Can food safety go green? A discussion in three scenes.Scene I: Food Safety Summit at NEHA's Annual Educational Conference
1:00 p.m., June 22, 2009
The room is packed. The panelists are, on the regulatory side, Aggie Hale, environmental administrator for the Division of Food Safety at the Florida Department of Agriculture and Consumer Services, and Jeannine Ertter, consumer affairs specialist with the Food and Drug Administration's (FDAs) Center for Food Safety and Nutrition. Industry is represented by Steven Grover, vice president of cost and product management for the Steak 'n Shake Company; Gary Cohen, a food-packaging expert from Unisource Worldwide; and Zia Siddiqi, director of quality systems for Orkin, Inc. Providing perspectives from academia are Emmanuel Iyiegbuniwe, associate professor of environmental health science at Western Kentucky University, and moderator Dave McSwane, professor and interim associate dean at the School of Public and Environmental Affairs, Indiana University.
Title of the discussion: "It Isn't Easy Being Green."
Industry Offers Some Solutions
Easy or not, the issue of sustainability in food safety has to be faced. All parties, government and private-sector--agreed on that. Public interest in the issue is strong and widespread.
"People want to eat in a restaurant that is environmentally correct," Cohen said. "They want to know that the air they're breathing has met certain standards."
Siddiqi confirmed that a lot of the food suppliers and retail establishments Orkin works with are concerned about impacts on the environment.
"The days of going in and bombing the place are over," he commented. His company aims for minimum possible use of pesticides and turns first to the least toxic chemicals. Many food-grade materials are now available. But he added a caveat: If an operator waits until a major pest problem is apparent, "there's not much green we can do." The integrated pest management (IPM) approach is key here. Good housekeeping, building maintenance, and sanitation may not be glamorous, but they form the "backbone" of sustainable pest control.
Moderator David McSwane asked about opportunities and challenges posed by the U.S. Green Building Council's (USGBC's) Leadership in Energy and Environmental Design (LEED) certification system. LEED uses third-party verification to certify building and community designs as green. The assessments use the following metrics: energy savings, water efficiency, CO Z emissions reduction, indoor environmental quality, stewardship of resources, and sensitivity to impacts.
Cohen noted a new development, "LEED for Retail," part of which focuses on commercial interiors. USGBC has been working with over 80 retail pilot projects to design these new programs. (For a sense of what the programs will involve and a checklist of what retail establishments can do to earn certification, visit www. usgbc. org/DisplayPage.aspx?CMSPageID=1734.)
"If I owned a restaurant and was looking for a competitive edge," Cohen said, "I would definitely be looking at what LEED for Retail is, because it will put a kind of good housekeeping mark on it."
Aren't Dollars Green Too?
Evident from Steven Grover's comments was the role that the financial bottom line can play in promoting green behaviors-as well as the challenges and limitations it may pose. For a sustainability practice to itself be sustainable, he said, it has to meet four criteria. It has to be profitable, it has to be executable, it has to be safe, and it has to be effective.
"I don't know a restaurant that doesn't recycle its grease," he said. "And the reason they do it is people pay them for it. They make money on it." (The grease gets used in biodiesel fuels and cosmetics.) Most restaurants also make an effort to conserve energy because "it's good for the bottom line." But, he said, "when you get to composting and sourcing locally, I pose a question. l have a 500-restaurant-unit chain. We use 17 million pounds of ground beef a year. If I tried to source that locally, I'd need an army of auditors to be able to audit those plants. It's not profitable, it's not executable, it's not safe, and it's not effective...."
Today most chains take a farm-to-table approach, he explained. Steak 'n Shake audits not only for food safety, but also for sustainability. It audits pesticide use, and it requires suppliers to have a plan and meet milestones, thus increasing sustainability practices every year. This system represents a change from 10 or 15 years ago, when most restaurant chains bought from middlemen and most had no knowledge of the farms their food came from. The market is pushing his industry towards sustainable practices, and he sees no need for regulatory intervention on this issue.
But can mass production ever be green? Yes, he argued, "because we work very closely with our suppliers to make sure that they are using sustainable agricultural practices."
In response to a question from the audience, he added a point of clarification. The tightly controlled mass system that supplies retail chains should not be confused with the system that supplies food directly to consumers. Much of the food that consumers buy is not audited, he said.
