NLGMA Comments — Joe Pezzini

Joe Pezzini
Chief Operating Officer,
Ocean Mist Farms
21,800-acre farm
Castroville, CA

I am in favor of a national leafy greens agreement. Three things we learned from the 2006 spinach illness outbreak are that 1) consumer health and safety is paramount - without confidence in our products we are out of business. 2) As seen by the FDA's "Do Not Eat Spinach" consumer advisory in 2006, all producers are attached at the hip. If one farm or company has a problem, it can and will affect all our businesses. In the case of the spinach outbreak regardless of where you were growing spinach, New York to California, we were all out of business. Finally, 3) while voluntary guidelines are good, they are only suggested best practices without validation of compliance. Specific, measureable and verifiable standards are the only way to determine compliance.

So for these three reasons I feel a national marketing agreement will benefit the industry. As this process goes forward with the USDA, a parallel legislative approach is winding its way through Congress. The House has already passed their version of food safety reform and the Senate is now in deliberation. While we do not know for certain what will be the outcome of legislation, the FDA has already gone on record to say they will create commodity specific guidance that they expect to become regulation in two years. I believe the best vehicle for verifying FDA regulation could be the national leafy greens marketing agreement.

At this time we are not sure how it might impact our operation. As most all leafy greens producers in California and Arizona are already a part of a rigorous state program, my guess is that it would not greatly change what we are already doing for food safety. However, no one knows what the standards will be as they are not yet created or adopted by a national program. Therefore like everyone we will have to wait and see where the USDA process leads.

If you read the proposed program language submitted to the USDA there is a prescribed method of review for standards by a Technical Committee made up of land grant university academics, FDA representatives and others. My belief is they will look at the body of research and data on best practices that now exists and come up with standards aligned with the FDA commodity specific guidelines with geographic and regional considerations for unique growing conditions.

I think in the long run this will standardize what we are all doing for food safety. It will eventually lead to one standard food safety audit instead of the multiple audits we are now subject to. In addition the proposed national marketing agreement will cover imported leafy greens. This will level the playing field for all domestic producers with import producers, but most importantly it will give the consumer confidence in all leafy greens in the marketplace regardless of whether it is from a local producer or product from outside the country.

Ultimately our reputations and livelihoods depend on our ability to produce and deliver safe and wholesome produce. Most importantly producing safe food is for the safety of our consumers, because after all, this is the same food we feed our family.