Produce and on-farm risk management

Produce-associated foodborne disease outbreaks have increased worldwide highlighting the importance of proper implementation of risk management practices (RMP). We determined the relationship between environmental characteristics (i.e., physical resources) of produce farms and implementation of RMP.

Following Preferred Reporting Items for Systematic Reviews and Meta-Analyses principles, we identified 36 studies to include in our analysis. Most study data were collected through surveys administered to growers in developed countries. Quality assessment results showed that studies on this topic should be more rigorously conducted (e.g., powering sample sizes and training data collectors) to yield better quality evidence. Agricultural waters were the most common environmental characteristic assessed, with many farms using unsafe water sources. Hygiene aids (e.g., accessible handwashing facilities), were lacking across many farms. Animal intrusion RMP were the least commonly assessed environmental characteristic. Only one study tested the relationship between on-farm environmental characteristics and RMP implementation reporting a positive relationship between accessible handwashing and worker hygiene practices.

Grower knowledge and perception of RMP combined with cost and ease in carrying out RMP might influence the availability of physical resources for proper RMP implementation. These results can inform practical interventions aimed to increase adoption of RMP on produce farms.

The relationship between environmental characteristics and risk management practices on produce farms: A systematic literature review

Agriculture

Dilhani Nisansala Jayawardhana 1 , Loan Thi Thanh Cao 2 , Thomas A. Yeargin 3 , Kristen E. Gibson 3 and Angela M. Fraser 1,*

http://scholar.google.com/scholar_url?url=http://131.220.45.179/ojs/index.php/fsd/article/download/69/997&hl=en&sa=X&d=18011325979091000715&ei=tuDCX4itNMeQmgGTyImoAQ&scisig=AAGBfm27ulzPEdzdGJcb8pYgpudYPZZCbA&nossl=1&oi=scholaralrt&hist=5kxqCikAAAAJ:5428478285509672052:AAGBfm0um7xNxqfVpArKOWnp4NG6xAm5og&html=&cited-by=

Manage problems before, not after alienating customers; what the NHL should learn from business

Some genius at CNN decided the National Hockey League, which resumes play in a few days after a protracted strike, could learn from the 1996 E. coli outbreak in unpasteurized juices produced by Odwalla that killed one and sickened at least 65.

While Odwalla did some creative risk communication, they, like the NHL, utterly failed at risk management by letting the crisis happen.

I’m gong back to Australia to play hockey, not talk about it.

Sometime in late September 1996, 16-month-old Anna Gimmestad of Denver has a glass of Smoothie juice manufactured by  Odwalla Inc. After her parents noticed bloody diarrhea, Anna was admitted to sorenne.hockey.jan.13Children’s Hospital on Oct. 16.  On 8 November 1996 she died after going into cardiac and respiratory arrest.  Anna had severe kidney problems, related to hemolytic uremic syndrome and her heart had stopped several times in previous days.

The juice Anna — and 65 others who got sick — drank was contaminated with E. coli O157:H7, linked to fresh, unpasteurized apple cider used as a base in the juices manufactured by Odwalla.  Because they were unpasteurized, Odwalla’s drinks were shipped in cold storage and had only a two-week shelf life.  Odwalla was founded 16 years ago on the premise that fresh, natural fruit juices nourish the spirit.  And the bank balance: in fiscal 1996, Odwalla sales jumped 65 per cent to $60 million (U.S.).  Company chairman Greg Steltenpohl told reporters that the company did not routinely test for E. coli because it was advised by industry experts that the acid level in the apple juice was sufficient to kill the bug.

Who these industry experts are remains a mystery.  Odwalla insists the experts were the U.S. Food and Drug Administration.  The FDA isn’t sure who was warned and when.   In addition to all the academic research and media coverage concerning verotoxigenic E. coli cited above, Odwalla claimed ignorance.

In terms of crisis management — and outbreaks of foodborne illness are increasingly contributing to the case study literature on crisis management — Odwalla responded appropriately.  Company officials responded in a timely and compassionate fashion, initiating a complete recall and co-operating with authorities after a link was first made on Oct. 30 between their juice and illness.  They issued timely and comprehensive press statements, and even opened a web site containing background information on both the company and E. coli O157:H7.  Upon learning of Anna’s death, Steltenpohl issued a statement which said, “On behalf of myself and the people at Odwalla, I want to say how deeply saddened and sorry we are to learn of the loss of this child.  Our hearts go out to the family and our primary concern at this moment is to see that we are doing everything we can to help them.”

