Western Growers Response to Reagan Udall Report: Roadmap to Produce Safety

The Reagan Udall Foundation (RUF) Report: Roadmap to Produce Safety, released July 28, 2025, is centered on the tenet that fresh produce safety is a shared responsibility. If responsibility is truly shared, then so must be the accountability—for both progress and failure.

Despite the rhetoric of shared responsibility, there lies a significant imbalance.  At present, growers of fresh produce bear the responsibility of assuring progress in food safety while also assuming all accountability for lack of progress.

Buyers, suppliers and others in the supply chain impose requirements on growers that may or may not be the best food safety practice for the grower’s field or crop. These mandatory requirements compete with, and/or are in addition to, the best practices for growing, harvesting and handling a fruit or vegetable crop.

Buyer requirements are a notable hindrance to progress in fresh produce safety and are often driven by business objectives rather than food safety. Growers cannot implement prevention-based improvements specific to their operations if their resources are tied to mandates that were not designated to address food safety risk but instead to check a box for a buyer.

For example, there has been significant public discourse regarding the distance of leafy green fields to cattle feeding yards in the southwestern U.S. Did you know that buyer requirements for how far the leafy green field needs to be away from the cattle feeding yard vary anywhere from1.5 miles to 5 miles? These requirements are in place despite science that tells us that distance alone is not the best risk management strategy for addressing potential pathogen contamination.

These arbitrary distance requirements distract from designing more appropriate and dynamic risk management strategies based on each field’s location, condition, crop and agronomic practices. A grower must default to static buyer best guesses of distance. To focus on food safety, a grower should adopt practices based on changing environmental conditions and not be forced to a mandate based on buyer assumptions that may or may not serve food safety. By the way, it would be interesting to know if these same buyers ask the cattle feeding yards (which is likely part of their beef supply chain) to also adopt practices that help to reduce risk for nearby leafy green growers.

To achieve shared responsibility in produce safety, the development and implementation of buyer requirements will need to 1) focus on risk management rather than checking a box; 2) align with known best practices in food safety for the specific crop and region;  3) be developed using transparent, open dialogue, inclusive of growers and other stakeholders; 4) and be based on and respond to input from experts that are absent conflict of interest.

Improvements in produce safety will not be achieved by supply chain participants working in silos and without end-to-end adoption of best practice standards globally for fresh produce production. Buyers should not continue with their status quo, as it is clearly not allowing for needed food safety progress. Consumers deserve better.