The LGMA standard was not created through a government rule-making process or by state regulators, but requires that compliance with the standard be verified by state and federal audits and inspections under the terms of a federal marketing agreement.10 In the United Kingdom, several pre-regulatory assessments are currently included by public regulators as part of risk-based regulatory frameworks for food safety. These include Red Tractor Assured Produce Scheme, and the BRC Global Food Standard. These pre-regulatory assessments are the product of an industry-level trade union and an industry association respectively, but both are incorporated into the public regulatory process as part of pragmatic risk-based regulation on the part of the United Kingdom’s public regulatory approach, and a desire on the part of UK retailers to demonstrate due diligence as required under the 1990 Food Safety Act .Retailers of fresh leafy greens in both the United States and United Kingdom have responded to outbreaks and public concern with an assortment of non-state regulatory methods to protect the safety of retail foods, best way to dry cannabis while reassuring consumers and protecting brand reputations.
Examples include a variety of retailer-branded food safety standards targeting field-level risk reduction through specific agricultural practices related to hygiene and use of safe farm inputs, including Tesco’s NURTURE standard and the parallel US and European standards managed by the private group GlobalG.A.P. These standards are typically similar to state regulatory controls for food safety, but attempt to exceed the terms of local law by adding additional levels of specificity and broadening the scope of food safety regulation to include additional values such as environmental improvement and labor protections.In the United States, 99% of lettuce consumed is grown domestically, and California produces roughly 75% of the nation’s supply of leafy greens. California’s agricultural industry 1 is one of the most valuable in the world, at US $8.85 billion in 2015, of which 1.96 billion is attributed to lettuce and other leafy greens . Leafy greens are typically grown along California’s central coast where mild weather permits their cultivation during most of the year. During winter months, the neighboring state of Arizona produces much of the nation’s supply, often through the same management companies and contractual grower networks that source from California during the rest of the year. When landholdings are held by one corporation in both areas, upper level staff and harvest crews move to Arizona for the winter articulation of the supply chain, in order to continue producing without weather-related interruptions. As with much of California agriculture, California’s leafy greens farmers for the most part tend to operate either relatively small farms, or very large farms, with fewer farms operating at middle scales .
This is in part due to the legacy of California’s historical agricultural development, in which agriculture was from its inception focused on large-scale for-profit production. Many smaller farms exist today in part because of the alternative agriculture movement that has been active in California since the 1970s, but the central coast area is known as “the nation’s salad bowl” because of the very large corporately-owned farms that dominate the agricultural market of the state and operate on an industrial scale using hired labor . Lettuces are most often harvested by machine, and harvested products typically go from the farm to a processing center where they are washed,together with other similar products, and then enter the retail supply chain or the wholesale market for shipment out of state. The UK lettuce industry is considerably smaller than the California lettuce industry, affecting many aspects of the supply chain that will be considered in the remainder of this chapter and Chapter 4. Lettuce cultivation in the United Kingdom also works slightly differently, and some of these differences will be explored in greater detail in my Industry Level results later in this chapter and explained in Figures 3.4 and 3.5. The UK fresh vegetable industry was estimated at a value of $2.12 billion in 2016 , of which 203 million comes from the cultivation of lettuces and other leafy greens. In the UK, climate allows leafy greens to be produced across much of the area of England and Scotland throughout the warmer months of the year, while wintertime leafy greens supply most often comes from Spain, Italy and the Netherlands.
Compared to California, farm sizes are distributed more equally between size categories, with an emphasis on smaller farms. Some UK leafy greens farmers have responded to economic pressures of market competition by banding together into grower associations, in which family-owned and -operated farms continue to produce goods but do so in mutual association in order to benefit from centralized marketing efforts and collective economic of scale.Data for foodborne illness always contain some degree of uncertainty due to the post-hoc nature of outbreak data collection. Many incidents of intestinal disease go unreported. For those that are reported, it is not always possible for monitoring authorities to be entirely certain which pathogen was responsible, whether it came from food or another source, and which food vehicle among many was ultimately at fault. Reports are sometimes missing data, and personal information from infected individuals can contain omissions, mistakes, or recall bias. When food vectors can be identified and a pathogen confirmed, there is often still some degree of uncertainty over whether the pathogen originated on the food itself or was introduced from elsewhere via contact with other people or surfaces during handling and preparation. In some cases, more than one pathogen is implicated, or more than one food type is the likely source. Estimates of overall disease burden contain additional uncertainty because they must be extrapolated from observed reports of illness by adjusting for expected reporting rates. While individual point estimates contain these and other known and expected sources of uncertainty, it is possible to examine overall aggregate trends. In 2014, the UK’s Food Standards Agency released the results of an in-depth national study of the domestic burden of infectious intestinal disease . From roughly 500,000 cases of food-related intestinal disease observed over a one-year period from mid-2011 to 2012, the researchers identified the share of disease burden belonging to 19 pathogens, across 12 food commodity vectors. This FSA-funded study represents the best effort so far to reduce