Additionally, two of the standalone standards were excluded from the analysis: Marks & Spencer’s ‘Field to Fork’ was excluded entirely because an audit checklist could not be obtained for review, and GlobalG.A.P. was excluded from analyses of farmer opinions and practices because only four farmers in my survey results for either nation claimed to carry this certification. The results presented here represent a combination of personal interviews and archival research, conducted during field research between 2014 and 2017 in multiple locations across California, and the United Kingdom. I report here the results of two different survey efforts. The first survey, piloted and released in 2014 to members of the California Farm Bureau Federation, yielded data for forty-nine California lettuce growers as part of a larger survey effort covering 965 California growers of a range of crops . This survey was designed to update prior 3 scholarship examining food safety measures among California farms since 2007. For the purposes of my research, I conducted five additional in-depth interviews with California farmers, two with regulators, and three with academic researchers to contextualize the results of that broader survey and inform my analyses of the responses of lettuce farmers who took part. The second survey reported here includes data from twenty-one in-depth interviews I conducted with UK farmers of leafy greens, designed to mirror the structure and topics of the survey delivered to California farmers. Further information is provided by nine additional in-depth interviews with representatives of major UK grocery retailers, academic researchers, indoor grow methods farmers’ trade associations, and food safety regulatory personnel, conducted in the United Kingdom between Summer 2014 and Spring 2016.

In-depth interviews during both research efforts followed a semi-structured format tailored to each interviewee’s unique position of knowledge within the food system, focused on elucidating the mechanisms behind how decisions are made at both the regulator and food retail industry level, what food safety and environmental pressures farmers experience, and in what ways differential value is placed upon food safety goals and environmental outcomes. Both farmer surveys contained approximately 30 questions, ranging from farm area and crops grown, to perceptions of the food safety regulatory framework, to field level management practices in place for food safety or for the promotion of environmental protection. Full interview questionnaires for my California and UK survey efforts can be found in Appendices I and II, respectively. To understand the social impact of overlapping state and non-state food safety controls, respondents were asked to specify what, if any, food safety certifications they currently held, and how they felt about the certification process and the public regulatory landscape around food safety. Farmers were additionally asked to assess which actors in the lettuce supply chain held the most power in setting field-level farmer practices, and in shaping the overall food safety regulatory landscape. Field level production practices were analyzed quantitatively, by assigning each farmer scores for food safety and environmental conservation. Interviews conducted in person followed the general structure and questions of the survey questionnaires, while also incorporating additional questions and further exploration of survey topics led organically by interviewees’ interests and expertise. To supplement data from interviews and survey results, I also present insights from an analysis of regulatory styles found in state and non-state food safety controls. To compare methods of state regulation of food safety across the United States and United Kingdom, I evaluate the most relevant food safety laws in each nation for their regulatory style and topics of primary focus.

To illuminate the landscape of non-state food safety standards, I present a comparative analysis of the structure and written requirements of eleven produce safety standards operating across the UK and California. Each standard was evaluated through its certification audit checklists, by assessing each audit clause or certification criterion within the standard for its topic focus and its regulatory style , enabling a quantitative comparison between standards. To compare the regulatory landscape emerging from the overlap of these state and non-state controls, I compare the approaches of both private and public food safety controls by organizing them into four categories based on focus and style. Because the two farmer surveys summarized in this dissertation were conducted during separate field seasons and survey efforts, the total number of respondents for each survey is not equivalent. Twenty-one UK leafy greens farmers were surveyed, compared to 49 US farmers. These differences reflect differences in response rate, as well as limitations due to amount of time in each location and different recruitment methods. In addition, because participation in data collection was entirely voluntary on the part of farmers, not all survey respondents chose to answer all questions on the survey, with the end result that the number of responses analyzed from each respondent group varies slightly from question to question on both surveys. Survey questions themselves also differed in some respects between my US and UK surveys. The survey instrument used for UK farms used slightly different language from that used in California, an intentional step designed to adjust for local differences in terminology related to various practices, as well as different local concerns, local policy bodies, and local supply chain structures. As a result, some information is reported for only one study population, and any comparisons of non-parallel data types will be clearly noted. Additionally, all reasonable efforts were made to ask questions in locally appropriate language and terminology for each study population, resulting in slight variations in wording between the two surveys.

