Do you want consumers and customers to trust you? Then you’d better have data and be ready to share it.
Part 1 of Our Series with Dr. Bob Whitaker
By Bob Whitaker, Ph.D., Whitaker Consulting LLC
August 10, 2022
The Center for Produce Safety’s Research Symposium was held in June 2022 and, as always, it was an excellent opportunity to hear from leading produce safety scientists as they share the results from their projects. The event also featured a discussion with former head of the Federal Aviation Administration (FAA) Randy Babbitt and Tim York, CEO of the California Leafy Greens Marketing Agreement (CA-LGMA). Babbitt described how the airline industry dealt with safety issues to drastically reduce accidents over the last three decades. The information he shared may reveal a path forward for the produce industry.
Data Sharing Can Improve Safety Outcomes and Restore Consumer Trust
In the 1990s, the airline industry was at a crossroads in terms of trust with consumers and government regulators. The decade saw a succession of fatal accidents (resulting in 931 deaths) due to plane crashes in the United States.1 Change was needed. A few visionary leaders within the industry came to the realization that data could be leveraged to find proactive solutions to these repeated failures that caused safety incidents. Furthermore, the transparency brought about by data sharing within the industry and with government regulators could restore trust with consumers.
This theory seemed valid, but there were significant hurdles that needed to be overcome to create a culture of data sharing. Data collected by every segment of the airline industry – including the hundreds of thousands of data points collected each second by modern aircraft and the observations made every day by those who work in the industry – were essentially sequestered within each company or within departments of each company. This lessened the value of the data and prevented the entire industry from understanding what actions needed to be taken to improve flight safety.
Overcoming Resistance from Industry Members
The airline industry is not a homogenous entity. The various members of the industry – pilots, mechanics, flight attendants, executives, aircraft designers and builders, carriers, airport personnel, and others – have different perspectives on their industry and on sharing their proprietary data. Concerns over competitors and regulatory agencies accessing this data was a formidable hurdle that needed to be overcome to foster greater data sharing. Fear of recriminations for accidents or operational “mistakes” led to a “keep your head down and do your job” culture where speaking up to report safety issues was not a customary practice. There was an “us versus them” mentality towards competitors and government regulators.
But a small group of visionaries comprised of industry executives, senior federal regulators, and senior leadership from the pilot’s union saw past this challenge and launched a voluntary incident reporting program. The program importantly created an environment where punishment was taken off the table to help encourage information sharing when mistakes were uncovered. There were certainly skeptics of this approach within and outside of the airline industry, but by the late 1990s, a unified, data-driven approach to airline safety was adopted. The industry culture was on the road to change with data sharing at the center.
The Results of Data Sharing: A Transformation in Safety
Over the next decade, with the freedom to provide information without recriminations, data was used to improve all facets of the U.S. airline industry. Data sharing rectified routine “pilot errors” and other issues related to safety incidents. Some examples of improvements that evolved in this period include:
- The development of standardized phrasing to ensure better understanding between air traffic controllers and pilots
- A simple system where pilots verbally double check changes in altitude and then confirm the information has been entered into the computer properly
- Revision of runway speeds and braking distances
- Revamping maintenance practices
This “data will set you free” approach had dramatic impacts. In 1996, prior to the adoption of the data-driven approach to safety, the fatal accident rate was one crash for every two million departures. Today, the fatality rate is one for every 120 million departures.1 The FAA has also established ten separate data reporting programs covering a broad array of airline functions and job categories, as well as a 10-person industry leadership team. Representatives from major and regional carriers, pilots, flight attendants, and air traffic controllers meet with the FAA administrator and top-level staff regularly to foster open communications, data sharing, and policy changes.
As a result, the industry has developed more extensive pilot training programs, data systems that identify engine reliability issues proactively, and mechanisms to alleviate hazards posed by pilot fatigue. It is important to note that while airline safety in other parts of the world has also improved, likely due to technological gains, the improvement is not as significant as what we’ve observed in the United States. An equally important lesson is that despite the impressive gains made by the industry, fears about data sharing and cooperation still bubble under the surface and threaten the culture of trust building. This serves as a reminder that one of the hardest things about culture change is to maintain the change after the initial crisis has passed.
Can the Airline Industry Approach to Safety be a Blueprint for Fresh Produce?
As you read these opening paragraphs, you likely recognized the parallels between the airline industry of the early 1990s and the fresh produce industry of the 2010s to 2020s. Current problems in the produce industry include:
- Repeated incidents in the form of product recalls
- Illness outbreaks and deaths
- Sensationalized media coverage
- A large, segmented industry with multiple perspectives on produce safety and a deep-seated reluctance to share data
- Adversarial relationships with government entities and consumer groups
- A mutual lack of transparency between the industry and FDA
- Diminished consumer trust in fresh produce safety
These are conceptually the same types of issues faced by the airline industry thirty years ago. The question is whether the approaches and strategies employed by the airline industry and FAA might be applicable to fresh produce.2
This is not the first time the produce industry has looked to the airline industry as a model for improvement. During the series of E. coli O157:H7 outbreaks that plagued the romaine lettuce segment of the industry in recent years, the failure to confidently identify the cause for these outbreaks led some produce industry leaders to call for adoption of root cause analysis. This could help the industry not only understand what led to an illness outbreak, but why it happened and how to prevent it from happening again – much like the root cause process The National Transportation Safety Board (NTSB) uses to investigate transportation accidents.