uncertainties using information from a meta-analysis of other disease source identification studies from nations broadly comparable to the UK in terms of general population health and public health monitoring systems, mathematical modelling, and expert consultation. According to these health statistics, the food class responsible for the biggest proportion of foodborne illness in the UK is poultry, at over 50% of illnesses. Red meats and produce are next most associated with illness, at much lower rates. The pathogens responsible for most hospitalizations and visits to physicians are Campylobacter, Salmonella, and E.coli . Previous large-scale analysis of public health data and research had placed the UK incidence of foodborne intestinal disease at nearly 2.5 million cases annually in 1992 and just over 1 million cases annually in 2000, showing an overall trend of improvement in public health outcomes which this latest study continues. In the US, how to cure cannabis it is estimated that risks from produce have been rising over the last several decades, increasing from 1% during the 1970s to as much as 12% during the 1990s . A large scale study of foodborne pathogenic illness from 1998 to 2008 found that 46% of foodborne illness during this time period was attributable to produce and especially to leafy vegetables, followed at 22% by red meat and poultry . These increases most likely represent a combination of factors including but perhaps not limited to increased produce consumption, more prevalent aggregation and processing steps, and changes in pathogen presence around livestock operations that may contaminate nearby produce . The most recent national US public health records maintained by the Center for Disease Control still implicate plant foods in 9.4 million reported cases of intestinal illness yearly, from which extrapolative estimates place the total actual number of foodborne illnesses at 47.8 million cases per year . Norovirus is credited with causing the largest number of illnesses and deaths in the US each year, while Salmonella, Campylobacter, Toxoplasma and Listeria are responsible for the largest numbers of hospitalizations and deaths. The United States Food and Drug Administration undertook an analysis of CDC outbreak data from 1996 to 2010, yielding 131 outbreaks from fresh produce in which it appeared likely that contamination had specifically occurred during growing, harvesting, manufacturing, processing, packing, holding and transportation of foods .
This research drove the establishment in 2011 of new national legislation instituting stronger preventive controls for food safety during primary production. Comparison suggests that population-adjusted foodborne illness rates as of 2000 were as much as 11 times higher in the US compared to the UK, although data interpretation uncertainties were noted from the difficulty of source identification, and national differences in reporting rates and disease severity may reduce the gap in overall foodborne illness burden . Notably, the food sources associated with illness in the UK are meats and poultry, while in the US plant foods are the highest source of risk, especially leafy vegetables.Research has offered somewhat mixed results so far as to whether standards instituted by private commercial entities can in fact create real change in the behaviors of their agricultural product suppliers. A study of food safety standards in UK, Canada and Australia concluded that the initial reasons for adoption of food safety standards—whether crisis-driven in response to outbreaks of pathogenic disease as in UK, or prevention-driven as tools for avoiding trade disputes as in Canada and Australia—significantly shaped the type of private and/or public solutions sought . A recent study of sustainable practices among produce and flower suppliers in South Africa concluded that one specific company-led eco-standard successfully created measurable improvements in environmental practice among suppliers . More such evaluations are needed, tracing the impacts of standards at state and private level, and their potential to drive change in social and ecological outcomes. Additionally, the challenge presented by overlapping and sometimes conflicting sets of requirements at state and private level has been noted by many scholars , yet efforts to harmonize this landscape of standards have not made significant progress. The presence of multiple private standards in one marketplace may act to fragment regulation of markets and further undermine harmonization efforts by creating additional parallel sets of prescriptive expectations . In the early 2000s, the Global Food Safety Initiative bench marking scheme sought to advance harmonization efforts by determining equivalency between standards and allowing existing diverse standards to be accepted as common currency in global marketplaces . Few studies have yet addressed the cumulative impact on farmers of following many overlapping food safety requirements from both state and non-state level, and the impact of bench marking efforts . Research is needed to explore relationships between private standards, the perceived pressures and constraints they generate for farmers, and resulting changes in land management decisions . I sought to illuminate this area of research and international environmental governance scholarship through my comparative case. At the conclusion of the previous chapter, I explored the network of state, non-state and hybrid food safety controls currently active for fresh produce grown in California and the United Kingdom. Table 2.2 provided a complete overview of food safety standards active in US and UK lettuce production. For my comparative study I will examine a subset of these standards, as listed in Table 3.2 below. Some standards imposed by retail or food service buyers of leafy greens products take the form of internal risk assessments that are used by the retailer or food service outlet as a barrier to entry for riskier suppliers, but which do not constitute full standalone produce production standards that seek to shape farmers’ practices. Such standards often require that prospective suppliers obtain produce safety certification from one or more external private standards operating at the national or international level before seeking to become a supplier. In order to contribute to scholarly efforts to analyze private standards separately from these sorts of risk assessments, instruments such as these were not considered in my analysis. My analysis rests instead on an examination of the full standalone standards most often referenced by these risk assessment tools as pre-requisites for initiating a supplier relationship.