Pundit Prevor’s plan to pump-up food safety

Jim Prevor, sometimes known as the Perishable Pundit, has offered a plan to improve food safety. Writing in The New Atlantis, Prevor says sure, government has an important role in food safety, but the current focus on legislation is misguided. Or at least that’s my summary. Here’s some more summarized stuff from Prevor’s article. The first two suggestions caught my attention – the rest is boilerplate stuff. (The complete article has also been translated into French by Albert Amgar and is available here.)

1. Switch to a negligence standard from a strict liability standard, and switch primary liability to the trade buyer

Because of strict liability, the primary food safety concern among retailers in the U.S. is that their vendors carry sufficient liability insurance. By contrast, in the United Kingdom and certain other foreign countries, supermarkets can be held liable in court if a person becomes ill or dies and it is shown that the retailer did not exercise proper due diligence in vetting suppliers.

Second, because the standard is strict liability, farmers and processors get no return on their investment in food safety if they have the bad luck to have an outbreak. In other words, the liability is strictly theirs whether they invested millions, going above and beyond all food safety standards, or they did nothing at all.

Combining this strict liability standard with a concentrated buying environment, where large chains such as Wal-Mart, Costco, Kroger, Safeway, and Supervalu account for the vast majority of purchases, results in a potentially troublesome situation. At these big buyers, although official corporate policy may place a priority on food safety and the individuals employed may care about food safety, the day-to-day institutional imperative is to get lower prices from vendors. Most producers are more than willing to give buyers exactly as much food safety as they are willing to pay for. But buyers, who are not liable for food safety problems, have precious little incentive to pay extra for higher food safety standards. …

In other words, food safety is primarily a tradable good in the marketplace. In deciding that the producer is liable no matter how diligent his efforts and that the retailer is not liable no matter how lax his efforts, the judicial system has distorted the way the market meets the consumer interest in food safety. Solving this problem is far more likely to enhance food safety than giving the FDA additional power. After all, the FDA doesn’t produce or buy food; it is always going to be a much more indirect player in moving the needle on food safety than members of the industry.

2. Root out bribery and corruption in food safety certification

The best federal agency to enhance food safety is not the FDA but the FBI. Few buying operations have the capability to have their own personnel inspecting and monitoring producers along today’s global supply chains. The solution is to rely on third-party certification agencies. Trade buyers can establish their own standards or agree to accept other well-recognized standards, such as those of the British Retail Consortium. Adherence to these standards is then confirmed by various independent auditing groups. This is essentially the same mechanism the USDA uses to implement organic certification. The problem is that there is widespread corruption associated with these certifications, especially in areas such as China, Eastern Europe, and many developing countries, though auditors that are less than rigorous are also well known in the United States.

The corrupt sale of certifications poses a fundamental threat to food safety, and switching to government inspectors doesn’t solve the problem. First, the U.S. government has no authority to run inspections in China. Second, if the government were to use locals in other countries to run inspections, it would face the same problems as a private auditor — keeping the loyalty of local employees whose family, clan, and national interests all compel them to approve facilities and products. Third, whether through sloth or corruption, there are all too many examples of government inspectors not doing their jobs right here in the United States — from rats running wild in a KFC that had been inspected just the night before to horrid conditions at the 7th Street Market in Los Angeles to a payola scandal at the Hunts Point Produce Market in New York.

Beyond establishing a proper liability regime, increasing the reliability of food safety certifications by rooting out bribery and corruption is perhaps the single most valuable contribution the federal government could make toward food safety.

What is a food safety culture?

Culture encompasses the shared values, mores, customary practices, inherited traditions, and prevailing habits of communities.

There’s lots of other definitions, but Amy and I spent some time figuring this one out so that’s what we’re going with. (That’s Amy, right, talking about language, culture, memory and Pied-Noirs, the former French inhabitants of Algeria, at her undergraduate alma mater, Truman University in Kirksville, Missouri, where she was feted Monday night.)

Frank Yiannas, the vice-president of food safety at Wal-Mart wrote in his aptly named 2009 book, Food Safety Culture: Creating a Behavior-based Food Safety Management System, that an organization’s food safety systems need to be an integral part of its culture, and that culture is patterned ways of thought and behaviors that characterize a social group which can be learned through socialization processes and persist through time.

Yiannas also writes:

• The goal of the food safety professional should be to create a food safety
culture – not a food safety program.

• An organization’s culture will influence how individuals within the group
think about food safety, their attitudes toward food safety, their willingness
to openly discuss concerns and share differing opinions, and, in general, the
emphasis that they place on food safety.

