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SPECIAL EDITION
The Cantaloupe Crisis:
Audits, Auditors And Food Safety

With 25 people dead and one miscarriage, the horror of the listeriosis outbreak on Rocky Ford-brand cantaloupe from Jensen Farms weighs on the industry. To those in the supply chain that have been implicated, they must rise every day carrying the burden of knowing they were part of this catastrophe.

To those not implicated, it is worth remembering that all the work on food safety in cantaloupes was really done on salmonella; listeriosis was not a prominently considered hazard. This means that we have no idea what hazard will pop up next — or on which product.

At first, there was a bit of a trend in the industry to demonize Jensen Farms as if they ran some kind of uniquely low quality facility – a proposition for which there is no evidence.

Then word broke that the packing facility had been audited and received a high mark. So the venom of a world looking for answers turned to attack auditors.

But an audit is not like a grade in high school. One can score very high against a particular standard — say “standard industry practices” — yet very low against another standard – say “best practices” — so a grade on an audit means nothing unless you understand fully against what standard one is being graded.

There are lots of issues:

• What is industry standard — what 90% of facilities do or what 10% of facilities representing 90% of production do?

• How can we avoid giving false assurance to those not going to study audit reports but just look at quick scores?

• If we make audits more rigorous, will it really be acceptable to flunk 80% of the nation’s facilities on these audits? Especially if the operators will never be able to meet the new standards?

• Right now, all the focus is on these horrible deaths. If this is a once-every-hundred years event, how much money will consumers want to spend on cantaloupes to make it a once-every-200-year event?

• Can retailers change procurement strategies to prioritize on food safety?

• Can the FDA articulate clear procedures that growers and packers must follow — and would it do any good?

To address these issues and more, we’ve decided to focus this issue solely on the Cantaloupe Crisis.

May God grant comfort to those who have suffered loss in this affair, and may He grant the industry the wisdom to find a path toward a safer tomorrow.




CANTALOUPE CRISIS ANALYSIS: While “Blame The Auditor” Frenzy Rages, It Pays To Look At Best Practices Vs Standard Practices

We’ve carefully analyzed the cantaloupe crisis in pieces such as these:

THE CANTALOUPE CRISIS: The Truth That Dare Not Speak Its Name: The Priority Can Be Safe or The Priority Can Be Local, But It Cannot Be Both

CANTALOUPE CRISIS ANALYSIS: Key Performance Indicators and Food Safety... Shall The Twain Ever Meet?

CANTALOUPE CRISIS ANALYSIS: The Need For An Aligned Supply Chain And An FDA That Won’t Punt On Food Safety

When Elizabeth Weiss of USA Today broke a story — Listeria-linked Cantaloupe Farm Had Rated High In Audit — that detailed the fact that Jensen Farms had received a top score — 96% — in a Primus audit done just six days before the first person fell ill from these cantaloupes, we received many letters, which we will deal with in due course. One simple letter, from a very intelligent person who closely follows food safety, gives us a clue as to the issue the industry has to deal with regarding audits:

What is your feeling about the responsibility of the third party certifier of the safety of the melons ?? . . .

Craig K. Harris
Department of Sociology
Michigan Agricultural Experiment Station
National Food Safety and Toxicology Center
Institute for Food and Agricultural Standards
Michigan State University
East Lansing, Michigan

Of course, anyone who works in this area knows that neither Primus nor any other auditor acts as a “certifier of the safety” of any produce item. There are no consumer websites urging consumers to buy audited product by these auditors and no corporate shield stickered on the cantaloupe or other items.

Although commercial buyers are free to set up their own standards —  and the world is filled with organizations that have standards, and one can get an audit on one’s conformance with those standards —  typically audits are simply scored against standard industry practices. They are not scored against optimal food safety practices at all.

That is what happened in this case. Jensen Farms did not have, and apparently Wal-Mart and others allowed it not to have, a Primus GFSI Audit. This was a standard Primus Good Manufacturing Practices Audit.

We have great respect here at the Pundit for Trevor Suslow of UC Davis, whose work we have featured many times including these pieces. Note that several specifically address cantaloupes and food safety:

Trevor Suslow Of UC Davis Speaks Out: The Truth About Consumer Reports, Bacteria And Packaged Leafy Greens

Salmonella And Tomatoes Linked In New Mexico

Consumer Guide To Cantaloupe Food Safety

Pundit Special Science Report: Part 1 — Food Safety Vulnerabilities In Yuma And Salinas

Pundit Special Science Report: Part 2 — The Science Of Waterborne Bacteria

Salinas Flooding Brings Out The Consequences Of The California Leafy Greens Marketing Agreement

Understanding GAPs

Pundit’s Mailbag — Cantaloupe Leaders Provide Roadmap To Safer Future

We also deeply appreciate the work of Stephen Patricio, who is the chairman of both the California Cantaloupe Advisory Board as well as the Center for Produce Safety, and is president and CEO of Westside Produce. 

Press reports lately, though, quote both Trevor and Garrett in a manner that mischaracterizes the state of the industry regarding standards on washing cantaloupes. The media is portraying it as if the Gold Standard practices of a half-dozen large California/Arizona firms are standard throughout the industry. They are not.

We would say the issue boils down to our original point that regional and local buying is interfering with food safety.

The issue is this: In the past Jensen Farms used a “hydro cooler” that had used recirculated water to wash and cool the melons. The recirculated water was treated with an antimicrobial. This season, it switched to a “one pass’ system that did not use recirculated water. It also did not use an antimicrobial.

We’ve been around this issue for more than 26 years and, in general, one-pass systems that do not use recirculated water are considered food safety advances. It is very hard to keep clean a dunk tank full of dirty cantaloupes with water being recirculated and a little chlorine is not a guarantee. Remember all the wash water during the spinach crisis was treated and that treatment did not prevent the crisis.

Still in the USA Today article, the quotes are clear:

Suslow, an expert on the post-harvest handling of produce at the University of California-Davis, said he was rendered "speechless" at news that Jensen was using untreated water to wash its melons.

The problem, which Suslow called a "red flag," was a switch by Jensen to a new fruit-washing system in July 2011. According to the FDA report and Gorny, that month Jensen Farms purchased and installed a used potato-washing machine to wash its cantaloupe.

According to the audit done by Primus Labs in August 2010, it appears that Jensen Farms had previously used a "hydro cooler" system to wash and cool the melons as they came in from the field, using recirculated water that was treated with an anti-microbial to kill bacteria.

For the 2011 harvest, the farm switched to a system in which cantaloupes were washed with fresh water that was not recirculated and "no anti-microbial solution is injected into the water of the wash station," the auditor, James DiIorio, noted on the first page of his audit.

"You would flat-out never do that, absolutely not," said Suslow, who spent more than six years researching cantaloupe safety and handling. No matter how clean the source of water is, once it's sprayed on "any kind of surface where you have multiple produce items rolling across it, you're trying to prevent cross-contamination … so you always add something to the water."

