Last month, Ask Dr. Bob introduced you to a new campaign from our colleagues at the Alliance for Food and Farming called “The Truth About Pesticides”. The alliance’s Marilyn Dolan joined him for that post. You’ll recall that the alliance commissioned a blue-ribbon panel of experts from different scientific disciplines to review claims being made that pesticide residues on produce are unsafe.
In a nutshell, that panel found Dirty Dozen-type claims to be groundless and without scientific basis. There is simply no documented scientifically-validated evidence that the very trace amounts of residues that might be found on fresh produce can cause health problems. The panel’s findings were unveiled to industry, the media and consumers back in July.
PMA is proud to have supported this campaign since its inception, including funding development of the consumer website, www.safefruitsandveggies.com. Simply put, our industry must act to counter the negative effects such claims have on our consumers. This summer, 29% of consumers The Hartman Group surveyed for PMA told us that they are avoiding eating fresh produce because of concerns about pesticide residues. The alliance is now working to get the word out about what the panel had to say – and in the process encourage consumption of all fresh produce, conventional and organic.
The environmental community’s response has been, let’s just say, strong. We’ve clearly hit a nerve. The Alliance’s intent in commissioning a review of these claims was to start a conversation on the subject. Unfortunately, the reaction of several activist groups – including the folks behind the Dirty Dozen list – has been the exact opposite. Rather than considering what we have to say, they appear to be actively working to squelch this new information. Their tactics so far have included trying to position the producer-backed alliance as a store front for the chemical industry, and trying to pressure state government officials into revoking grant funding the Alliance received to help it get the word out about the science report.
PMA and our colleagues at the Alliance are hopeful that at the end of the day, facts and reason will prevail – and consumers will eat more fresh produce, not less because they’ve been frightened. We invite you to help us get the word out to consumers and consumer media about www.safefruitsandveggies.com. For more information on what you can do, contact the Alliance for Food and Farming.
Unfortunately, not everyone is interested in advancing the consumer’s right to know. Recently, we learned just how strongly entrenched one television show host’s opinions are. In September, the Alliance, PMA and several other organizations contacted Dr. Mehmet Oz after he aired a particularly egregious segment. Alas, even this doctor by training wasn’t interested in the facts if it gets in the way of good theater. That gives you an idea of the long, uphill climb we have ahead of us. But at the end of the day, climbing that hill is what’s best for our consumers, for public health – and yes, for our industry, too.
Julia Stewart:
Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob”. Today I’d like to welcome PMA’s Director of Food Safety and Technology, Johnna Hepner, to talk about the intersection of two very hot topics. Johnna, small family farms are the life’s blood of our industry and with the buy local trend many small growers are getting a renewed shot in the arm. However, as we’ve seen increasing focus on produce food safety, many small growers feel they’re being pressed to do something that is overwhelming.
Johnna:
Yes Julia, that’s right. The focus on local sourcing is definitely shining a spotlight on smaller growers — and with that spotlight has come discussion over whether they should be required to comply with federal food safety measures.
Julia:
So Johnna, are food safety and small grower two mutually exclusive terms?
Johnna:
Some might think so, Julia. In fact, it has been suggested that small farms should be exempted from some of the food safety legislation currently being debated by Congress. But that’s not in anyone’s best interest, and especially not that of the small grower. Small growers as well as large ones all have sound reasons for ensuring they have the most up-to-date food safety practices.
Julia:
Well, why should the food safety rules have to apply to small growers?
Johnna:
First of all, we can’t say that small growers don’t cause foodborne illness outbreaks. The identified causes of produce-related outbreaks, like field-level contamination or contaminated inputs like water, don’t discriminate between small or large producers. And even now, smaller outbreaks could be slipping under the radar, since it typically takes a critical mass of illnesses to catch the public health community’s eye. Currently about 70 percent of reported foodborne illnesses are never linked to a specific source.
Julia:
And where are buyers on this?
Johnna :
The reality is that the market is another real driver for this. Most buyers already require their produce suppliers to have food safety programs, and to be audited. If you want to sell your goods to the retail or foodservice market, you will be required to address food safety – buyers won’t risk anything less. So if small growers don’t comply with all the accepted standards, it could actually result in potential business being closed to them.
Julia:
So, small growers should be included. But how do they get started, if they haven’t started already?
Johnna:
It starts with the risk assessment and risk management process, Dr. Bob has spoken extensively about this in previous posts. Since the food safety net can’t have any holes in it and nobody wants to risk their farm or harm consumers, all producers must use baseline standards to conduct risk assessments – and then minimize the risks those assessments expose.
The good news is that food safety programs and costs are scalable. As a small grower, you’ll probably face lower food safety costs than a larger grower. For example, you likely have fewer water sources, less acreage, fewer products produced – and fewer buyers requiring audits.
Julia:
Where can they get help if they need it?
Johnna:
You can start right here with this blog, which contains a wealth of information on understanding and implementing food safety. And PMA members have access to our food safety staff, which include top-level subject matter experts who understand our industry and can really help deliver real-world solutions. We’re accessible to you. And finally, the PMA-founded Center for Produce Safety is a tremendous source of ongoing food safety research and information. Their website is cps.ucdavis.edu.
Last but not least is the local grower food safety workshop series that PMA is putting on with Sysco Corporation, I discussed this in a previous post.
I think we all agree that our first commitment must always be to protect consumers. PMA is committed to working with our industry’s small and local growers to ensure that you too can thrive and grow in this new reality.
