January 17, 2017

Western Growers Comments on PMA/United Ethical Charter

The Produce Marketing Association and United Fresh Produce Association Joint Committee on Responsible Labor Practices, has published a proposed “Ethical Charter.” The committee is seeking public feedback on the draft Ethical Charter, which purports to “provide a framework for demonstrating and driving responsible labor practices across the global fresh produce and floral supply chains.”

Western Growers submitted the following comment to the Joint Committee:

As you know, Western Growers’ members based in California, Arizona and Colorado already adhere to some of the strictest state labor protection laws in the country. Moreover, our members care very much about the wellness, respect and safety of the workers who help produce the majority of the fresh fruit, vegetables and tree nuts grown in the country. To that end, our members already comply with the Ethical Charter without having to make changes to their operations or the manner in which they treat their workers. In our view, the Ethical Charter is clear, comprehensive and uses appropriate standards. All members of the fresh produce and flower supply chain, including the buyers, should be doing these things already.

We are concerned, however, with how the Ethical Charter may be used by some in the buying community. Specifically, it appears that the Joint Committee’s initial goal of leading the industry to a single auditable standard has gone by the wayside due to a lack of consensus by the buyer representatives on the committee. Western Growers does not believe there should be any audits conducted by produce buyers into the business operations of their produce suppliers absent reasonable cause to question the compliance of the producer’s labor practices. However, a single audit is certainly preferable to a proliferation of buyer initiated audits, and resultant audit fatigue, such as we have seen in the context of food safety. If some buyers end up requiring their suppliers to adhere to the Ethical Charter plus additional, individual buyer-initiated requirements, then the committee’s efforts will be deemed by industry to be a failure.  We encourage the committee to do what it can, if anything, to avoid such a result.

Western Growers members are encouraged to review the Charter and submit comments to the Committee here and also to forward those comments to Western Growers’ Jason Resnick.

Please direct any questions to Jason at (949) 885-2253.