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Pundit’s Mailbag — SCS Takes Exception To Analysis Of Sustainability Standard

Jim Prevor’s Perishable Pundit, March 14, 2008

We’ve been deeply engaged with industry efforts to wrestle with the issue of sustainability.

In addition to giving a presentation at the most recent PMA convention, we also taught a class this week on the subject as part of the United Fresh Executive Development Program at Cornell University.

We also have run a series of articles on the subject, including pieces such as these:

Michael Pollan’s Sustainability Arguments Unsustainable In Context Of Economics

A Call For An Industrywide Sustainability and Social Responsibility Initiative:

Sustainability Being Steamrolled — Does A Sustainable Vision Encompass only Organics

Pundit’s Mailbag — Organic Icon DiMatteo Weighs In On Sustainability Standard

Now we have received a letter taking exception to our analysis of the state of Scientific Certification Systems’ efforts to develop a sustainability standard for the industry:

As an avid reader of the Perishable Pundit for news of important issues and breaking trends in the food industry, I have appreciated the coverage you have given to the issue of sustainability. However, I was surprised to read your coverage of the current ANSI standard setting initiative for sustainable agriculture.

The March 6 issue contains several inaccuracies that may confuse your readers about the ANSI process, the role of the draft standard, and the opportunity for industry participation. I hope you will give me this opportunity to address these issues.

First, it is critical for your readers to understand that the ANSI process is, by definition, an open, multi-stakeholder, non-proprietary process for establishing American National Standards. Industry representatives (producers, retailers, food manufacturers, etc.) will occupy 50% of the Standards Committee positions. Indeed, the ANSI process ensures that industry representatives are directly involved and take a leading role in establishing the final standards that emerge. This ensures that economic viability and practicality are central considerations.

Second, under the ANSI process, a draft standard for trial use is submitted to serve as a placeholder document only, to stimulate discussion, and to provide test data from field applications that can inform the discussion. However, it is entirely up to the Standards Committee to determine what the final standard will ultimately be. In other words, by going through the ANSI process, the objective is to ensure that there will be a full vetting of each issue by a balanced committee of stakeholders.

Third, many unfounded concerns were expressed in the letters you have published thus far, both about process and substance. I would suggest that readers contact the Leonardo Academy regarding its response on process issues, and in addition, visit the Leonardo Academy website to download the Q&A document, which is updated and posted as new questions arise. I suspect that most of your readers’ concerns can be addressed directly in this way. I am also happy to correct misunderstandings about the draft standard submitted.

Now, let me speak to the need for a national standard. Over the past year, a public outreach effort, reported in a wide range of industry publication has been underway to acquaint agricultural sector stakeholders with the American National Standards Institute (ANSI) process. The purpose of this year-long education drive has been to invite stakeholders from as many different perspectives as possible to join in the process in order to share their views about the promise and practice of sustainable agriculture in a public, non-proprietary, consensus-driven forum.

Understandably, each different stakeholder group wants to ensure that sustainability is defined in a way that supports its own interests. These differences of opinion are one of the major reasons why a national dialogue on this subject is so desperately needed, in a balanced multi-stakeholder setting. Here are some other considerations:

  • Sustainability claims have emerged for a wide range of agricultural products, from foods and flowers to fiber-based products and biofuels. These claims may be based on laudable achievements, but lacking a common framework and a common set of sustainability indicators, they cannot easily be distinguished from “greenwashing”. The likely result is the dilution of such claims, and the accomplishments they represent, as a market force for positive change.
  • Growers’ sustainability practices are under scrutiny from their downstream customers, and retail-driven supply chain management programs and scorecarding systems are emerging. Growers increasingly recognize the need for an active voice to ensure that these initiatives do not impose conflicting or wholly impractical demands.
  • The proliferation of “sustainable” and “green” certification labels in the marketplace, based on competing proprietary standards, introduces a confusing array of interpretations, and imposes unnecessarily redundant costs upon growers seeking recognition for their efforts.
  • Half of American consumers now state that they select products based on one or more sustainability attributes, according to a 2008 survey conducted by Information Resources, Inc.
  • A comprehensive framework that brings product safety and quality into the equation is needed to ensure that these attributes, as central to successful business as environmental and social goals, are included in sustainability planning and investment.

A voluntary standard developed under the ANSI process can address these concerns and others, heading off potential disputes in an open, reasonable manner. It represents an opportunity to put concerns to rest, and seek common solutions.

CHALLENGES AHEAD

The challenges ahead are significant. There are clear regional variables, important product sector distinctions, concerns that the interests of small and mid-scale farmers be protected, and awareness that standards must remain flexible enough to encourage continuing innovation. Likewise, there is a growing recognition that sustainability is itself a journey, one that ultimately involves relationships along the entire value chain, from grower to consumer. Moreover, there are still many unknowns, because our understanding of sustainability evolves along with our increasing knowledge about the risks to the environment. But it is these very challenges that provide the most compelling reasons for stakeholders to engage in a constructive, forward-looking sustainability dialogue.

