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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
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