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

Jim Prevor’s Perishable Pundit, October 23, 2011

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.