Traceability to production source is strongly emphasized by EU food hygiene rules articulated at the member state level by UK public health agencies. British produce packaging typically carries clearly visible supplier codes that link each product to its original field and farmer, sometimes including the name of the farm or even farm owner on the back of the package. American packaging does not always contain supplier codes or any specific information on source, beyond regional descriptors of geographic origin. Common leafy greens supply chain practices such as aggregation of many producers’ fresh harvests during washing and processing mean that in some cases contaminated products cannot be tracked, and the feasibility of tracing backward from produce outbreaks differs enormously even from one leafy greens product to another . In another supply chain difference potentially related to traceability, UK fresh produce consumed within national borders does not typically travel as far geographically between harvest and final sale as CA agricultural products, many of which reach their final retail points of sale in the far corners of the United States. This can further complicate tracing efforts in the event of food safety crises, vertical farming pros and cons and long storage intervals may contribute to a higher potential for foodborne illnesses to develop and persist in shipped goods . Scholars in both the US and UK have used the transdisciplinary concept of ‘food miles’ as a way to think about the food system’s capacity to deliver desired social goods including food safety and environmental protection .
Invisible structural processes such as long supply chains that distance consumers from the sources of food production also disempower them from considering potential sources of risks. Although measuring and representing food miles meaningfully presents many challenges , food miles as a concept can make visible “missing objects” such as the length of fresh produce supply chains, allowing them to be considered as contributors to observed outcomes and part of social interventions proposed to solve market failures .Consumers in the UK and the US also each have a different culturally-constructed awareness of food safety risks, owing to different histories of food safety failures and regulatory responses in each location. Scholars have noted for many years that US consumers and regulators, in comparison with Europeans, seem to be more worried and anxious about a variety of food risks including inadequate nutrition, foodborne pathogens, harmful macro-nutrient profiles, carcinogens, and spoilage . European consumers and regulators have, by contrast, tended to be more cautious in the face of technological threats such as genetically modified organisms. These and other background framings of safety and risk in turn shape how regulators, retailers, and farmers think about what should be controlled, and how consumers think about the risks they may face. One difference that emerged during my interviews was the differential weight placed by UK regulators and retailers on farm-to-fork supply chain management. Yet another place where the impact of the BSE crisis on the development of UK food safety responses can be felt, the UK’s longstanding official focus on farm-to-fork supply chain management at both public and private level creates a system in which the expectation is that field level practices are receiving special regulatory oversight and must be kept under control.
In the US, the focus on farm to fork food safety regulation for fresh produce has come somewhat later, and is fully articulated only by the recent FSMA language. Other differences in how food safety is thought about and framed by various supply chain actors in the UK and in the US most likely stem from the influence of EU consumer protection priorities on UK food safety response. Pesticide use and regulation are very high on the radar for European Union member countries, and farmers and regulators are very aware of the many complex limitations that the EU-coordinated pesticide regulatory system places on them. In my interviews, UK standards and UK farmers I spoke with gave equal or greater priority to chemical safety in comparison with foodborne pathogen safety. During my UK field research, the phrase “food safety risks in fresh vegetables” was most often interpreted by both laypeople and members of industry or government as being a question of pesticide residues, until I offered additional specifics and turned the conversation to pathogenic foodborne illness. By contrast, California farmers, standards, and regulators seemed readily accustomed to separating pathogens from chemical residues, and considered pathogens to be higher priority. In CA, the phrase “food safety risk in fresh vegetables” was most commonly interpreted as having to do with foodborne pathogens that make people sick, rather than as a question of chemical residues or other hazards. Both concerns exist and are subjects of regulation in both locations, but the differences in discourse between CA and UK stakeholders in the lettuce industry show that different locally constructed meanings are contributing to different regional framings of food safety. In another difference over framings of what constitutes appropriate priorities for food safety, my interviews revealed a curious transatlantic bifurcation over the issue of what constitutes clean produce, or dirty produce. In CA, pre-washed lettuce products are seen as 5 cleaner and safer, and washing of leafy greens is a standard step in processing. In the UK, washing of leafy greens is also a common processing step, but a noticeable percentage of the UK consumer market views pre-washed lettuce as potentially more contaminated and less fresh than lettuce that has not been cleaned prior to sale. California lettuce farmers expressed to me that washing in anti-bacterially sanitized water was expected as a minimum level of safety assurance for the US market.
