CHANGES IN QUALITY PARAMETERS IN THE UNITED STATES
by Peter Furth
Presented to the
In 1968, the American Spice Trade Association, Inc. (ASTA) held a number of meetings with the New York District Office of the United States Food and Drug Administration (FDA), with the intent of increasing the industry's self-regulation of the cleanliness of spices at the time of importation. As a result of these meetings and a growing understanding within the trade at that time, ASTA adopted its first set of Cleanliness Specifications for Unprocessed Spices, Seeds, and Herbs in 1969. This was a milestone for the industry, and many feel it was the first time in the history of the spice trade than an event occurred which caused a significant upgrading in the quality of merchandise received from source countries.
Although there were subsequent revisions to these specifications in the 13 years which followed, ASTA has never achieved a formal cooperative program with the FDA. However, the industry did assure that a significant percentage of spice imports were being analyzed at the time of importation. In 1982, ASTA began reviewing all Certificates of Analysis on an annual basis. After four years of compiling this data, which included more than 17,000 Certificates of Analysis, we found that a high percentage of the lots were, in fact, complying with our Cleanliness Specifications.
A number of events occurred during the 1980s which caused the United States spice trade to review its program. Over time, some members became complacent with the program. As a result, some lots were never being sampled and some lots were being re-analyzed when the importer did not agree with the first results. This caused a reaction not only from the Food and Drug Administration, but also from a number of members in the industry as well. ASTA faced a critical decision.
The American consumer has placed increasing demands on the food industry to supply a safe, healthy, and clean food product at all times. At times, some may feel that we in the United States have become too restrictive, but the reality is that we are only responding to the strict demands placed on us by those who buy our products. The diversity and selection of food products in the American marketplace is one of the greatest consumer opportunities in the world today. Our industry's growth is, in many respects, dependent on our ability to supply that marketplace with wholesome, nutritious and safe foods. To that end, both the industry and the regulatory authorities have responded to the demands placed upon them by the consumer. Those who have chosen not to have been forced to pay a high price. To cite a few examples of why industry and government must always be responsible to the consumer, one needs only to look at the difficulties the apple industry faced in light of its use of the pesticide Alar or the current controversies facing the use of MSG (Monosodium Glutamate).
ASTA has heard, understood, and responded in many ways to these demands. We have, in the last decade, instituted numerous programs and procedures which, we believe, makes our system a strong and effective one to help ensure that we provide a good product to our customers.
I would like to briefly outline the steps we have taken to broaden and, in some respects, tighten our program.
Perhaps the most significant changes were those taken with respect to our Cleanliness Specifications. In 1988, our Board of Directors charged the Standards Committee to attain agreement from our trade on a single set of FDA/ASTA macroscopic standards. This was an issue for several reasons. First, there were significant quantitative and qualitative differences between ASTA and FDA on macroscopic specifications for raw, unprocessed spices, primarily in the excreta category. Second, there was an obvious disparity in the ASTA contract which stated that merchandise traded on that contract must comply with FDA regulations and ASTA Specifications. Our Accredited laboratories were only charged with analyzing raw material samples for compliance to ASTA Specifications, not to those of FDA. Third, it was a well-known fact that FDA was only sampling approximately 2% to 4% of imported foods. Thus, it became incumbent upon the industry to rely on self-regulation if we wanted to assure our customers of a safe and healthy spice supply.
In 1989, our members unanimously voted in favor of changes which created a unified set of macroscopic standards which are, at all times, at least as restrictive as FDA's Defect Action Levels.
In addition to these modifications, a number of other changes were made to the program which significantly improved our system. In 1987,m the membership adopted the Commodity Tracking Program, which became effective in April 1989. This program, which is incorporated into the ASTA contracts, requires all results of analysis to be reported in to the ASTA office. Through the use of a computer program, results are tracked on a pass/fail basis and an official ASTA code number is assigned to each passing certificate. Goods that fail are not assigned a code number until evidence is given that they have been reconditioned and a proper analysis after reconditioning has been conducted. The United States Customs entry number, commodity name, importing vessel name, bill of lading number, and marks are all screened to insure that duplicate samples are not drawn on the same lot. The system has worked well, and it is our belief that re-analysis of the same lot without reconditioning has been eliminated.
