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Pundit’s Mailbag —
Pundit Logic On Food Safety Regulation

Jim Prevor’s Perishable Pundit, November 30, 2006

After reading some responses regarding the Buyer-Led Food Safety Initiative, it’s good to hear concerns from both sides. How is my logic here?

When distributors first started using HACCP programs, it was not required but gained interest with distributors as certain chains and various types of customers required it. What is wrong with a standard protocol that is not mandatory, but is a standard that buyers may require from shippers?

The standard could be set by buyers and grower/shippers, so it is practical and reasonable from a production standpoint and a measurable standard with designation such as HACCP. Just as HACCP places responsibility for ensuring food safety appropriately on the food manufacturer or distributor, this program could do the same for grower/shippers.

— Al Zuckerman
Executive Director
ProMark Group, Inc.

Al doesn’t need any help from the Pundit when it comes to logic. In fact the Pundit well remembers reading Profitability in Fresh Produce: Your Foodservice Guide to Commodity Information, Yields, Portions, Handling, and Receiving. The PMA put this guide out a half decade ago, and it was developed by a task force led by Al Zuckerman.

Included in the guide was: A Word About Food Safety: Includes details about the elements of a good food safety program.

So Al has been involved with these issues for a long time.

And his thoughts are common sense. The industry has no easy path to impose mandatory anything, especially not on a nationwide basis. Buyers can and perhaps should propose things, but unless it is practical for grower/shippers it won’t happen.

HACCP plans are often required of growers but the dynamic is such that, especially on processed product, they are more difficult to make effective than with processors. There are a limited number of processors, so the processors are relatively easy to audit and inspect. There are thousands of growers.

In terms of the difficulties on spinach and leafy greens, the key buyers are missing from the Buyer-led Food Safety Initiative. The buyers of the produce, in this case, are the processors.

It has become clear that these buyers did not always have the rigorous inspection mechanism necessary to make sure that growers didn’t just sign representations and warranties but actually did what they were representing and warranting.

The reason so many are now emphasizing mandatory regulation is that the spinach crisis taught us that the industry may be punished based on its weakest link.

What did it matter if a particular company maintained a perfect supply chain? They got closed down with the rest of the industry.

There are so many small growers that are not members of PMA, United or WGA. How do we make sure they are in compliance?

The obvious answer is that the industry needs to do three things:

First, every entity needs a HACCP plan drawn up and certified by a food safety expert. Not just photocopies of someone else’s plan.

Second, there needs to be minimum standards on frequency of water testing, fencing, etc., regardless of the requirements of the HACCP plan.

Third, every entity must be audited by a third party or by the buyer to confirm compliance with the HACCP plan.

This doesn’t guarantee safe food, but it would be a substantial improvement. It is probably the best that can be done short term. It would be required by buyers at every stage of the process — retail, foodservice, wholesale, processor and exporter/importer. In the long term, it will probably be incorporated into a government food safety regulatory screen.

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