The FDA and “Smarter Food Safety”
In July 2020, the FDA introduced its “New Era of Smarter Food Safety.”3 This multifaceted effort focuses on traceability and implementation of root cause analysis when incidents occur. It is built around the general theme of using emerging technologies to capture and analyze data and develop preventive food safety measures. In a recent speech, Frank Yiannas, Deputy Commissioner for Food Policy and Response at FDA, stated that “actions on food safety speak loudest when it comes to building trust.”4 This simple statement is a call to action for the produce industry to leverage the spectrum of industry data – including industry knowledge, artificial intelligence, machine learning, and the internet of things (IoT) – to develop preventive strategies and, ultimately, re-build trust. Yiannas went on to say, “In the data age, collaboration will increasingly involve public to public and private and public organizations sharing data and converting that into information and the entire food system getting smarter together. At FDA, we are working on data trusts and have started a few projects to do just that.” Putting the pieces together, it sounds exactly like the process the airline used in the 1990s.
The concept of data sharing and partnership building in relation to the produce industry is intriguing. It certainly raises some important questions:
- Might it be possible to use the airline industry/FAA blueprint to build industry consensus on data sharing? Can this overcome current produce safety challenges and build preventive practices that enhance the safety of our products?
- Like the airline industry, could the produce industry develop a mechanism to share food safety data that shields ownership of the data, thereby creating an environment where recriminations by customers and regulators are diminished and quantitative and qualitative data are valued?
- Could an earnest effort towards data sharing and transparency within the industry be an impetus to create working partnerships with state health departments, USDA, and FDA? Will this improve existing policies and expedite outbreak investigations and the open sharing of data and observations?
- Over a decade after the Food Safety Modernization Act (FSMA) was signed into law, how might FSMA have been improved if safety data had been shared with the FDA? Would a partnership with the FDA built on trust lead to more meaningful and sensible regulations that could truly improve produce safety across the entire supply chain?
- Could a unified approach to data sharing and partnership with the Centers for Disease Control (CDC) permit more effective identification of causative foods during outbreaks? Would this speed up traceback investigations, reduce market disruptions, and better protect public health?
- If CDC had more confidence in the produce industry and trust was built through transparency, might CDC have the freedom to advocate more aggressively for the health benefits of fresh produce consumption?
- Would data sharing and analysis lead the industry to ask better questions of academic researchers and technology developers? Might these experts then use the data to further our produce safety knowledge and develop risk and science-based strategies to improve produce safety?
Produce Industry Challenges to Data Sharing
These are all fascinating questions to ponder, but how do we get to an industry culture of data sharing, transparency, and trust? There are some significant challenges owing to the diversity within our industry, a long competitive legacy, regulatory frustration, and denied realities. But essentially, the horse is already out of the barn. Data collection and analysis already drive operational and marketing business within the produce industry daily, so it is not like the concept is foreign.
The industry has become reluctantly acclimated to sharing audit and microbial test results with customers over time, and this trend is expanding. The means for data collection, analysis, and sharing are readily available and even mobile, and clearly FDA is pointing in this direction. Most importantly, we know that our current strategies of baseline food safety regulations, auditing, and discriminant microbial testing are not preventive or effective.
Produce companies collect millions of data points yearly that reside in three-ringed notebooks or exist as digitized files, in what amounts to a hard drive masquerading as a digital file cabinet. New illness outbreaks emerge monthly, while our technology to detect contaminations and outbreaks far outstrips current preventive technologies. Overall fresh produce consumption has declined by about 10 percent since 2004.5 Like the airline industry did three decades ago, it is time to acknowledge change is needed. Perhaps that journey requires an examination of how our data can be used to improve produce safety.
1. “The Airline Safety Revolution.” Andy Pasztor, April 16, 2021. Wall Street Journal. https://www.wsj.com/articles/the-airline-safety-revolution-11618585543.
2. “Collaboration Needed to Solve Challenges, Build Opportunities in Ag.” Tim York, July 7, 2022. www.thepacker.com/news/industry/collaboration-needed-solve-challenges-build-opportunities-agriculture.
3. New Era of Smarter Food Safety” – https://www.fda.gov/food/new-era-smarter-food-safety.
4. “Food safety actions are key to build trust.” Joe Whitworth, June 23, 2022. Food Safety News. https://www.foodsafetynews.com.
5. “2020 PBH State of the Plate.” Produce for Better Health Foundation. 2021. https://fruitsandveggies.org/stateoftheplate2020.