For Odwalla, or any food firm to say it had no knowledge that E. coli O157 could survive in an acid environment is unacceptable.  When one of us called this $60-million-a-year-company with the great public relations, to ask why they didn’t know that E. coli O157 was a risk in cider, it took over a day to return the call.   That’s a long time in crisis-management time.  More galling was that the company spokeswoman said she had received my message, but that her phone mysteriously couldn’t call Canada that day.

Great public relations; lousy management.  What this outbreak, along with cyclospora in fresh fruit in the spring of 1996 and dozens of others, demonstrates is that, vigilance, from farm to fork, is a mandatory requirement in a global food system.  Risk assessment, management and communication must be interlinked to accommodate new scientific and public information.  And that includes those funky and natural fruit juices.

This one time, at Scout Camp, I got norovirus

I was in Beavers and Cubs for a couple of years as a kid (that’s the Canadian equivalent of Boy Scouts). Each week my parents dropped me off and the parent/volunteer organizers led us through games and crafts (I remember capture the flag and making wooden cars). Every year there was an overnight camping trip that I opted out of. It wasn’t the possibility of norovirus that kept me from camp; it was the rumors of cold, wet cabins.

Centre Daily Times reports that Seven Mountains Scout Camp in Spring Mills PA is shutting down for the the final week of a scheduled camp after 20+ campers became ill with what sounds like Norovirus.

Jim Kennedy, the executive director of the Juniata Valley Council of the Boy Scouts of America, said Sunday his staff decided to “be cautious and safe” and close the camp. About 140 campers were expected to arrive Sunday.

Kennedy said he’s in daily contact with the county health department and will continue to work with that staff.

“We’ve taken their recommendations in cleaning the camp,” he said.

That includes bleaching everything, including mattresses, picnic tables, the pool, camp office, shower house, and every other part of the camp (not sure what the bleach will do on the picnic tables – if they are wood, there’s lots of organic matter to gobble-up the active compounds -ben).

As of Sunday, Kennedy said water and swimming pool tests at the camp came back clean.

While he said extensive cleaning efforts have taken place since Friday, Kennedy said staff also have begun making changes at the camp to address the spread of germs. He said they installed hand-washing stations that campers would’ve used this week, “so they could thoroughly wash their hands in front of us.”

Other efforts include changing meals from family style to cafeteria, changing meal cleanup so there is limited contact with items belonging to multiple people, and bringing in nurses for health screenings upon arrival to camp.

The changes sound like good proactive practices that camps should be employing anyway – in the absence of illnesses.
 

Communicators bungle the crisis: Tiger Woods, Maple Leaf, it’s not about the talk, it’s the actions

The Wall Street Journal and every armchair analyst out there is saying that Tiger Woods is blowing the communications thing; he’s losing credibility, and fast.

Tiger Woods’s handling of the scandal is a textbook case in poor crisis management, say crisis managers.

Days of near-silence dealt a blow to the golfer’s once squeaky-clean reputation.

"At best, it looks like he’s coming clean because he got caught," says Karen Doyne, co-leader of Burson-Marsteller’s crisis practice. "Whether you’re a celebrity or a multinational corporation, you can’t expect credit for doing the right thing as a last resort."

In a crisis, the timing of a statement is as critical as its content, she says. "The ideal in any crisis situation is to get something out within three hours, but certainly within 24 hours," she says.

The rest of the Journal story goes with the usual fare about being fast, factual and trying not to fart in public.

But good communications is never enough. With any risk, or crisis, or problem, what is required is solid assessment, management and communication. Screw up any one, and the brand or person will suffer.

Leslie Gaines-Ross, chief reputation strategist with public relations firm Weber Shandwick … points to Canadian food-maker Maple Leaf Foods Inc.’s handling of a listeria crisis in 2008 as a good model. The same day labs confirmed the listeria strain’s presence in some of its products, CEO Michael McCain shot a television ad apologizing; he also posted the ad on YouTube.

Yeah, McCain and Maple Leaf got the communications part right – but they screwed up the assessment and the management. They should have known listeria would be accumulating in those slicers and they should have managed the problem far faster as the bodies were piling up (22 died).