Rather than increasing differences between the surveys, these adjustments were intended to reduce variation resulting from differences in language, and to ensure that variation observed was a faithful representation of actual practice and actual perceptions of governance institutions.This study focused on evaluating public and private standards and their impacts on farmer practice and farmer decision-making as a result of produce standards and regulations. Because my focus was on farmer experience, and farmer decisions in the realm of environmental conservation—the ultimate outcome of multiple overlapping governance forces as seen by farmers rather than by regulators—I did not specifically investigate details of how the preregulatory risk assessment scheme Red Tractor Assured Produce and the industry-led harmonization effort by the British Retail Consortium may influence the form that public regulation takes in the UK, or the articulation of public and private regulatory processes. Rather, I have evaluated those two standards at face value as component standards within the regulatory landscape, because that is how farmers experience them. For similar reasons, I have compared the explicitly pro-environmental Linking Environment And Farming standard alongside other non-state food safety controls with fewer explicit references to environmental conservation because farmers indicated that they regard LEAF as a safety standard comparable to any other I examined. My analysis acknowledges and aims to engage these differences as a meaningful indication of how environmental conservation is valued by a range of food safety controls active simultaneously in the lettuce production market.As a starting point for my comparison, I examined the state regulatory frameworks in place for produce food safety in the United Kingdom and United States. At the time of this research, the UK was a member of the European Union, meaning that national food safety regulation in the UK is shaped by EU requirements, and vice versa, in a shared governance arrangement that incorporates a multi-level strategic bargaining process and two-way transfer of priorities . The top levels of EU food safety regulation take two different forms: regulations and directives. Regulations apply to member states directly, cannabis dryer without any need for member states to create local interpretations. Directives, conversely, are general guidelines which member states must adapt to local contexts and implementation systems. Food safety goals are articulated here as broad principles which are meant to guide member states’ actions as they construct action plans specific to their industries and local administrative authority structures. Action plans must fit within the broad principles set forth by European Food Safety Authority , but must put them into practice by providing enforceable local regulatory specifics. Beginning at the highest levels of state regulation applicable for leafy greens production in the United Kingdom at the time of this research, European food safety rules are presented in Reg EC No 178/2002. This regulation standardizes food safety goals and definitions for EU member states and forms the backbone of the European food safety system. The regulation does not specifically address food safety concerns in individual foodstuffs or their respective supply chains, but rather focuses on establishing basic terminology and expectations, along with the procedure to be followed in cases where problems are known or suspected.

The regulation’s stated goals of “a high level of protection of human life and health and the protection of consumers’ interests, including fair practices in food trade, taking account of, where appropriate, the protection of animal health and welfare, plant health and the environment” makes explicit mention of a range of parallel goals that must be considered as part of food safety, including environmental health. Use of the precautionary principle is explicitly defined as a guideline for maintaining the safety of the food supply, along with risk analysis. Food businesses such as producers, processors, and manufacturers and retailers of food items are stated as the ideal controllers of food safety because of their proximate knowledge of any risks and appropriate solutions. Traceability is also elaborated as an important prerequisite of ensuring safe food. Article 18 of the regulation reads “The traceability of food, feed, food-producing animals, and any other substance intended to be, or expected to be, incorporated into a food or feed shall be established at all stages of production, processing and distribution.” UK food safety regulation within this European framework is layered beneath EU controls and is predicated on the UK’s 1990 Food Safety Act. The law makes no mention of produce or specific pathogens, following instead the general style of EC regulation in setting goals, definitions and procedures to be followed in the event of a problem. Section 7 of the act names as an offense “rendering food injurious to health” . In cases 4 where food has been sold that is injurious to health, the state can prosecute the provider of that food item under the law. Several defenses are listed which can absolve a food business of criminal responsibility, most notably the defense of due diligence, defined as “a defence for the person charged to prove that he took all reasonable precautions and exercised all due diligence to avoid the commission of the offence by himself or by a person under his control” . A subsequent law, the Food Standards Act 1999, established the UK Food Standards Agency and outlined its role as the controller of food safety within the United Kingdom. Pursuant to these two acts, the FSA has released numerous fact sheets and guidance documents interpreting the 1990 Food Safety Act for owners of food businesses. In a 2009 guide for food businesses, FSA presents examples of situations and actions that the 1990 Food Safety Act would apply to, and explains that the concept of due diligence is designed to protect both consumers and businesses. In their words, the due diligence defense is “designed to balance the protection of the consumer against defective food with the right of traders not to be convicted of an offence they have taken all reasonable care to avoid committing” . The FSA fact sheet Monitoring microbial food safety of fresh produce released in 2010 contains basic information on the names and risk factors for certain food pathogens with guidance for produce farmers in avoiding or reducing the potential for pathogen transmission through food products. The document emphasizes that there are “no statutory criteria for indicator bacteria on unprocessed fresh produce” and thus no specific microbiological targets that are required by law for fresh produce. Key practices recommended for maintaining microbial safety in produce include the use of potable water for irrigation, regular testing of water sources, avoiding the application of raw uncomposted manure on crops that are typically eaten uncooked, and minimizing the degree of contact between irrigation water and the edible portion of crops.In comparison, in the United States, government food safety is managed through a similarly multi-level array of federal, state and local bodies, with requirements that become more specific and enforcement-oriented at local levels.