• When it comes to creating, strengthening, or sustaining a food safety culture
within an organization, there is one group of individuals who really own it –
they’re the leaders.

• Having a strong food safety culture is a choice. The leaders of an organization
should proactively choose to have a strong food safety culture because
it’s the right thing to do, as opposed to reacting to a significant issue or
outbreak.

• Creating or strengthening a food safety culture will require the intentional
commitment and hard work by leaders at all levels of the organization,
starting at the top.

• Although no two great food safety cultures will be identical, they are likely to
have many similar attributes.

• Identifying food safety best practices can be useful, but one major drawback
to creating such a list is that it doesn’t really demonstrate how these activities
are linked together or interrelated. It misses the big picture – the system.

• To create a food safety culture, you need to have a systems-based approach to
food safety.

Chris Griffith, formerly of the University of Wales in Cardiff, and colleagues, have just published three papers in the British Food Journal with their take on food safety culture.

Griffith proposes that food safety culture is,

The aggregation of the prevailing, relatively constant, learned, shared attitudes, values and beliefs contributing to the hygiene behaviours used within a particular food handling environment.

Griffith also writes there are many attributes from organizational safety culture that can be applied to food safety culture, including:

• it describes beliefs shared by members in an organization;

• it requires a contribution from people at all levels;

• it has an impact on work performance/behaviour, practices or behavioural norms;

• it concludes a set or subset of values and attributes that are relatively stable and which may be resistant to change;

• there are likely to be a range of factors contributing to culture and that business
with a strong culture can achieve this in a range of ways;

• culture is communicated to and learned by new staff;

• an organization can be composed of several subcultures; and,

• there maybe different food safety cultures at different levels within an
organization, especially in larger ones.

The second paper concludes that food safety does not happen by accident and to produce safe food consistently, especially on a large scale, requires management. Management includes the systems that are used and the organizational food safety culture of compliance with those systems. Food poisoning will never be totally prevented however to a considerable extent a business does get the food poisoning it deserves.

I’m thinking Peanut Corporation of America, and about 100 other examples.

Finally, Griffith et al. develop six potential groupings to assess food safety culture within an organization including ; food safety management systems and style, food safety leadership, food safety communication, food safety commitment, food safety environment and risk perception.

These are valuable contributions to the emerging concept of food safety culture. Chapman and I look at how best to influence and nurture that culture – how to keep the mundane aspects of food safety relevant for all those communities in the farm-to-fork food safety system including farms, food processing facilities, domestic and international distribution channels, retail outlets, restaurants, and domestic kitchens.

Creating a culture of food safety requires application of the best science with the best management and communication systems, including compelling, rapid, relevant, reliable and repeated, multi-linguistic and culturally-sensitive messages. That’s why we create food safety infosheets (in several languages), blog posts (even the silly ones) and get out in the field to figure out what works best. Talking with people helps.

The best food producers, processors, retailers and restaurants should go above and beyond minimal government and auditor standards and sell food safety solutions directly to the public. The best organizations will use their own people to demand ingredients from the best suppliers; use a mixture of encouragement and enforcement to foster a food safety culture; and use technology to be transparent — whether it’s live webcams in the facility or real-time test results on the website — to help restore the shattered trust with the buying public.

Market produce safety at retail so consumers can choose

I’m no fan of economic estimates of foodborne illness. The numbers are somewhat fantastical and the assumptions behind the numbers are usually oblique and obscured.

I’m also not a fan of whining.

In response to a study released earlier this week by the Pew Charitable Foundation’s Produce Safety Project, which pegged the annual cost of foodborne illness at $152 billion and which Chapman has already taken to task, United Fresh Produce Association president Tom Stenzel said,

“It’s really a shame that, once again, advocates for food safety legislative reform are stoking unneeded anxiety about produce safety. This report inappropriately lumps together data from all foods and all food contamination events, including those at church picnics and cross-contamination after sale to the consumer. There’s no data on illnesses actually related to contamination from the farm, which is a much smaller subset cause of foodborne illness. … The fresh produce industry is working tirelessly to grow and market the safest possible products. We strongly support national government oversight of produce safety standards to ensure a science-based, commodity-specific approach no matter where a product is grown. What’s harmful about tactics like this is that advocates are actually scaring consumers away from the very products they need to be consuming more of for better health.”

Dude, you need a better writer. And an editor.

Rather than complain, why not advertize and market all the outstanding food safety efforts your members are undertaking, at retail, so concerned consumers, who have heard a thing or two about produce-related outbreaks over the past 20 years, can make their buying decisions based on evidence rather than faith? Make your testing data public. And stop whining.