The Bottom line: Simple Comparative Analysis

 Bottom Line

Equitable Food Initiative is in essence a farmworkers label. Its approach to workers’ rights and participation meets the DFTA criteria expectations. EFI’s significant deficiencies and concerns are mainly ones of omission rather than commission; specifically, the absence of support for small scale farms and long-term, direct and fair trading relationships.

Associated Organizations: Andrew and Williamson Fresh Produce International; Bon Appétit Management Company; Calvert Investments; Center for Science in the Public Interest; Consumer Federation of America; Costco Wholesale Corporation; Farmworker Justice; Farm Labor Organizing Committee (FLOC); National Farm Worker Ministry; Oxfam America; Pesticide Actin Network North America; Pineros y Campesinos Unidos del Noroeste (PCAN); United Farm Workers (UFW)

Program Claim(s) in the program’s own language:  The Equitable Food Initiative certification program develops standards, training processes and a certification to protect farm workers and produce safer, healthier food…benefiting workers, growers, retailers, and consumers alike.

Labor standards cover worker health and safety, freedom of association, fair wages, benefits and conditions of employment, freedom from discrimination and retaliation, dispute settlement, employer-provided housing, a social premium, and protections for H2A workers.

Pesticide standards deal with the management of pests, soil, water and habitat. The standards promote an Integrated Pest Management approach to managing crops in order to minimize the use of highly hazardous pesticides. EFI requires full pesticide use reporting, including quantification of pesticide risks to workers and the environment.

Food Safety standards address accountability and record-keeping, water use, soil amendments, environmental assessments, animal controls, and post-harvest packing, storage, testing and transportation.

Resources used for review: EFI Certification Requirements Version 1.1;  EFI Compliance Criteria; MIT Living Wage Calculator; website; personal communications (email and phone) between DFTA staff and EFI staff.

Summary of DFTA findings:

Equitable Food Initiative does not present itself as a fair trade program. It has not claimed to be based on Fair Trade principles; has made no assertions or claims that it addresses price or fair transactions to the grower; or claims to benefit small or family-scale farmers in any specific way —scale anywhere along the food chain is not addressed by the program at all.  The DFTA, however, evaluates certification programs that make social or economic claims. Food Alliance made the very same point that it is not and does not claim to be a fair trade label, so this is not the first time the DFTA is evaluating such a program. EFI does have an explicit claim regarding fair working conditions: ‘Safe and Fair Working Conditions’ is one of its principal claims and, along with the benefits of its program to farmers and farmworkers, it is featured prominently on EFI’s website, materials, and in the general understanding of the program. It is for this reason—a clear social claim of fairness or justice – that the DFTA is evaluating EFI.

EFI is a comparatively new program. It certified its first farms and was also scheduled to release Version 1.2 of its Standards during the preparation of this evaluation. EFI is comprised of the following organizations, all founding members: COSTCO, the Consumer Federation of America, Andrew and Williamson Fresh Produce International, Bon Appétit Management Company, Calvert Investments, Center for Science in the Public Interest, Farmworker Justice, Farm Labor Organizing Committee, National Farm Worker Ministry, Oxfam America, Pesticide Action Network North America, Pineros y Campesinos Unidos del Noroeste, and the United Farm Workers.The EFI certificate is currently implemented by SCS Global, a California-based certification organization.

The organization’s mission is to “ensure a dignified livelihood for farmworkers; a stable and professionally trained agricultural workforce for growers; and a safer and more environmentally sustainable food for retailers and consumers.” Its label purports to “create a new level of assurance for retailers and consumers that food safety protocols are observed and that workers are treated fairly.”