Maybe Tiger should have kept his 4-wood in his pants.
 

Baseball, cars, and food: Controlling the risks

"If it provides more safety, then I’m all for it," says the New York Mets’ All-Star third baseman, David Wright, of his new Rawlings S100 batting helmet. Wright was clocked with a pitch two weeks ago (see video here) that left him on the disabled list with post-concussion symptoms until tomorrow’s opener in Denver, where he hopes to try out the new helmet.

It has a thick Polypropelene liner and an additional composite insert. "We’re confident that it will withstand a pitch up to 100 mph," said Mike Thompson, Rawlings senior vice president for sports marketing and business development.

The AP reports that all Minor League Baseball players will be required to use these helmets next season, as beanballs and subsequent concussions are inherent risks to America’s pastime.

"It’s one of those things that happens," said Scott Rolen of the Cincinnati Reds, who recently landed on the Major League’s DL with a concussion. "Nobody’s out there trying to throw at guys’ heads – that’s the idea. We’ll go out there and compete. I mean, we drive home every day, too, and that’s not real safe."

It’s true: people accept risks everyday. But they do so trusting that everyone involved is controlling the risks to the best of their ability – from pitchers to helmet manufacturers, from fellow drivers to auto makers, and from cooks (at home or elsewhere) to food producers.

When eating, it’s the culture of food safety of everyone from farm to fork that will determine the level of risk an individual is accepting. They should all adopt the attitude: "If it provides more safety, then I’m all for it."

Improving sampling and risk communication at FSIS

Chuck Dodd is dreamy – as a student, that is.

What teacher wouldn’t be proud when a student does a class assignment, and it eventually gets published in a peer-reviewed journal?

Chuck took my graduate course, Food Safety Risk Analysis, in the early part of 2008. For the final assignment, students are required to take a food safety risk issue of their choosing, and develop a risk analysis report for an audience, like a regulatory agency, integrating risk assessment, management and communication.

Chuck’s report – after editing and thoughtful comments from colleagues – was recently published in Foodborne Pathogens and Disease, entitled, Regulatory management and communication of risks associated with Eschericia coli O157:H7 in ground beef.

The Kansas State University press release that went out this morning says, in part,

What consumers may not be finding out about recalls and the inspection process, however, could make them doubt the effectiveness of what is actually a pretty good system to keep food safe, according to Kansas State University researchers.

Charles Dodd, K-State doctoral student in food science, Wamego, and Doug Powell, K-State associate professor of food safety, published a paper in the journal Foodborne Pathogens and Disease about how one government agency communicates risk about deadly bacteria like E. coli O157 in ground beef.

Publications, Web pages and recalls are all used in this risk communication.

Dodd said that although the Food Safety and Inspection Service generally does a good job of keeping meat safe, it’s easy for consumers to think the opposite, particularly when a recall tells them that the food in the fridge or pantry may be dangerous. In their study, Dodd and Powell looked at what information consumers can take away from the Food Safety and Inspection Service’s Web site, and suggest government agencies can more clearly communicate their role in keeping the food supply safe.

"We as Americans tend to expect more from regulatory agencies than we should, so we set ourselves up for disappointment," Dodd said. "Occasionally, regulatory agencies may create unrealistic expectations by the way they communicate with the public. The message of our paper is to say that the Food Safety and Inspection Service is doing a good job, considering the amount of resources it has. We are trying to open up dialogue about how its role could be communicated more effectively." …

Testing is just one tool that the Food Safety and Inspection Service uses. Its role is to monitor what other stakeholders are doing to keep food safe. "As a regulatory agency, the Food Safety and Inspection Service is monitoring food safety, not necessarily testing it themselves," Dodd said. "I think that’s what a lot of us consumers misinterpret. We need to remember that regulatory agencies allocate, not assume, responsibility."

He got an A in the class. And he collects his own cow pies for sampling (left).

Dodd, C.C. and Powell, D.A. 2009. Regulatory management and communication of risks associated with Eschericia coli O157:H7 in ground beef. Foodborne Pathogens and Disease, 6(6): 743-747.

