January 15, 2020

The Role of Influence in the Food Safety Paradigm

“Influence”, or more specifically “influencers”, is the theme for this month’s magazine. It is a timely subject as Western Growers and the industry struggle with how to stem the ongoing outbreaks of foodborne illness associated with key commodities such as romaine.

Securing safe food is a shared responsibility of all parts of the supply chain, peripheral enterprises and those that oversee industry actions such as the U.S. Food and Drug Administration. It requires coordinated and collaborative effort among all parties if we are to make progress, with success only be measured by fewer illnesses. But many of the relationships between parties who own part of the food safety issue are not of the nature where there is direct authority to dictate or control what needs to be done to protect the public.  So “influence”—the act or power of producing an effect without apparent exertion of force or direct exercise of command—is the tool that must be brought to bear to change food safety culture and systems.

Western Growers is an “influencer” within the fresh produce supply chain, having some sway with producers, shippers and handlers. But resolution of this issue cannot and should not fall entirely on the backs of the suppliers. WG must team up with other influencers to ensure we are all working in a coordinated fashion toward a common goal.

To paraphrase the overarching rule of law governing fresh produce food safety: “Thou shalt not introduce contaminated food into the market.” This precept places the responsibility for control directly on the supplier, and emphasizes the enforcement function for our regulatory partners to ensure that food is safe. These roles and responsibilities are important but have yet to yield a meaningful reduction in outbreaks or illness. Rather than doing the same thing over and over and expecting a different result, Western Growers proposes that industry, agency and other invested stakeholders examine more cooperative models that will support discrete industry and regulatory objectives, as well as our common goal to protect consumers.

To further our interest in a new model (to supplement industry preventative work and agency investigative and enforcement work), Western Growers proposes expanding public/private partnerships to advance food safety.

While industry has been voicing some of these concepts with FDA for quite some time, a recent meeting of the “Private and Public, Scientific, Academic, and Consumer Food Policy Group” (PAPSAC), held annually at the Harvard Kennedy School for Business and Government, gave WG President and CEO Tom Nassif the opportunity to raise the issue of supporting the produce industry in its pursuit of solutions instead of punishing them every time an outbreak occurs. He found a receptive audience from a variety of stakeholders including leadership from FDA, National Academy of Sciences, STOP Foodborne Illness, Wegmans, Harvard, MIT and others. In fact, new forms of collaboration were part of the agenda for this meeting and, in keeping with the WG theme of new, a new paradigm must be established.

Raising the issue was only the first step! Following the PAPSAC conversations, WG staff was charged with organizing follow up conversations to generate concrete, actionable ideas on how diverse interests might coalesce to advance common goals. An exploratory conversation was facilitated by Western Growers in mid-December with several of the PAPSAC participants (leaders at FDA and others). At this point, these relationships and conversations are still in their formative stages, but the initial call was substantive and yielded some promising areas for follow up, including:

1.  a receptivity on the part of FDA to explore how industry might be engaged directly with the agency during investigations, traceback and environmental assessments, affording FDA the opportunity to tap into industry expertise as necessary to speed their process and improve output;

2.  a willingness to jointly communicate key messages to industry on findings, projects, and values of collaboration;

3.  the development of programs and structure that would help spur the collection and coalescence of valuable (industry generated) data; and

4.  investment of funds, resources and expertise to better understand root causes and potentially other areas of cooperation.

The recurring outbreaks in romaine must be stopped. The current authoritative paradigm of FDA pressure on industry to change—corresponding industry changes—and then another outbreak before the cycle repeats is not working. Constructive partnerships that allow us to work within and between our respective spheres of influence must be explored if we are to protect the consumer and the long term viability of the commodity. Western Growers, through Nassif’s influence within PAPSAC, has initiated the dialogue and set the stage for more cooperative work, it is now incumbent upon all of us to use our influence to carry forward new cooperative efforts to resolve ongoing issues.