Happy New Year to all fellow subscribers. I have only been on the list
for a couple of months now, and have enjoyed ALMOST every posting, from
the factual, to the sensible, to the downright weird.
Over the last few days a thread has emerged which has encompassed a
range of issues from organic honey through to food safety issues. Whilst
some good stuff has been written, some has also come from people who you
can almost visualise 'foaming at the mouth' as they have written it.
Whilst I am not in the USA I feel that it may be useful to put together
a piece containing my thoughts on this issue.
On the organic issue first. I am not an organic fan and I don't buy
organic goods. I am friendly with a professional analyst who tells me
frequently of anomalies he discovers in this matter. Farms which are
indubitably and verifiably organic having higher pesticide residues in
their crops than non organic farms is commonplace, and, even without
deceiptful use of pesticides hinted at in another posting, this can
easily be attributed to spray drift from farms in the vicinity, or even
coming down in the rain.
Here in Scotland a few seasons ago we had a major producer who started
marketing his honey with a large flashy 'ORGANICALLY PRODUCED' sticker
on the lid. He did so to gain an advantage over his fellow producers.
This was done on honey produced almost entirely from rapeseed (canola),
which he also labelled as white clover. Both claims were obviously
bogus. Whilst the latter description was strangely not illegal (rather
than being legal) due to historic issues, despite analysis showing 86%
rapeseed pollen, the former was certainly a claim which would have
brought conflict with bodies in the mainstream organic movement. And
rightly so. The consumer is entitled to protection from such claims.
In the UK organic certification is handled by a body called the Soil
Association. You can apply to them to have your product certified as
organic. They are non governmental and highly ethical, so if you don't
meet all the criteria you won't get approved. There is a market out
there for organic produce and those seeking to buy organic goods are
generally willing to pay a premium for it. This scheme entitles you to
use the Soil Association logo on your approved products, and although it
will cost you a bit to get approval, it will then let you tap into this
premium market. Their inspectors will travel anywhere in the world to
see the process right back to source before issuing approval. The
consumer is also safeguarded by the knowledge that, if it carries the
Association logo then it will be proper organic produce. Organic
consumers take a very hard line on the subject, it is either organic or
it is not, they will not accept such claims as 75% organic or whatever
as was suggested by one respondent. We, Denrosa, certainly cannot meet
the needs of the Soil Association although we explored the matter
several years ago, and as one respondent said, it is unlikely that any
beekeeper in an industrialised or intensively farmed area of land will
ever be able to do so. Please note that in this case it is the consumer
who sets the standard he or she requires, and if we cannot meet it we
either have to accept that or change our practices to meet that need. We
cannot attempt to have the height of the bar lowered so that we just
sneak over, as to this type of client this will not be acceptable. It is
also surely fair to those who do invest the time and money into meeting
the criteria in order to achieve the higher price, that they are not
then undermined by people taking a free ride on the back of their
investment and simply putting an organic label on produce which,
strictly in terms of the criteria, is not. In the event of absence of
non governmental supervision of such a scheme in the USA ( you tell me,
I don't know), it is surely a good idea for them to take a hand in it,
but, unless you all want to pay taxes to benefit only a few producers
and consumers, it surely should be self financing. In other words, user
pays. You want a certificate allowing you to tap into a premium market
then you, not everybody, should pay for getting that certificate.
Take your beekeepers hat off for a moment and put on your consumers hat.
You will want the foods you buy to have been produced in correct
conditions, and that the claims on the label are accurate and true.
Anything which assists in ensuring this is normally helpful to you, the
consumer, although it may, at least superficially, be unhelpful to you,
the producer. Which neatly brings us round to food safety.
I buy many foods from many countries round the world. How can I be sure
that the product I buy from say Guatemala, or Turkey, or USA, is safe?
I can only feel secure because of the quality control activities of both
the brander(who may or may not be the producer) and the vendor. Very few
of us go right back to the source producer for our foods, except perhaps
to farm shops, or in the case of beekeepers to their premises or
roadside stands, instead we almost all now shop in supermarkets of one
form or another, and thus cannot know at first hand about production
conditions or quality control at source. These companies have a legal
obligation to audit the products they sell and the premises they are
produced in to protect us, the consumers. It is not exactly worded as
that, but they are obliged to demonstrate 'due diligence' in their
selection criteria for the goods they sell.