Meanwhile, Back at the Agencies
On the regulatory side, the strength of public interest is also being felt. But the panelists from the public sector did not express quite so much certainty that the institutions they represent are adequately engaging the issue. Aggie Hale of the Florida Department of Agriculture commented that her agency frequently gets calls from "grassroots people" wanting to "do something" and that "at this time we don't have the answers. We don't have the communication within our own agencies, which is unfortunate."
She thinks the regulatory agencies need to get together and start purposefully working on these issues--because, she added: "they [these issues] are not going to go away. People are going to keep calling us and asking."
Hale and Ertter both commented that terminology is a problem. No one really knows what anyone else means by the words "green" and "sustainable." Hale also noted that "cost" is another ambiguous term: "Are we just counting pennies?" she asked. "Will you go to that store because that product was made cheaper, regardless of what they did to the environment?"
The Hardest Question
What, moderator McSwane wondered, about areas in which food safety and sustainability goals appear to conflict? He cited water usage issues and the need for high temperatures in dishwashing machines to ensure food safety. "How do we find common ground?" he asked.
Grover's answer: communication. It helps if all parties understand each other's goals and objectives, then build on the areas where there's broad agreement. Maybe, he suggested, "tackle some of those other more contentious issues down the road."
Iyiegbuniwe, however, argued that while communication is good, he also sees a need for government agencies like FDA and USDA to become more involved in a regulatory capacity.
Scene II: Communication Comes to California
Location: The Central Coast
This region supplies the majority of salad greens consumed in the United States. But it also has delicate ecosystems, including the Monterey Bay Marine Sanctuary. Water pollution has been a concern for decades. In response, California has developed a nonpoint-source program run through the Central Coast Regional Water Quality Control Board. So far the program has relied on education and incentives for growers to adopt practices that are easier on the environment (including the use of vegetation buffers around fields). The water board has made a significant financial investment in this approach, according to Diane Stuart, who recently completed her doctorate in environmental studies at the University of California-Santa Cruz and whose work focuses on the intersection of food safety and environmental issues in the region.
In the wake of outbreaks associated with produce--especially the spinach-associated E. coli outbreak of 2006 and the pepper-associated Salmonella Saintpaul outbreak of 2008--the growers have been subject to another set of pressures. Some retail companies and distributors have been demanding that their suppliers take draconian measures to ensure that fields are not contaminated. Growers have been asked to increase the size of bare-ground buffers around fields, to remove habitat, to kill wildlife--to take a number of steps that could be damaging to the environment in general and water quality in particular.
"Putting copper sulfate in ponds to get rid of amphibians is pretty common," Stuart said. "And using poison bait for small mammals."
Only small growers and organic growers seem to have avoided these strictures, she said.
Waiting for the Science--But Maybe Not with Bated Breath
The dilemma stems in part from a lack of solid information. Are wildlife even a significant vector for the pathogens E. coli 0157:H7 and Salmonella? Studies from other regions have shown the rates at which wildlife carry these pathogens to be very low Is that also the case in the California Central Coast region? Studies are now under way.
Consensus also has not been reached about other practices thought to enhance food safety. Some studies, Stuart pointed out, have indicated that widespread removal of vegetation could increase the chance of pathogens moving over the landscape. In the absence of clear-cut knowledge, she believes a fear of litigation is driving many of the more scorched-earth policies. At the same time, the various parties to the issue have been reaching for as much peer-reviewed information as they can find to support their positions. (For a taste of the research, see the sidebar above.)
So it's not clear that if science does reach solid conclusions, that will resolve the problem. If, for instance, deer turn out to be a vector for foodborne pathogens, Stuart suspects that environmentalists will still want to protect them. And if they turn out not to be a vector, she suspects that the food industry will still want to keep them out of fields.
"Science can inform decision making," she said, "but it doesn't make it black and white." Fundamental questions of values are at stake.
From "Conflict" to "Co-Management"?
Stuart has been involved in supplying information for mediation efforts. A number of groups have participated in the discussions, including the Wild Farm Alliance and the Nature Conservancy, as well as organizations focused on protecting small farmers. On the other side of the issue are large growers' associations, industry leaders, and large private companies who are in a position to set standards for growers.
The latter group represent a new set of interlocutors for those concerned with water quality in the area. "Everyone's sort of realizing that people interested in conservation and water quality have to talk to these industry groups rather than the farmers," Stuart observed.
