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Coalition Of Associations Seeks Dialog
With Food Safety Leadership Council

Jim Prevor’s Perishable Pundit, November 15, 2007

Our piece, Food Safety ‘Arms War’ Claimed As WGA Responds To Publix Demand For ‘Enhanced’ Produce Standards, pointed out that WGA’s letter to Publix was so incendiary that, as we wrote: “… if this issue is to be resolved, it can only be resolved through the vertically integrated associations. They now will have to step in after a major mess has been created.”

And so the vertically integrated associations have stepped in. We are told that Tom Stenzel of United, in response to pleas by some of United’s members, led a campaign for a collective response. In the end, a Who’s Who of grower organizations, plus the vertically integrated PMA and United, issued a far more temperate letter, this time written to Larry Kohl, who is the Director of Food Safety for the Walt Disney World Co., and part of the Food Safety Leadership Council that has developed the food safety standards Publix referenced in its letter.

The new joint letter points out concerns with the FSLC metrics, points out the importance of the whole supply chain working together, and requests a meeting:

November 14, 2007

Mr. Larry Kohl
Walt Disney World Co.
Food Safety & Health
PO Box 10000
Lake Buena Vista FL 32830-1000

Dear Mr. Kohl,

We understand that you help coordinate a group of company representatives that has prepared the attached Food Safety Leadership Council On-Farm Produce Standards. On behalf of the organizations shown below representing a wide cross section of the produce industry, we write to express our strongest concern about this document and its potential implementation, and ask that you share these concerns with all relevant parties.

In recent days, many produce suppliers have received letters from Publix, Avendra LLC, and possibly others which state that their companies are members of the Food Safety Leadership Council (FSLC) and go on to require suppliers to comply with the set of practices outlined in this document. It is unclear from this document exactly which companies are part of this effort, what legal and/or organizational structure exists for the FSLC, and what specific expectations may exist for your produce supply networks.

The demands outlined in these individual companies’ letters and the content of the FSLC document present neither a scientific approach to enhance food safety nor a respect for the produce, retail and foodservice industries’ mutual commitment to deliver the safest possible fresh fruits and vegetables to our consumers everyday. As you know, we all share a commitment to providing consumers the safest possible foods, and we ask that you step back from this unilateral and unfounded direction to engage in a real scientific and professional dialogue with your produce suppliers, technical representatives from our industry’s trade associations, academia and government. Together, we should be engaged in mutual efforts to ensure an approach to food safety that can truly make a difference for our consumers, rather than focusing more concern on liability placement than actual sound, scientific and achievable food safety practices.

Let us list several specific concerns with the FSLC document and approach.

  1. Produce food safety demands a commodity-specific approach. While broad principles of risk prevention apply and are embodied in FDA’s Good Agricultural Practices (GAPs) for on-farm production, the specific standards and practices that should be employed for different commodities vary greatly. The FDA has directed industry to pursue commodity-specific GAPs as the best way to enhance produce safety overall, and huge strides have been made in addressing best practices for those commodities which have had recent links to foodborne disease outbreaks. The FSLC document’s “one-size-fits-all” approach contains specifications that clearly should not apply to many commodities, and in fact, could be counter-productive in requiring growers to focus on the wrong things.
  2. It appears that the FSLC document is based largely upon the approach industry has taken in preparation of Commodity Specific Food Safety Guidelines for the Production and Harvest of Lettuce and Leafy Greens, which were subsequently adopted as the metrics for compliance measurement under the California Leafy Greens Marketing Agreement. These standards have been developed and revised over several years with intense analysis of scientific issues, current research understanding, and production practices; and vetted extensively with industry, academic and government scientists. We believe this represents the current best practice standard for production of leafy greens. Both the National Restaurant Association and the Food Marketing Institute recognize the validity of these leafy greens food safety guidelines and support producers complying with these standards. Also, the Food and Drug Administration has reviewed these metrics, and never advised of any areas where they believe these are inadequate.

    Given that wide state of support for these best practices, FSLC members must be careful not to imply in any way that your approach would provide any higher level of safety than compliance with these industry standards. Our industry is committed to continuous improvement in food safety, and certainly expects to frequently revise best practices to incorporate the latest science and understanding of risk prevention strategies. We would be extremely interested in discussing with you both the current best practice standards for leafy greens and the suggestions for production and testing that you have outlined in the FSLC document. But this must be a scientific discussion committed to mutual industry efforts to develop and agree on best practices to serve our consumers, not to create a bifurcated food safety system with different groups setting separate and unilateral requirements.
  3. On a practical level, you must know that some standards such as the water requirements outlined in the FSLC document cannot physically be achieved in many cases, even by world class producers. Perhaps you were thinking of a target for producers to strive for, but without further discussion, our best scientists just don’t understand what you have in mind. Similarly, some of the recommendations in your document are inherently based on opinion and judgment where science is insufficient, such as distance of production from animal grazing. Science today cannot tell us an exact distance, and we would therefore argue that expert consensus among industry, academia and government is the best way to address such unknown scientific questions until research can provide better evidence for risk-based decision-making. Otherwise, we are faced with an escalating, unscientific approach — if a 100-foot buffer is good; a 1,000-foot buffer must be better. Or why not 1,000 yards; or perhaps a mile, or two, or three. This is indeed a slippery slope without real science to guide these judgments.

In conclusion, we respectfully urge FSLC members to reconsider your approach seeking to enforce the practices outlined in your document. We believe enforcing these practices would be inappropriate for many commodities, add unscientific and needless requirements to already existing best practice standards widely endorsed in the scientific community; could be counterproductive to produce safety in diverting attention from real issues; and would create an “us-against-them” food safety split in the produce supply chain.

