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Chinese Garlic And Food Safety

Jim Prevor’s Perishable Pundit, June 21, 2007

Our piece, China Plays Down Food Safety Problems, didn’t mention any fresh produce imports from China, but China is a significant supplier of garlic, and the piece struck close enough to home to prompt this letter:

As an industry we all have concerns about food safety and product integrity. Whether the commodity happens to be carrot juice, spinach, tomatoes or melons, a food safety problem for one is a produce industry problem for all.I have friends that pack spinach grown outside of California that are still trying to get back to sales levels achieved prior to the outbreak.

When CNN attacked the California produce industry, I think most of us in the industry felt as if it was an indictment of our industry as a whole.

China has been a popular target in the press of late. Perhaps the recent trouble with China’s consumer goods has been welcomed by some as a distraction away from our own problemsand shortfalls. But, the fact is that produce from China has not been responsible for any of the produce-related outbreaks that have plagued us in recent memory.Finger pointing hurts everyone.

Several areas in China have made the commitment to non-mechanized, small farm organic agriculture. There are entire counties dedicated to growing organically. We import garlic and ginger products from a company that is certified organic by the Organic Crop Improvement Association (OCIA International) based in Lincoln, Nebraska, and recognized by the USDA’s National Organic Program (NOP).

You correctly point out that organic certification inspections are conducted annually. Our facilities in China are audited to comply with standards for successful certification by JONA (Japan organic certification, with more stringent criteria than our USDA/NOP), HACCP, ISO 9000 and BRC Global Standards (a European certification). In addition, we do internal audits and testing, including weekly testing of the water.

In the end, does it not come down to trust and reputation? I Love Produce has an office in China overseeing our purchases and operations.Our name is on every product we sell.Our customers deal with I Love Produce because of our professionalism. This is no different than customers that deal with Dole because of their expertise in Chile or Chiquita because of their expertise in Central America. Customers deal with the category leaders because they know their produce is grown, packed and shipped with the highest quality standards regardless of whether the origin is imported or domestic.

In 2003 we hosted a trade media tour of our facilities in China. The facilities were reported to be among the best in the world. If anyone needs further convincing,please consider this letter as an open invitation to the Pundit, Produce Business and/or any Chainstore executive. If you would like to see what is really happening in China’s food industry, we invite you to see it first hand.

— Jim Provost
I Love Produce, LLC
Kelton,Pennsylvania

Jim, though still a young man, has been around a long time. Long enough to see the garlic industry transformed by the availability of relatively inexpensive Chinese garlic.

Quite correctly, Jim points out that none of the current food safety issues related to China have affected Chinese garlic. However, the absence of an outbreak doesn’t prove that proper food safety procedures are being used in growing and processing all the garlic in China.

Jim’s letter reaches us at an opportune time as The Washington Post just ran a piece entitled, Cause for Concern In Chinese Bulbs? — the piece highlights the way the discovery of food safety flaws that led to problems in both human and animal food is making people question all facets of the food safety system in China.

The article raises general concerns on imports of food from China and the inability of the FDA to inspect a reasonable sample of those products:

The FDA, responsible for inspecting some types of food from 130 countries, last year was deluged with 21 million shipments of food imports, among them 199,000 from China worth about $2.3 billion. FDA inspectors refused 298 food shipments from China in the first four months of this year: They included catfish laden with banned antibiotics, mushrooms laced with illegal pesticides, and others. The rejection rate for Chinese goods is about 25 times that for Canadian goods.

The FDA has 1,750 inspectors, but only 450 work at ports, notes William Hubbard, a former associate director of the agency. “There are 419 ports of entry, ship, air and land crosses,” he says. “The FDA is able to staff 40 of them. Some [workers] are part time.”

