Readers may remember back in November when I announced the first installment of a two-part post on produce safety. It's taken me a few months to get around to it, but here we are: part 2!
Photo of a "sterile farm" courtesy of the Wild Farm Alliance.
Part 1 of this post found me sitting awkwardly at an FDA meeting on produce safety. Agency reps wanted to know how they could streamline their process for dealing with outbreaks of illness linked to produce like the one in 2006, when nearly 300 poor souls got body-rocked by E. coli 0157:H7 from bagged spinach. By far the most popular proposal at the meeting (the opinion of yours truly notwithstanding): Create a state-of-the-art system that can trace our nation's produce from field to plate and back. Preferably one that involves lots of bar-code scanners.
A common criticism of this type of system (besides the fact that it's absurdly expensive) is that it doesn't actually fix the contamination problem. It merely ensures that if hundreds of people get horribly ill, we can figure out more quickly where the offending product came from. The produce industry likes this approach, because it would help avoid disasters like the Great Tomato Mistake last summer, when the CDC and FDA wrongly publicized tomatoes as the cause of a nationwide Salmonella outbreak. (It ended up being traced to jalapeno and serrano chilies, but only after consumers had stopped buying tomatoes. The tomato sector has still not recovered.)
But the industry also claims to realize the limitations of traceability systems. In California, the leafy greens industry — a category that includes growers and buyers of spinach, lettuce, mixed greens, kale, chard, etc. — has moved forward with an on-farm food safety program that claims to reduce the chance that those crops will become contaminated in the first place. These types of industry-led programs are becoming more and more popular across the country. And while they may sound good, I'm here to report that if they continue to proliferate, things are going to start looking quite dire for small, organic, and diversified farmers, for farm-to-institution arrangements, and for the rural environment.
Down on the farm
Here's a quick backgrounder: After the E. coli/spinach episode in 2006, big leafy greens producers in California (where the toxic spinach was grown) got together and drafted guidelines to reduce the risk of contamination on farms. These guidelines had some issues: they were based on the assumption that the E. coli had gotten on the spinach via wildlife in the fields, so they recommended that producers keep animals out with fencing, traps, or by removing vegetation on the farms where wildlife could hide. I don't need to tell you that in the sustainable ag world, removing vegetation is not a popular approach. Less vegetation means less biodiversity, poorer water quality, fewer beneficial insects, and less happy native pollinators, as Marc reported. But the guidelines were fairly broad, allowing for some flexibility. They were also voluntary: Producers didn't have to comply with them, although there was some pressure to.
Groups representing the interests of small and sustainable farms fought hard to make some reforms and to keep the guidelines voluntary, and they succeeded. But the thing is, buyers — companies like Dole or Chiquita's Fresh Express, or even food service companies like Sysco that contract directly with producers — don't want voluntary. From their point of view, if they "recommend" that their producers do certain things and they don't do them, and then an outbreak happens, the company gets the blame…and the economic hit. It all comes down to liability, kids.
So it was that the big leafy-greens buyers in California created their own sets of food safety "super metrics," practices that farmers must follow if they want to sell to these companies. The super metrics are based on the freakish idea that the more sterile the farm, the safer it is. Farmers have been required to mow down all non-crop vegetation on their farms, maintain huge swaths of bare earth around their fields, and/or set out poison bait and traps for any and all wildlife. Fresh Express says that if a wild pig enters a field, that field must be taken out of production for two years before they'll buy from it again. (The Associated Press has a good article on the super metrics here.)
Many farmers can't even talk to the press about what they're being asked to do — the metrics are proprietary to the companies and therefore confidential — but those that have, do not seem happy about it. So why don't the farmers just choose to sell to companies that don't require these super metrics? Because 86% of the leafy greens grown in California are bought by just four companies. In other words, most farmers, especially those too big for farmers' markets, have no choice.
We have to wonder why these companies thought the super metrics were going to bring them to the food-safety promised land, Moses-style. Many of the super metrics aren't based on science and could even make things worse, according to critics (some of whom are quoted in that AP article). Case in point: vegetation around waterways has been shown to filter 99% of pathogens moving between the field and the water, but growers are being asked to mow it down.
We also have to wonder what these companies were thinking when they decided to focus so much attention on farmers, given that the biggest contamination risk for leafy greens is the processing stage. According to a study by the Community Alliance with Family Farmers [PDF], since the FDA started tracking them 10 years ago, 98.5% of leafy greens outbreaks has involved bagged products — those cellophane sacks of "ready to eat" salad mixes and baby spinach from the grocery store. Yeah, it's important for farmers to take reasonable steps to prevent contamination in their fields, but the real problems arise when processors wash thousands of truckloads of greens in the same wash water, bag them in what one critic calls "a pathogen incubator," ship them across the country, and let them sit on the shelf for 15 days.
A national no-no
The leafy greens super metrics are limited to California right now, but since the tomato/chili debacle, produce buyers around the country are beginning to move in the same direction with other crops. Many have taken a voluntary guidance document created by the FDA for fresh produce safety, added their own bells and whistles (often unreasonable ones, from what we can tell), and required any farmer who wants to sell to them to certify that they are complying with the requirements. Oh, and the farmer has to cover the costs of the certification. Can't afford it? Can't or don't want to comply with the requirements, which are most often designed for large farms growing only a few crops, not smaller, diversified farms? Go find another market.
This spells trouble for the local food community. I recently spoke with a man working in the dining hall of a large university who was trying to design a farm-to-university program, but the produce distributor he worked with was requiring all farms that sold to it to comply with its food safety program. The small farmers he'd recruited for the F2U program couldn't do it. "I can't go around the distributor and work directly with the farmers," he said. "We serve too many meals a day, and the logistics would be a nightmare." He's trying to work something out with the distributor; keep your fingers crossed. He predicts that within a year, most food service companies in the country will be requiring something of this sort of its producers.
I want to be able to end this downer of a post with some sort of "take action" message, but the truth is, I'm not sure what to do. We can, as consumers, tell the companies selling fresh produce that we don't want to buy products from "sterile" farms. We can pressure the FDA to force companies to disclose the food safety requirements they impose on farmers, so at least we'll be able to critique them more accurately. And we can call on companies to show some leadership (and common sense) and work with small farmers to design more flexible, reasonable food-safety guidance. 'Cause I don't know about you, but when I think about the kind of farm I want to support with my food dollars, the last word I would use to describe it is sterile.