behind the Term “Sustainable Production”
Over the last several weeks a growing group of concerned agriculturalists have been meeting with one common goal, to determine California agriculture’s role in the nationwide sustainability draft standards discussion.
As it stands now, “sustainable agriculture” in the current national standards draft ultimately means that a producer that signs onto the program with the ultimate goal of certification, will eventually become an organic producer on any acreage used to grow sustainable products. More and more buyers are requesting that their suppliers produce commodities utilizing sustainable measures. My questions are:
- Do they truly understand the meaning of that term in these draft standards, and
- Why can’t conventional as well as organic producers qualify for this certification?
Scientific Certification Systems wrote the ANSI standards and the Leonardo Academy is facilitating the process. Further development of the program begins in Ohio in May of this year, and the goal is that by 2010 the final sustainability standards will be in place. This set of standards will more than likely supersede any standards put forth by other certifying agencies, akin to National Organics Standards.
It is our goal to convince the decision-making committee that sustainability should include conventional and organic producers of vegetables and salad items.
As we made our way through the standards document, we became more and more aware that if the final standards compare to the draft standards as written, only a few producers would qualify to place a stamp on their product that reads ”produced in accordance with ANSI standards for sustainable agriculture”.
We honestly feel that much of the concept behind this document is good and should be the driving force for the protection of the environment, the economy (including social issues) and product integrity as time and technology allows. It would truly be unfortunate to see the major goals of the “sustainability concept” go down in flames because, as now written, either you’re in (with the agreement to become an organic producer) or you’re out! There is no incentive to become just “a little bit pregnant”!
The way we currently see it, there needs to be multiple levels of sustainability.
One level may well include producing organically. But there should also be a level that allows conventional production methods with the caveat that certain high standards of methodology be attained. There are economic, environmental and social benefits to both organic and conventional growing methods. Let’s create a document that takes into account the positive aspects of each.
We encourage your readers to log on to this site. The document is 127 pages long, but you don’t have to read too much of it to understand the incredible pressure it places on our industry.
Read the conformance requirements in section 3.0 for producers and handlers. It will lead you to section 6.0 (mandatory prerequisite requirements for producers and handlers).
In section 184.108.40.206, titled “Pesticide Phase-Out”, you will find more details on pesticide requirements for sustainable growers.
One might read into this section the possibility of permanently allowing certain pesticides if “alternative controls” are not found.
It is scary to think that some obscure committee, which is possibly made up of members heavily weighted towards organic production, will make that decision when they believe that everything can be produced organically. Members of all facets of food and fiber production need to be at the table discussing the future of the term “sustainability”.
It is sad to say that this pressure on agriculture is occurring well after pesticide manufacturers have begun producing tools that are more target-specific and less hazardous to the environment. The days of the “non-specific legacy” pesticides are rapidly waning. (More reason to allow conventional production to become part of the sustainable family!)
We have rapidly experienced the demise of durable goods production in this country due to rising costs stemming (in part) from regulatory issues that are not imposed on products imported into the U.S. Luckily it is much tougher to take our rich, productive farmland and climate and move them to China and Taiwan… or is it?
We have the ability to continue feeding the growing masses. We can’t allow this sustainable trend to remove that opportunity.
We are asking that major buyers join forces with us in this effort so their shelves won’t lack for product after demanding sustainable production methods.
Bob Martin and the producers group have identified the key problem. ANSI will wind up accepting some standard called “sustainable” — buyers, wanting the label, will demand “sustainable” product and the whole industry will collapse.
It is actually much worse than that. Consumers and the consumer media will want “sustainable” product, and they will pressure retailers to offer it.
Yet none of these people will have any real idea what is in the standards or what it means to endorse them.
There are two very big problems with this draft standard. One is substantive and the other is procedural:
On the substantive side, all sustainability standards are an attempt to balance the economic, environmental and social responsibilities of the sector involved — yet this particular one places almost no emphasis on economic viability. This is a crucial flaw. Sustainability, inherently, must be sufficiently profitable to enable a business to attract capital. It is not sustainable if it makes you go out of business.
Beyond that this draft provides no basis for the way in which these three responsibilities — economic, environmental and social — are balanced other than the prejudices of the people who happen to be on the committee. No responsibilities are defined in a way that allows us to challenge the definitions.
Without definitions, it becomes impossible to judge whether any action will actually encourage or impede any particular goal. The least controversial things — say the use of soy-based ink rather than petroleum-based ink — become highly complex when you start considering the environment down in Brazil where they are cutting down trees to grow all that soy.
