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A disjoint constitution between inspectors, processors, and consumers and the cider industry in Michigan. Toby A. Ten Eyck,1 Donna Thede,2 Gerd Bode,3 and ...
Ó Springer 2006

Agriculture and Human Values (2006) 23: 205–214 DOI 10.1007/s10460-005-6107-4

Is HACCP nothing? A disjoint constitution between inspectors, processors, and consumers and the cider industry in Michigan Toby A. Ten Eyck,1 Donna Thede,2 Gerd Bode,3 and Leslie Bourquin4 1

Department of Sociology and the National Food Safety and Toxicology Center, Michigan State University, Michigan, USA; Nutrition & Regulatory Affairs, Kellogg Company, Michigan, USA; 3Division of Cancer Prevention, National Cancer Institute, National Institutes of Health, Bethesda, MD, USA; 4Department of Food Science and Human Nutrition, the National Food Safety and Toxicology Center, and Food Safety Policy Center, Michigan State University, Michigan, USA 2

Accepted in revised form March 4, 2005

Abstract. The transmission of a product or idea from one culture or point of origin to another and the maintenance of control outside the new locality has been referred to as the distribution and maintenance of ‘‘nothing.’’ This perspective has been used to describe the global marketplace and the influence of large multinational corporations on the politics and cultures of host countries. This paper uses this concept, but within a much smaller context. Using the sensitizing concept of a ‘‘disjoint constitution,’’ we interviewed health inspectors and apple cider producers in Michigan to determine if the implementation of the Hazard Analysis and Critical Control Points (HACCP) program designed to ensure food safety was characterized by a power differential that would favor the inspectors. In addition, a larger survey of processors and an internet survey of apple cider consumers was conducted to supplement this data. It was found that HACCP had characteristics of both ‘‘nothing’’ and ‘‘something’’ and that better communication is needed between these groups to move it further along toward the something end of the continuum. Key words: Cider industry, Communication, Food safety, HACCP, Michigan Toby A. Ten Eyck is an Associate Professor in the Department of Sociology and affiliated with the National Food Safety and Toxicology Center at Michigan State University. His work focuses on the development, dissemination, and interpretation of mass media risk messages. Donna J. Thede completed her Ph.D in Food Science partially through this research project and is now a Senior Scientist in Nutrition & Regulatory Affairs with the Kellogg Company. Gerd Bobe conducts research on nutrition and cancer as a fellow in the Cancer Prevention Fellowship Program, Division of Cancer Prevention, National Cancer Institute, National Institutes of Health (Bethesda, Maryland). Previously, he evaluated food safety policies for the Department of Food Science and Human Nutrition and the National Food Safety and Toxicology Center at Michigan State University. Leslie D. Bourquin is an Associate Professor in the Department of Food Science and Human Nutrition and is affiliated with the National Food Safety and Toxicology Center and Food Safety Policy Center at Michigan State University. His research examines factors influencing the effective implementation of food safety standards and the ultimate impacts of these standards on public health.

Introduction Ritzer (2004) has argued that the transmission of a product or idea from one culture or point of origin to another without taking into consideration the cultural and social landscape of the other is the distribution of nothing, especially when control of that entity continues to be centrally located. Ritzer’s stage is the global village and

his targets are often large multinational corporations, but this same phenomenon also can be found on a smaller scale. This paper focuses on what three different groups – inspectors, apple cider processors, and consumers in Michigan – know about a food safety program that is now required for cider processors to wholesale their product. The program, Hazard Analysis and Critical Control Points, or HACCP (pronounced haÆsip), grew out of a

