Checking in this morning as I get ready to make the 43 mile trek to the Kansas City airport for a short hop to Chicago…
I’m looking forward to the Midwest Produce Expo that opens today, followed by the U.S. Apple Association Marketing Conference on Thursday and Friday.
As I scan headlines from the web this morning, I see the U.S. Department of Agriculture released a new report on Chilean stone fruit.
While the general perception is that stone fruit is fading in Chile, the report indicates that while growers have been pulling out some blocks of fruit, they have been replanting orchards with greater density and yields.
What’s more, weather conditions seem to favor a bounce-back year for peaches and nectarines. Cherry output has been rising recently, despite disappointments in deliverable volume because of weather events and the fragility of the fruit. In this passage the USDA report details some of the particulars behind the unstoppable cherry push:
The cherry production area continues to expand significantly every year. Industry sources have indicated that during last few years between 1,500 to 2,500 hectares yearly have been planted, totaling almost 18,000 hectares today. Close to 40 percent of the total planted area is still not in production or is in the incremental stage of production. As a result cherry production should increase significantly during the next few years if we have favorable weather patterns. Cherries are one of the few fruits that producers are increasing their planted area significantly in spite of the continued fall of the dollar value against the peso which is hurting the fresh fruit industry in general by increasing production costs which are in pesos and diminishing returns which are in dollars. Producers have expanded the production period by introducing more weather resistant varieties and planting these further south.
The main varieties planted are Bing, Sweet Heart and Santina which together represent over 88 percent of the total cherries exported. Among the main new-planted varieties are Lapins, Van, Stella and Summit. A total of over 70 varieties are planted in Chile.
Although Chile has great potential for cherry production, every year the total output is affected by both climatic factors and/or the extreme delicacy of the fruit. A pre-harvest rain or other adverse weather conditions can damage the delicate skin of the fruit. These factors make the fruit production very expensive, as it requires extreme care and specialized labor. The harvest can only be done by hand; there is no mechanization. Chile has great potential because it is one of the few countries that can produce off season in the southern hemisphere for the large quantity of consumers of the northern hemisphere. Chile has an advantage over other countries like South Africa where there is cheap labor, but average temperatures are too high. New Zealand does not have enough suitable land for cherry production and Australia has water problems. Chile produces 2 percent of total world production but it meets almost 80 percent of the off-season demand.
The amount of time and effort devoted to evaluation of the produce safety rule by individuals and organizations of all types and stripes is staggering, and we are nowhere near the November deadline for comments.
Consider this thoughtful submission from The George Washington University. From the paper's powerhouse conclusion:
FDA’s proposed Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption does not meet statutory and executive requirements, and may needlessly harm consumers as well as small farmers domestically and abroad. First, estimates supporting the rule are based on very limited data and unscientific methods. FDA nevertheless relies on point estimates, rather than presenting a range of likely effects. Second, FDA does not consider unintended side effects associated with higher prices for the fresh commodities covered. Third, even accepting FDA’s analysis at face value, the selected option does not maximize net benefits as required by presidential Executive Orders 12866 and 13563. The recommendations below would address some of these issues in the proposed rule and analysis.
Exempt Farms with Annual Sales less than $100,000
FDA is both authorized by the statute to provide small farms with additional flexibility, and instructed via Executive Order to maximize the net benefits of its rule. The exemption threshold proposed in this rule neither provides small farms with this flexibility nor maximizes net benefits. Based on the agency’s own analysis, exempting all farms smaller than $100,000 would maximize net benefits while also providing additional flexibility for small farms.
Remove ETBS Standards
Because of the relatively high cost and low benefit of the standards for equipment, tools, buildings, and sanitation, FDA should remove these standards from its rulemaking. Despite contributing the least to overall contamination risk, FDA’s proposed standards for equipment, tools, buildings, and sanitation have the highest cost per illness avoided. FDA and farm resources would be better directed toward standards to reduce more tangible risks, such as worker health and hygiene and agricultural water.
Use of Ranges Instead of Point Estimates
Despite very significant uncertainty in both the baseline estimate of risk from foodborne illness and the reductions achievable from implementing the measures proposed in this rule, FDA provides single point estimates of benefits and net benefits. Given the limitations regarding data and methodology used in its baseline estimate and limited information regarding how contamination occurs, FDA should be more transparent about the uncertainty underlying the baseline risk of foodborne illness used in this rule.
Reliance on a single point estimate of the efficacy of this rule implies a degree of certainty FDA does not have, and may misrepresent the benefits of the proposed standards. While it would be preferable for the agency to rely on existing literature and experiments to gauge the likely efficacy of the standards, the available data could be improved by using a range of benefits rather than a point estimate. Using its own survey results, FDA should calculate a range of benefits resulting from reducing foodborne illness by between 42 and 88 percent. This range is more likely to contain within it the actual efficacy of the standards than a single point estimate for efficacy and benefits.
FDA should add language to its final rule committing to measure efficacy at two-year increments following implementation of the rule, measured as percent reductions in foodborne illnesses. This information will tell both the agency and the public how accurate its estimates were, and will provide information for future rulemakings on how to tailor standards to achieve desired outcomes. In addition, retrospective review efforts may be able to provide information on whether the small business exemption was appropriate for maximizing net benefits. If the retrospective reviews indicate that FDA’s standards were ineffective, FDA should consider a rulemaking to change the standards to best reflect the lessons learned.
There is a lot of solid reasoning in these comments by GW, but I can’t believe the suggestion to widen the exemption for the FDA food safety rules will please too many in the industry.