The article raises some specific concerns on dehydrated garlic imports from China:

Fresh garlic isn’t the only form of the vegetable causing concern. The U.S. Department of Agriculture’s Foreign Agricultural Service says dehydrated Chinese garlic imports increased 384 percent in the past 10 years. Layous and others cite a 2002 report by the now-defunct Americans for Wholesome Food, a coalition of businesses and organizations dedicated to educating consumers on domestic and imported garlic powder. The AWF’s report, based on independent lab tests, found “high levels of lead, arsenic and added sulfites in two supermarket-brand imported garlic powders from store shelves.”

In general, though, considering the scale of imports, there are only a smattering of concerns regarding imported garlic and typically they are related to processed product:

The FDA said it could not provide information on detention and refusal rates of Chinese produce and how they compare with those for other countries. But FDA records show that since 1994, fresh and processed garlic have been targeted for automatic detention and surveillance. Numerous shipments from several companies — five Chinese, one Canadian and one Argentine — were refused because of insects or insect damage, mold or filth between 1994 and 1996. The Canadian firm had repacked Chinese garlic and shipped it, peeled, in five-pound jars. Thirteen fresh garlic shipments from China were refused at California ports.

AWashington Post search of nearly 900 FDA “refusal actions” from May 2006 to April 2007 turned up 18 shipments of garlic products from several countries. Some examples of rejections: from China, chili garlic sauce, because manufacturing information was not provided; from Canada, garlic paste, made in unsanitary conditions and inadequately labeled; from Argentina, “filthy” garlic bulbs. In May and July 2006, 13 shipments of garlic in mango, tomato and green chili sauces from India were refused, 11 because of pesticide residue.

Since 1991, the Centers for Disease Control and Prevention has determined that three food-borne illness outbreaks (each involving fewer than five people) were caused by garlic oils. Twice, the bacterium that causes botulism was found. After outbreaks in the 1980s related to garlic in soybean and olive oils, the FDA required that oils contain an acidifying agent, and it recommended refrigeration.

Garlic, by its nature, is not particularly vulnerable to food safety concerns, and because it is eaten as a cooked product, it has a built-in “kill step” that makes it unlikely to be a source of food borne illness:

For several reasons, experts say, fresh garlic is safer than processed, and they suggest ways for consumers to make it even safer.

Michael Doyle, director of the Center for Food Safety at the University of Georgia, says that garlic has natural inhibitors against pesticides. Marion Nestle, professor of nutrition and food studies at New York University and author of “What to Eat,” says the skin also protects somewhat against pesticides, if any were used. “Pesticide residues can be removed by washing,” she says.

E. coli and other bacteria on fresh garlic would probably be only on the exterior, Nestle says.

She and Doyle agree that besides peeling and discarding the skin, the one sure-fire way to kill off microorganisms is to turn up the heat.

“A quick dip in boiling water would do it,” Nestle says, “as would searing.”

And, of course, the price difference is so great, and with a “kill step,” the food safety risk so small that even the stalwarts of the industry in California use Chinese garlic in certain applications:

Although most of our fresh garlic comes from halfway around the world, it’s cheaper than garlic grown in California. For example, California garlic bulbs were priced at $4.99 a pound at Whole Foods Market last week, but a pack of five Chinese bulbs — about a pound — were just 79 cents at Great Wall supermarket in Falls Church. The U.S. Department of Agriculture says garlic prices have dipped 12 percent in a decade.

California growers think that stinks, because it’s killing their business. They grew 18,000 acres of garlic last year, which is only about 2 percent of the world’s supply. A decade ago, they grew 36,000 acres. In the early 1990s, U.S. trade officials found that China was "dumping" garlic, or selling it below what it cost to produce. A 377 percent tariff caused imports to dip for a while until shippers found a loophole.

Some California growers and processors say that even though they don’t like Chinese garlic, they buy some because it’s cheaper than what it costs them to grow it — even in Gilroy, the “Garlic Capital of the World,” which in July will hold its 29th annual festival celebrating the vegetable.