One way of doing this is by ensuring that the producer has in place a
correct and auditable system of ensuring product safety. Such a system,
and there are much worse which could have been imposed, is HACCP (Hazard
Analysis Critical Control Points). It works by focussing in on areas of
risk in a process, and by its very nature therefore is a much more
onerous thing in a meat plant than in a honey facility. Record keeping
is crucial, as is the accountability of those completing the records. In
our case the crucial, (high risk) areas are very few, and thus our HACCP
system is fairly simple. Risks are graded, full records kept, and thus
batch traceability can be achieved, minimising the danger to you, the
business, in the event of a product recall.
The beauty of HACCP is that, given some good quality guidance either
from a consultant or from literature, you can write the system yourself
at very low cost. Then you can do the forms on your home computer and
you are in business. As a honey producer it is relatively easy to do but
it is crucial to take the view of an outsider looking in and not take
the part of the hostile producer resistant to the changes that may be
required. Embark on it with hostility and it is unlikely that you will
devise a system satisfactory to your larger customers. Fail to implement
HACCP at all and it is likely that you will eventually lose all but your
smaller clients as the need for due diligance defences increases,
particularly in a litigious society like the USA.
Market forces were quoted in one post. Well eventually market forces
will make you do this, even if you don't want to, unless you are small
scale, in which case you are selling largely on your own reputation and
will not need any such protection.
I call it protection most advisedly. It is also (my first thought) an
unwanted imposition and a pain in the butt. However, upon reflection,
after having gone through the exercise, it is actually a good thing and
helps our business move onwards and upwards, both in improved
organisation and the sense of security it gives to prestigious clients,
who then feel safe to select your products for their stores rather than
competing brands. It protects because, when correctly implemented and
the right disciplines are in place it should prevent you making any
serious errors or lapses in quality which could damage your interests.
It will also enable you to pass any damages claim 'down the line' to the
next one back in the supply chain, because you have taken, and recorded
the fact that you have, every reasonable precaution.
Someone else touched on batch sizes. We segregate by site(yard). This
apparently involves extra work but it turns out that that was just a
perception before doing it as in reality it does not. It is wise to
break you batch size down to as low as is reasonably achievable. Batch
size is up to you. It can be by yard, or days run, or whole season, or
whatever. How effective the segregation is is also for you to decide,
but you must bear in mind the need not to compromise the system by a
silly shortcut. For example we only allow the extractors to drain for a
few minutes between batches, and then any residues just go in with the
next lot. In large industrial scale extracting plants segregation by
yard is not practical, so you use some other system such as a days run.
The crucial point is that if for some reason your product turns out to
be contaminated with heaven knows what, the smaller and more precisely
traceable the batch is, the easier it is to establish the source,
attribute a cause, and probably establish your own due diligence defence
against any claim. The batch in question may need to be condemned, so
the smaller it is the better protected you are. What a tragedy it would
be to be lazy about batching and just call your whole years production
one batch to find that there was something wrong with some of it. It is
almost an insurance policy and can result in lower product liability
insurance premiums.
From the consumer point of view it is probably perfectly apparent that
most honey is well produced and packed. However I can tell you a couple
of examples that show the need for legislative intervention. A
beekeeper, in another part of the country, was rapidly expanding his
enterprise, and everything seemed most impressive. The product was well
packed and presented and of good quality. Photographs showed the nice
modern packing plant. Trouble was the packing plant did not exist. The
honey was being extracted, filtered and packed in an old set of chicken
sheds with earth floors and which had not even been properly cleaned
out. There was visible chicken dirt in the corners of the building. The
guy was not investing in the correct hygenic infrastructure and just
selling more and more honey from more and more hives without incurring
the cost base of other producers. Another guy was doing fine and
genuinely had a very nice plant, trouble with him was he did not have a
large enough shed and stored his empty jars in an adjoining barn. All
were washed prior to use so everything was OK till the environmental
health officers found that, prior to washing, the jars were contaminated
with rat urine. The consumer could not have known, and so someone has to
be there to police our interests. Proper, effective, and auditable HACCP
systems are one way of doing this without overly intrusive governmental
action.
Someone also mentioned restrictions imposed by the EU causing a lack of
flexibility on behalf of honey packers. The only grounds I can see for
this is in the legal weights legislation which apply to certain product
groupings only. I do not find the legislation to be all that intrusive
and is only really there to protect consumers.
As for the guy who was selling the 'Organiclly Produced' honey? Well he
was stopped but has had a few other ruses since then. Currently it is
'Original Cold Pressed' which unfortunately is another can of worms all
together, and also much in need of legal clarification.
Sorry about the length of this piece, a lot of which will be of no
interest whatsoever to beekeepers, but it is a debate which will no
doubt run on and on for a very long time, and ultimately, through our
food purchasing patterns, will affect every one of us.
Murray
--
Murray McGregor
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