Perhaps that last point is our greatest risk, but one we should be able to avoid by working together. We know your companies well as industry leaders, and respect the fact that you want to do the very best for your customers in providing safe foods. Your produce suppliers share that unequivocal goal, and believe that we must work together as a total supply chain in order to fulfill our mutual objective of the safest possible produce. This issue cannot descend into an “us-against-them” fight or we all lose — we simply must work together to bring wise, consistent, scientific and industrywide best practices to on-farm production, post-harvest handling and processing, distribution, retail and foodservice operations. No sector is exempt, and no one sector has all the answers.

Mr. Kohl, please convey to your group our strong desire to engage in the earliest possible meeting to discuss these issues and ways we can work together for food safety. We will bring together scientific, technical and business representatives of our organizations and your produce suppliers to engage in dialogue to hopefully find a better course ahead that meets our shared goals for food safety.

Please respond to Dr. David Gombas, senior vice president for food safety and technology, United Fresh Produce Association, as your primary contact in setting up a meeting and moving forward. Please also let David know if you have any questions or comments in the meantime. Thank you.

Sincerely,
American Mushroom Institute
California Avocado Commission
California Citrus Mutual
California Grape & Tree Fruit League
California Strawberry Commission
California Table Grape Commission
California Tomato Farmers
California Tree Fruit Agreement
Florida Fruit & Vegetable Association
Florida Tomato Exchange
Georgia Fruit and Vegetable Growers Association
Grower Shipper Association of Central California
National Potato Council
National Watermelon Association
New York Apple Association, Inc
Northwest Horticultural Council
Produce Marketing Association
Texas Citrus Mutual
Texas Produce Association
Texas Vegetable Association
United Fresh Produce Association
U.S. Apple Association
Western Growers

It is a much nicer letter than the one Western Growers wrote and one more likely to jumpstart an obviously much needed dialog.

There is a lot of fault to go around here:

The Food Safety Leadership Council

The food safety staff at the members of the Food Safety Leadership Council who drafted these metrics clearly did not attempt to access all the resources one would expect them to access in developing their standards.

The produce industry association letter is actually quite kind to say that “… you must know that some standards such as the water requirements outlined in the FSLC document cannot physically be achieved in many cases, even by world class producers. Perhaps you were thinking of a target for producers to strive for, but without further discussion, our best scientists just don’t understand what you have in mind.”

It is a politic way to broach the subject as is giving the FSLC an “out” by suggesting that what the FSLC standards clearly require is actually a “goal” — but, here, being polite is also hiding the real problem

In fact the FSLC members almost certainly do not “know” it is impossible. Most of the food safety experts employed by FSLC member companies — and these are world class organizations, with world class food safety staffs — are not experts in agriculture.

And they didn’t reach out to get help. It is impossible for the FSLC to have consulted adequately with experts in growing produce and for WGA, PMA and United Fresh to be blindsided with these new standards. Afterall, most of the leading experts work for member companies or are closely affiliated through industry-funded agriculture food safety initiatives.

As a result, we have a very odd situation that we need to resolve. We have a set of food safety standards that seem to require virtually the same thing of high risk items and low risk items — that seem to require virtually the same thing in every growing area. Basically this is a list of standards developed without any consideration for the realities of agriculture.

Because it was developed without the appropriate consultation, it also is perceived as disrespectful. The produce association letter explains: “The demands outlined in these individual companies’ letters and the content of the FSLC document present neither a scientific approach to enhance food safety nor a respect for the produce, retail and foodservice industries’ mutual commitment to deliver the safest possible fresh fruits and vegetables to our consumers everyday.”

It is always easier to resolve issues if the parties have mutual respect for one another. The days ahead are unlikely to be easy.

The Retail and Foodservice Organizations
Attempting to Enforce These New Standards

The Food Safety Leadership Council made a major mistake in not consulting properly with experts in production agriculture. Yet, it appears that these standards were developed by experts in food safety and quality control quite far from the produce procurement operations. So, in a sense, though foolish in not seeking all the help they could get and discourteous in not paying any respect to the work of the produce industry in enhancing food safety, the actual people involved were being foolish and discourteous with respect to strangers.

Perhaps more inexplicable is that the actual procurement teams could just send out mass mailings to vendors. After all the procurement teams work with these vendors, they know all the efforts related to the California Leafy Greens Marketing Agreement… surely they have the internal pull in their organizations to say — “Hold up — before I start sending out mailings, I want to sit down with our top 20 vendors and give them a heads-up and a chance to give some feedback.”

Considering all the talk about partnerships and strategic alliances, one is flabbergasted that in 2007, sending out ultimatums directed to “Dear Produce Supplier” is considered an acceptable business practice.

Now in fairness, we have not heard of Wal-Mart, Darden or McDonald’s sending out such ultimatums — not coincidentally, these are the Food Safety Leadership Council members with the closest and most long-term alliances with their vendors.

One of the many not inconsiderable costs of this episode will be a deterioration in the relationship between the buying organizations that sent out these demands and the vendors who received them. Many are likely to be not so much outraged as depressed at receiving the letter. They thought they had a long-term strategic relationship with the buying organization, yet they learned that they had nothing of the sort.

Western Growers Association

When one’s customer behaves in a way that you wish they wouldn’t, it is a delicate situation — which means it has to be handled delicately. Sending out a letter — and widely distributing it — with words such as “Our questions are not rhetorical. We hope and expect that they will be answered” — is simply counterproductive.

Publix is not a member of WGA. Publix has no obligation to respond. And to write such a letter without first picking up the phone and at least trying to arrange a friendly meeting, without trying to work though the board members from Food Safety Leadership Council member companies on the PMA and United boards, is really not the route most likely to lead to a success.

We hope that the letter didn’t so raise the defenses of Publix and Food Safety Leadership Council member companies as to make a productive resolution impossible.

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