Abstract

Foodborne illness outbreaks and ground beef recalls associated with Escherichia coli O157:H7 have generated substantial consumer risk awareness. Although this risk has been assessed and managed according to federal regulation, communication strategies may hamper stakeholder perception of regulatory efforts in the face of continued E. coli O157:H7 outbreaks associated with ground beef. To mitigate the risk of E. coli O157:H7 contamination in ground beef, the beef industry employs preharvest and postharvest interventions, while the U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) provides regulatory oversight. Policy makers must understand and clearly express that regulation allocates, not assumes, responsibility. The FSIS role may be poorly communicated, leading consumers, retailers, and others in the farm-to-fork food safety system to misrepresent risks and creating unrealistic expectations of regulatory responsibility. To improve this risk communication, revisions may be needed in FSIS-related documents, Web pages, peer-reviewed publications, and recall announcements.

Antenna in your mocha latte?

The US Food and Drug Administration (FDA) maintains a list of Food Action Defect Levels in the Code of Federal Regulations "to establish maximum levels of natural or unavoidable defects in foods for human use that present no health hazard."

A local news station in Michigan got hold of this list and started asking people on the street how they felt about the number of bug parts allowed in their coffee and the amount of rodent "excreta" tolerated in their chocolate.

My local news station in Wichita, Kansas, broadcast their story Tuesday while I shook my head and chuckled. There were a lot of interesting faces as people looked from their cup to the list and back again.

In the end, I got the impression that the public is okay with a few bug parts (and laugh about getting the extra protein), but won’t stand for the poop.

We here at barfblog.com continually advocate keeping as much poop out of food as possible, and proudly wear our t-shirts that declare, "don’t eat poop" with a message about handwashing on the back.

But I’m not crazy. I realize, like the FDA (not the USDA, as asserted in the story, which primarily regulates only meat and poultry products), that it’s virtually impossible to keep the entire (non-meat and -poultry) food supply 100% poop-free. Therefore, I’m glad there are regulations in place to reduce the microbial risks associated with that poop. (The poop that got into the peanuts at the Peanut Corp. of America plant violated those regs.)

I’m just saying… some poop happens. Risks that cannot be eliminated can, and should, be controlled. Responsible, informed producers and consumers do this every day with tools like the FDA Defect Action Level Handbook and tip-sensitive digital meat thermometers.

Do your part: wash your hands and stick it in.

Great communications, lousy management: Is Maple Leaf the new Odwalla?

Last week I dusted off some old slides to talk with an industry group about best practices in food safety. I got bored of hearing myself say the same thing about 10 years ago, but sometimes, it’s best to stick to basics.

Risk analysis is composed of risk assessment, management and communication. Over the years I’ve studied dozens of outbreaks of foodborne illness and concluded that a producer, or processor, or retailer needs to be excellent at all three—assessment, management and communication – and if they fail at just one, they will suffer the economic and associated hardships.

There is no doubt that Michael McCain and Maple Leaf Foods has practiced excellent risk communication since being fingered as the source of a listeria outbreak in Canada that killed at least 20 and sickened 60. I’ve said so from the beginning. I’ve also said that

it is impossible to judge whether Maple Leaf was practicing good risk management and assessment because no one will come clean on who knew what when as the outbreak was developing.

But that hasn’t stopped Canadians from gushing in a blindly patriotic way about how McCain set the ‘gold standard’ for reputational and financial management.

Maybe, but communications alone is never enough, just like science alone is never enough. And precisely because no one – government or industry – has come clean on who knew what when, it’s not surprising to hear

the Canadian federal government has delayed for months the release of notes on conference calls

held at the height of last summer’s deadly listeriosis outbreak — a lag some experts say breaks Ottawa’s own information laws.

At issue is an Access to Information request by The Canadian Press to the Privy Council Office for “all transcripts and minutes” of the crucial exchanges last August and September.

The Odwalla 1996 outbreak of E. coli O157:H7 in unpasteurized juice was also textbook risk communication, but the company was eventually revealed to have cut corners and ignored warning signs. Will Maple Leaf undergo similar scrutiny?

Below is an except from my 1997 book, Mad Cows and Mother’s Milk, about the Odwalla outbreak.

Sometime in late September 1996, 16-month-old Anna Gimmestad of Denver has a glass of Smoothie juice manufactured by  Odwalla Inc. After her parents noticed bloody diarrhea, Anna was admitted to Children’s Hospital on Oct. 16.  On 8 November 1996 she died after going into cardiac and respiratory arrest.  Anna had severe kidney problems, related to hemolytic uremic syndrome and her heart had stopped several times in previous days.