Suslow called this a "fundamental error with just tragic consequences. We can't know that it absolutely made a difference, but I honestly think it could have prevented the scale and scope of what happened."

***

The problems that were found at Jensen Farms are "Packing House 101," said Stephen Patricio, chairman of the California Cantaloupe Advisory Board. "Every common surface must be cleaned, rinsed and sanitized," he said. "These are all just known, recognized practices."

"It's just disgusting to me," Patricio said of both Jensen Farms and Primus Labs. "I think of the damage that they've done to our industry as the result of this oversight. No, I won't even talk about it as oversight, it's abuse."

Dr. Suslow and Mr. Patricio are, of course, free to attempt to persuade others that these are desirable steps, indeed that these are essential steps. They may well be correct. In fact we suspect they are correct.

It is worth noting, however, that they have not succeeded in persuading Wal-Mart or Costco of these facts. Neither retailer, nor any other retailer that we are aware of, has a specification on procurement of cantaloupes that all cantaloupes must be washed with an anti-microbial if the water is non-recirculating.

The FDA guidance on the matter makes no mention of any requirement for antimicrobial usage in single-pass or non-recirculating systems. See the highlighted and underlined section below:

Melon Cooling Medium

Melons typically are cooled by forced-air cooling or by use of a chilled water drench or flume immersion. Melon cooling with water, if done correctly, may reduce microbial loads on the outside surface of melons by 2-3 logs CFU. Microbial reduction on melon surfaces is dependent on disinfectant concentration and contact time. However, once present on the surface of a melon, human pathogens cannot be completely eliminated by washing.

Prolonged soaking of melons in aqueous solutions containing wash water disinfectants is not an effective means of eliminating surface microbial contamination of the melon rind and may actually aid in the infiltration of human pathogens into the edible portions by creating an infiltration driving force.

Melon cooling water also may be a significant source of microbial cross contamination if there is insufficient water disinfectant present. In addition, because melon cooling water is colder than the melons, infiltration of small amounts of cooling water may enter melons through the stem scar and rind. Forced-air cooling operations can avoid the risk of infiltration but also may spread product contamination if forced-air cooling equipment is not cleaned and sanitized regularly.

FDA recommends:

  • Evaluating water quality of cold water used to cool melons to ensure that water is of sufficient microbial quality for its intended purpose.
  • Evaluating and monitoring water disinfectant levels to ensure that disinfectant is present at levels sufficient to reduce the potential risk of cross-contamination when melon cooling water is re-circulated. If melons are fully submerged in water as a means of cooling, they are more likely to have cooling water infiltrate into the melons and consideration should be given to cooling water quality variables such as pH, soil (including organic) load, turbidity, and product through-put capacity, to ensure that the wash water disinfectant of choice is effective in reducing the potential for water-to-melon cross-contamination.
  • Using single pass (or one use) cooling water of sufficient quality for this intended purpose also may be used to cool product.

  • Cleaning and sanitizing equipment on a regular basis to ensure that the potential for cross-contamination is minimized when forced-air cooling is used to cool melons.

There is no such requirement on other commodities either. For example, there are no requirements for antimicrobial usage in single pass or non-recirculating systems for tomatoes or in the rigorous California Leafy Greens metrics, which has this to say about post harvest systems:

Single Pass vs. Multiple Pass Systems

Single pass use – Water must have non-detectable levels of E. coli or breakpoint disinfectant present at point of entry

Multi-pass use — Water must have non-detectable levels of E. coli and/or sufficient disinfectant to insure returned water has no detectable E. coli (minimally 1 ppm chlorine).

Remedial Actions:

If any one sample exceeds the acceptance criteria, then the water shall not be used for this purpose unless appropriate disinfectants have been added or until remedial actions have been completed and generic E. coli levels are within acceptance criteria:

Conduct a sanitary survey of water source and distribution system to determine if a contamination source is evident and can be eliminated. Eliminate identified contamination source(s).

For wells, perform a sanitary survey and/or treat as described in Appendix A Sanitary Survey.

Retest the water at the same sampling point after conducting the sanitary survey and/or taking remedial actions to determine if it meets the outlined microbial acceptance criteria for this use.

For example, if a water sample for water used to clean food contact surfaces has detectable E. coli, STOP using that water system, examine the distribution line and source inlet as described in Appendix A Sanitary Survey, and retest from the same point of use. Continue testing daily for 5 days at the point closest to use, and do not use the water system until it consistently delivers water that is safe, sanitary water and of appropriate microbial quality (i.e. Negative result) for the intended use. If any of the any of the five samples taken during the intensive sampling period after corrective actions have been taken have detectable E. coli, repeat remedial actions and DO NOT use that system until the source of contamination can be corrected

The issue is really Best Practices vs. Standard Practices. Dr. Suslow and Mr. Patricio work mostly in California and Arizona, and this is the location of the world class facilities that handle high volumes. These desert cantaloupes are either field-packed — and thus not washed at all — or packed with sophisticated wash systems that Dr. Suslow and Mr. Patricio are talking about.

It is important to note that there are fewer than ten of these facilities in the country, yet there are hundreds of places, maybe more, that pack some cantaloupe at some point in the year.

When the FDA goes into a facility, it has the gift of 20-20 hindsight and unlimited time and resources to solve a food safety issue such as this one.

It is thus able to identify many ways in which this facility falls short of the ideal. It would be a terrible mistake for the industry, though, to think that this means that this was some horrid facility. It was not. It was a perfectly mainstream facility, better than many.

The flaws the FDA found at Jensen Farms could be found in the vast majority of produce packing facilities with a team there day and night swabbing and looking for days and weeks on end. But as with Jensen Farms vs. the California/Arizona industry, these packing facilities account for a small percentage of the nation’s produce.

Auditors Not At Fault

Auditors don’t write standards and don’t write POs. Any buyer has the right to go to Primus or any auditor and say, “We don’t want standard industry practices… We only want to buy world-class best practices.” We have no doubt Primus would gladly change its audit and fail people left and right.

To expect auditors to impose such standards on the trade without the support of either government regulation or buyer demand is to place bizarre weight on a very thin reed.

The government, media and academia should understand, though, that, almost by definition, everyone cannot be “best of class,” so demanding a “best of class” standard will mean flunking lots of producers, indeed most producers. It would mean Wal-Mart would, during the domestic season, buy from the half dozen or so largest packers. Of course, nothing is stopping Wal-Mart from doing that right now.

Over and over again, we have been repeating our story about Costco and its problems with carrots a few years ago in Canada. You can see the original piece here. The question we raised was how — in a company really seen as an exemplar of food safety practices — did a buyer decide it was better to buy carrots from an obscure Mexican grower through an intermediary in Los Angeles rather than buy direct from, in our example, Grimmway?

We harp on this because this is the actual food safety problem in produce. The key to food safety is to know who you are buying from and to have worked with that company over many years to achieve shared values. There must be transparency and mutual commitment to work together.

