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GAP Program Still Leaves Questions

Jim Prevor’s Perishable Pundit, March 29, 2007

The California Department of Food and Ag came out with its press release announcing what we announced yesterday — that the Leafy Greens Marketing Agreement Board has accepted the industry-generated GAP for use in its verification program.

You can read the release here.

The release raises three interesting points:

POINT ONE:

The metrics, which are guidelines for good agricultural practices (GAP) to be followed by marketing agreement signatories, were proposed by a coalition of leafy greens industry members, and were reviewed and endorsed by food science experts in academia and government.

The Marketing Agreement requires that the standards be
“…scientifically peer reviewed by a nationally renowned science panel…”

Who was on this panel? Who selected the panel? Do they have any conflicts of interest? What did they have to say in their peer review on the standards? How can anyone judge if these standards are good, bad or indifferent if the composition of the panel and their comments on the standards are not released?

POINT TWO:

We recognize and appreciate the numerous GAP initiatives coming forward from trade organizations and private companies, said marketing agreement board chairman Joe Pezzini. However, the California Leafy Greens Marketing Agreement program is the only initiative that will incorporate on-site field inspections that are conducted by a government inspection and verification entity. The California Department of Food and Agriculture will be using state and federal inspectors trained by the USDA.

Joe is pointing out a crucial fact, which is that standards are only half the deal; actually implementing them is the crucial thing. So verification is required. Buyers who simply accept without verification that a vendor is doing what he claims to do are putting their customers at risk. Trust but verify should be the watchword.

One thing for the Board to be cautious of is that as we read the Agreement, it doesn’t actually require that every field be inspected. It just means farmers have to open their fields to inspection. We think it is important that the Board make sure that, in fact, every field gets inspected.

POINT THREE:

To date, 54 handlers representing 98 percent of leafy greens produced in California have signed up for the marketing agreement.

There is something really wacky here, and it is possibly hurting the industry. Fresh Express represents over 40% of the packaged salad business and it is not a signatory.

Admittedly the board is broader than packaged product. Still, the math doesn’t work.

The CDFA refuses to show even the Board its numbers and won’t explain where or how it came to these numbers.

The most logical explanation is double counting. So a grower grows product for Dole and Dole sells the bagged product. The CDFA must be counting both the grower’s sale to Dole and Dole’s sale to the consumer.

Maybe they are even triple counting: A grower sells to a processor who is labeling a product for another handler who then sells the product to consumers.

It is very irresponsible for the CDFA to act this way. In response to Eric Schwartz’s letter that we ran yesterday, one buyer told us that he saw no reason to constrain his supply chain because if 98% of the leafy greens grown are under the agreement, he would have no choice but to buy Marketing Agreement product anyway. If other buyers are thinking like this then the inaccurate CDFA numbers are making it easy for buyers to not take a position. This, in turn, makes it easy for producers to not sign up.

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