Bill Christopher of the 50-year-old Christopher Ranch there, one of the largest U.S. growers, explained why: “A 30-pound box of Chinese garlic is $14, but our cost [to produce it] here is $26.27.” Although he claims California garlic tastes better — independent lab tests show it’s denser in texture than Chinese — his company uses imports in some prepared products, such as sauces.

Like Christopher, John Layous of the Garlic Co. in Bakersfield, Calif., buys Chinese imports to keep costs low. He supplies Costco, Sam’s Club and food-service companies. Layous rails against what he sees as China’s unfair competitive advantage, saying his 185-person company, in business since 1980, pays decent wages and provides health and other benefits, unlike Chinese growers. “Another big addition to our costs is the expense we go through to make a safe product,” he says, adding that U.S. companies are government-regulated to ensure food is safe.

So the concern with fresh garlic from China is really not a food safety one. Processed product is another story. What is consistent among the food safety issues from China is that, unlike in the United States, many of the issues are related to intentional adulteration of the food with cheaper ingredients.

That is what this whole melamine issue in dog food is about. In our piece yesterday, we referenced infants being malnourished because their powdered baby formula was adulterated. The AWF finding we reference above of adulterated garlic powder should be taken very seriously when viewed in this context. This time it may be an accidental contamination; another time it may be an intentional adulteration with a cheaper ingredient.

Now, of course, we had safe food, or as safe as our knowledge could make it, long before we had any government regulation anywhere. In the absence of government regulation, we have to depend on the companies that produce the product and the retailers and foodservice operators that sell and serve the product.

The Pundit is often invited to “inspect operations” of growers and packers all over the world. Jim was kind enough to invite the Pundit on the trade media tour he reference but a conflict prevented us from taking advantage of that trip. We certainly hope to go another time.

One thing is certain, though… We don’t go anywhere to pass judgment on the food safety systems. How could we? We are not an auditor, making a surprise visit, with the power to demand records. Besides, even if we were shown water test results and pesticide application data and soil test records, we wouldn’t know how to evaluate that data.

And food safety is a result of systems, procedures and HACCP plans — even a trained auditor or regulator can’t evaluate food safety procedures and compliance with such procedures on a walk through a field, packinghouse or office.

So reputation and competence are everything. Obviously trade buyers will feel more comfortable buying from a company with an on-sight office, long experience and a personal understanding of the stakes for trade buyers in buying unsafe product.

Is that enough? On a product such as fresh garlic — probably yes. On other products — maybe not. And one will demand a Primus audit all the way from China.

Certainly retailers still need to have standards and not simply buy from the broker with the lowest bid.

When we get into an area such as organic certification, there are more problems. The Pundit has a friend who is a kosher-certification rabbi, often working in China. The plant he recently inspected passed muster, except the employees often brought pork — which is not kosher — into the plant for their lunch.

To achieve the kosher certificate, the rabbi made the factory ban pork from being brought in for lunch and posted signs to this effect. The employees complied… right up to the moment the rabbi flew back to America. Then the employees, with the winked eye of a complicit management, brought for lunch what they chose.

Obviously, if one trusts completely the supplier or the government, then none of this matters. Yet we have auditors and regulators because we don’t trust anyone that much.

And the culture and financial incentives leave someone wondering about compliance. Is that small organic farmer really going to care so much about being organic that he will disk his crop under and bankrupt himself because something inadvertently spills in the field? If a crop failure looms, will these people, with no financial reserves to draw on, still avoid spraying and simply accept a crop failure and utter destitution?

Is the OCIA, based in Lincoln, Nebraska, really there enough to be certain about what is going on?

Jim’s point as to branding is precisely correct: in the absence of a strong governmental regulatory process, one depends on the integrity of brands. That may be great consumer brands such as Nestle or Kraft watching carefully what happens in their factories or it may be trade brands such as Jim’s I Love Produce LLC that trade buyers put trust in.

In reference to the Soviets, Ronald Reagan used to use a quote that came from Damon Runyon which seems apropos to this situation. When it comes to food safety in China: “trust but verify.”

Many thanks to Jim for his frank letter on this important subject.

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