In our last piece, we pointed out that a food safety expert such as Frank Yiannas at Wal-Mart would almost surely have preferred that Jensen Farms buy brand new stainless steel equipment specific for cantaloupes. That is true, but only part of the story. After all, farmers are famous for their mechanical flexibility and ability to use and adapt economical used equipment. Sam Walton would have almost surely said let us drive costs out of the system and see if we can find ways to incorporate the used equipment to produce safe cantaloupes.

The problem is that because there is no mutual commitment, there is little transparency. A packer such as Jensen Farms won’t want to have a conversation with Wal-Mart because if Wal-Mart says “buy new equipment,” the farmer or packer has no assurance Wal-Mart will provide a price that justifies purchasing that equipment.

What To Do About Audits?

Recognizing that this “blame the auditor” frenzy is bizarre, we can say that the industry does need a different kind of auditing tool.

Right now, the system is that auditors go out, produce an audit and they give a score that is typically cued to industry standard practices and put comments in the notes. In this Jensen Farms situation, for example, the fact that no anti-microbial was being used in the wash water was specifically indicated in the notes as a possible area for analysis. It wasn’t scored against Jensen on the audit because it is not required in the FDA Guidance or by standard industry practice.

In theory, what is supposed to happen is that the audit will be submitted to Wal-Mart, a food safety expert will carefully review it and many discussions will be held about each of these notations on the audit. Wal-Mart, Frontera and Jensen Farms will all come to a conclusion about whether the additional safety gained by adding an antimicrobial to the water outweighs its cost and perhaps other negative impacts, say chlorine on the workers. They will also come to an agreement on which antimicrobial to use and in what quantity. They will request a follow-up visit by the auditor to confirm this problem has been appropriately resolved.

This is the way current audits are designed to be used. If, instead, a secretary receives the audit and checks it off on a compliance spread sheet as the secretary would the receipt of a commercial license, then files it to never be seen again, the audit is not being used properly.

The problem is that this ideal procedure is almost never followed. Melinda Dwyer at Costco is passionate about food safety and tries to do this, but she can’t possibly do it for all of Costco’s vendors, and most companies don’t even have one person working on this.

This is one important reason why our references to an aligned supply chain as the key to food safety are so important. It takes a lot of resources to vet and stay on top of a supplier. A company must constrain its supply chain because it can’t possibly do the right job on a large number of vendors.

As a practical matter, what has happened is that audits are consistently misused. So when questioned about food safety, many buyers at retail and wholesale may just say “hey, these guys got a 96 on their Primus audit” and never even look at the paper.

So, with these facts and this horrid situation, we would lay out four key issues for the trade regarding audits:

1)  What Standard Does Each Retailer Want?

There are many standards out there, but most audits focus on standard industry practices. That is what the whole movement toward harmonization of audits almost intrinsically leads to.

The first question a retailer has to address is whether it is satisfied with that standard. Wal-Mart, for all its pushing on food safety, didn’t demand a different standard of audit. It didn’t demand a GFSI audit, and it didn’t ask Primus to fail the facility unless it operated under all “best practices”.

The trade associations like to suggest that we can have a unified standard. We can, but, by definition, all God’s children can’t be above average.

2)  Who Is Going To Determine “Best Practices”?

Ok, we now all realize that the audit is based on industry standards and, surely, many buyers will say that industry standards are too low and they want to audit firms for best practices.

Sounds good. But who decides what is a best practice? Is it dry harvesting of cantaloupes? Or is it washing with an anti-microbial? Which anti-microbial? In what concentration? Is just washing with anti-microbial enough, or should it be a one-pass system with anti-microbial?

These are not just details. Decisions such as these are the essence of food safety.

3)  How Can We Make Audits Easy To Use?

It is clear that for the produce industry, the optimal outcome would be that a passed audit would symbolize a lot more than conformance with industry standards. To do that the comments would have to be moved into the body of the audit and scored against the company. Many more companies would get low scores or fail the audits. Is the industry prepared for this?

What about government? We would estimate that more than 80% of the packing houses in America would fail a “best practices” audit. Not only that but most cannot meet the standard ever. This is because they involve things like building pre-cooling facilities. Is Washington D.C. going to be OK with putting so many people out of business?

4)  Frequency Of Audits Or Surprise Audits

One of the likely reasons that the Primus audit showed the facility in a good light is that they knew Primus was coming and gussied up the place.

There is nothing wrong with having a first audit on a scheduled basis. Then, intrinsic in every audit regime, has to be a follow-up audit to verify that the audit has been reviewed, non-conformities resolved, all comments addressed.

If something is important enough to put on an audit, then it is important enough to make sure it is being done.

Audits still can only verify conditions on a specific date and time. If the next day the facility head doesn’t like the change made to the pension plan and decides to neglect his job or actively do something evil, then the audit won’t catch it.

It is hard to do surprise audits, especially in foreign countries. Even domestically, word gets around quickly that the auditors are in town.

Still, the possibility of putting on a show for auditors necessitates more frequent visits. Certainly world-class foodservice firms such as Darden and McDonald’s have staff visiting facilities quite often.

Auditors could visit more frequently, but quarterly visits would cost almost four times what an annual audit does. Is the world ready to pay this price?

Auditors didn’t cause this problem. Yet it would be a great thing if any wholesaler on any terminal market could hit a button on a computer and say, “This is OK. It is audited to Best Practices.”

The system now is obtuse. It is as if a teacher gives a student a 96 because on the curve of other students he is doing great – but then writes a lot of comments saying that the student can improve in many ways.

Many won’t even look at the comments because the grade is expected, in school, to speak for itself.

It doesn’t in audits, and that is a big industry problem.




Trevor Suslow Of UC Davis Speaks Out:
Reflecting On Pathogens, Produce, And Practices

Trevor Suslow is Extension Research Specialist, Preharvest to Postharvest Produce Safety at the University Of California, Davis. There is nobody in the world who has spent more time studying the food safety issues surrounding cantaloupes. In light of the Jensen Farms outbreak, we are pleased to share this reflective piece:

MIRROR, MIRROR ON THE WALL…

In my opinion, Jensen Farms is ultimately the responsible party, but is not a produce industry pariah. There are many parties that bear responsibility for the tragedy imposed upon the victims, and their families, after eating Listeria-contaminated cantaloupe. The ripple effects wash over the Colorado cantaloupe industry, the cantaloupe industry at large, and the melon and produce industry as a whole. 

From the information available at this time, it appears clear that an exceptional combination of factors converged with the result of widespread facility and product contamination. I firmly believe, based on my experience and exposure to produce production and postharvest handling nationally and internationally, that a combination of failed or absent preventive hurdles will ultimately emerge as the key factors at this one operation.

However, I am equally certain that potential or likely predecessors exist more broadly than is being truthfully and self-critically appraised. I am concerned that members of the broad produce industry are too readily dismissing this as the negligence of “one bad actor” rather than taking the information, as it comes into the light, as a critical time for re-assessment of vulnerabilities.

Though the investigation is on-going, this is the responsible time to become better informed about the systemic nature of the linkages that exist between pathogens, produce, and practices. In all operations there exists the potential for shifting levels of risk inadvertently, by indifference or by ignorance, from routine and safe to beyond the boundaries of our control.