This proposed standard leaves enormous ethical, economic and environmental questions on the table: If all production adopted this standard, what would the yields be? Would we feed the world? Or would people starve? Or would we expand production and destroy the rain forest to grow sufficient crops to feed everyone? What would be our vulnerability to insects, fungus and other problems?
Now we could all sit down and have a vigorous discussion on these issues. Unfortunately, the process has been fixed.
If you read the Frequently Asked Questions document, you find astounding things:
Q. Who selects members of the Standards Committee?
A. The Leonardo Academy is solely responsible for the selection of Standards Committee members, based on applications received.
Q. On the list of experts consulted, why apparently have no national “mainstream” agriculture and commodity associations been consulted in developing the draft standard?
A. The draft standard was developed with extensive input, but clearly a much wider net must be cast in the development of the final standard. Agriculture and commodity associations are among the many stakeholders invited to participate in the development of the ANSI standard.
The Standards Committee is the one with the power to accept or reject things. That Committee is chosen in the most undemocratic way possible — by the personal predilections of the people at some organization in Madison, Wisconsin.
Then, though they invite the elected boards of directors of industry organizations to “participate,” they don’t give them a vote and they don’t bring them in at the beginning of the process, only at the end.
On this basis, none of these organizations would want to lend credibility to this effort. Why work hard if some arbitrarily chosen committee ignores you?
The stacking of the deck goes beyond the individuals selected for the Committee; it goes to the heart of its makeup. The FAQ says this:
Q. How do you define stakeholders? What stakeholder groups will participate in the development of the standard? Where do government representatives and academic researchers fit in?
A. The Leonardo Academy constitution approved by ANSI recognizes four stakeholder “interest groups” that must be equally represented in the establishment of standards — producers, users, environmentalists and general interest. For the purpose of this agriculture standard, these groups would be interpreted as follows:
- Producer — representative of entity that produces or supplies goods (growers, shippers, packers, farmer organizations,)
- User — representative of entity that uses goods (retailers and restaurants, food service companies, product handlers, processors, distributors, and manufacturers).
- Environmentalist — individuals and representatives of organizations focused on preserving and improving the environment
- General Interest — anyone not in the above categories (government representatives, labor groups and representatives, academic scientists, consumer groups, other interested parties).
Note that this stakeholder definition is not widely accepted; it just happens to be in The Leonardo Academy constitution.
Note the inclusion of 25% of the seats on the board for “Environmentalists.” This Pundit bows before no man in his love for the environment, but “environmentalists” is just a special interest group. There is zero logic in setting aside seats for people who happen to favor the environment over other interests. Why not 25% of the seats for those who favor economic development? This is simply the bias of the particular people and organizations running this project.
It is really quite despicable. Instead of sitting down and saying they want to work together to build a more sustainable world, the forces behind this effort just want to steamroll anyone who would disagree with them.
We found a press release on the Leonardo Academy web site which you can see here claiming they were soliciting for stakeholders to join the process. But we are pretty well-read in this industry, and we can state unequivocally that nobody ever called the Pundit to ask if we might promote the availability of seats on this Committee. Nobody sent us a press release. It all means nobody was trying very hard to do any stakeholder engagement. It sounds like the fix was in.
In fact the process used here was in direct violation of ANSI requirements that call for openness, balance, consensus and due process:
Accreditation by ANSI signifies that the procedures used by the standards body in connection with the development of American National Standards meet the Institute’s essential requirements for openness, balance, consensus and due process.
The agriculture organizations that sent the letter have a pretty good strategy. Turn to ANSI, point out the abandoment of ANSI standards to engage stakeholders and encourage everyone involved to narrow the standard into a kind of “organic plus” so organic growers who want an additional certification can get that. In the meantime, the broader industry can work on a new sustainability standard that really involves all the stakeholders.
Western Growers, United Fresh and PMA are all now on the issue and it will require major efforts to stop this from coming out horribly wrong.
We’ve been working for two months now on a Sustainability Conference for the industry. We’ve had fantastic feedback from Sydney to London and all across North America. Our first survey is going out next week. If you are interested in the field and want to participate in the conference as a partner, as a sponsor, as a member of the steering committee, as a speaker or an attendee, there is still time. Please let us know right here.
As we write this, the Pundit is getting ready to leave for the Cornell University/United Fresh Executive Development program. Our part of the program is to focus on “critical industry issues” as they arise. The only problem is we have to pick the issues months in advance. Last year, we focused on Food Safety. This year: Sustainability as a Strategic Imperative. Good call.