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Second Appeal To NRA

Jim Prevor’s Perishable Pundit, March 8, 2007

We’ve been focused on the National Restaurant Association and its intention to unveil its own food safety plan. First we published an interview with Donna Garren, Vice President, Health and Safety Regulatory Affairs for the NRA, under the title of National Restaurant Association Soon To Unveil Its Own Food Safety Plan. We then published An Open Letter To The Board Of Directors Of The National Restaurant Association to urge the association to engage with its members’ supplier base and the rest of the produce industry rather than unilaterally announcing a final plan at a conference.

For those who don’t know her, Donna Garren is a terrific person. She is smart and knowledgeable with a PhD in food science and technology. She also has intimate knowledge of the produce industry, having worked at United as Vice President, Scientific and Technical Affairs for six years. Before that she worked for Boskovich Farms as its Director of Research & Development and Product Safety.

She knows the issues, she knows the people and she is a scientist. It is inconceivable that, given her druthers, she wouldn’t prefer to work collaboratively with other scientific and technical people such as her fellow PhD’s, United’s David Gombas and Jim Gorny who, along with WGA’s Hank Giclas, we honored with an award for service to the trade.

So why the secrecy?

Why is it that although the produce industry has been keeping NRA fully apprised of its thinking on technical and scientific issues and industry standards, the NRA won’t share its thinking?

After all, there are only two possibilities.

POSSIBILITY ONE: NRA and is experts have substantive issues with the proposed GAP metrics. They have studied the matter and feel strongly that the produce industry is, say, underestimating the migration rate of E. Coli 0157:H7 and thus much larger buffer zones are required between growing areas and potential reservoirs for E. coli 0157:H7.

If this is so, then obviously NRA should be passing on its thoughts, even preliminary thoughts on these matters.

This is science and, of course, the produce industry scientists could overlook something or interpret something differently than another scientist would. So, of course, the produce industry would welcome any critique that NRA and its scientists would like to make. That is why you can read the draft GAPs on PerishablePundit.com, the United Fresh web site and the web site of the Western Growers Association. The industry welcomes input and feedback. We want the best possible standards.

POSSIBILITY TWO: NRA and its scientists have no objections to anything the GAPs contain. They have no scientific arguments to make, no need to hold discussions. Instead what is happening is some kind of association politics in which the executives at NRA want to be seen as demanding things from the supplier base as opposed to cooperating with the supplier base.

So the NRA plan is just to take the GAP standards developed by the produce industry and add a bunch of superfluous requirements. Not requirements they are prepared to defend on a scientific basis. Not even requirements they are prepared to defend on some rational relationship between enhanced standards and caution. Just something they are interested in doing so they can say “we are tougher than you.”

These types of things happen all the time. Normally we can dismiss it as the price that is paid for the jockeying between different organizations.

But food safety is too important to allow such petty bickering.

Where consumer health and safety is at stake, where the livelihoods of countless farmers are at stake, we can expect industry trade associations to work together toward the same goal. Especially because NRA is doing its own members no good.

NRA’s plan is to reveal its secret food safety plan at a conference at the end of March — by which time no standard could have much effect on the Salinas season.

In fact all that NRA is doing is assuring that if someone gets sick, its members will be vulnerable to law suits on the grounds that they are selling product that doesn’t meet the standards that their own association recommends.

Far better to keep these recommendations as a draft form, share them with the produce industry for analysis and discussion as a draft. Use the conference to reinforce this process.

The GAP standards are a living document, designed to be changed as the science advances. The current proposed GAPS are before the CDFA right now, something very close to them will be adopted very soon.

But the Yuma season will come up fast enough. Let NRA be a part of version 2.0 of the GAP documents.

Food safety depends on the entire supply chain working together. NRA’s penchant for secrecy and unwillingness to involve the supplier base is, in fact, inimical to the efforts needed to ensure safe food for the patrons of America’s restaurants.

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