The juice Anna — and 65 others who got sick — drank was contaminated with E. coli O157:H7, linked to fresh, unpasteurized apple cider used as a base in the juices manufactured by Odwalla.  Because they are unpasteurized, Odwalla’s drinks are shipped in cold storage and have only a two-week shelf life.  Odwalla was founded 16 years ago on the premise that fresh, natural fruit juices nourish the spirit.  And the bank balance: in fiscal 1996, Odwalla sales jumped 65 per cent to $60 million (U.S.).  Company chairman Greg Steltenpohl has told reporters that the company did not routinely test for E. coli because it was advised by industry experts that the acid level in the apple juice was sufficient to kill the bug.

Who these industry experts are remains a mystery.  Odwalla insists the experts were the U.S. Food and Drug Administration.  The FDA isn’t sure who was warned and when.   In addition to all the academic research and media coverage concerning VTEC cited above — even all of the stories involving VTEC surviving in acidic environments — Odwalla claims ignorance.

In terms of crisis management — and outbreaks of foodborne illness are increasingly contributing to the case study literature on crisis management — Odwalla responded appropriately.  Company officials responded in a timely and compassionate fashion, initiating a complete recall and co-operating with authorities after a link was first made on Oct. 30 between their juice and illness.  They issued timely and comprehensive press statements, and even opened a web site containing background information on both the company and E. coli O157:H7.  Upon learning of Anna’s death, Steltenpohl issued a statement which said, “On behalf of myself and the people at Odwalla, I want to say how deeply saddened and sorry we are to learn of the loss of this child.  Our hearts go out to the family and our primary concern at this moment is to see that we are doing everything we can to help them.”

For Odwalla, or any food firm to say it had no knowledge that E. coli O157 could survive in an acid environment is unacceptable.  When one of us called this $60-million-a-year-company with the great public relations, to ask why they didn’t know that E. coli O157 was a risk in cider, it took over a day to return the call.   That’s a long time in crisis-management time.  More galling was that the company spokeswoman said she had received my message, but that her phone mysteriously couldn’t call Canada that day.

Great public relations; lousy management.  What this outbreak, along with cyclospora in fresh fruit in the spring of 1996 and dozens of others, demonstrates is that, vigilance, from farm to fork, is a mandatory requirement in a global food system.  Risk assessment, management and communication must be interlinked to accommodate new scientific and public information.  And that includes those funky and natural fruit juices.

When worlds collide: engineering and food safety

After breakfast in the morning, my husband and I go our separate ways until dinner. Bret, who studied agricultural engineering in college, designs turf equipment. That’s him at right on an old prototype mower managing the turf in our backyard.

As you all know, I studied food science and industry. With the help of Doug and Phebus, I found my way to writing about food safety.

Our worlds collided this morning when I pulled his engineering magazine out of the pile of mail in the kitchen and saw the words “food safety” staring back at me.

The cover article was by another ag engineer, Nathan Anderson, who works with the FDA’s National Center for Food Safety and Technology in Illinois.

In the article, Anderson points out that,

“Increased concern over microbiological safety in terms of public health and international trade has led to a shift in how microbial risks are assessed and controlled.”

In order to have fewer sick people and more world trade, governments are adopting new risk-based approaches to food safety management and ditching the old prescriptive control measures.

Anderson’s article describes the Food Safety Objective (FSO) approach to risk management, which sets as a goal a maximum population for a certain microbe in the food being processed.

Processors must then control the levels of the microbe on/in incoming product initially, reduce levels if necessary, and prevent any increases.

This, of course, can be expressed by a mathematical equation (since it’s an engineering concept). But I won’t do that here.

Developing processes based upon known risks—as opposed to long-standing beliefs—is a smart way to do business. Engineers just say it differently than food safety writers.

Engineer: 

burger + E. coli + food thermometer > burger + E. coli + color-based estimate

Food safety writer:

Powell: Irish government did the right thing recalling dioxin-laden pork products

Friday we took baby Sorenne to her first pediatrician’s appointment. Everything was cool, we went and got some groceries, and on the way home a reporter from the Times of London rang me up. He wanted to chat about dioxin in feed in Ireland and had actually found a technical report me and a couple of students wrote almost a decade ago about dioxin in Belgian feed.