In the areas of labor rights and worker responsibilities, EFI claims are comprehensive and most accurately meet DFTA expectations and goals for the domestic fair trade movement. Farmworker organizations, a significant stakeholder group, have been active participants in the program’s formation. Their continued participation seems integral to the program’s success. The unequivocal support for freedom of association and union recognition, however, does not diminish the need for written employment contracts. The Leadership Team concept exemplifies EFI’s approach and commitment; it is a mechanism by which workers have gained leverage in their relationship with their employer. This leverage is expressed most profoundly in workers’ involvement in the certification program itself -- especially in terms of verifying and enforcing the program standards-- exhibiting the markings of an open and transparent process. The Leadership Team has the potential for being a model worth replicating by other programs.DFTA looks forward to how the intensive training of the Leadership Team and of the entire workforce will create, in EFI’s words, the intended “opportunities for promotion and increased responsibility” and ensure “authentic” participation among all stakeholders on the Leadership Team. If EFI’s “anecdotal evidence” can be quantified, if not realized, then it may serve to bode well not just for EFI and its affiliated workers, but across the entire food system. We note, too, that the current selection process for determining members of the Leadership Team has yet been codified and for now, at least, this process is left to the workers on individual farms. How accurately all functional job categories and demographics can be and are equitably represented is of keen concern to DFTA. We acknowledge that this concept is a work in progress: EFI stated in its written response to DFTA’s evaluation that: One of the eventual pillars of our verification approach will be the “EFI 24/7” system whereby any worker on any certified farm will be able to share concerns or report issues of compliance that have not adequately been addressed by the Leadership Team or management on the farm. DFTA looks forward to this development, the specifics of its implementation, and EFI’s capacity to measure its success and effectiveness. This strong approach was why we initially thought the process may be compromised without the requirement compelling inspectors to conduct confidential, individual employee interviews as part of the on-site assessment. Further, the process may be compromised without a requirement confirming that such interviews will be conducted in a language primarily understood by the farmworker, and that workers and farmers both understand these interviews will be kept confidential. When this concern was raised and brought to EFI’s attention, the program acknowledged this “guiding principle” was indeed “overlooked” and absent in its scheme documents, and stated it would be codified and included for the next revision of its certification requirements. We look forward, then, to seeing these three concerns included.

EFI’s environmental approach is not so distinctive and is marked by inconsistency. EFI does not require certifications that promote environmental stewardship or organic certification, and does not address GMOs. It does, however, require of all operations the development of an Integrated Pest Management Plan. There is language that addresses manure and soil and water management practices, but not wildlife habitat, biodiversity, or sustainable practices. EFI does not explicitly ban any pesticides that are harmful to the environment or human health.

EFI’s initial and current decision-making body is composed of a 12-member self-defined steering committee reflecting the institutional make-up of the founding organizations (see above). The structure and representation of this body is expected to be reconstituted in the next year, expanding and broadening stakeholder participation to include an anticipated addition to the “grower” category, and inclusion of ‘environmental and independent groups,’ which will be nominated by the current steering committee. In the areas of governance and implementation, EFI currently falls short; for one, the by-laws are not on EFI’s website.  The standard-setting and revision processes do not include any formal process for public input and there is no clear process for the public or others to file complaints. This level of public involvement is considered less than the norm by most certification programs and falls below DFTA standards. Provisions are scheduled to be made for increased public consultation in the standard revisions process. The stakeholders who contribute to that process should be publicly identified. Other proposed changes — EFI is undergoing a change in its institutional status that is not expected to be finalized and implemented until April 2015— that could significantly alter its internal structure and its by-laws may warrant a reexamination of DFTA’s initial findings.

There is no prescribed number of indicators or thresholds that must be met for EFI certification. Rather, all non compliances, according to the program manager, must be closed prior to the issuance of a certificate. The requirements to maintain those performance levels in subsequent verifications, unfortunately, are also not comprehensive or clear. 

In answer to a series of questions on this subject the certification manager wrote: For the verification audits that happen during Year 1 & 2 a minimum of 66% of the indicators is required to be audited.  This selection of indicators is based on:

            NCs [Non-Conformities] that were identified (and closed) in previous audits

            Critical and Major indicators

            Information of possible NCs that have been received by the CB [Certifying Body] or EFI since the last audit through channels such as EFI 24/7.

