It will be crucial to see if the benefits of NURTURE that I saw evidence for in my interviews carry over now that NURTURE is a module within Global G.A.P., or whether the character of those interactions and the high quality environmental and food safety “license to operate” that they helped to shape are significantly changed under Global G.A.P. management. It will also be interesting to see how this merger of standards affects market penetration of the Global G.A.P. standard. Global G.A.P. certifications active between 2014 and 2015 were not followed exclusively by any farmer interviewed during my study, but did show up as an additional standard followed concurrently by several farmers in my sample. If the merger with NURTURE allows Global G.A.P. to extend its market impact over a larger number of suppliers without fundamentally changing the structure of the NURTURE standard or its potential for positive landscape-level impacts, this merger could be one sign of positive evolution within harmonization of international food safety standards.Since I began this research, the FDA Food Safety Modernization Act in the United States has gone from a proposed rule making, to a final rule awaiting implementation, to the early stages of implementation within the US agricultural economy. Collection of the California data examined in this dissertation began while the proposed rule making was undergoing public comment, and concluded soon after initial publication of the final rule. At the time of publication of this dissertation, the Produce Rule is in effect. The first inspections called for under the FSMA Produce Rule were delayed in the beginning of 2018 by budget concerns for training new FDA inspectors, pruning cannabis issues around feasibility and definitions of certain requirements, and the complexities of developing state-level inspection protocols for the new rule.
Although the new requirements 11 are now in full effect as of September 2018 for all food businesses at all levels, FDA has reported that requirements for some types of produce farms will see a delay in enforcement reaching into 2019, or even 2020 . For many larger farms, changes have amounted to only minor refinements to existing food safety measures, because these producers already adhere to the most stringent rules in production due to their articulation with international trade networks and their deeper financial capacity to pay for audits and absorb additional costs. Conversely, for small and medium sized farms without large financial resources and for alternative producers following ecological farming methods that fit less readily into current HACCP risk-assessment frameworks without necessarily being less safe, the enforcement of FSMA’s newest provisions will present significant hurdles for day-to-day operations. Small farmers commented during the initial notice and comment cycle for FSMA that the new rules would likely put some smaller and alternative producers out of business due to the high cost of additional adaptation measures and inspections. The two iterations of the new USDA Harmonized GAP standard that I included in my analysis prior to their full implementation have also now gone into effect and have been adjusted for the enforcement of FSMA. This standard in its two iterative versions formed my category 2 Prescriptive Safety Plus, reflecting their attempts to incorporate clauses with a broader view of combined environmental and food safety concerns, and process-oriented controls in addition to prescriptive clauses. With my results from the previous chapter in mind, entry onto the state regulatory stage of standards with even a slight additional inclusion of these elements that I saw positively correlated with environmentally friendly farming practices and improved farmer experience could be a positive sign for the regulatory landscape. However, it will be necessary to see whether harmonization efforts are durable over the longer term, or if the landscape of standards remains subject to fragmentation. Hybrid food safety controls in the United States have also changed to accommodate new requirements at the national level. According to the LGMA board, as of August 2017, the LGMA standards applicable in both California and Arizona have been updated to reflect the new regulatory baseline represented by the FSMA Produce Rule.
This update was responsible for 12 the increase in prescriptive safety controls I observed in my comparison of standards, which saw the 2018 LGMA standard move back into my category 1: Prescriptive Safety. In comparison, the previous 2015 LGMA revision had contained enough process-oriented controls to place it within my category 3: Flexible Safety, representing a significant transition toward process-oriented controls that has now been reversed as private standards have intersected with changing public regulation. Producers entering into or maintaining certification to the LGMA in 2018 and beyond are now considered to be in full regulatory compliance with FSMA through the audits they already undergo. With the ability to signal full compliance through an already established public private partnership with USDA backing, the LGMA standard appears to have enhanced value and durability in a post-FSMA leafy greens market. This may complicate harmonization efforts,while also demonstrating an important back-tracking of the prior trend toward greater reliance on process-oriented food safety controls.On June 23 , 2016, residents of the United Kingdom voted in a historic referendum over rd the future of their membership in the European Union. The campaign to leave the EU won the vote by a margin of 51.9% to 48.1%, providing the popular basis for initiating the political process of exiting from the EU’s economic and political partnership represented by the EU. Under the terms of Article 50 of the Treaty on European Union, the UK has until March 29 , th 2019 to officially leave the EU with a negotiated agreement and its mutual parliamentary ratification. As of the time of writing, negotiations over the agreement are still underway, and although agreement has been reached on many specifics, the full terms have not yet been permanently established. Among many pressing economic questions for the nation, questions remain over what the UK’s exit will do to build upon or alter the functioning of the existing food safety and environment regulatory landscape in which fresh produce is currently grown. No matter what the precise terms of the final agreement, the UK’s exit will almost certainly change the face of British agriculture. The current UK leafy greens market benefits from a high degree of migrant labor drawn from other member countries within the EU under free migration rules.
