The Bottom line: Simple Comparative Analysis

 Bottom Line:

Overall Food Alliance Certified falls too far short of meeting what the DFTA considers to be a claim “fair working conditions” for the DFTA to recommend or support it.

 

Associated Organization: Food Alliance

Program Claim(s) in the program’s own language:

FA provides the food and agriculture industry with sustainability standards, evaluation tools, and a voluntary, third-party certification program based on these principles:

  • Protect, conserve and enhance soil, water, wildlife habitat and biodiversity
  • Conserve energy, reduce and recycle waste
  • Reduce use of pesticides and other toxic or hazardous materials
  • Maintain transparent and traceable supply chains
  • Support safe and fair working conditions
  • Guarantee food product integrity, with no genetically engineered or artificial ingredients
  • Ensure healthy, humane animal treatment
  • Ensure continual improvement of practices

Food Alliance suspended services for 6 months, from February of 2013 to August of 2013. Applications for certification have been accepted continuously since Septmeber 1st, 2013. 

Web link to program description/label/claim: http://foodalliance.org/

Resources used for evaluation: General Description of Standards, Food Alliance Producer Certification Program Standards and Procedures Manual, Whole Farm/Ranch Inspection Tool, Handling Operation Program Standards and Procedures Manual, Food Alliance website, Handler Application, FA Sustainability Standard for Nursery and Greenhouse Operations, FA Sustainability Evaluation Tool for Nursery and Greenhouse Operations, Evaluation Tool for Wildlife Habitat and Biodiversity Conservation / Wildlife Habitat and Biodiversity Conservation v1.0 (2012), Food Alliance Nursery and Greenhouse Production: Greenhouse Operations v1.0 / Evaluation Tool for Plant Production: Greenhouse Production v1.0 (2012), Evaluation Tool for Plant Production: Field Production v1.0 (2012), Evaluation Tool for Safe and Fair Working Conditions v1.0 (2012), FA Sustainability Standard for Farmed Shellfish Operations (2012); personal communications (email and phone) between DFTA and FA

In addition there are a number of crop-specific documents which DFTA has examined some sampling of, as well as requested FA to indicate if any crop-specific standards might alter the outcome of this evaluation, which at this time does not appear to be the case.

 

Summary of DFTA findings:  

Note: In February 2013 Food Alliance (FA) suspended its operations.  According to FA all certified operations were able to continue to use the seal through December 2013. In September 2013 FA announced that it had secured adequate funding and support to reactivate its certification program.  DFTA may have to amend this evaluation based on any changes made to the program going forward.

FA has not claimed to be a fair trade program or to be based on Fair Trade principles, and has made no assertions or claims that it addresses price or fair transactions to the grower.  Nor does the program claim in any way to benefit small- or family-scale farmers in any specific way: scale is not addressed by the program at all.  That said, FA does make a claim of fairness toward workers.  “Safe and Fair Working Conditions” is one of its principal claims, and features prominently on its 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 the program based on how well it comprehensively covers all the areas the DFTA has identified as crucial to a fair trade or social justice market claim.  Even though the scope of FA is limited in terms of what areas of the DFTA criteria it addresses, nonetheless a program such as Food Alliance Certified could conceivably be assessed as a legitimate program worthy of public support, so long as the claims it does make are backed up.  Unfortunately the DFTA has not found this to be the case.  For one, workers’ rights per se are not adequately addressed by the program (although this is contested by the program).  Fair trade and social justice certifications, even those that have not received high marks from the labor sector, almost as a matter of course refer to workers’ Right to Freedom of Association, along with other internationally recognized rights such as those outline by the ILO.  FA does not; employer “openness” to working with groups of workers is encouraged by the scoring system but not required.  (See below for more discussion of the scoring system.)  As a second example, FA does not require wages beyond minimum wage although its certification system would encourage employers to pay workers above the minimum.  DFTA’s position is that a living wage should be the goal (if not immediate outcome) of any certification making a claim of social or economic fairness.  As part of its scoring system higher wages, as well as bonuses, profit sharing, and other measures are encouraged, but they are also lumped together with measures such as employer avoidance of favoritism, which in our opinion ought to be a baseline requirement.

In the areas of governance and implementation FA also falls short.  While the program does well at disclosing to the public in a user-friendly way who is involved in the program, including staff, board, Stewardship Council, an advisory body, not all stakeholders seem to be represented, notably labor. (Note that as of October 2013 the board has recently been reconstituted and a list of board members is now posted on the FA website; the Stewardship Council has not.) There is much less opportunity for public involvement than considered the norm by most certification programs.  The standard-setting and revision process does not include any formal process for public input, and there is no clear process for the public or others to file complaints.  (There is a public input form on the website, but as stated it may not be reviewed for up to six months, which may be appropriate for general feedback, but not for a complaint per se.)  That said, FA did provide a list to the DFTA of organizations and individuals who submitted feedback and comments during the program’s most recent standards revision in 2002.  FA should be commended for the fact that it is a diverse group of labor, farmer, environmentalist, and other stakeholders.  However, the concern remains that there is not broad and diverse enough ongoing participation, and it is also not clear how the program responded to all the comments received.  DFTA would recommend that FA consider adopting a practice engaged in by many other programs of  publicly sharing comments received and the program’s responses.

In terms of monitoring, FA has far less written in terms of protocols and guidelines for inspectors and reviewers than most other certification programs, and does not strictly require inspectors to conduct confidential employee interviews as part of the on-site assessment (DFTA is still waiting confirmation from FA on this last point).

It is important to note other aspects that FA does well.  While not as stringent as organic certification on the issue of pesticides, the program comprehensively covers environmental issues, including banning the most toxic pesticides, and prohibiting GMOs in their certified products.  (Occupational health and safety, however, mainly adheres to only what is legally required.)  FA also addresses other environmental concerns such as soil and water conservation, and the humane treatment of livestock, although the DFTA has not yet evaluated the program in this last area.

 

Food Alliance has in place a scoring system, designating each standard as Level 1, 2, 3, or 4, and placing them into various program areas, such as Soil and Water Conservation, Safe and Fair Working Conditions, etc.  In each area the applicant must reach an average of 3.  This provides flexibility but also makes it more challenging for someone on the outside to assess the impact; Level 1 standards in most cases fall short of DFTA criteria.  Level 2, 3, or 4 standards in many cases meet DFTA criteria, but since they are not required per se, we cannot evaluate the program as having met the threshold. 

 

FA has informed us directly that in most cases meeting only Level 1 would result in a recommendation to improve, but there appear to be no written guidelines for this.  In September 2013 Food Alliance provided additional information to the DFTA documenting inspection results.  The data provided show that for most criteria sections related to Safe and Fair Working Conditions, certified operations scored between 70% and 93% compliance, with the highest rates of compliance in the areas of Employee Compensation and Benefits, and the lowest in the areas of clear non-discrimination policies and farmworker support services.  FA also provided a break-down of how frequently certified operations scored a “1” on any criteria, showing a similar spectrum of results.

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

For a print version of this summary, please click here.