Presentation regarding Produce Traceability as presented to FDA & FSIS on December 9 & 10, 2009 in Washington, D.C.

1. Consumer Expectation:
Traceability
David W. Plunkett, JD, JM
Center for Science in the Public Interest
FDA-FSIS Public Meeting on
Traceability
December 9, 2009

2. Center for Science
C t f S i
in the Public Interest
Bi-national consumer advocacy
organization founded in 1971
by Michael Jacobson
– Focuses on nutrition and health, food safety,
alcohol policy, and eating green
– Publishes award winning Nutrition Action
award-winning
Healthletter
– Represents 950,000 subscriber/members in the
p ,
United States and Canada

3. Consumer Expectations: Traceability
Support for Traceability
– Polling on Trace
– Polling on Costs
– Random A i
R d Assignment C t
t Costs
– Feasibility
Factors in Trace System Effectiveness
– Consumer Awareness and Biases
Meeting Consumer Expectations

4. Consumers Value Traceability
Polling
– Support for trace system that enables FDA to
trace food back to its source – 94%
Hart Research/Public Opinion Strategies, June-July 2009
p g y
– Support for government being able to trace food
from production to sale if problems arise – 97%
National Research Center Consumers Union Nov 2008
Center, Union, Nov.
– Support for labels disclosing region, state, or farm
of origin to ID source of contaminated food – 79%
CSPI members’ poll 2008

5. Source Information is Important
Country of Origin Labeling
– Support for COOL – 93%
CSPI Members’ Poll 2008
– Support for more information on source – 76%
“[T]here’s still a significant gap between
consumer expectations and what retailers/
manufacturers are providing.”
f t idi ”
IBM Survey, June 24, 2009
– Read COOL info often or sometimes – 52%
Harvard Food Safety Survey, May 12-June 1, 2008

6. Willingness to Bear Costs
Polling
– Would pay 3% to 5% more for additional safety –
72%
Hart Research/Public Opinion Strategies, June-July 2009
p g y
Studies
– Experimental auction lends support to poll results
“The empirical analysis shows that consumers were willing to pay non-
trivial amounts for a traceability assurance… For consumers,
traceability has the most value when bundled with additional quality
assurances.
assurances ”
J.E. Hobbs, Liability and Traceability in Agri-food Supply Chains

7. Random Assignment of Costs
Decline of Food $ as % of family budget
– 1958: Food purchases represent18.4% of
disposable income
– 2008: Food purchases represent 9 2% of
9.2%
disposable income
Annual spending on food = $ ,
p g $1,165 B
Economic Research Service
Estimates of the annual cost of food-borne
illness range f
ill from $6 9 B t $357 B
$6.9 to
Crutchfield & Roberts, ERS, 2000 (5 pathogens only); Roberts, 2007 (WTP)

8. Random Assignment of Costs
Per capita expenditures/costs
– Food: $3 832
F d $3,832
– Food-borne illness: $1,174
Random assignment of illness costs
g
– $26 (no doctor visit) to $30,998 (hospitalized HUS) per case
– $1.8 million (age ≥ 85) to $9.3 million (infant) per life
Frenzen,
Frenzen ERS Cost Calculator 2007 (STEC 0157 only and 2003 $)
Calculator,
Random assignment of industry losses
– Spinach: Loss of $350 million
– Tomatoes: Loss of $425 million ($300 M CA; $25 M GA)
Press Reports, UGA

9. Cost of Implementing Traceability
Traceability in H.R. 2749
– CBO stated cost depends on future regulatory
decisions and so could not be estimated
Factors
– Costs: Infrastructure, standardization,
replacement of legacy systems, labor, records
p g y y , ,
– Benefits: Lower recall costs, improve consumer
confidence and supply chain management
Institute f F d T h l i t
I tit t of Food Technologists

10. Feasibility of Tracing – Produce
Lessons – Salmonella saintpaul 2008

11. Traceability for Marketing
Perishable Agricultural Commodities Act
– Trace to ensure fair dealing and resolve di
T t f i d li d l disputes
t
Price Look-up Codes
– Trace-like system for inventory control; pricing
y y ;p g
– Labels adapted for COOL information
Customer loyalty programs
– Tracing
T i customer preferences (who buys what)
t f ( h b h t)
Consumer question
– Economic traceability is common; why can’t we have better
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safety traceability?

12. Attitudes Toward Notices
Inattention to notices
– Of those with internet access –
th ith i t t
Ones who ever visit government website for recall information
– 20%
Ones who read little or nothing about recalls – 25%
Optimistic Bias
– “Recalls are relevant to others, not me.” Own food
purchases are unlikely to be recalled – 38%
– Of persons suffering illnesses 5% said source was recalled
food, but 11% said knew others made sick by recalled food
Food Policy Institute, April 14, 2009

13. Consumer Expectations
Traits of an effective trace system
– Provides easily understood information about
food’s source (not just codes or electronic tags)
– Uses standardized product identifiers so that
recall information is easy to communicate
– Relies on pro-active communication (such as
customer loyalty systems to alert consumers)
– Supported by relevance information (retail
consignee; posting alerts in store)

14. Contact Information
David W. Plunkett, JD, JM
Senior Staff Attorney
y
Center for Science in the Public Interest
1875 Connecticut Ave, NW
Suite 300
Washington, DC 20009
phone (202) 777-8319
fax
f (202) 265 4954
265-4954
e-mail dplunkett@cspinet.org
On the internet:
www.cspinet.org
www cspinet org