The Fruitful Fight for Tight Food Safety: The California Leafy Greens Marketing Agreement Leads the Way
Amid FDA disarray, U.S. lettuce industry tightens safety regulations.
In the stormy sea of food safety regulation, the produce industry takes its ownkraken approach—a self-imposed regime forged in science and backed by a robust enforcement model to maintain the sanctity of U.S. lettuce, setting a shining example for broader applications.
Despite the tempestuous seas of a chaotic partnership reshuffle under the Trump Administration, marked by whirlwind restructurings and austerity cuts to food oversight and research, the lettuce landscape bears the enduring mark of stringent regulations.
This self-governing spirit is vital, Tim York, CEO of the California Leafy Greens Marketing Agreement (CLGMA), asserts, in grappling with the intricate web of the produce supply chain and the inherent safety challenges besetting field-grown produce. This groundbreaking, self-funded coalition quick-steps the FDA's regulatory stride to quash and cope with outbreaks and recalls that trace back to the industry's formative days.
The Skyrocketing Cost of Safety
"The CLGMA is a game-changing effort. Here is a program that the industry knows will be expensive," bemoans Dr. Max Teplitski, chief science officer at the International Fresh Produce Association. "Numerous educational resources," such as scientific analyses, demonstrate the considerable cost of the program: a study reveals that following implementation, growers' expenses for CLGMA compliance virtually doubled, averaging around $21,500 per acre.
CLGMA mandates are specific, quantifiable, and verifiable through third-party audits mandated by California law. These impartial audit inspectors, compensated by the State of California, work diligently to ensure farmers conform to CLGMA's high standards. The State then recoups the expenses via CLGMA member assessments, effectively eliminating conflicts of interests, asserts York.
Romancing the Movies, Wrestling Odds, and Clearing Phone Storage
Produce Safety Ripples Beyond Leafy Greens
Members of the CLGMA who cultivate other crops expand the regulatory dictums to their entire agricultural ventures organically, according to York. LGMA guidelines inform the rest of their food safety practices and blanket their row crop vegetable operations, as industry experts recognize the importance of intraspecific consistency to maintain high-grade food safety standards.
An Economics Study Backs LGMA's Expansive Reach
A USDA Economic Research Services study underscores LGMA's broad influence: businesses tend to apply LGMA standards consistently across their entire production range, preferring uniform practices over divergent ones for different crops.
CLGMA's innovative format is one-of-a-kind, York points out, citing the California Cantaloupe Advisory Board and Florida tomato industry as noteworthy examples of organizations that have similarly implemented member-mandated USDA state inspections and auditing programs.
Guarding Annually Over 55 Billion Servings
California and Arizona-based CLGMA members, along with their sister CLGMA program, control an estimated 98% to 99% of their respective state production (based on USDA census data)—equating to 90% to 94% of the nation's lettuce and leafy greens production. This translates to well over 55 billion servings of greens devoured by U.S. consumers per year, placing the risk of foodborne illness in perspective.
The Statistical Anomaly of Safety
While consumption of lettuce and leafy greens remains safe and robust nationwide, the category has a history of being associated with incidents of foodborne illness, including some high-profile episodes. However, according to York, an isolated case of illness is still concerning: "Even though it's a statistical anomaly or rounding error, we still feel compelled to focus on minimizing incidents." Preventing outbreaks and dealing with their causes is of paramount importance to industry stakeholders.
Small Producers Struggle to Keep Up
York accepts that a small percentage of growers outside the CLGMA remain in the shadows of this stringent food safety framework. According to him, these smaller, independent producers are often unable to adhere to CLGMA's strict criteria due to a lack of resources, primarily due to the scale at which they operate. Although CLGMA ensures that these smaller operations have access to all the necessary information to guide their own decision-making, they cannot implement the same extensive testing and analysis required by the program.
Put simply, "We're in the business of commodities, so when tainted lettuce surfaces, our entire industry is affected,", states York. A 2018 romaine outbreak originating from a non-CLGMA member farm in Santa Barbara County, California, serves as a grim reminder of this shared vulnerability.
Retailers Need to Embrace Higher-Cost CLGMA Products
Robust food safety measures come at a price, and in a low-margin business, buy-in from retailers, food service operators, and other intermediary buyers is crucial to offset the risks. Securing their commitment to purchase exclusively CLGMA-certified products can prove difficult but essential in safeguarding public health.
CLGMA frequently convenes with the Leafy Greens Safety Coalition, which includes major players such as Walmart, Kroger, Costco, Wegmans, Yum! Brands (KFC, Pizza Hut, and Taco Bell), as well as other influential players, such as Sysco and McDonald's. The objective is to forge alignment on food safety standards and policies, with York acknowledging that "We don't always align, but it's an open dialogue to address our concerns and find common ground solutions."
FDA Rules Lack the Precision Required by the Produce Industry
The FDA's responsibility is to establish a broad, nationwide minimum standard applicable to all 50 states. The produce industry, however, requires scientific, risk-based specificity due to the myriad variables, topographical differences, farming systems, weather patterns, and overall unpredictability of outdoor agriculture. Even when the probable cause of an outbreak emerges, solutions may be restricted due to the nuanced and complex nature of open-air farming scenarios.
CLGMA Remains Ahead on Water Quality Initiatives
Faced with the reality of water-borne pathogens potentially tainting produce, CLGMA presses forward on enhancing water standards. In an unprecedented move, the FDA recently rolled out its first registered preharvest water treatment rule for produce. Described by York as a long-awaited development, an earlier version, he explains, had been "so flawed that the industry protested, forcing the FDA to withdraw it and go back to the drawing board." Years ahead of the game, CLGMA has upheld high water standards from the outset, and will refine their metrics further this year, informed by data-driven insights on California and Arizona water systems and farming procedures.
Setting New Safety Benchmarks: The Romaine Pathogen Testing Model
Since its debut in 2023, CLGMA's Romaine Test and Learn data-sharing program has amassed more than 40,000 pre- and post-harvest pathogen tests from 75,000 acres of member farms. Inspired by the FAA Aviation Safety Information Analysis and Sharing Program, whose impact on commercial aviation safety is well-documented, the initiative seeks to create a database of industry-wide testing data that will help in the early detection and prevention of future outbreaks.
According to York, "When the USDA or FDA undertakes an investigation, they typically take 50 samples, which are broken down into 500 subsamples. Talking about the testing requirements around the acreage of romaine in California, you're looking at millions of dollars, considering the low incidence of a problem." The Romaine Test and Learn program's vast data reserves make tracking potential contaminants and isolating the sources of outbreaks significantly more feasible, moving one step closer to safeguarding the U.S. lettuce supply and beyond.
- As costs escalate due to the CLGMA's stringent food safety regulations, many crop cultivators find it challenging to maintain compliance, particularly smaller, independent farmers who lack the resources to meet the program's extensive testing and analysis requirements.
- In the realm of finance, the CLGMA's member assessments not only cover the expenses of third-party audits but also serve to eliminate conflicts of interest by recouping the costs effectively, ensuring a transparent and accountable system for maintaining high-grade food safety standards.