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need to provide safe food for the National Aeronautics and Space Administration (NASA), including the elimination of pathogens, toxins, and foreign objects from food and beverages. HACCP was required previously in the US seafood and meat packing industries. In January 2004, it also was required for all cider processors who had wholesale accounts. According to the National Advisory Committee on Microbial Criteria for Foods, HACCP is defined as ‘‘a systematic approach to the identification, evaluation, and control of food safety hazards,’’ and a HACCP Plan is ‘‘the written document which is based upon the principles of HACCP and which delineates the procedures to be followed’’ (NACMCF, 1997: under ‘‘Definitions’’). This plan requires that processors develop a flow chart to pinpoint places where problems could arise during the manufacture of their product, keep records of what is being done to minimize risks, have a kill step for microbial contaminants if applicable, and then have both the flow chart and records periodically checked by inspectors (Satin, 1999). The impetus behind HACCP requirements for the juice industry stems from a series of outbreaks associated with juice products, the most notable being a 1996 outbreak linked to unpasteurized cider manufactured by the Odwalla Company which contained E. coli O157:H7 (Postlewaite, 1999a, b). The idea that these regulations constitute ‘‘nothing’’ stems from the notion that the program was developed by individuals and organizations outside the industry who required it to be adopted without taking into consideration nuances specific to the industry. In addition, while cider processors are asked to develop their own HACCP plans, the final approval of their plans, as well as their implementation and regulation, falls under the control of state and federal health inspectors. It is not our intention to blindly criticize the HACCP policy. Instead, we seek to understand its implementation, including barriers, within an industry that is characterized by small processors who are often independent and work in small, family-owned businesses where the product being regulated is often only a small portion of their operation. We discussed the HACCP policy with cider processors and state inspectors and asked consumers about their perceptions though an online survey. We adopted the sensitizing concept of a ‘‘disjoint constitution’’ to better articulate the gap between these various groups, which also helped us to better understand the power differentials involved. Before discussing our findings, we offer a more complete discussion of nothing and the concept of a ‘‘disjoint constitution.’’

Nothing, constitutions, and power It is difficult, if not impossible, to describe nothing. To be nothing, there could be no description; nothing can be

said of nothing. Even a void is something, as Ritzer (2004) mentions when referring to a vacuum. So, we begin with a similar qualification. Nothing, in this text, refers to an event or situation in which local circumstances are not taken into account when introducing something from a different locality, and control of that entity is maintained in a central location. The concept of nothing, however, is difficult to conceptualize and operationalize given its common usage in everyday language. For that reason, we borrow the concept of a disjoint constitution from Coleman (1990), which refers to a situation in which one group develops and enforces a set of rules that other groups must follow, despite the fact that they have had little or no input into their development. Nothing, as a result, revolves around issues of power and control. Power, according to Lenski (1973), is the ability to make change in the face of resistance. The ability to make change is typically the outcome of control and the successful mobilization of resources. Resources can include economic, social, or cultural capital (Bourdieu, 1984) with success and acceptance of change often embedded in being able to use all forms of capital, which translates into cultural resonance (Gamson, 1992). While not explicitly stated, disjoint constitutions can be found in many parts of the social landscape. Work on the Gay Rights Movement, for example, found that power or change only comes when a group is able to challenge a dominant text that has been placed upon it by others (Bernstein, 2003). A ‘‘constitution’’ is nothing if subordinate groups accept the text from those above them and can do little to modify it. Because their own culture and individual needs play little part in developing the rules by which they will abide, the dominant group continues to hold a privileged position. Modernity is often described as just such a social environment, one in which institutions control much of our everyday activity (e.g., Giddens, 1991; Beck, 1999; Agger, 2004), and the larger the institution (e.g., multinational corporations), the more likely their rules will be found in other systems (Ritzer, 2004). This compliments Ritzer’s idea of nothing, as subordinate groups are expected to follow rules for which they were not consulted, and enforcement is maintained elsewhere. It should be clear that we are not discussing the inability of local groups to make sense of this new situation, but rather that they have little say over the centralized control of the introduction and maintenance of the intruding entity. Given that our focus is on gaps between groups connected to cider production in Michigan and levels of power wielded by these groups, the disjoint constitution becomes central. Such situations can and do change through strategies of exit and voice (Hirschman, 1976), though such a display of emotions and concerns is indicative of the arrival and awareness of nothing. In addition, those voicing concern or exiting must have