Those facilitating these discussions have tried to avoid the word "conflict." The preferred term is "co-management." What would co-management look like? Stuart said it would, first of all, involve educating both food safety auditors and those doing environmental-quality work to be cognizant of each others' issues as they develop solutions.
For instance: Vegetation buffers might be specifically designed to reduce pathogens. Constructed wetlands are already used in wastewater applications and have been shown to significantly reduce pathogens in water that moves through them. Why not use them instead of bare-ground buffers around fields? Grass buffers might be another possibility, she said. Those too have been shown to reduce movement of pathogens.
The process of finding a solution that works for all parties will be a long one, she believes. But she ended on an optimistic note. The environmental groups and government agencies have spent decades building trust with growers. That model has informed their approach to the current problem.
"Instead of being combative, people are trying to work together. People are talking."
Scene III: The National Park Service Models Co-Management
Escaping the Zero-Risk Trap
Back in 1970, the U.S. Public Health Service (PHS) lost many of its environment-related functions to the newly formed U.S. Environmental Protection Agency. That was because the public health community was not sufficiently addressing environmental issues, according to CAPT Chuck Higgins. As a member of the PHS Commissioned Corps, Higgins has had assignments at CDC and FDA over the course of his career. Currently he directs the Office of Public Health for the National Park Service.
Sometimes, he added, public health was even hostile to environmental issues.
"It was that whole psychology of conquering nature," he said. "A lot of our public health interventions have reflected that. If we've got bird flu--well, kill the birds. We protect human health to the detriment of something else. It's a win-lose situation."
Part of the problem is that food safety messaging from federal agencies has sometimes inadvertently implied a zero-risk approach. Fears of liability, too, have tended to escalate toward the expectation of zero risk. And that is an expectation that cannot be met, he said, "unless you're going to put everyone in a bubble and sterilize it."
The goal should be to reduce risk, not to bring it to zero.
In the long term, that saner approach may also be the healthier one since it's in the interests of human health to have healthy ecosystems as well as healthy agricultural animals.
Lessons Learned from West Nile Virus
At the National Park Service, the public health mission is embedded within another mission--the preservation of the nation's natural, cultural, and historical heritage. As a result, NPS's Office of Public Health has to deal with traditional human health issues in "some unique ways," Higgins said.
In the case of the West Nile virus, a lot of local health departments responded to the arrival of the virus in a traditional way--by spraying for mosquitoes or larviciding. But in the National Park System, all native species are protected. That includes mosquitoes. The pathogens themselves may be protected, if they are native. (West Nile virus is not.)
In extreme cases, the Office of Public Health does have the authority to declare a public health emergency, which would then trump the preservation mission.
"But we try to use that very sparingly," Higgins said, "because most of the time it's truly not necessary."
So Higgins' office looked for ways to promote a healthy ecosystem that would minimize transmission of the West Nile virus in the first place. If one species of mosquito dominates an ecosystem, the risk of transmission is greater than if, as in a healthy ecosystem, several species thrive. That's because the species that are more effective vectors will face competition from others. NPS also has found that a simple and effective intervention is to teach park visitors how to protect themselves with clothing and repellants. Parks in swampy areas opened an hour later in the morning or closed earlier in the evening when the species in question were most likely to feed.
Higgins acknowledged that a local health department can't close an entire city down at seven in the evening. The challenge would be to translate the NPS approach into other settings. And yes, in the short term, it might be cheaper just to spray--to take what Higgins called the "just-say-no approach"--at least if, as Aggie Hale put it at NEHAs Food Safety Summit, "cost" is measured only by "counting pennies." In the long run, Higgins thinks the best way to address health threats is to unify disease surveillance, research, and management activities for animals, humans, and the environment. He recommended the One Health Initiative as a source for ideas along these lines. (See www.onehealthinitiative.com/about.php.)
But is it always possible to reconcile the health of humans, animals, and the environment?
A solution is always possible, he said. With the right research, it's always possible to come up with ecologically sound public health interventions. "It just depends which choices you make."
And that does come down to values. To what extent are we willing to spend current pennies on future goods? To what extent will we weight long-term public and environmental well-being against (monetarily) cheaper short-term fixes?