When it comes to food safety, I am a firm believer in the saying and in applying, “You don’t know what you don’t know”. I know this applies to me and I try very hard to guard against complacency in challenging my deficiencies in subject areas beyond my expertise or my version of common sense.

Recently, I was driving around a rural farming area between extension meetings, as I often do, just to see what was going on locally. A field had been staged for harvest and what struck me was the close proximity to a potential source of airborne contamination. Not the field itself but the equipment and packing materials that would subsequently be brought over to the scheduled harvest blocks.

By chance, that potential became reality as a plume was discharged and drifted across the area. I was the only one around to observe this event and I could not know that anyone responsible for the harvest operations would observe or react to this hazard. Clearly the person who dropped the materials and equipment at this spot wasn’t in tune with the risk potential because it was that obvious.

It was easy to determine who to contact and the situation was corrected immediately and communication of the concern was shared with all involved. The likelihood for contamination was more certain than in most situations where a specific practice or potential for exposure to pathogens may be observed, but one can only speculate as to whether a random illness or identifiable outbreak would ever result. Even in this situation, it is most likely that other food safety controls would have had to fail or other handling practices or fresh processing would have to promote growth of any live pathogens. The fear is that no one down the supply chain would have a clue of this exposure if the people on site didn’t see a problem.

Would a documents audit or even on-site harvest-ops audit get positive marks for having packing material off the ground and equipment surfaces cleaned between fields? I have no doubt that full scores would be awarded. Would the auditor recognize the concern I felt existed in the absence of being at the site but not present during an actual exposure event? I believe that most of the time the answer would be yes; however the long skepticism that has limited confidence within and outside the industry for the uniformity of skills applied to produce audits has not been diminished by a series of apparent deficiencies connected to several outbreaks and recalls.   

I am not suggesting that the produce industry as a whole is riddled with failures in preventive food safety management; however, I have used the cartoon above in many GAPs workshops and industry trainings over the past several years to promote the need for honest self-appraisals.  Sometimes, it isn’t easy to look in the mirror and accurately assess the reflection. Self-awareness also doesn’t always work, especially if one isn’t trained to recognize the problem, which may be subtle or complex. Perhaps worse, it does no good to have someone entrusted to point out the flaws merely give you a sense of false perfection or false security by a poorly constructed judging system and limited or absent secondary review of reports.

The whole supply chain should be considering what actions each link should take to prevent a re-occurrence of recent events. I sincerely hope that at least these two broad actions among the supply side will emerge from the immediate aftermath of this tragedy.

•  All operations should take a team approach to re-analyzing hazards and practice-specific risks with individuals of diverse background, including experienced individuals from cross-operational units and external experts.

• Though applicable to all scales, medium and small-scale suppliers especially should become informed and ideally participate in the evolving educational programs being developed by the Produce Safety Alliance. As the training programs being designed in anticipation and in advance of the pending FDA Produce Safety Rule become a reality, it is critical that growers and handlers commit to attend, extract, and even challenge the practicality of information and guidance that is intended to assist in skill-building towards effective preventive program design and self-audits.   

—Trevor Suslow

The opinions of the author are individual and do not necessarily reflect or represent the position or opinions of the University of California or any other individual or party.

Trevor is a good person and, without a doubt, he has been shaken to the core of his being with the thought that a supply chain to which he has offered much counsel should now be responsible for such loss.

We can only endorse the idea that this is a time for reflection.

Trevor is also 100% correct that we are hearing in the industry too many attempts to demonize Jensen Farms.

As we mentioned in this piece, Jensen Farms may have made mistakes but the kind of mistakes it made could well happen again to other people in other contexts.

Demonizing them as somehow off the scale of produce operations has the convenient, and false, effect of making everyone feel like it couldn’t happen to them.

People are always responsible for their actions, so if Jensen Farms made errors, its owner and executives are, of course, responsible. But those who bought the product and sold it to consumers made errors of oversight, and these people and organizations are responsible for the errors they made as well.

If you believe in the regulatory state, you also have to say that regulators failed in their responsibility to articulate and enforce clear standards that would have prevented such a problem.

As Hillary Clinton taught us, “It takes a village,” she was referencing the fact that children are raised in an environment, and what that environment supports makes it easier or harder for parents to raise their children as they would choose to.

Well, so it is with food safety. Every operation exists in an ecosystem. We need to ask if that overall ecosystem — legal, regulatory, buying end, etc. — is the sort that encourages the thoughts and actions that lead to food safety.

Jensen Farms seems to have failed, but it did not fail alone.

Many thanks to Trevor Suslow for sharing his informed thoughts with the industry at large.

 




When It Comes To Audits…
Retailers Get What They Specify

William Neuman over at The New York Times, who we recently spoke to regarding the lawsuit filed against the FDA in the Del Monte Fresh cantaloupe imbroglio, now is, of course, writing about the Jensen Farms cantaloupe issue. The article, titled Listeria Outbreak Traced to Cantaloupe Packing Shed, has caught the attention of the trade:

Jensen Farms hired an auditor called PrimusLabs, based in California, to inspect its facility. Primus gave the job to a subcontractor, Bio Food Safety, which is based in Texas. Jensen and Primus declined to provide a copy of the audit report.

Robert Stovicek, the president of PrimusLabs, said his   company had reviewed the audit and found no problems in how it was conducted or in the auditor’s conclusions.

“We thought he did a pretty good job,” Mr. Stovicek said. He said the auditor, James M. DiIorio, has been doing audits for the company since March.

He said that Mr. DiIorio had received two one-week training courses as part of his preparation and had also gone on audits with other auditors.

Asked how Mr. DiIorio could have given high marks to a facility that the F.D.A. described as a breeding ground for      listeria, Mr. Stovicek said, “There’s lots of variations as to how people interpret unsanitary conditions.”

Mr. DiIorio did not return phone calls seeking comment.

Trevor V. Suslow, a professor of food safety at the University of California, Davis, said auditors may give farmers, processors and retailers a false sense of security. “There needs to be training, certification and auditing of the auditors,” he said.

This raises many issues. After all, we don’t think there is a person in the whole FDA who knows more about auditing than the auditors. While some UK retailers have expertise here, not many US retailers do. So who is going to train whom in what is unclear. In any case, shortly after the article was published, we received the following letter:

Per the excerpt from The New York Times article above, Jensen Farms hired Primus to audit its food safety practices, and the company was found by an auditor that Primus subcontracted the audit to, to be in compliance with their standards.

What does this say about Primus, and about the idea of sub-contracting this function? I guess there are audits, and then there are “audits”!

— David N Cook
Sales
Deardorff Family Farms
Oxnard, California

David is a smart guy. When he wrote us last, it was during the Salmonella Saint Paul crisis, and he took early issue with the FDA’s claim that it was a tomato based outbreak:

Your piece, Pundit’s Mailbag — Can Tomatoes On The Vine From Mexico Be Sold?, is as good an explanation of how the FDA works in these cases as I have heard.