HACCP implementation in Michigan resources that are deemed important by the centralized power structure. Otherwise, these actions will have little impact. If HACCP is an example of a disjoint constitution, especially between inspectors and processors, we can expect that the implementation of this program will be difficult as processors will question its legitimacy. The question then becomes whether or not they control resources that are deemed important by regulators. A caveat at this point is in order. HACCP is not the first regulation imposed on cider processors. Federal and state regulations have been part of the food industry in the US since the late 1800s (Goodwin, 1999), and many debates have been waged between various food industry actors and regulators over a myriad of topics (Ten Eyck and Williment, 2004). Thus, the idea of a disjoint constitution for these people is not new. The principles of HACCP, however, are new in the sense that processors are being asked to develop their own plans, which will then be given the stamp of approval by someone outside the industry.1 With this background, the conceptual and methodological frameworks are set. We will investigate the ways in which the HACCP program has been introduced into the cider industry in Michigan. Our purpose will be to get a sense of how the rules and regulations of this program fit within that industry and how those enforcing the rules have offered exceptions or opportunities, if any, to the rules. We also will ask consumers if the HACCP program has meaning for their own behaviors, since they, it has been argued, are the reason for the change. We now set the context for the study by offering a brief overview of food safety from a social science standpoint and give further information on the HACCP program.

Food safety as a social issue Food has been part of the sociological enterprise for some time, though it has only recently gained prominence as a topic of inquiry in its own right (Beardsworth and Keil, 1997). There is still some ways to go, however, as the term ‘‘food safety’’ does not appear in a preliminary search of article titles (using JSTOR) of the top three sociological journals – American Journal of Sociology, American Sociological Review, and Social Forces. Food, however, can make people sick, and it is thought that nearly 70% of all foodborne pathogens are introduced through human intervention (Chinsman, 1987). In addition, food safety issues have an impact on perceptions and choices in the marketplace (Ten Eyck, 2000), and regulations and opportunities for retribution are made to minimize the risks involved for actors throughout the food commodity chain (Robeck, 1996). Estimates of foodborne illnesses and the social landscape in which people play the sick role offer opportunities to better understand how and when political and

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medical intervention would be appropriate. As is often the case, science and legislation are outpacing social research, and new food safety programs have been developed and imposed on various processing industries with little thought to how they will be accepted. HACCP for juice beverages – and the high priority for HACCP among food safety agencies and inspectors – is just one such example. The HACCP program evolved out of procedures followed by NASA to provide safe foods for astronauts while in space. Both the United Stated Department of Agriculture (USDA) and the Food and Drug Administration (FDA) have adopted HACCP as the best program to prevent foodborne illnesses (O’Donnell, 1994). Seafood processors were the first food handlers to have a mandate for HACCP put in place in 1995 (Dowdell, 1995). Meat processors and juice producers also are either required to have HACCP programs in place, or will shortly (LaBell, 1996; Butler, 2001). Finally, HACCP is the control system recognized by the Codex Alimentarius Commission and is the standard for international trade. HACCP, according to Satin, is meant to get food processors to ‘‘focus on identifying and removing all hazards within the production and distribution system that could result in food-borne disease outbreaks’’ (1999: 166). This can include the temperature of food/ingredients when they arrive at a processing plant, holding temperatures, and the temperature of the food as it is leaving the facility. It can include schedules, procedures, and chemicals for cleaning equipment, employee hygiene practices, cooking procedures, and packaging materials. One of the advantages (though some also argue that this is one of the major disadvantages) is that the implementer (i.e., the processor) is also the guiding force behind the HACCP plan. While health/government inspectors can offer some insight into the structure of the plan and tell plant personnel if it is adequate or if the processor is in accordance with the plan, the burden of the development, implementation, and maintenance of the HACCP plan falls on industry (McSwane et al., 2000). This quasi self-regulation is a form of disjoint constitution. While the processor is being told to follow HACCP, s/he is given some leeway for how the specific program is to be developed. Whether or not this will minimize the friction of change and help improve the relationship between processors and inspectors is a point we hope to investigate. In addition, we are interested in assessing whether consumers have any knowledge about the program.