What the NPS Approach Means for Food
Again, NPS has some advantages. Commercial food service establishments can operate on park grounds only with the permission of the agency. As part of their contract, they are required to follow the mission and management policies of NPS. In an interesting echo of Steven Grover's comments, Higgins noted: "We very much decide how they will operate."
Some conflicts--"or better to say perceived conflicts," he said-have arisen. In asking park concessions to be environmentally friendly by obtaining produce locally, the park staff found themselves at odds with a basic tenet of food safety: The food should come from an inspected source. Here was a dilemma.
Well, asked Higgins, what is the purpose of getting food from an inspected source? It's to ensure that the food is being produced according to FDAs good agricultural practices. So NPS looks for ways to verify locally that the sources met those standards. Sometimes that means educating local suppliers about good agricultural practices and requiring them to provide NPS with a self-certified statement that they are following those practices. Sometimes it means enlisting a state or local health department to verify compliance. Sometimes it means that NPS staff or a park concession do the verifying.
"I think you can find ways to meet the intent of the Food Code without a scorched--earth policy," he said. But again, one has to understand the goal-reduced risk, not zero risk.
"The focus needs to be on the outcome. When environmental health comes into conflict with environmental goals, it's because we're focused on the wrong things. We're essentially focused on making sure that the inspection forms are marked correctly"
What About That Resource Problem?
Long-term health and long-term costs can seem like abstractions, especially in the current economic climate. How are local health departments supposed to even think about this while their budgets (the ones measured in pennies) are being slashed in the here and now?
Higgins suggested tapping into the energy and enthusiasm of natural allies. Kitchen gardens, for instance, have become a "green" trend among restaurants. To ensure that the produce is raised safely, local health departments really ought to be educating operators in safe gardening. And who has the staff for that?
"If I'm the Denver health department," he said, "why not get the, say Denver garden club involved in helping me help restaurants? Teach them how to teach others how to grow things safely. They probably would love to run around town helping people with that."
Another example: NPS has on staff a large group of dedicated and enthusiastic interpretive rangers. A few years ago, the agency decided to harness that energy to help the public avoid zoonotic diseases as they come in touch with nature. The Office of Public Health asked interpretive rangers in the over 400 parks across the system for proposals to incorporate public health messaging and teaching into their hands-on work, their lectures, their walks.
"They fell all over it," Higgins said. "They did a wonderful job."
The office gave out small grants--about $5,000, and the rangers began incorporating a wide range of public health information into their interpretive talks. All the Office of Public Health had to do was review the materials to make sure they were accurate. The initiative-as well as the content of the talks--originated with the staff themselves.
Higgins acknowledges that solutions of this nature don't completely address the resource dilemma. But, he believes, "Where there's a will there's a way"
More on Wildlife and Leafy Greens
* Stuart, D., Shennan, C., & Brown, M. (Fall 2006). Food Safety Versus Environmental Protection on the Central California Coast. Exploring the Science Behind an Apparent Conflict [Research Brief #10, The Center for Agroecology & Sustainable Food Systems]. Santa Cruz: University of California. This literature review paper identifies studies on the issue, including studies that have found deer not to be significant carriers of E, coli. Available online at http://repositories.cdlib.org/cgi/ viewcontent.cgi?article=1036&context=casfs.
* Doyle, M.E., Archer, J., Kaspar, C.W., & Weiss, R. (August/October, 2006). Human Illness Caused by E. coli 015TH7 from Food and Non-food Sources. [FRI Briefing]. Madison: Food Research Institute, University of Wisconsin. Available online at http://fri.wisc.edu/briefs/ FRIBrief_EcoliO157H7humanillness.pdf. Another literature review study--this one lists studies that point to wildlife as vectors of E. coli 0157:H7.
* Proceedings of the 23rd Vertebrate Pest Conference, March 17-23, 2008, San Diego, CA. The conference proceedings include papers from a special symposium on wildlife and food safety and are available online at http:H wifss.ucdavis.edu/headcontent/newsletter/2009Feb_newsletter.php.
Editor's note: Thanks to the Center for Environmental Research and Technology, which recorded sessions at the AEC. Video of the panel discussion "It Isn't Easy Being Green" is available for viewing, free of charge, on the NEHA e-Learning Web site. NEHA members can obtain free continuing-education credits by viewing the session. Visit www. neha.org/elearning/index.html.
Rebecca Berg, Ph.D.