NLGMA Comments — Bob Jones Jr.

Bob Jones Jr., Co-owner
The Chef's Garden
150-acre farm
Huron, OH

As a grower of leafy greens, I am very leery of what exactly the intent of the NLGMA proponent group is. First of all, I understand very well the necessity of having a robust food safety program at the grower level and what that means to the confidence of the marketplace and the value that brings to all of us in the leafy greens industry. The NLGMA proposal was written very strategically by Western Growers and its legal team and I am unable to gain from reading it whether it is truly a food safety document or a marketing plan. The California agreement was extremely successful and did exactly what I believe was intended in gaining public trust at a very vulnerable time for the Western Growers Association. However, I do not understand how extending this to a national effort benefits anyone except those same WGA growers. For these and other reasons, I am not in favor of the NLGMA.

The proposed NLGMA will have a very dramatic effect on our family farm here in Ohio. We are now and have been for years, third-party audited and continue to look for ways to improve on both the quality and safety of the products we grow and sell. The metrics in the CLGMA, which are the assumed metrics of the NLGMA as they chose not to include those in the proposal to the USDA, are written by and for the cultural practices, climate and size of the large western-style growers.

Those metrics do not consider nor will they work for those outside of that growing region. I cannot begin to determine, based on my personal experiences, what good food safety metrics should look like for growers of leafy greens in Florida or Wisconsin much less California or Arizona. My contention is that those folks probably can't determine what will work best for me either.

The cost of instituting standards that have not proven effective for any particular growing area, are based on assumptions or unproven/disproven science, will, in the best case scenario, not have a positive effect on the safety of the product and in the worst case scenario will put many growers out of business because they simply cannot comply with these costly requirements. Developing standards or metrics on a state by state basis is the only way to have truly effective and sustainable benefit to the industry and to the consuming public.

My opinion is that if passed the NLGMA will negatively affect the industry as a whole -- and that includes the local food movement in this country. The American consumer is demanding that they know where their food is coming from and how it is being grown. They want to know the name of the person who harvested the greens in their salad! And they want to know that that person is doing everything that they can to protect them and their families. Consumers today are far too savvy to be duped by this type of a marketing ploy. They already know that the problem of food safety does not exist on the farm. The consumers know that lettuce grows in the ground and that there are inherent risks in eating anything that grows in the ground, they also know that when you harvest lettuce and greens in massive volumes, mix those greens with those from dozens of farms together, put it in a plastic bag and expect it to sit on a shelf for two to three weeks that it may not taste the best or even be good for you! Today's consumer is a very well informed and very intelligent consumer, to expect them to accept that a smoothly written marketing plan can overcome good common sense is not smart nor does it show respect for the very people who buy our products.