Desert Glory - voluntary certification system for traceability

Passed along by Sebastian Cianci of FDA, one presentation from the FDA's traceability public meeting on Oct. 16:

Desert Glory

Production Standards and Traceability

Components of a Food Safety Certification System

October 16, 2008

Desert Glory believes that the fresh produce industry needs a system that protects public health and promotes commerce which goes beyond traceability. That is why we are proposing a voluntary pre-certification system for the industry modeled after the successful U.S. Customs Border Patrol process, C-TPAT. The program would provide a meaningful opportunity to increase public safety and expedite return to commerce. The following questions help explain the concept.

1. How does the certification system you’re proposing differ from the traceability proposals put forward by industry leaders under current FDA consideration?

The current proposals focus on traceability and only go as far as “one step forward and one step backward.” Yet, Desert Glory has full product traceability, tracking the tomato from not only from the date it was harvested but to a specific sector of one of our 450 greenhouses and all the way to the consumer who purchases our NatureSweet brand. No, traceability was not the determining factor in clearing tomato products during the recent Salmonella incidents, geography became the eliminating factor in that instance. But geography does NOT take into account production practices and traceability.

Our proposal is to have growers, shippers, distributors and retailers work together on a voluntary certification program that includes best production and distribution practices as well as full product traceability. Then, when a food safety failure occurs, those participants in the certification system have the opportunity to quickly and efficiently show test results and documentation that will expedite their return to commerce and ultimately narrow the governing agency’s search span.

2. Why haven’t industry groups advocated for a certification process?

There are various traceability proposals being floated around which have been in the works for years. It is our belief that they do not go far enough to provide incentive to growers to join such as ensuring early release of safe product. This is why we are advocating for a voluntary certification program that will qualify businesses based on proven production practices and regular random testing.

3. While you are a U.S. company, all your production is in Mexico. What are your peers in Mexico doing to ensure food safety practices for imported product?

Desert Glory has focused on operating our farms based on the highest standards possible. We concentrate our efforts in producing and delivering a safe product. We recently held a food safety session with other farmers in Mexico, helping them to implement the discipline required for best practices.

Please note that in our discussions with other Mexico growers, they were shocked and discouraged that even Desert Glory, with its fully traceable systems, was restricted from commerce of its Roma tomatoes during the recent Salmonella outbreaks. They see little reason to invest in traceability systems if there is no business advantage during a crisis.

4. How are you working with industry groups in moving forward policy changes?

We believe industry groups are working hard for their member organizations. Our practices often exceed the standards being recommended by industry groups and while we support their efforts to generate attention to the need, we advocate an incentive to growers who can qualify for certification.

5. Is certification realistic if you are not a greenhouse grower?

The certification program we are advocating is based on the guidelines for good agriculture practices which can apply to all growers. But ultimately it is up to the FDA to establish the criteria for a certification program that best ensures the safe delivery of produce to market.

6. Can growers of all sizes participate in your proposed voluntary certification program?

Yes, regardless of size or scope any grower can participate. For example, some of the smallest growers today participates in certification when growing Organic produce. Although we do believe a program with a sliding scale is the best approach.

7. Can a traceability system really protect the public?

A traceability program is not enough which is why we are advocating for a voluntary certification process so that producers who have the ability to prove themselves clear of any contamination can do so immediately and continue commerce. This also helps the FDA narrow the search field therefore expediting the identification of the source which ultimately protects human welfare and safeguards the industry from a full shutdown.

8. How do you control product safety once it is in the distribution centers?

Desert Glory works directly with and prequalifies our distribution centers based on a propriety audit of Desert Glory standards. We would advocate that all participants in the supply chain have certification procedures and work together for a seamless system.

9. Should different standards be required of domestic vs. international growers?

A certification system should be passed on standards of production, packing and distribution with verification from third-party sources and random testing. It should not be based on geographical profiling. The difference between tomatoes shipped from Mexico to Michigan and those shipped from California to Michigan is based on how that tomato is produced and shipped, not where it was grown.

10. How much would a certification system based on the C-TPAT model cost?

As the industry works together with the FDA to determine specific required elements the cost of such a program will be better calculated. Much of what should be required is a matter of discipline and not one of capital investment. For instance, tracking tomatoes by a specific growing field or greenhouse means that a packer must incorporate discipline to put a break in the production line, clean it and recode the packaging or boxes when a new greenhouse or field comes on line. It is discipline and standards that will make the biggest difference.

Some of the smallest growers today incur costs of certification when growing Organic produce, typically one percent of their revenue. We believe that a program with a sliding scale is the best approach therefore opening up to all size of growers.

11. Has Desert Glory ever had a recall?

No, Desert Glory has never had a recall. But as part of our best-practices we conduct random product recalls that enable us to account for a product’s full traceability within three hours.

For more information contact:

Janet Greenlee

(512) 495-7165

(512)968-8306