However, I would take issue with one word you use in the piece, I’ve capitalized it below:

“So the reason the government KNOWS it is tomatoes…”

Given that the FDA admits it has found no tainted tomatoes and now states that it probably never will find the true source of this outbreak (LA Times Fri Jun 13 buried on page C2), how can they say that they KNOW anything?.

The FDA should be honest and say they ASSUME or SUSPECT that tomatoes are the culprit and go from there.

Thanks for your great work on this issue.

— David N Cook
Sales
Deardorff Family Farms
Oxnard California

David, of course, turned out to be 100% correct. The FDA turned out to be wrong.

Now, he weighs in again and raises more issues to think about.

On the issue of contracting out the audits, two thoughts come to mind:

First, it is not clear that how the auditor gets paid is the key here. If instead of paying him on a per audit basis, he was on salary. Would James M. DiIorio have turned in a different audit?

It is not an unreasonable question. After all, people with their own business whose income is dependent on getting assignments might be hesitant to be really tough on an audit for fear they won’t be given assignments again. In this case, there is no evidence of that. And such an issue would apply to employees as well. They might fear losing their job if the customers start complaining.

In this specific case, the key issue of the lack of an antimicrobial in the one-pass or non-recirculating wash system, was carefully noted on the audit report. The auditor noted it but didn’t detract points because of an assessment, as we mentioned here, that in a non-recirculating water system neither the FDA guidelines nor standard industry practice requires an anti-microbial be added to the water.

There is a question here of how divergences between industry standard practices and best practices should be handled. But there is little evidence that this auditor did a bad job, and there is no evidence at all that if he was on payroll, as opposed to a contractor, the outcome would have been different.

We actually hear that some of the best auditors become contractors because they can can make more money than as a salaried employee of any of the auditing companies. So some of these contractors are among the best auditors out there.

Second, many years ago we asked Primus what they could do to help small and regional growers improve themselves, and the contracting program was part of that effort which we profiled here. It was an effort to reduce the costs of audits.

But it was not mandatory then and is not mandatory now. This is where buyers have to get involved. Wal-Mart is well aware that contractors are being used. All Wal-Mart has to do is issue a specification that it will only accept audits done by full time employees of auditing companies and it will get exactly that.

The downside is cost: In many cases the contractors are spread out and a decision to use only employees for audits will often involve an extra travel day to and fro. That roughly triples the cost of the audit. Add in the plane, hotel room, food and the fact that you probably have to pay auditors more of you want them to consistently travel, and the actual out-of-pocket audit cost might increase four or five times.

Wal-Mart hasn’t perceived an upside in food safety sufficient to justify this cost or Wal-Mart would have required that auditors all be employees. We can’t say we see this either.

Third, the auditor is important but, assuming competency, the crucial issue is the standard. Auditors don’t get to walk through a tomato field and take away points because they think it would be safer if the tomatoes were grown in a greenhouse. There is no FDA guidance to that effect; it is not industry standard, etc. There needs to be a standard against which things are audited. 

There are lots of public standards — the British Retail Consortium, SQF, etc. — or as with Marks & Spencer in the UK, a buyer can create its own standards.

In this case, despite its avowed commitment to GFSI, Wal-Mart did not require a Primus GFSI audit — only a standard Good Manufacturing Practices audit was used. The very fact that two separate things exist implies that one will audit for things the other will not.

Although it should also be noted that even if Wal-Mart had a GFSI audit, it is not clear it would have made a difference. The thrust of these audits is not pass or fail; it is improvement. So the GFSI audit might have revealed more things for Jensen Farms to work on, but unless Wal-Mart is carefully reading these audit reports and has established standards for when it will stop buying, it is not clear that if the FDA report had been transcribed word for word by the Primus auditor and added as an addendum to his audit, this would have caused Wal-Mart to stop buying.

There are, of course, audits and then there are “audits,” as David Cook says, but Wal-Mart gets exactly what it wants and what it is willing to pay for.

If Wal-Mart wanted a GFSI audit performed by a full time Primus employee, the company would specify it. If Wal-Mart wanted specific standards for its product that are not yet in the FDA advisories or standard practice — say that all wash systems, one pass or recirculating, must use antimicrobials or that all cantaloupes must be dry harvested or that all cantaloupes must be pre-cooled — then the company would specify it and get it.

That Wal-Mart didn’t specify any of this hardly seems like something to hold an auditor responsible for.

Many thanks to David Cook for his thoughtful letter.

 




When A Buyer Is Short Of Product...
Do We Have A Plan To Ensure Food Safety?

The Pundit just had an opportunity to spend a few days at Michigan State University. We’ve gone up every year for some time to lecture and this time we were honored to also have the opportunity to deliver — thanks to the generosity of the Ferris family —  the  John (Jake) and Maxine Ferris Global Agribusiness Lecture.

What an ego-enhancement to walk over the campus finding posters with the Pundit’s name on it urging attendance. We came home feeling mighty favorable to those Michigan folks.

So it was a special treat to receive a letter from the President of a prominent Michigan-based produce firm:

To have a tragedy like the cantaloupe outbreak and the loss of life it has involved is hard to understand. I think of the families that are experiencing great loss and the enormity of the loss is hard for me to wrap my head around. My heart goes out to them.

Any time an outbreak or recall for a potential outbreak happens, my stomach turns because it could happen to any of us involved in this business, and it affects the whole industry.

Food Safety seems to be a moving target. Audits done by different companies and by the government vary, and the auditors themselves can vary based on what an individual auditor's focus is. Audits make sure the industry is following procedures and keeping a paper trail to verify the procedures are being done properly, when they are to be done.

It is up to the grower, packer, shipper, and processor to follow through daily. We as an industry are learning as we go where food safety is concerned, and the amount of recalls that occur is up significantly.

Ten years ago, you rarely heard of a recall on produce. I believe our industry has to be proactive and diligent in getting an audit system in place that is universal to all growers big and small, all shippers big and small, and all terminal, retail, and foodservice receivers.

The point made about whether Jensen sold direct to Wegmans or Wal-Mart has no influence on a food safety program. In fact, it is quite possible that Jensen Farms would have sold its product for less money, and its food safety practices would have been the same. Middlemen are, and always will be, a necessity in our business.

When chains are short from their supplier, a broker is called. If they are short today, a terminal buyer is called. As far as customers wanting to pay for food safety, customers want a safe product at the lowest price, and the consumer wants a safe product at a low price. As a major chain advertises its falling prices, the buyers of the company are trying to back up that statement.

There are no easy answers… I know growers are pinched from the rising cost of farming, the rising cost and demands of bringing food safety practices into place, and the demands from customers and consumers for cheap food.

We represent growers who are the hardest working families I know, who love what they do, who want to deliver a safe, healthy, and delicious product to market.

As the Pundit has covered well, the challenges that a grower faces daily are many; a grower needs to update equipment, facilities, and pay extra people to implement and keep track of new regulations.

To do that, growers need to be able to sell their produce at a profit.

