Western Growers' De Ann Davis Discusses Moving from Reactive to Preventative
BAKERSFIELD, CA - Our industry has three main points of contact with the Food and Drug Administration: The first, through Produce Safety Rule inspection under the FDA Food Safety Modernization Act (FSMA); the second through surveillance sampling assignments; and the third through outbreak investigations.
These interactions are not preventive. More can be achieved through a focus on a collaborative partnership with growers based on food safety knowledge and continuous improvement. An overemphasis on compliance by the agency will not work. There are too many farms, too much local crop complexity compounded by too little scientific knowledge on the effectiveness of current field food safety practices.
So, how do we attain a collaborative process that values domestic growers in comparison to how the interactions occur now?
First, Produce Safety Rule inspections are primarily conducted by the states and we agree that approach is sound as they know the topography of their state, their conditions, challenges, and the growers themselves. They want to support businesses in their state and help them be successful. But, there are more than 20,000 farms subject to FSMA in California alone, and states need the authority to build technical assistance resources and research capacities that allows them to meet growers where they are at.
Surveillance sampling assignments are extremely disruptive to industry, as produce has a short shelf-life compared to the time it takes to receive test results. Sampling assignments result in economic losses, food waste, supply chain disruptions, and are not an effective use of resources.
In recent years, Western Growers has invested considerable time and resources in developing the first fresh produce industry data sharing/analytics platform, GreenLink. We have also focused on sharing pre-harvest testing data collected from growers with the FDA.
However, with respect to a sampling assignment currently taking place in California, the FDA has disregarded this data and the potential to incentivize data sharing and analytics to enhance food safety and maximize the use of public/private resources.
These assignments also teach us a great deal about the need to improve the accountability and leadership structure within the FDA itself. When concerns arise, the industry can feel like a hot potato getting tossed around.
Another way that growers interact with the FDA is when the agency conducts an outbreak investigation. The current methodology that the FDA undertakes for such an investigation from start to finish needs to be reconsidered.
To begin with, the FDA is often not the first contact with a grower in connection with an outbreak—that is someone up the supply chain. When the FDA does contact a grower during an investigation it is a one-way exchange where the FDA asks for certain records but fails to seek to understand the records they are requesting; there is no follow-up.
The grower is left with no knowledge about learnings from the investigation, why they were contacted, or what should be doing differently going forward.
We believe that there are lessons to be learned from the aviation industry and how the FAA conducts accident investigations. It is worth noting that the FAA’s investigation division is called the Office of Investigation and Prevention. As the name suggests, that model incorporates investigation, data collection, risk analysis, and information sharing. The idea is to learn and then share with the whole industry to improve aviation safety for everyone. That type of mindset would be useful at the FDA.
If we continue under the present model of allowing the development and implementation of foodborne illness detection efforts to outpace necessary development of prevention programs for fresh produce, we will fail the consumer by undermining the accessibility, affordability, and trust in these nutritionally important foods.