Data and methods This study was funded by the USDA and focused on the development, implementation, and impacts (e.g., public

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health) of HACCP programs within Michigan cider mills. The project consisted of testing cider samples for pathogens, indicators of microbiological contamination and patulin,2 in addition to studying the social aspects of HACCP. Interviews with 11 processors took place during the summer of 2002 and were supplemented by a mail survey of processors conducted by the research team during September 2002. An internet-based survey was conducted by Market Facts, Inc. in the Fall of 2002, focusing on consumers who had purchased and consumed apple cider in the past 12 months. Finally, seven Michigan State Department of Agriculture (MDA) inspectors were interviewed in the Winter of 2003. According to MDA records, there were 199 active cider mills in 1997 and 110 active mills in 2002. We were given the names of 134 mills by the MDA in 2002. All mills were sent surveys in 2002 (20 of which were returned due to mailing problems). Of the remaining 114 surveys sent to processors, 54 were returned completed (47% response rate) and could be compared to data from the same mills in 1997. Processor surveys consisted mainly of questions concerning general manufacturing processes, such as the use of dropped apples, the frequency of equipment cleaning, and the use of chemicals in the apple washes. During the interviews, which were conducted both face-to-face and by telephone, processors were asked to think about HACCP with regard to its overall efficiency as well as to their own operations. Interviews were open-ended and tape-recorded. One shortcoming of the survey, given its focus on microbial concerns and general manufacturing practices, was that it did not retrieve typical sociodemographic data, such as gender. Our experience interviewing processors and collecting samples from the cider mills for laboratory analysis, made it clear that this industry is dominated by males. However, a majority of the mills currently operating in Michigan are run by families, and both husbands and wives (and older generations and in-laws) have some say in the running of the business. The male–female/family dynamics of the mills is beyond the scope of this paper, though we did get some sense of gender issues regarding mixed sex processor-inspector interactions. We cannot provide a precise measure of how widespread such interactions are, but we do offer some insights from the interviews we completed. Seven inspectors were also interviewed in an open-ended format, with notes being taken during and after the interviews. These inspectors covered a total of 47 cider mills in Michigan. Five individuals involved in the project were present during these interviews, which took place during an annual meeting of MDA. The consumer survey was conducted by Market Facts, Inc., a company that conducts surveys using various approaches, including internet-based surveys (www. marketfacts.com). The survey focused on consumer

behavior and was given to 1000 Michigan residents. Of these, 497 said they had purchased and/or consumed apple juice or cider over the past 12 months. Questions were asked regarding their perceptions of safety, freshness, and other quality issues of cider/juice as well as pasteurization and HACCP. Findings from all studies are discussed and compared below.

Findings Inspectors We begin our discussion from the standpoint of the inspectors, as we assume they are closest to the government agencies that promulgate and enforce food safety regulations in the food industry. First, we were interested in whether inspectors thought HACCP was needed for the cider industry, though it should be noted that these inspectors mainly have been trained to give advice and not solutions to processors with regard to HACCP. Because these inspectors investigate many different food establishments, we thought they might have some insight into how HACCP would apply to the cider industry. Effective HACCP implementation did not seem to be a concern, as inspectors felt that many of the ‘‘problem’’ mills had closed for various reasons over the past decade and that most of those still in business either had taken steps toward implementing a HACCP plan, would discontinue their wholesale accounts (and thus be exempt from the HACCP regulation), or eventually shut down. In short, they felt that HACCP implementation would be relatively easy given the current situation in the Michigan cider industry. Since we had already spoken with some cider mill owners and managers, we knew that their views were not in accordance with those of many of the processors. As a result, we focused on what happened when someone asked for guidance in developing a HACCP program. Since the seven inspectors we interviewed inspected 47 of the 134 mills listed on the MDA mailing list, their instructions would have been heard by over one-third of the mills in (legal) operation in Michigan. Their two main pieces of advice were (1) find out what others have done through the internet, and (2) consider operators to be experts and thus in the best position to develop a HACCP plan. This assumes that the mills have internet access (most do), and that the operators would know where to look for other HACCP programs that would be appropriate for a cider mill. That those plans are readily available and/or easily accessible is open to interpretation. In addition to the internet consideration, the notion that mill operators are in the best position to construct a HACCP plan presumes that these people are knowledgeable about food safety and that they are willing to

