A Quality Assurance Program and You
As the pecan industry prepares to enter a comment period for its own quality assurance program, we dive deep into the what, the why, and the how.
Pecan growers and industry members across the country can attest to this.
“Customers are already demanding that agriculture move into more sustainable operations. Big corporations, even governments, are requiring that we have some kind of sustainability plan in place or don’t use certain chemicals,” pecan grower Troy Swift says. “This is driven by their customer. The customer has never been more concerned about where food comes from and how safe it is.”
Swift owns Swift River Pecans in Lockhart, Texas, and has planted/grafted over 1,000 trees in his two orchards. Besides growing native and improved pecans, Swift also operates a lumber mill and retail store. Responding to his customers’ requests for sustainability, he recently has turned to regenerative agriculture with plans to rejuvenate his soil and reduce inputs.
“The carbon sequestration and global warming topics are big, and it’s ingrained now in purchasers and governments. So, those of us that are out ahead of this will have more of an opportunity to sell to corporations and governments that require these programs,” Swift says.
As agriculture companies and industries race to meet those consumer demands and anticipate future regulations, many have turned to another tool: Quality Assurance Programs.
Among those is the American pecan industry. In August 2019, the American Pecan Council approved the hiring of KCoe Isom, a food and ag consulting and accounting firm, to develop and draft a voluntary Quality Assurance Program for the industry. This step came after a strategic planning process that identified five main areas of change and opportunity for the industry. The process to develop a Quality Assurance Program began in late 2019 and continues today.
With guidance from pecan growers and other industry members, KCoe Isom continues to develop a QAP for the pecan industry. The APC will soon open the voluntary program’s draft for a comment period. But before that happens, what exactly is a Quality Assurance Program? And why would a company or industry choose to enact and follow one?
At its most basic definition, a Quality Assurance Program aligns an industry or company within a set of standards, communicates to customers that the product is high quality, and gives the industry or company credit for practices it’s already doing.
“The purpose of a Quality Assurance Program is to collect a vat of best practices for an industry or a company and demonstrate what expectations are or what good work is already being done,” explains Lisa Becker, CPA, Senior Associate with KCoe Isom. “It’s meant to really articulate to customers and consumers what practices are in place related to topics of importance for those groups.”
These topics often include food safety, sustainability, business ethics, worker health and safety, traceability, and resource management. The quality in Quality Assurance Programs does not simply refer to the product itself, though.
“A QAP focuses on quality in terms of not only food safety but also how the product is grown, produced and processed, and whether or not it’s demonstrating the standards that need to be met to produce a high-quality product,” Becker specifies.
There are generally two ways to build a QAP. One type of program is more quantitative and entails specific data requirements, while the other takes a qualitative approach based on practices. For instance, a quantitative QAP may require participants to follow specific water usage rates, while a practice-centric QAP may warrant specific water use or conservation practices. Companies typically set quantitative programs, while industries often develop a qualitative type.
The process for developing a QAP begins with a materiality assessment. During the assessment, KCoe Isom identifies what issues are most important to the industry, customers, and other stakeholders and leverages leading guidelines and protocols. At the same time, KCoe Isom also assesses the topics’ importance to stakeholders and their social, environmental, and economic impacts. From there, they can prioritize the material topics that are the most important and impactful.
The materiality assessment then forms the Quality Assurance Program’s foundation. The company or industry reviews and provides initial feedback. For instance, for the pecan industry, an APC working group made up of industry members—growers, processors, etc.—reviewed the standard, provided input, and refined the standard and governance.
Once approved, that standard is then presented to the rest of the industry for a comment and review period before approaching the final phases. Throughout the entire process, KCoe Isom acts as a guide for the industry or company. Instead of issuing demands or rules, KCoe Isom merely gathers information and resources, builds the framework, and then follows the industry’s input or direction—shaping the QAP to meet industry needs. The pecan industry’s QAP, which is about to enter its comment period, was developed in this same collaborative manner.
“This is a program written by the industry for the industry. We as KCoe have come in as technical experts in pulling together a lot of these resources and pulling stakeholder information together, and talking about these protocols,” Becker explains. “But at the end of the day, this program has been reviewed and approved and inspired by the QAP working group, the APC, and various growers and processors we’ve engaged with along the way through surveys and interviews. So, it’s really meant to be a program the industry built for itself.”
It is important to note that a Quality Assurance Program of any kind is a living program. Once released, it can be updated and changed as focus areas shift and customer requirements evolve.
“It gives the industry the opportunity to make sure the program is valuable and useful over time,” Becker explains. “It’s not static and it changes with the industry and with stakeholders. The industry is in control of that.”
That control extends to the reasons why a company or industry would choose to implement a Quality Assurance Program (QAP). A key purpose of these programs is to give industries and companies the power to communicate to customers the practices or initiatives they are already doing, as well as show they are meeting customer expectations and demands.