Maybe it is time to change the way we market produce in this country. Is the lowest price always the best value?

Randy Vande Guchte
President
Superior Sales, Inc.
Hudsonville, Michigan

Randy has done an incredible job of building up Superior Sales over the last two decades. With a record of accomplishment such as his, you have to take what he has to say most seriously.

We would say that his letter exemplifies many of the issues that the industry has to deal with:

A)  Randy points out that retailers who are short will buy what they need from a broker or wholesaler. So how can these buyers know they are buying acceptable product? There are only two ways: They can trust their vendor — so they can know that Superior Sales is on top of it. This is what people who buy from Sysco, US Foods or Supervalu are doing. But we know that the vast majority of intermediaries are not up to this task.

They could also rely on certifications. But audit reports are not generally in the public domain, and if you can’t read the comments, you really miss the full impact of the report. So Jensen Farms, if asked, presumably told people it received 96 out of 100 on its audit. Yet now we know that this fact didn’t give a complete picture of what someone interested in food safety would want to know.

So Randy’s accurate point about how shorts are filled leaves the industry with a food safety problem.

B)  The obligation of the grower, packer, shipper and processor to follow through daily that Randy mentions is certain. But it is not clear what they are obligated to follow through on.

Produce is not a situation where there is a clear line between safe and unsafe practices. Many food safety experts would argue that Jensen Farms, in moving to a non-recirculating wash system, made a food safety advance.

Common issues such as water testing don’t provide automatic answers. Testing water quality is good. But should it be tested annually, quarterly, monthly, weekly, daily, hourly, etc.? There are no easy answers.

With the exception of sprouts where many producers feel the FDA standards damage the product and employee health, we know of very few situations where the FDA has established a clear standard and the growers, packers, processors and auditors have failed to follow through.

C)  Whether Wal-Mart or Wegmans buys directly or through intermediaries doesn’t necessarily matter. Wal-Mart could tell Frontera what it wants, and you can be sure Frontera will make it happen. Wegmans can tell the fresh-cut processor that if it wants to sell Wegmans, it can only buy fruit from GFSI-audited firms or from a list approved by Wegmans.

Yet, as a practical matter, we would say that it is hard to sustain a food safety culture if one is always insecure in where the next order is coming from.

The FDA report indicated than an absence of pre-cooling may have contributed to this problem. Building these pre-cooling facilities, though, is a major investment. To finance their construction, Jensen may have needed to walk into a bank with a signed contract from Wal-Mart committing it to purchase these pre-cooled cantaloupes. Even if Jensen had the cash, it wouldn’t want to invest it unless it knew it had a market that would pay a premium for this particular food safety effort.

The issue is not intermediaries versus buying direct. In the UK, where supply chains are very aligned, retailers will often use a company such as Mack Multiples to handle logistics and other needed service between the grower/packer and the retailer.

The issue is whether the supply chain is 1) transparent enough that frank food safety discussions can be had, and 2) Committed enough that people can make investments with the confidence that the fruit of that investment has an appropriate home.

D)  In fairness to retailers, very few simply buy the lowest price. The focus on price seems overwhelming, but that is because day-to-day discussion takes place in a world after all specifications have been met.

Although Jensen Farms is being demonized, in truth it met all of Wal-Mart’s standards. Maybe Wal-Mart did buy from Jensen because it was cheaper than California or maybe because Wal-Mart wanted local and regional product. We don’t know. But Jensen Farms had a Good Manufacturing Practices Audit — which was the requirement. If the company did not have this, then no amount of discounting would have likely gotten them through the door.

The question is whether this is simply an issue to be addressed through raising standards – so Wal-Mart has to require a GFSI-audit instead. Or is this an issue that has to be driven into procurement, that some mechanism has to be created to incentivize buyers to choose the safer option?

Right now, as long as the product meets the chain’s specifications, the buyer wants to buy the lowest cost item. Can we change this?

Many thanks to Randy Vande Guchte for weighing in on this important industry issue.




A Call To The Buying Community:
Uniform Food Safety Standards Are Required

Our pieces, THE CANTALOUPE CRISIS The Truth That Dare Not Speak Its Name: The Priority Can Be Safe or The Priority Can Be Local, But It Cannot Be Both and CANTALOUPE CRISIS ANALYSIS: Key Performance Indicators and Food Safety... Shall The Twain Ever Meet? brought many letters including one from a one-time frequent correspondent:

I read with interest your articles regarding “CANTALOUPE CRISIS ANALYSIS”. Although I am on the frozen vegetable side now, it is interesting to see that the underlying issue has not changed. Just as finished product testing is becoming somewhat of a comfort level in fresh, blanching has done the same to an extent on the frozen vegetable side.

Until a statistically valid protocol is accepted by the buying community, both become more of a marketing component than a fire wall for food safety. As long as buyers continue to maintain two sets of criteria, one for larger producers who are perceived to be able to afford more extensive levels of certification, and one for the smaller suppliers who cannot, the issue of price over food safety will always be a problem.

Neither the fresh nor the frozen industry needs regulation to determine which takes precedence. If the buying community determined tomorrow that a 5 acre farm should operate under the same base line practices or metrics as a 5,000 acre farm, whether it is in Colorado, China, or wherever, the debate would correct itself immediately. If we learned one thing over the past five years, it is that pathogens don’t distinguish between the size of the farm or the brand name on the box.

For those buyers that don’t have the resources of an internal quality department that pre-qualifies vendors, there are plenty of reputable third-party organizations, from the LGMA to SQF, that could be used for base lines.

All the certifications in the world aren’t going to stop the bird that flies overhead, but at least having a base line would avoid a systemic farm issue like contaminated irrigation water or soil amendments, and make sure that commodities grown directly on the ground have an industry-accepted method for cleaning based on the latest science and equipment available.

In the early days of the LGMA, it became a reality in large part because the buying community banded together after realizing that an illness impacts an entire category and not just the packer involved. It is long overdue to take the same position on base line food safety standards.

—Eric Schwartz
President and Chief Executive Officer
Patterson Vegetable Company
Patterson, California 

Eric had been President at Dole Fresh Vegetables during the spinach crisis and, starting at that time and through other positions, he has contributed letters and done interviews here at the Pundit that include these pieces:

Pundit’s Pulse Of The Industry: Dole Vegetables’ Eric Schwartz

Pundit’s Mailbag — How About Subsidy Money For GTIN Conversion?

Pundit’s Mailbag — Dole’s Schwartz Comments On Silent Buyers

Pundit’s Mailbag — More Questions About Leafy Greens Board

Pundit’s Mailbag — The Deadline Approaches

Pundit’s Mailbag — Organic Industry’s ‘Situational’ Standard

Single Step Award Winner — Eric Schwartz Of Dole Vegetables

Pundit’s Mailbag — PMA’s Opportunity To Learn From Friends And Foes

Pundit’s Mailbag — Lesson From Avocadogate: You Get What You Tolerate

Dole Hit With Another Recall

Dole’s Schwartz Sheds More Light On Recent Recall

Arizona Marketing Agreement One Step Closer To National Leafy Green Standard

Why The Secrecy On Inspection Agency Lab Results?