The microbiological safety of wash water is typically controlled through disinfectants, added according to prescriptive safety rules that effectively bring microbial risk in wash water below the threshold permitted even in municipal drinking water. One California food safety manager at a leafy greens farm noted to me that this requirement for the disinfection of leafy greens made little sense to her, because the toxic disinfectant has to then be rinsed off with pure water that is technically dirtier from a microbiological standpoint than the initial rinse. By contrast, in my UK interviews, air racking farmers noted that some customers increasingly view unwashed produce as having a higher guarantee of food safety than produce that has been washed and bagged before sale. UK farmers aware of this alternate view of safety made comments like “if we washed it, they’d wonder what happened to it that we wanted to hide” and “unwashed rocket goes for twice the price of washed now because consumers think it’s safer if no one has interfered with it.” Although exploring and testing each of these attitudes in depth was beyond the scope of this dissertation, it was clear during my field work that differences in societal expectations of food safety could provide important context for my findings. The language in which food safety is couched and the priorities seen as important in each location have bearing on the overall discursive climate surrounding food safety, potentially shaping or constraining the actions of those who seek to solve produce safety problems.Similarly, and not at all unexpectedly, I also noticed a systematic difference between the two nations in how my interviewees described the growing environment in our conversations. Differences in word choice painted a picture of the environment as helpful, or as dangerous and risky. Not every person I spoke with in each location exhibited the same linguistic choices, but a general trend did develop. On the whole, regulators in each location seemed to share similar framings in which the value of the environment was central, while farmers I spoke with in CA showed a much greater focus on the environment as a source of risk. My expectation is that this difference stems from what my interviewees reported as the preferential framing of food safety risks as problems generated by wildlife, as articulated in CA private food safety standards and retail buyer communications.
CA regulators took a fairly balanced approach to the topic, starting from a position of protecting economic concerns and moving between environmental considerations and public health goals when approaching food safety as a topic. Interviewees in state level agencies spoke to me many times of the tide of anti-environment sentiment they saw among farmers of leafy greens and other fresh produce in the wake of outbreaks and private requirements to protect crops from animal incursion. One individual who had been involved in transmitting food safety messaging at the state level and had some experience with assisting farmers to incorporate specific pro-environment land management practices into their operations told me that he was seeing “a reversal of several decades of conservation work” because of new food safety fears. In his view, it had been a long slog getting farmers to abandon the worst herbicides and pesticides and become comfortable with allowing sustainability practices that helped them comply with e.g. official water filtration requirements. Food safety pressure from buyers had brought back those anxieties for farmers, bringing with them the desire to fight and control the wild environment. Both regulators and farmers in CA reported to me that the farming community was worried about nature threatening their operations. Another CA interviewee from the policy side put it succinctly when he summed up the change in discourse by saying “nowadays, you don’t want to be encouraging [presence of wildlife], you want to be discouraging.” UK regulators evinced a similar focus on the economics of agriculture and food production, followed by acknowledgement of public health alongside sustainability concerns. But instead of signaling that they had experience with farmers who were preoccupied with food safety to the determent of environment, they unanimously agreed that farmers in the UK would not think of the safety and environmental matters as separate. Rather, they indicated that farmers thought of all of it in hybrid terms, considering the environment in the same breath as economic or public health concerns. Conversations with regulators invariably shifted to discussions of the EU Common Agricultural Policy which permits farmers to receive financial benefits for environmental protection practices and sustainable land stewardship efforts. As a result of this official focus and, for some, solid revenue stream for portions of their land not exploited for intensive agricultural production, a broad-based environmental awareness was quicker on the lips for the UK farming community. Farmers I spoke with echoed this different starting point, often seeming surprised that I chose to separate my questions into two sections, one for food safety and one for environmental conservation. Many of them specifically indicated to me that “those are really the same, no?” and explained in various terms that food safety was a natural result in their minds of a healthy farming environment and local biodiversity. One interviewee from a trade association who had long experience with UK farmers and some exposure to views from American farming groups via conferences in the US said to me pithily “over here we talk about how to maintain biodiversity and beneficial insects, whereas my American colleagues are much more of the opinion that they should kill everything.” A deep accounting of contemporary environmental thought as seen in leafy greens production was not my goal with this study, but this difference did emerge as commentary on a deeper divergence in environmental framings among farmers and supply chain actors that could contribute to broad differences in food safety perspectives surrounding leafy greens.Owing to different histories of agricultural development, UK interviewees I spoke with placed a different value and importance on the visual appearance of farms than did my CA interviewees. The function of farms as visually pleasing parts of the pastoral landscape in the UK seems to be an important background framing for food safety management decisions. Several UK farmers I spoke with indicated that some things they might otherwise do to manage food safety on their farms would not be feasible in their current locations simply because of the impacts they would have on the farm’s outward appearance for passersby. These farmers perceived conflicts between what risk management might indicate as the safest route, and what the broader local community would visually allow. Prohibited practices in this vein included fencing of field margins, removal of trees, clearing of bare ground buffer strips between fields and unmanaged lands or field divisions, and building of extensive glasshouses and poly tunnels to protect sensitive crops from environmental uncertainty and animal incursion.