California Leafy Greens Marketing Agreement Emerges as a Model Program for Food Safety
With the implementation of the California Leafy Green Products Handler Marketing Agreement (LGMA), huge strides have been made by farmers, shippers and processors of leafy greens in the area of food safety. This marketing agreement, now just over one year old, represents a unique and unprecedented commitment to protecting public health.
As we are all aware, the E. coli outbreak of September 2006 had significant costs—both economic and human. While the industry suffered a severe economic blow, the human costs were much greater and we will not forget the victims. Those victims are what motivates this industry and their continued commitment to food safety. Although the leafy greens industry has always prioritized food safety, farmers, shippers and processors recognized that more effort was needed to protect public health. The question was how to do it. Several potential solutions were discussed, including regulatory and legislative options at both the state and federal levels. These discussions were broad and included parties from both inside and outside the industry. As these discussions progressed, the leafy greens industry was determined to address the issue in a responsible manner and to do it in a way that would rebuild confidence among consumers, buyers and regulators.
In the end, the decision was made to create the California Leafy Greens Handler Marketing Agreement (now simply referred to as the LGMA). The marketing agreement gave the farmers, shippers and processors of leafy greens a vehicle to protect public health that could be in place in time for the next year’s growing season. This marketing agreement vehicle also provided the industry with the flexibility to quickly change and amend the program based upon sound science and new breakthroughs in food safety research. This flexibility is one of the key benefits of the LGMA structure.
So, how does the LGMA protect public health? Very simply, the LGMA, operating with oversight from the California Department of Food and Agriculture (CDFA), is a mechanism for verifying through mandatory government inspections that farmers of leafy greens follow LGMA-accepted food safety standards. Farmers, shippers and processors, representing over 99% of the volume of leafy greens produced in California, have shown their willingness to follow this set of food safety standards by voluntarily signing onto the LGMA. Once a company joins the LGMA, it becomes mandatory for that member company to sell and ship product only from farmers who comply with the LGMA accepted food safety standards. The audits are conducted by the CDFA inspectors who received special training and certification from the United States Department of Agriculture. Member companies of the LGMA have agreed to tax themselves to collectively pay for the mandatory government audits.
As stated above, the LGMA operates with oversight from the CDFA. The LGMA Board of Directors was appointed by the secretary of the CDFA and all actions of the LGMA and its Board of Directors must be approved by the secretary. The LGMA Board of Directors consists of thirteen industry members, representing all growing regions of California as well as one public member.
The Food Safety Standards
As the LGMA was being created, there was a parallel effort to develop a set of food safety standards. The food safety standards, sometimes referred to as good agricultural practices or metrics, were developed by university and industry scientists and food safety experts along with farmers, shippers and processors. The standards were reviewed by state and federal government health agencies.
The LGMA food safety standards focus on farm practices and cover key risk areas in five main areas:
• General requirements that require all member companies to have a complete food safety compliance plan, an up-to-date grower list and a written traceback program that can identify any potentially affected product quickly.
• Environmental pre-season and preharvest assessments to ensure conditions that can affect food safety, such as animal intrusions, flooding and proximity to animal feeding operations, are not present or have been properly mitigated.
• Water use that requires extensive testing and record keeping for all sources of water used in the production of leafy greens.
• Soil amendments that again require extensive testing, certification and record keeping for all amendments, including compost and fertilizers.
• And worker practices and field observations that verify farmers are in compliance with the program’s requirements in the area of worker safety and field sanitation.
Documentation is at the heart of all of these efforts. Through mandatory government audits, the LGMA structure ensures that all of these standards are being implemented in the field and accurately documented.
The Audit Program
The goal of the LGMA is to protect public health by minimizing potential sources of contamination at fields and farms. The mandatory government audits required by the LGMA are designed to determine whether a member company is in compliance and member companies are audited on a regular and random basis throughout the year.
If an LGMA member company is found to be out of compliance with the food safety standards, that company is issued a citation. Each citation is recorded at one of four levels ranging from a minor infraction to a flagrant violation. The LGMA Compliance Audit Process provides opportunities for member companies to take corrective action on citations that do not pose an immediate threat to food safety and public health. Flagrant violations, which could result in a potentially unsafe product reaching the marketplace, result in decertification from the LGMA program. Decertification has significant sales implications for a company, as grocery stores and restaurants who buy California leafy greens products support the program by only purchasing from companies who have passed the mandatory government audits. Further, both Canada and Mexico will only allow imports of California leafy green products from companies who are members of the LGMA in good standing.
From July 23, 2007 when the audits first began through today, over 500 government audits of LGMA members and farmers have taken place. The audit includes five specific areas of inspection with several "checkpoints" that inspectors must review for compliance. There are 184 checkpoints that government inspectors must verify during an audit.
During the initial six months of the program, mandatory government audits found 400 violations of the LGMA food safety standards. None of these involved unsafe product that reached consumers. Many of the violations were related to documentation and record keeping and all have been corrected.
However, overall compliance with the LGMA food safety standards is really quite high with LGMA member companies in compliance with 99.3% of the checkpoints audited.
We have been very pleased with the efforts of the industry to comply with this unique and rigorous program that has become a model program for farmers in other states. However, even a 1% lack of compliance shows that we must improve, and it is very apparent from what I’ve seen as the public member of the LGMA board that this industry will continue to work diligently to raise the food safety bar even higher.
The Big Picture
The California LGMA is perhaps the most visible part of the industry’s commitment to safety, but it is not the whole story. It’s important to recognize the huge strides the industry has taken to improve food safety in the wake of the 2006 tragedy. In 2007, the LGMA commissioned a survey of its member companies to find out what other steps have been taken to improve food safety systems in order to protect public health.
The survey found that overall spending on food safety practices, already high prior to the outbreak, has tripled since September 2006. Based on the industry survey, LGMA member companies have doubled the number of people employed specifically to work in the area of food safety. Water tests have increased five-fold. The industry has increased buffer zones due to neighboring operations or animal intrusions that, in some cases, have resulted in the loss of productive acreage.
We have also seen the LGMA become a model for other states and industries. The leafy greens industry in Arizona has already adopted its own marketing agreement based on the California model. The tomato industry has established a food safety program using the LGMA model for guidance. There is active discussion of a national program that would bring this approach to the leafy greens industry nationwide.
In addition, the program has received international recognition as well with the LGMA import requirements by both Canada and Mexico.
Consumer Reaction
So, what about our consumers? Does this program increase their confidence in the safety of leafy greens products? The answer is a resounding "yes." In a national consumer survey commissioned by the LGMA, consumers responded very positively to the LGMA food safety program to protect public health. In fact, 85% of consumers reacted favorably when they were told about the food safety programs mandated under the LGMA. Additionally, 70% of consumers said the LGMA food safety program and structure increased their confidence in the safety of leafy green products.
We all know that maintaining vigilance is crucial to the industry’s future. While there is still much work to do, we can now say more than ever that the California leafy greens industry is producing a safe, delicious and nutritious product that consumers can buy with confidence.
E. Scott Horsfall is the Chief Executive Officer of the California Leafy Green Products Handler Marketing Agreement. He can be reached at s.horsfall@comcast.net.