The gist of our point is simple. Food safety in produce retailing has mostly been punted to the QA or food safety department.

As always, Eric is thought-provoking and, from a food safety standpoint, he is repeating what is both obvious and clear: That if we have carefully studied matters and determined that, say, a 100-yard buffer zone or daily tests of the water supply are essential for food safety, then these standards should be applied to all vendors, large and small.

Yet even while we say this, the industry is doing itself no favor if we don’t recognize the problems with this argument:

1) OUR SCIENCE IS REGIONAL

We applauded the launch of the Center for Produce Safety and it has surely done much good work. One thing it has not done, though, is produce a large body of science that tells us a lot about food safety in areas that do not have large industry sectors to pay for the research.

Just because something has been found to be effective in one region doesn’t mean it is the thing to do all over the world. Yet, in most of the world, no studies have ever been done. Studies are expensive and thus unlikely to be done unless the industry meets a certain critical mass in a particular place.

2) OUR SCIENCE IS A JUDGMENT CALL

If we really knew that some specific action would guarantee safe food, that would probably be a strong case for action. In most cases, though, our best food safety knowledge is a continuum. We may believe that larger buffers are better, more frequent traps are better, more frequent water testing is better… but there is no clear place along these continuums to stake our case. It is a judgment call.

3) WE HAVE MANY CONFLICTING VALUES

The reason we don’t have even more rigorous food safety standards for large producers is because we also value things such as producing economical food for the world. So even if we could prove that putting a trap every foot along a row of spinach or cantaloupes, and checking those traps three times a day would produce a modest increase in food safety, it is not likely we would do it because it is too expensive and would work counter to our value of producing plentiful fresh food for all.

So safety is a value, and economical food is a value and we compromise between them. Yet there are still other values. The Tester Amendment, which we opposed, is an expression of a national sentiment that small and local is important.

If food safety standards, say buffer zones, will make it impossible for the two-acre farm to stay in business, then many will say that this is simply too high a price to pay for a modest increase in food safety.

Of course, understanding the arguments doesn’t mean that buyers have to endorse them, and Eric’s letter leads us to some additional points:

A) Many buyer demands and vendor claims are based on pseudo-science, such as finished product testing regimes that are not statistically meaningful.

B) Although buying organizations may want to defend other values, they are doing a disservice if they pretend that there is no cost or trade-off to those values.

In the end, we come back to our original point: that any commercial buyer can only have ONE TOP PRIORITY at a time.

Eric calls for common baseline standards for all producers of all sizes.

That is fine. But what is a baseline is not going to always be clear — especially when one is trying to establish a baseline against wildly divergent geographies.

Yet even if that can be overcome, we would say any baseline is still just a minimum acceptable standard. If we are serious about food safety, we want performance evaluations and compensation programs changed so that buyers have both instructions and incentives to go beyond the baseline and ante up to reward those who do exceptional work in food safety.

This seems unlikely to happen unless there is a change in legal liability standards. We wrote about that issue in The New Atlantis in a piece titled, How To Improve Food Safety.

Many thanks to Eric Schwartz for weighing in on this important industry issue.




A Choice Had To Be Made: Which Was The Top Priority: Buying Cheap, Buying Regional Or Buying Safe?

We received more than a few irate contacts when we dared to suggest that the Wal-Mart buyer who bought this produce was focusing on local and regional, not on the highest food safety standards.

Of course, everything is relative, and to some, Jensen Farms should be seen as neither local nor small:

I think your articles on the listeria/melon outbreak loosely and incorrectly equate "small" and "local" and both with Jensen Farm.

"Small" in the food safety context is a category for exemption from some federal regulatory steps, but not state and not all FDA food safety oversight. 

"Local" is a genuine marketing and conceptual trend exemplified by such phrases as "know your farmer,"  "buy from your watershed," (or within some distance like 90 miles), "be a locavore," "buy fresh and local".  It has the benefit of making a market for local tastes and choices, and increasing those choices by not necessarily requiring long shipability, and being responsive to the development of local or multi-ethnic or fusion cuisines. 

As was the case for the beginning of organic, restaurants knowing their farmers are key leaders in developing "local." However, their overall choices and ingredients can be world-wide. To the non-ideological, the two are compatible: buy a lot of produce that is locally excellent.

I'm having some difficulty seeing how you can use either term, "local" or "small",  for Jensen Farm. 

Their distribution has sickened people from 23 states so far. Even in the early stages of the outbreak, you used the odd notion that because the most cases from the outbreak were in Colorado and (approximately) neighboring states, this implicated "local" food safety. As if neighboring states were equivalent to neighbors to a farm. Regional, maybe. But to use "local" even in the early stages seems wrong. And, later in the outbreak reporting, were consumers in Maryland and New York state really buying "local" from Colorado? It makes no sense, Jim. I suppose you were thinking of the 275 mile definition of "local" as part of the two tests for "small" under the Tester amendment.

Jensen Farm still would not qualify as "small," but perhaps that is why you might be talking about neighboring states.

As for size, this cantaloupe recall alone totaled 300,000 cases, only one of several products they grow. The gross sales volumes on their cantaloupes alone puts them about 5 times the upper limit for "small" in the implementation of the new FDA law (15-18 count per case, even at $1 per melon and 15 count — that's $4.5 million). So "small" relative to California and Arizone desert production, not "small" in terms of food safety.

—Dan Cohen
Maccabee Seed Company
Davis, California

Dan has contributed many pieces to the Pundit, including these:

Pundit’s Mailbag — National Marketing Orders And Agreements

Pundit’s Mailbag — Two Windows And Two Issues

You May Never Look At Spin The Bottle The Same Way Again

Perishable Thoughts — Higgins Boat Story Tells A Tale Of Perseverance

Setting The Record Straight On Fresh Express’ FreshRinse Wash

We appreciate him giving us a chance to comment on this issue. Local has no legal definition in produce marketing. Whole Foods, for example, declares that on a corporate level, products that travel up to 7 hours by car or truck can be classified as locally grown. The Interstate speed limit in Colorado is 75 miles per hour. If a trucker does 80, that means a load from Denver, Colorado is in Lubbock, Texas, within seven hours where it can be marketed as local.

The government has criteria for exemptions from the Food Safety Modernization Act, but our use of the term small is referring to actual food safety capabilities. For example, does the operation have the scale to support full time food safety staff of high quality?

The gist of our point is simple. Food safety in produce retailing has mostly been punted to the QA or food safety department. These folks set up a standard and, if they are not undermined by, say, having unauthorized product go through someone with a vendor number, they can block purchases from unapproved vendors.

Once they give an approval, though, the QA and food safety teams lose all influence. There are 10 approved vendors and the buyers make their selection.

Our point was that the buyers are not in any way incentivized to make this choice based on food safety.

One obvious driver for the decision is cost. Another is a desire to have more local or regional produce.