Troy Swift is a part of the native pecans working group for the pecan QAP. He says his customers have shown more and more interest in sustainability. They want to know that “this healthy nut is grown in a healthy manner.”
“[QAP] is assuring the customer—whether that’s HEB or France or China or whoever it is—that you are using the most environmentally responsible chemicals and you’re using them properly by following the label—or you’re not using them at all,” he explains. “You are assuring that you’re growing these things as environmentally sustainably as you can, and I think that if you have a program that has different line items on it that you can demonstrate, you will be a successful company.”
The QAPs, therefore, enable industries and companies to proactively address consumer and external stakeholder concerns.
“If you do not have a Quality Assurance Program, if you’re just spraying because it’s time to spray and doing it because it has always been done that way, I think eventually you’re going to be left behind,” Swift says. “I think it’s hard to see that happening now, but 5 to 10 years from now, some kind of proof for QAP is going to be on somebody’s Purchase Order (PO), and you’re not going to ship against that PO if you don’t have that assurance program.”
This scenario leads to the next reason why industries and companies choose to enact a QAP—competition. Those entities with a sustainability plan or QAP set themselves apart within the marketplace.
Green Valley Pecan Company has had an active Quality Assurance Program for over 20 years; within the last 14 years, the company has formalized its program and honed in on food safety and quality. Customer demands for traceability and transparency continue to be a major reason for Green Valley’s QAP.
“[Wholesale] customers are wanting and demanding brand preservation. They don’t want to be involved in any type of recall or negative publicity. So, I think that’s why they’re pushing on the supplier to make sure they have good QAPs,” says Green Valley Pecan Company’s Director of Plant Operations, Brenda Lara.
From Green Valley’s experience with a QAP, Lara thinks these programs also allow industries and companies to consistently produce a safe, high-quality product.
“I really think that helps drive the company’s reputation, and overall the consumers gain confidence with these companies that can consistently deliver on the specifications they want,” she adds.
An industry or company may also develop a Quality Assurance Program to manage risk and protect itself from recalls, quality-damaging events, or production-related emergencies. A QAP shows consumers and ingredient buyers that there are controls in place to protect them. Without a QAP in place, companies and industries as a whole could be in danger.
“When the whole PCA [Peanut Corporation of America] thing with peanuts happened, consumers backed off buying peanut products and peanut butter because of salmonella,” Lara shares, detailing how consumers lost trust. She adds that consumers might have felt as if the company was trying to hide information from the public because it lacked a good QAP.
An individual company may implement a Quality Assurance Program to protect itself during food safety recalls like this one. That company could use the QAP as a marketing tool to separate itself from others in the same industry. But in the grand scheme of things, consumers quickly focus on the entire industry when a food safety recall happens, as seen within the peanut industry.
“If anybody is involved in any type of pathogen recall, people don’t necessarily think about that QAP. They take the recall as a whole,” Lara explains. “The testing methods are getting more and more specific, so the detection limits are lower and lower. That’s why these programs are really important. They’re preventing you from having these issues not just with pathogens but also with quality. Because as a consumer has tighter and tighter expectations; the FDA puts out mandates…we want to stay ahead of it and not be coming from behind the 8-ball.”
The pecan QAP is currently in Phase 3 of the project. According to the American Pecan Council, this phase includes some working group and committee meetings, an industry-wide survey, and the public comment period once they have the finalized draft.
After it’s approved, the pecan Quality Assurance Program becomes active, and industry members can begin applying for certification if they wish. Once certified by a third-party verifier, industry members can then place the QAP seal on their products. The American Pecan Council hopes to wrap up Phase 3 in the coming months and will share any dates and details on its website or newsletters.
As the comment period nears, industry members like Brenda Lara with Green Valley Pecan Company think a QAP could help to unify the industry.
“Right now, our industry tends to be very disjointed, and there aren’t common specifications,” Lara says. “It’s pretty much led by each individual company and what their level of commitment is. But I think if everybody took a look at implementing Quality Assurance Programs, it would give confidence to the industry as a whole.”
Troy Swift, a board member for the Texas Pecan Growers Association, has a similar stance on the QAP. He sees the Quality Assurance Program as a necessary step forward. The almond industry already has a quality assurance program, and other tree nuts, like walnuts, are also starting to develop their own.
“The demand [for quality assurance] is going to be there whether the APC does it or not,” Swift clarifies. “The APC is, fortunately, the attempt of organized growers to have some control over this. But in agriculture, sustainability [or] quality assurance of some sort is either going to come from governments or from large corporations that buy pecans.”
For Swift, this program would ensure pecan growers and the industry a seat at the table. With the APC leading the charge, he says pecan growers can shape the program and make it workable. “We want pecan growers establishing those standards, not bureaucrats,” he adds. “The pecan industry has to proactively align with customer expectations and demands. That’s the bottom line for us all to survive in the long run.”