David W. Plunkett, JD, JMCenter for Science in the Public Interest

Consumer Expectation:Traceability

FDA-FSIS Public Meeting on Traceability

December 9, 2009

Center for Science 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

Healthletter– Represents 950,000 subscriber/members in the

United States and Canada

Consumer Expectations: Traceability

Support for Traceability– Polling on Trace– Polling on Costs– Random Assignment Costs– Feasibility

Factors in Trace System Effectiveness– Consumer Awareness and Biases

Meeting Consumer Expectations

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

– Support for government being able to trace food from production to sale if problems arise – 97%

National Research Center, Consumers Union, Nov. 2008

– Support for labels disclosing region, state, or farm of origin to ID source of contaminated food – 79%

CSPI members’ poll 2008

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.” IBM Survey, June 24, 2009

– Read COOL info often or sometimes – 52%Harvard Food Safety Survey, May 12-June 1, 2008

Willingness to Bear Costs

Polling– Would pay 3% to 5% more for additional safety –

72%Hart Research/Public Opinion Strategies, June-July 2009

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.”

J.E. Hobbs, Liability and Traceability in Agri-food Supply Chains

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 disposable

income Annual spending on food = $1,165 B

Economic Research Service

Estimates of the annual cost of food-borne illness range from $6.9 B to $357 B

Crutchfield & Roberts, ERS, 2000 (5 pathogens only); Roberts, 2007 (WTP)

Random Assignment of Costs

Per capita expenditures/costs– Food: $3,832– Food-borne illness: $1,174

Random assignment of illness costs– $26 (no doctor visit) to $30,998 (hospitalized HUS) per case– $1.8 million (age ≥ 85) to $9.3 million (infant) per life

Frenzen, ERS Cost Calculator, 2007 (STEC 0157 only and 2003 $)

Random assignment of industry losses– Spinach: Loss of $350 million– Tomatoes: Loss of $425 million ($300 M CA; $25 M GA)

Press Reports, UGA

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– Benefits: Lower recall costs, improve consumer

confidence and supply chain managementInstitute of Food Technologists

Feasibility of Tracing – Produce

Lessons – Salmonella saintpaul 2008

Traceability for Marketing

Perishable Agricultural Commodities Act– Trace to ensure fair dealing and resolve disputes

Price Look-up Codes– Trace-like system for inventory control; pricing– Labels adapted for COOL information

Customer loyalty programs– Tracing customer preferences (who buys what)

Consumer question– Economic traceability is common; why can’t we have better

safety traceability?

Attitudes Toward Notices

Inattention to notices– Of those with internet access –

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 foodFood Policy Institute, April 14, 2009

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)

Contact Information

David W. Plunkett, JD, JMSenior Staff Attorney

Center for Science in the Public Interest1875 Connecticut Ave, NW

Suite 300Washington, DC 20009

phone (202) 777-8319fax (202) 265-4954

e-mail dplunkett@cspinet.orgOn the internet:www.cspinet.org