If it becomes significantly harder for migrant laborers to gain access to the UK to work in agriculture, the UK produce sector could face steep competition from nearby EU countries where low-wage field labor is more easily attainable. Additionally, current environmental requirements and income support programs that some UK farmers presently enjoy under the EU’s Common Agricultural Policy will end by claim year 2020 under the terms 13 currently provisionally agreed by EU and UK negotiators as of November 14 , 2018 th . These direct payments and the regulatory mechanisms and requirements that underlie them provide the basis for UK environmental regulation in the farming sector, ensuring minimum standards of environmental protection and stewardship . Direct income support payments to farmers are slated to continue in the form of internal payments from the UK treasury until the next Parliamentary elections, due in 2022. Commentary from the UK parliament cites reasons that this exit and reorganization could be favorable for UK farmers, including relief from the more onerous parts of EU bureaucratic control and standardization of farming methods, record keeping, and crop timing . The UK’s DEFRA has announced plans to replace the direct payments with a new system designed to fix certain problems within the CAP payments, which some UK critics say do too much to reward large landholdings and too little to support real environmental stewardship. In a speech given to the Oxford Farming Conference in January 2018, Michael Gove, drying room current UK Secretary of State for Environment, Food and Rural Affairs, explained that DEFRA plans to move the nation away from CAP and its “resource-inefficient” methods of production, moving from “subsidies for inefficiency to public money for public goods” such as natural capital and environmental land stewardship. Such statements contain important clues 14 for basic framings of the values of food and farming which will soon decide which paths are considered by policy makers. Public expressions such as these pay service to the goals of environmental conservation and public goods such as food safety, but with uncertain guarantees during this ongoing time of negotiation. In February of 2018, ahead of major EU-UK negotiations, Britain’s National Farmers Union released a collaborative statement from 37 organizations representing the UK food and farming industries, in which they detailed their shared vision for what a successful British exit from the EU should aim to establish. Among other trade related goals, the statement calls on UK policy makers to ensure that new UK agricultural standards after the separation continue existing commitments to high environmental, health and animal welfare standards. However, recent evidence from the ongoing Brexit negotiations suggests that food standards may not be on track to ensure ideal outcomes for public health. With the announcement of a new program titled “Regulating Our Future” the UK Food Standards Agency has announced that its plans for food standards after Brexit will strongly favor private regulation over public regulation. This has some industry watchers worried that the future may hold a return to the scandals and failures of food industry self-regulation that plagued UK food production in the 1980s and 90s. Critics have warned that the new program undermines the publicly accountable enforcement provisions of the UK’s 1990 Food Safety Act by placing responsibility for food inspections on private commercial assurance providers instead of local and central government. Those wary of such a shift warn that this would be a misstep because private assurance firms would have a commercial incentive to serve their food industry clients over the interests of the public . Moreover, critics point out that regulatory over-influencing by corporate food actors was exactly the problem that the FSA, as a central independent watchdog agency, was famously created to solve. Non-state and hybrid standards can be effective tools for ensuring desired outcomes for food safety and the environment , but are most effective when paired with strong state regulation.First and foremost, I suggest that ensuring optimal outcomes for food safety and environmental management will require additional efforts to combat the division of food safety and environmental concerns into separate administrative and industry silos. Currently, my data show that these goals are being pursued separately by public and private standards in the United States, and through imperfect overlapping agencies within the UK government. In many cases, private standards push the frontier of regulation farther than public mechanisms, and form the most immediate point of contact uniting regulatory goals with buyer requirements and farmer practice. Currently, private standards in both nations are facing changes and updates in the wake of fluctuating regulatory climates, leaving private standards in a state of uncertainty and flux. I suggest that it is now especially important for private food safety standards in both nations to explicitly consider environmental goals alongside food safety goals. My results indicate that more balanced standards of this nature are correlated with more positive farmer experience, improved attitudes toward the natural environment, and higher use of conservation-oriented practices, goals which should be among those established during the current reorganization of regulatory priorities at public and private levels. Private standards are increasingly becoming international or global in scope, extending the reach of private regulation far beyond that of public regulation. Delivering effective food safety guarantees in global supply chains will require a shift toward more complete, internationally bench marked or otherwise harmonized standards, and nimble governance frameworks with a view of safety that does not ignore sustainability. However, market forces are currently still encouraging standards to proliferate and stay focused on food safety to the exclusion of other concerns. Additionally, regime transitions in both UK and US government make it less likely that the most balanced food safety standards currently available will be able to maintain their environmental completeness and broad conception of food safety going forward. It will be important for areas of the developed world that have rigorous and effective standards to maintain them in the face of incentives to race to the bottom, converging around standards which aim to deliver safety instead of other goods, rather than in addition.