HACCP implementation in Michigan put their livelihoods on the line for a program they might not endorse. Given that the inspectors had regulatory power over the mill operators, we were led to ask how they would know if HACCP was not being followed and what would cause an inspector to close down a mill. We found very little consensus – a condition that may have created mixed messages within the cider industry. In fact, the range of responses offered insight into how inspectors differ from one another, either because of what they have seen or what they think of as hazardous. A couple of the inspectors mentioned the hygiene of workers and the general working area; another mentioned pests such as mice. Yet another mentioned that animals close by (e.g., horses or cattle) would cause him to question the cleanliness of the mill. One inspector mentioned that some processors would let their household pets run through the processing area, something he saw as a problem. Another mentioned concerns with petting zoos that were in close proximity to the processing area. This shows that not only are inspectors approaching mills with varying concerns, but that they seem to be unaware of the importance of farm diversification and agro-tourism (e.g., Edmond et al., 1993; Bowman, 2004). Petting zoos and animals were not seen as tourist attractions that helped the farmers bring in customers, but as safety concerns. This concern, however, may not be out of place given the connection between animal fecal matter and E. coli O157:H7 contamination. These inspectors also mentioned that some smaller processors were worried about the costs of extra paperwork and the equipment needed to treat cider to be in compliance with HACCP regulations. In the end, however, inspectors believed that the situation was under control. They found that some of the smaller producers who had wholesale accounts were either going to give them up, were thinking about buying equipment to treat the cider, or were trying to come up with ways around the regulations (one inspector said that a mill operator asked if trading cider for something else from another store was considered wholesale). These inspectors said that much of this had worked itself out over the past 5–10 years in that many of the marginal mills had gotten out of the business after 1997. Processors If HACCP is nothing and signified through a disjoint constitution, then we must find evidence that cider processors feel that it is inappropriate for their operations and are concerned about having little say in its implementation and enforcement. While such sentiments were not hard to find, it should be pointed out that this view was not unanimous. A few processors said that their relationships with inspectors were good, and one, after being asked about his initial reaction to HACCP said,

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‘‘something has to be done. We already were doing a HACCP thing, so this was not much of a problem.’’ Others, though, were not so positive. The first interview was done with the wife of a processor in the northern part of Michigan’s lower peninsula. When first contacted and asked about HACCP, she told the interviewer that she and her husband had already said everything that needed to be said to their inspector. In short, the issue of HACCP was not welcomed with open arms. When this processor became aware that the interviewer was not another inspector or a state employee, but conducting research on HACCP implementation, she said, ‘‘government is overstepping its boundaries. They know nothing about this industry, yet they are setting the rules.’’ Since this person had nearly 40 years of experience in the business, we decided to ask if she felt inspections were necessary. She said, Inspections are important, but they need to be done by people who know the industry. Those government people who are sitting at their desks making big money will never become farmers, because farmers don’t make any money. Later, when asked if she were an inspector what would she look for, she explained, using her own business as an example: We got written up for two things – an unwashable ceiling which is 13 feet off the ground, and we once had some black mold in one of our coolers. We cleaned that up and painted the whole inside of the cooler to make sure it doesn’t happen again. Still, every time the inspector comes in, it’s like someone walking in with a gun. Everyone is on pins and needles, and that’s not a good situation. We should be working together, not against each other. They should reward us for doing things right. The perception of a disjoint constitution is clear in these statements. While inspections were felt to be important (i.e., mills and other food processing and retailing outlets need to be checked), the people conducting the inspections were not felt to be knowledgeable about the business. They were perceived to have made the rules, and the rules themselves were controlled in a centralized location (where people put their feet up on their desks). Any potential information that inspectors would be able to provide would likely be viewed as suspect, as these inspectors were perceived to be outsiders and not familiar with the detailed workings of a processing facility. This solipsism was evident with most processors, even those who felt they had a good relationship with their inspector. As one processor said (after saying he got along fine with the inspector), ‘‘this guy was just up the street looking at a 7-11, and after he gets done with me, he’ll go inspect a restaurant. I can’t expect him to know what I’m doing, and it’s often the case that