In response to a follow up question on this matter the certification manager wrote: the role of the critical – major - minor designations during the verification audits will be further developed… This system has yet to be approved and fully integrated into the scheme but will be taken under full consideration during the upcoming scheme revisions.

In discussing the verification audits the program manager wrote: The smaller set of indicators that will be investigated during these audits will be chosen partially based on the classification with a heavy concentration on critical and major indicators. We are aware that the performance threshold of EFI is extremely high and, for many operations, requires significant culture change.  We are monitoring closely if our current 100% pass is the best model for measuring what, in some cases, will be a long process perhaps better measured through continuous improvement metrics.

DFTA recommends that clarity on this matter be given priority during the revisions and EFI utilize the revision process to seek input from a plethora of stakeholders, and other programs, with the goal of strengthening its standards, not weakening them.

The freshness of the EFI program and its avowed declaration of not being a fair trade program present new dimensions for a DFTA evaluation. In light of that, DFTA staff is especially appreciative of EFI’s level of cooperation at this juncture; acknowledging both its transparency and recognition that refinement and improvement will come. The domestic fair trade movement is the better for that. EFI has written: “We are fully aware that the EFI scheme remains a work in progress. But we made the strategic decision to start the certification process nonetheless, in the knowledge that only by beta-testing our scheme would we gather the data and observations necessary to refine and improve it. We have been as transparent as possible in acknowledging where we are in the development of the scheme, and the role that beta-testing plays in engaging new stakeholders and preparing for revision of the standard and scheme in 2016.”

DFTA hopes such awareness during its upcoming program development and revision processes will extend to continual improvement in other areas as well. DFTA also hopes EFI considers how to apply aspects of domestic fair trade in a broader context as it continues to address issues of social and economic justice. In a follow-up correspondence about our suggestion to include a “glossary of terms,” EFI reported that a “draft vocabulary document (was) developed that will be going to the Scheme Committee on February 3 for approval ahead of public dissemination. To your point, this will benefit the audiences of our documents greatly in understanding the minutiae of the scheme.” DFTA applauds this decision.

Domestic fair trade should represent substantive and qualitative differences from the conventional food and agricultural system, benefitting the most marginalized - workers as EFI does - and also small-scale producers and farmers. At EFI, farmers and buyers are already coming to the same table and building relationships, but nothing is formally required to ensure they will be fair, stable and long term. EFI could utilize this strong mechanism that is already in place for meaningfully and productively creating practices such as: the sharing of added value; shared risk and affordable credit; provisions for farmers to receive fair and prompt payments; and the development of stable relationships that include contracts and agreements established before the harvest, or that extend beyond one season.

DFTA encourages EFI to leverage what it has done well and to consider how the domestic fair trade movement could be supportive of these ideas and suggestions. In including the suggestions, the entire movement, and the agriculture and food system, will benefit.

 

 

Key to Chart
The program is exemplary and meets the DFTA's criteria expectations. The program has some innovative approaches to this issue that may serve as a model.
The program appears to have a comprehensive approach to this issue in general alignment with DFTA criteria. There are some concerns or issues to highlight regarding the program's approach to this issue.
The program addresses this issue and may meet some of the criteria, but significant concerns, questions, or shortcomings compromise the approach. There is inadequate information or outstanding questions preventing a reliable assessment of the program's approach to this issue.
The program either does not address the issue at all, or clearly fails to address it in a manner consistent with DFTA criteria. Not applicable / not addressed by program
Summary Indicator
Summary
1. Supports small scale and/or family farms
2. Ensures decent working conditions for farm and food workers
3. Supports long-term, direct, and fair trading relationships
4. Adequately restricts materials and practices that are harmful to people and the environment
5. The program is implemented well and has thorough monitoring in place

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