Julia:
Absolutely! Thank you Johnna.
Listeners, you can learn more about food safety topics at AskDrBob.pma.com. Thanks for joining us!
Julia Stewart:
Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob” with PMA’s Chief Science & Technology Officer Dr. Bob Whitaker. Bob, hopefully most everyone in our industry is aware that the Food and Drug Administration has been working on developing produce-specific food safety rules. Can you tell us a little more about the most recent action on that front?
Bob:
Sure, Julia. You’ll recall that shortly after taking office, President Obama established a Food Safety Working Group and tasked them with focusing on upgrading U.S. food safety laws. One of that group’s recommendations was that FDA should increase its regulation of the produce industry. They looked at the incidence of foodborne illnesses linked to produce, and decided that action needed to be taken to reduce that incidence. Earlier this year, FDA established a docket so interested parties could share views to help in the development of produce-specific food safety regulation. (“Docket” is government-speak for a formal opportunity for the public to provide input to government on a particular topic.) Specifically, they asked what preventive controls could be put in place to avoid contamination of produce by pathogens, since our industry doesn’t have access to viable steps such as cooking to kill microbes that might get on our products. PMA prepared and submitted extensive comments in July.
Julia:
Bob, I know you and our members have been working with folks at FDA to educate them on our industry, the particular food safety challenges we face as fresh foods grown under an open sky, and the current state of our industry’s food safety capability. PMA believes the days of fighting government in an adversarial way are gone – in fact, its in our best interests to get the smartest oversight we can get. We look at working hand-in-hand with regulators to help them better regulate us. So, how do these comments fit into our cooperative strategy, and lead to smarter governance of our industry?
Bob:
You’re precisely right Julia. We must work with government to get what we want and need. FDA really is trying to understand where we are on food safety right now, and the best way to move forward. The docket is a tool for them to gather input from various stakeholders around the country. We chose to prepare comments because it’s a critical time when the agency is reaching out to us for direction in developing controls for the safety of our products that will impact us well into the future.
Also, as you mentioned, PMA has been very involved in coordinating educational opportunities for FDA staff. For example, Bryan Silbermann hosted FDA Commissioner Peggy Hamburg and her number two Michael Taylor on a tour of farms in the Delaware area last fall. I’ve hosted several tours for FDA and Center for Disease Control and Prevention officials out West, including a tour this spring in Nogales. We hosted several FDA scientists at a program with the PMA-founded Center for Produce Safety, which had an incredible first research symposium in June, we’ve talked about CPS in other blog posts. And most recently, our food safety director Johnna Hepner helped with a field tour for Agriculture Secretary Tom Vilsack.
There’s nothing more impactful than showing them what we are doing on the ground, every day. All these activities are stepping stones — part of the process of helping FDA create effective and workable rules and standards for our industry.
Julia:
Tell us how these comments were developed.
Bob:
Our comments document a lot of the things we’ve been saying to FDA over the years. However, this is the first time we’ve been able to leverage PMA’s new volunteer leadership structure, and our new Produce Safety, Science &Technology Committee, chaired by Joe Pezzini of Ocean Mist and vice-chaired by Martin Ley of DelCampo. Staff developed the comments based on our real-world industry experience and with industry input, and then we took them to this committee as a sounding board to ensure they reflected industry needs and interests.
Julia:
So what’s notable in our comments?
Bob:
There is so much of critical value in them…first and foremost we called on FDA to better define produce-specific food safety standards. This means not only defining the core aspects of how to design a food safety program, such as beginning with a risk assessment process to drive your program – but also the more technical and operational elements, such as conducting audits and auditor qualifications. We know that most audits are virtually identical, so the current lack of recognition of audit equivalency is a major issue complicating our industry’s food safety work. FDA has the chance to resolve that.
Another important theme in our comments revolves around the wealth of food safety data that’s out there, just waiting to be mined for answers. We specifically suggested that FDA partner with the industry to share their data – for example, we can learn a lot from the information they collect as part of their outbreak investigations. And the industry can offer our expertise in helping them better understand our processes and mechanisms. We can combine the data that we’re both collecting to better affect food safety.
The third key theme I want to mention from our comments is that of how to make sure that everyone in our industry fulfills their commitment to food safety. One of the big questions surrounding produce food safety is how to accommodate small and local growers. In our comments we’ve made the case that food safety is completely scalable to any size operation, large and small. From a food safety perspective, it doesn’t matter where the produce comes from; consumers do not expect to be injured in the consumption of a food product. FDA and the produce industry need to and can operate under a common set of expectations regardless of the size or origin of the source production.
Julia:
Wow, Bob. Just those few issues will really affect our industry. So, what’s next as far as FDA’s march toward regulation is concerned?
Bob:
The next step is for FDA to develop draft regulation for public review. That was originally scheduled to be published in October of this year, but now it looks like it won’t be coming out till 2011. They’ve recognized the complexity of our industry and the enormous amount of crucial issues which must be addressed. After the draft rule is published, we’ll get another chance to provide comments on it and work with FDA. This is very much a give-and-take between the industry and the agency.
Julia:
Thank you Bob.
Listeners, you can read PMA’s preventive controls comments by visiting the PMA website; go to PMA Resources, then Government Relations, then Regulatory Interaction – and look for our comments to FDA dated July 23, 2010. We’ll also include a link in the written version of this blog post. These comments cover a lot of other significant issues in our comments, and I encourage you to take a look at the full document. I’m sure some of our future posts will cover other specific issues mentioned in our comments.