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I’m educating him.’’ According to the processor, this meant that there were times when the inspector asked about a certain procedure that would make sense in another setting, such as a convenience store or restaurant and was curious about why a cider mill was different. This same processor also felt that inspectors over the years would come to his business either with a chip on their shoulder (this person said he had problems with past inspectors, specifically a female inspector), or had been told to look for something specific by their supervisors, and so were ‘‘just out to find something wrong so they could make a good impression.’’ It is unfortunate that we did not gather more information about gender relations within these interactions. We did get a small glimpse into possible problems when interviewing female inspectors and male processors, as there seemed to be a tendency for male processors to be concerned with female inspectors, and vice versa. This is not surprising given the literature on gender and power (e.g., Ridgeway and Smith-Lovin, 1999), especially in this agricultural, blue-collar context. As Ridgeway and Smith-Lovin made clear, one must make a distinction between structural and gendered effects when investigating interactions between men and women in such contexts, as we are socialized to take both into account. The fact that discord seems to be more prevalent, or at least taken to a higher level, between female inspectors and male processors calls for more research and thought about what this means for regulatory and enforcement processes. We would predict that gender could be a barrier to HACCP implementation, but examining that cultural barrier is beyond the scope of the present study. While the structural and contextual variables that may block or promote the acceptance of regulations do need further investigation, it became clear that the disconnect between inspectors and processors was evidence of a disjoint constitutional arrangement. The awareness of a disjoint constitution does not automatically mean that people will find it inappropriate. As mentioned, some processors felt that the HACCP rules were appropriate, or that since they were already taking steps in that direction, that the new regulations would not be much of a burden.3 These processors tended to be the operators of larger facilities. Smaller processors, by contrast, were not as willing to say that all was fair. As one of the smaller processors

explained, ‘‘I would lose half of my customers if I pasteurized, and I will lose half of my customers if I don’t. The extra cost of pasteurizing doesn’t make sense to go that route.’’ Juice HACCP requires a performance standard that includes a 5-log reduction in the pertinent pathogens of concern, though a specific technology or process was not exclusively advocated in the regulation.4 Currently, a number of technologies exist, such as thermal pasteurization and UV light treatment. Equipment for the former tends to be more costly, as one processor who bought used heat pasteurization equipment was quick to tell us. The concern with extra costs without extra benefits was echoed in a number of interviews, though some processors knew of the costs, but thought they would benefit in the long run from purchasing and using some kind of treatment equipment. This becomes clear in the processor survey. Table 1 shows how the 54 processors we surveyed felt about HACCP implementation and what it would do for foodborne illnesses and their own operations. Nearly half (48%) disagreed with the statement that HACCP was necessary for cider safety, though 31% agreed with the statement. Thirty-five percent agreed that HACCP could reduce the incidences of foodborne illnesses in cider, as compared to 32% who disagreed (though this still leaves a third undecided). Also, during a focus group session with processors prior to beginning the interviews, we were told that HACCP would be appropriate for some mills (‘‘There’s always a bad apple in every batch, and then all of us pay for it’’), though not necessarily their own. That some processors thought HACCP could be useful highlights the fact that HACCP is something to some people. On the other hand, while processors were as likely to agree as disagree on the effectiveness of the program, they were much more likely to agree that it would entail additional costs – costs over which they would have little control. Seventy percent of respondents either agreed or strongly agreed that there would be unnecessary expenses (and no one strongly disagreed with that statement), and 60% either agreed or strongly agreed that it would result in unnecessary oversight from the government (i.e., inspectors), though 17% disagreed and 2% strongly disagreed. This pushes HACCP back toward the nothing end of Ritzer’s continuum, as he argues that the incursion of nothing is often accompanied by a sense of loss (2004).

Table 1. Processors’ perceptions of juice HACCP regulation. Statements

Strongly Agree

Agree

Neither

Disagree

Strongly Disagree

HACCP implementation is necessary to insure cider safety HACCP reduces the incidence of food-borne illness linked to juice consumption HACCP regulation results in unnecessary expense Juice HACCP regulation results in unnecessary oversight