The ANSI process for writing the national standard will begin in earnest later this spring. Every stakeholder’s point of view will be taken seriously. The draft standard that has been published is a placeholder document that has already served its purpose in stimulating debate on key issues, but it should be understood as just that — a placeholder — rather than as a document set in stone. The objective, in the end, is to arrive at the best, scientifically supportable standard that can be used to support and drive measurable agricultural improvements and land stewardship, and highlight the agriculture industry’s ability to address the key environmental and social issues of our time.

— Linda Brown
Executive Vice President
Scientific Certification Systems

We thank Linda for her letter and are pleased to let her have her say. We actually are in complete agreement on the need for a national standard. As Tim York of Markon Cooperative wrote in his letter that kicked off this line of our coverage, we desperately need an industry standard to head off every buyer from developing his own.

Our problem is not with the concept; it is with the specific execution being used in this particular effort. We also find that many choices made by Scientific Certification Systems are presented as if they are required by the ANSI process, when that is not the case. Specifically, we note seven things about this letter:

  1. Although the letter states that our article “contains several inaccuracies,” the letter does not identify even a single inaccuracy in our piece.
  2. To say that the ANSI process is “by definition, an open, multi-stakeholder, non-proprietary process” is a truism. That doesn’t mean that the way the process is approached will make no difference in the outcome. So, for example, the choice of the Leonardo Academy to handle Process Administration is not required by the ANSI process. For that matter, the Leonardo Academy makes it very clear that it is not developing a standard but is providing “process administration for standards being developed by other organizations”. And who might be this “other organization”? Why it is no other than Scientific Certification Systems. Note that nothing in ANSI requires this process go through either the Leonardo Academy or Scientific Certification Systems.
  3. Although it may be true that “ Industry representatives (producers, retailers, food manufacturers, etc.) will occupy 50% of the Standards Committee positions,” it is irrelevant. First, the Leonardo Academy reserves the right to pick all members of the Committee. Since the produce industry had no choice in the selection of the Leonardo Academy, it should not be obligated to accept its choices of who serves on the Committee. Second, the whole process is biased by the arbitrary reservation of 25% of the seats on the committee for environmentalists. Environmentalists are a special interest group; they deserve a place at the table but no more so than advocates of economic development and many other interest groups. Note that reserving 25% of the votes for environmentalists is not required by ANSI. This is in Leonardo’s Constitution, not ANSI’s.
  4. Linda writes that “… under the ANSI process, a draft standard for trial use is submitted to serve as a placeholder document only,” but this is completely optional. If we wanted to begin the process with stakeholder engagement to determine issues of concerns and ask for feedback on those issues before drafting a document — nothing in ANSI precludes that process.
  5. We ran a link to the Leonardo Academy Frequently Asked Questions and we do so again here. But it is not the responsibility of produce industry companies to go, like supplicants, begging to understand the intricacies of the Leonardo Academy Constitution. If the Leonardo Academy has the slightest interest in gaining credibility in the produce trade in the hope of being an acceptable facilitator, it is incumbent on it to reach out and persuade. To date, it has done nothing.
  6. We published two letters as part of our article. One was signed by Bob Martin of Rio Farms on behalf of a group of California producers. The other was signed by these 33 organizations:

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

Croplife America

Cotton Incorporated

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

RISE

United Soybean Board

U.S. Rice Producers Association

United States Soy Export Council

USA Rice Federation

To simply dismiss concerns expressed by these organizations as “unfounded” — as if they are all a bunch of ninnies who don’t understand the process or the substance — is a little unfair. We would think it more reasonable to think the executives of these organizations understand both the process and substance and are not happy with either.

  1. Although Linda points out that “…each different stakeholder group wants to ensure that sustainability is defined in a way that supports its own interests.” — and we suppose that is fair enough — it is noteworthy that plenty of people, including the Pundit, are critical of the process that has been followed, although they have no particular interest to push.

Our position is simple:

  1. The facilitator has to be agreed on by the stakeholders — Leonardo Academy has not been agreed on.
  2. The allocation of board seats has to be agreed on by the stakeholders — The arbitrary allocation of seats to environmentalists has not been agreed on, nor has Leonardo’s right to choose the committee.
  3. The scope of the standard (Should it include biofuels? Should organics be separate?) has to be agreed on by the stakeholders. The current scope has not been so agreed.
  4. No draft document that creates a rebuttable presumption. Anyone can attach any number of standards as examples of things that have been done. The first draft, however, should be developed by people the stakeholders have elected. That has not happened here.

Basically SCS made the decision to go ahead and work with the Leonardo Academy, which is not required by ANSI. Since there is no industry consensus that Leonardo is the right facilitator or that its constitution, with it’s a priori allocation of 25% of seats to environmentalists, is just, this process is a dead end. We have to start again.

These are tough issues, and we respect Linda for standing up and defending her beliefs and the actions of her employer, Scientific Certification Systems. We have no doubt that Linda believes deeply and sincerely that her efforts are helpful to the industry.

Others, however, have different opinions and they are not obligated to acquiesce in a process they feel profoundly unfair.

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