Our point was, and is, that one can have a lot of priorities but only one top priority. Nobody from Wal-Mart has stood up to explain why its executives would have thought that this relatively small producer — producing less in a season than California ships in a day — was the place in America most likely to produce safe cantaloupes.

If they didn’t think that, what did they prioritize over safety that made them buy this product?

Many thanks to Dan Cohen for his insights into this issue.

 




Vendors Risk Much By Not Standing Up For Food Safety Premiums

It is often useful to look at related industries to see how they handle food safety issues. So, for example, we’ve looked at issues such as pasteurization of nuts in pieces such as these:

Pundit Pulse Of The Industry: California Almond Board

Point/Counterpoint: Raw Foods Advocates Get Steamed About Pasteurized Almonds

Now — after reflecting on our Cantaloupe Crisis coverage — a vendor of “organic, certified, pasteurized, walnuts” sends a note urging producers to stand up to buyers when it comes to food safety.

I have been a long time reader and love your insights. Being in the nut business, I often feel like a long lost cousin who is related to the produce industry but is overlooked and left off the mailing list for produce family gatherings. Although our less perishable nature puts us in a different set of circumstances for marketing challenges, the product still comes from the field.

I have been amazed at how weak some sellers are when it comes to dealing with buyers. While it may be the buyers of these products who pay the bills for the invoice, it is the packers and/or growers who pay the costs of the recall should there be an issue. For some reason, it appears as though people are too willing to let a buyer’s decision to push a price target allow themselves to be talked into putting their livelihoods at risk by cutting corners on food safety.

Our company has spent over 2 years bringing an organic certified pasteurization system into production in the walnut business. This is very important as Canada, Europe and other markets have either very restrictive or zero tolerance levels on residuals for Propylene Oxide, the most common pasteurization system for nuts. In the past 6 months, Canada has endured two recalls for E. coli in walnuts, and although many of my competitors are not convinced that pasteurization is necessary, our company has forged our own path down that road.

Recently, I was offering walnuts to a customer in Canada. This customer did not want to pay for pasteurization even with his competitors having 2 separate recalls in the prior 6 months on the same product. The immediate problem I saw was that the buyer was willing to gamble on food safety, yet I would be on the hook for the losses if things go badly, so I declined to sell him and offered to send him the phone numbers of 78 of my competitors who would ship unpasteurized walnuts to him because I would not.

He then changed his mind and paid the up-charge. While there are certainly those out there who would cut corners on safety to save $0.07/lb, if sellers are soft on demanding food safety be a shared cost, they run the risk of letting people who are willing to pay become free riders and do damage to the entire industry by hindering the progression of higher safety standards.

People go into business expecting that they can produce a product and sell it for a profit generally because they believe in the product and have faith in their ability to produce it. For some reason, they are not as sold on their ability to market the food safety aspect. While it is easy to point the finger at the buyers who are reluctant to pay the costs of higher food safety, it is the producers who have the most to lose and thus should be pushing back much harder to protect the reputation of their respective commodities and the produce industry as a whole.

Mike Poindexter
Poindexter Nut Company
Selma, California

We appreciate the letter very much. In general, we do think that vendors do need to state their case more strongly. Still, the letter brings a few points to mind:

1) This is the difference between a true perishable and a semi-perishable. Doubtless there are lots of reasons to want to sell walnuts now, not later. But there is nothing like the urgency to sell lettuce before the weekend hits.

2) It also is not necessarily true that vendors pay the cost of recalls. Sometimes they do, but true recalls often can be covered by insurance.

3) The pasteurization process is a case of an explicit charge — .07 cents a lb in exchange for a specific benefit — pasteurized walnuts. Most foods safety efforts in produce are along a continuum. So if company A tests its water monthly and company B tests it weekly, there is no known measure of how much additional safety that investment will produce. Or put another way, what is the buyer getting for his money? Implicit in this is that “cutting corners on food safety” is really not the right analogy because you can always do more — bigger buffers, more testing, more trapping etc.

It is actually an interesting question: Imagine a produce vendor having two different levels of food safety. A retailer calls to the vendor, who explains, “We have cantaloupes with a Good Manufacturing Practices audit for $10 and we are working a GFSI-audit cantaloupe for $10.50.” Which would the retailer buy?

And how would the retailer reconcile its choice with its self-proclaimed commitment to food safety?

Many thanks to Mike Poindexter for bringing a little “nuttiness” to this issue.




Cantaloupe Crisis Discussion To Take Place At New York Produce Show And Conference

With all the benefits of technology, there is something about sitting down face to face that can make it easier to think through industry problems and move toward improving the situation.

So at the upcoming edition of The New York Produce Show and Conference, we are going to steal a page from our IDEATION FRESH Foodservice Forum and do some ideation about this cantaloupe situation and its broader meaning for food safety and the industry.

We will borrow the Penthouse Suite from the Spouse Program as the trade show ends at 5:00 PM on Tuesday, November 8, 2011, and the Pundit will coordinate a casual and frank conversation on the issue, including a discussion of what really happened, why it happened and, most importantly, seek out ways for how we can do better.

There is no charge for this intimate exchange of ideas but, for security reasons, you need a show badge to get into the venue.

If you think you would like to be a part of this small group, please send us a note here so we can get an idea for the numbers.

You can register for The New York Produce Show and Conference here.

Hotel rooms are available here.

Travel discounts at this link.

And opportunities to sponsor this event and others at the show, as well as exhibiting opportunities, can be accessed by e-mailing here.




Cantaloupe Crisis Round-up

Just to help everyone keep track, these are the main pieces we have written about the Cantaloupe situation:

October 4: 2011:THE CANTALOUPE CRISIS: The Truth That Dare Not Speak Its Name: The Priority Can Be Safe or The Priority Can Be Local, But It Cannot Be Both

October 12, 2011:CANTALOUPE CRISIS ANALYSIS: Key Performance Indicators and Food Safety...Shall The Twain Ever Meet?

October 20, 2011: CANTALOUPE CRISIS ANALYSIS: The Need For An Aligned Supply Chain And An FDA That Won’t Punt On Food Safety

October 23, 2011: CANTALOUPE CRISIS ANALYSIS: While “Blame The Auditor” Frenzy Rages, It Pays To Look At Best Practices Vs Standard Practices

October 23, 2011: The Cantaloupe Crisis: Audits, Auditors And Food Safety

October 23, 2011: Trevor Suslow Of UC Davis Speaks Out: Reflecting On Pathogens, Produce, And Practices

October 23, 2011: When It Comes To Audits… Retailers Get What They Specify

October 23, 2011: When A Buyer Is Short Of Product… Do We Have A Plan To Ensure Food Safety?

October 23, 2011: A Call To The Buying Community: Uniform Food Safety Standards Are Required

October 23, 2011: A Choice Had To Be Made: Which Was The Top Priority: Buying Cheap, Buying Regional or Buying Safe?

October 23, 2011: Vendors Risk Much By Not Standing Up For Food Safety Premiums

October 23, 2011: Cantaloupe Crisis Discussion to Take Place At New York Produce Show And Conference

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