8% 10%

23% 25%

21% 33%

33% 20%

15% 12%

27% 23%

43% 37%

14% 21%

16% 17%

0% 2%

HACCP implementation in Michigan The final component of processors’ perceptions and the nothingness (or somethingness) of HACCP relates to consumers. Processors are located between inspectors and consumers, so their perceptions toward the latter may give some indication of whether they think their customers actually know or care about this particular program. In a couple of interviews, processors were quick to say that their customers wanted unpasteurized cider because heating it changed the flavor. Table 2 shows the perceptions expressed in the survey. The first column in Table 2 shows the overall response rate to the statement, ‘‘HACCP will make consumers more confident.’’ The rest of Table 2 is split between processors who thought HACCP was necessary for cider safety, those who did not, and those who were neutral. As is readily apparent from the first column, only 16% either agreed or agreed strongly that consumers would be more confident, and a small majority (51%) either disagreed or disagreed strongly, while one-third were neutral. In addition, it was mainly those who thought HACCP was necessary for cider safety who also thought consumers would be more confident in the cider. The third column of Table 2 relates to nothingness. While nothing can lead to a feeling of loss, a true nothing raises no emotions. HACCP was something to those people falling within the second and fourth columns of Table 2. The neutral category, consisting of only 11 respondents, also tended to be neutral concerning the question about consumers – there were no emotions involved either way. HACCP was nothing to them. Of course one could argue that these people had mixed emotions towards HACCP or just did not want to answer the questions. This is possible, though it is just as plausible that they felt very little toward the program. If, in their minds, HACCP did have a story attached to it, and they were in control of its implementation and regulation, there would be more reason to think about it. Consumers The final component of this commodity chain, and the group that HACCP was meant to protect, is consumers. The motivation for applying HACCP to cider mills was

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an outbreak in 1996 of E. coli O157:H7, which proved fatal to one child who had consumed unpasteurized cider. Studies which focus on food safety in general have often found that consumers are concerned with the food supply (e.g., Unkelsday et al., 1998; Bruhn and Schutz, 1999), so one might assume that consumers are keeping track of the industry and its regulations. However, a number of processors contend that their customers want to continue drinking unpasteurized cider. As mentioned, any processor who has wholesale accounts must treat his/her cider in some manner, often interpreted as thermal pasteurization. Given the adamant standing of some processors against pasteurizing cider and the lack of public arena attention given to HACCP (106 articles appearing in US newspapers archived by Lexis-Nexis between 1994 and 2004 contained the term HACCP), we decided to ask Michigan consumers if they were even aware of HACCP and if they were at all concerned about the safety of their apple cider. Table 3 shows that HACCP was not widely known among the 497 consumers surveyed. While 70% of consumers said that pasteurization would decrease pathogens, only 20% thought of HACCP as a food safety program, and 72% had no idea what HACCP stood for. It is interesting to note that 21% thought unpasteurized juice would be organic and natural, and another 20% thought it would taste fresher. From this standpoint, the idea that consumers want unpasteurized juice stands on shaky ground. In fact, 67% of these consumers mentioned being very concerned about pathogens in their juice (data not shown). Given this lack of knowledge about HACCP but a concern with pathogens, it may be assumed that labeling information on the safety of the cider would prompt consumers to purchase it. Instead, consumers indicated that the label statement most likely to influence buying decisions was ‘‘100% juice.’’ This was chosen by 69% of consumers, followed by ‘‘fresh’’ at 55%. ‘‘Pasteurized’’ was chosen by only 31%, though 46% said they would like to see the statement ‘‘Passed Food Inspection’’ somewhere on the label. Processors not treating their cider to meet the performance standard required by the HACCP regulation are now required to put a label on

Table 2. Processors’ perception of consumers’ response to juice HACCP. HACCP will make consumers more confident in buying cider from mills

Agree strongly Agree Neutral Disagree Disagree strongly

Overall

6% 10% 33% 36% 15%

HACCP implementation is necessary for cider safety Agree (n = 16)

Neutral (n = 11)

Disagree (n = 25)

21% 22% 29% 21% 7%

0% 0% 70% 30% 0%

0% 8% 21% 46% 25%

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2%

On the other hand, many consumers did claim to be concerned about the safety of the food they were purchasing, and were interested in labeling statements indicating that the processor had done something to increase the safety of his/her product. The label, however, would mean little at this point if it mentioned HACCP, unless this was accompanied by a statement explaining HACCP. The gap, then, would seem to be between actual knowledge and a symbol, and not the desire to have a food safety program in place.