In addition to these changes, over the last few years we have also instituted a Laboratory Accreditation Program. Our labs are audited once a year and are required to perform at a predetermined minimum level. We now have three accredited laboratories. We have also added definitions of extraneous matter to our Cleanliness Specifications, and are currently working on the development of sampling guidelines. At the same time, we are always reviewing and updating our analytical procedures to ensure that our laboratories can do the best job possible of obtaining accurate results.
ASTA has continued to emphasize the importance of a higher quality product in other ways as well. A number of years ago, our Sanitation Committee, which is being renamed the Quality Assurance Committee, began its work with the development of a pamphlet on warehouse sanitation. This expanded into the creation of the Clean Spice Manual. We then began holding overseas education seminars where we presented our program. We have held programs in India, Egypt, and Turkey. We are currently working to design a Hazard Analysis Critical Control Point (HACCP) program for the prevention, detection and control of Salmonella in pepper. Once the program is designed, it is our intention to incorporate it into our presentation in pepper producing countries. We believe our Clean Spices Program is a model program for producing and consuming nations to work together to provide the highest quality products in the most effective and efficient manner.
One other area that has received increased emphasis and attention in the United States, as well as Europe, is that of pesticides. Whether or not we all agree, the reality is that our consuming public is very skeptical when it comes to the use of chemicals on food products. Three examples of problems concerning pesticides serve to illustrate the attitude of the American consumer.
A few years ago, a news program highlighted the use of the pesticide Alar on apples. The apple industry was not prepared to deal with the public and the media. As a result, their sales dropped dramatically, and the confidence of the American public in that industry will probably never be the same.
A check by the FDA showed that two grapes in a crop of 600,000 tons imported from Chile were found to be contaminated with 1 gram of cyanide. Many examinations of all subsequent ship0ments found no further incidences of cyanide. But, as a result of the adverse publicity, no American consumer bought those grapes, and the effect on the industry was the loss of millions of dollars and a total crop.
A few years ago, the voters in California approved Proposition 65, a restrictive piece of legislation that was heavily promoted by consumer activist groups. This law awards fines and prison sentences to companies that violate the resulting regulations and has forced many industries to cease operations in California. At the same time, various other states are considering similar legislation.
ASTA has begun to deal with the pesticide issue in a number of ways. A few years ago we began to screen samples of importers for the presence of pesticides. We are currently completing Phase II of this project and expect to have the beginnings of a database in place in a short time. We are in the process of expanding this program into a Pesticide Screen Management Program, which we expect to be ongoing for many years to come. We have also begun to incorporate a Pesticide Education Program into our efforts at educating both our domestic members and overseas suppliers. This year, we published a pamphlet entitled, Pesticides and Spices, as part of that program.
There are two other areas where we have undertaken work and programs which reflect our moves towards more stringent quality requirements. The first is in the area of microbiology. We are currently working to update our Microbiological Analytical Methods and plan on publishing in the next edition in the near future. The second area is that of finished goods specifications. Over the last two years our Manufactured Products Group has worked to develop templates, outlining the parameters which should be addressed in specifications for processed spices. Work is continuing in this area, and the current thinking is that ASTA should develop specifications for those areas which are regulated by the government. We may also look into creating a database of information concerning all parameters, so that we can give the industry a profile of the merchandise which is currently entering into commerce.
ASTA has also begun a legislative program for the first time. This year, there are a number of bills under consideration in the United States Congress which would have a significant impact on the food industry in general, and the spice industry in particular. These bills deal with pesticides, food safety, the FDA's enforcement powers, and other subjects such as lead in foods and reporting requirements for those using toxic chemicals.
ASTA has been working to help ensure that the final drafts of the legislation meet the needs of the lawmakers and the industry to protect the public interest. At the same time, the laws that are passed should be fair, reasonable, and equitable.
We must always remember that all of the programs and activities detailed today are in place not because we as an important trade want to place unfair or unreasonable demands on the producers overseas. Rather, we are acting in response to the growing demands placed on us by our customers - whether they are the ultimate consumer or the food companies who buy our products. These demands are generally for a clean, safe food supply. The pressures put on the spice processor in the United States, not unlike many of our counterparts in other parts of the world, have often translated into similar pressures on our suppliers.
Instead of viewing these demands as a barrier to effective trade, we would suggest that those of you who are suppliers to the United Sates spice market view them as one of the greatest opportunities in the world today - to participate in a large and growing consumer oriented marketplace by supplying wholesome, nutritious, clean, and safe products.