Indeed, I was the same person, oops, hang on a sec, removed the car seat from car, then chatted for about 20 minutes as I trugged the groceries up the hill.

The stories are running Sunday morning in London and my quotes are an excellent example of baby brain: some of the right words are there, but much of what I said comes across as gibberish. Nevertheless, the stories provide an excellent overview of the dioxin-in-Irish-feed crisis.

In the central science laboratory in York last Saturday, scientist Martin Rose stared in disbelief at his dioxin detector. He had injected a sample of Irish animal feed into the machine, and the results had gone off the scale. The level of toxic contamination was at least 5,000 times the legal limit.

Rose knew there was some urgency about the analysis. The Irish authorities had asked the laboratory team to work over the weekend to get test results in a few days; normally it would take four weeks.

At 3.40pm on Saturday last, Alan Reilly, deputy chief executive of the Food Safety Authority of Ireland (FSAI), was given the bad news. He called Brian Cowen and outlined the grim scenario. While only 8% of Irish pork was contaminated, it could not be isolated quickly.

Every minute that the taoiseach dallied, consumers were eating dioxin-laden Irish meat. How much damage that might be doing to people’s health was not known. Nevertheless, Cowen made his decision almost immediately. Aware of the damage it would do to Ireland’s pork industry, he ordered a full recall of all pork products from September 1.

“I actually can’t believe this decision is even being questioned,” said the FSAI’s Reilly. “I’m astonished by the people saying that we shouldn’t have ordered a recall. If we had left that meat on the shelves, leaving people to eat contaminated product, we would have been lambasted for being irresponsible, and in all probability we’d be out of our jobs.

Doug Powell, scientific director of the International Food Safety Network at Kansas State University, said off-the-scale readings from the feed justified the action.

“When you get those kind of numbers the response should be ‘let’s pull everything.’ If the public perceive that the authorities knew there was a risk and didn’t do anything, then they’d be crucified. From a crisis-management point of view it’s clear they did the right thing. Compare that with [the similar contamination crisis in] Belgium and we see the mess that came out of that.” …

The International Food Safety Network’s Powell believes that the government’s policy of annual testing is insufficient. “One test a year is only a snapshot. How do you know what they are doing the other 364 days?” he said. “We talk ‘farm to fork’ food safety all the time, but are the guys making the feed taking it seriously? We need to get a culture where the manufacturer is saying ‘we can’t mess this up’ rather than waiting for somebody to catch you. Everybody needs to have a culture of food safety. The marketplace can be brutal but that’s why we need to change attitudes.” …

According to Powell, the way forward is to change the culture that led to the crisis. “There will be a stigma associated with the product for a while,” he said. “The marketplace is going to demand better. Supermarkets will want to know what is going into the feed of their pigs. The producers and the processors can’t just say they have testing in place; they’ve got to prove it.”

Below is the abstract from the technical report we produced on the dioxin in Belgian feed crisis of 1999. The entire report is available at http://www.foodsafety.ksu.edu/en/articledetails.php?a=3&c=9&sc=64&id=316

In the spring of 1999, dioxin was introduced into the Belgian food supply, including exports, via contaminated animal fat used in animal feeds supplied to Belgian, French and Dutch farms. Hens, pigs and cattle ate the contaminated feed and high levels of dioxin were found in meat products as well as eggs. What followed was yet another European food safety scandal filled with drama and public outcry. There were government investigations, the removal and destruction of tons of eggs and meat products and huge economic losses. The case study of this incident reported here illustrates how the crisis unfolded, and evaluates how the Belgian government managed and communicated this crisis, based on publicly available documentation. The government’s major error, based on the unfolding public discussion of the events, was a perceived failure to publicly acknowledge the crisis, resulting in accusations of a self-serving cover-up. The government’s poor crisis management and communication strategy became the focus of intense public and media criticism and blame. Moreover, the significant issue of poor quality control in the food and feed industries was pushed to the sideline. Not only was the reputation of the food supply tarnished but public confidence in the government was damaged, leading to the resignations of two cabinet ministers and the ousting of the ruling party in a national election. This study confirms the basic components required to manage food-related stigma:

• effective and rapid surveillance systems;

• effective communication about the nature of risk;

• a credible, open and responsive regulatory system;

• demonstrable efforts to reduce levels of uncertainty and risk; and,

• evidence that actions match words.