Tom Levitt: How do you see the problem of food safety in China today?
John Yasuda: A part of the problem is bureaucratic malfeasance and corruption, but I think to say that it is entirely about venal bureaucrats is an oversimplication. China’s food safety problem is a systems problem. There are a significant number of government officials, producers and organisations that actually seek to address food safety, but they’re having a very difficult time developing an integrated solution.
The problem is that within China’s centrally driven, highly fragmented food safety framework, regulators at different levels of government don’t understand how they are to function as part of a system. Individuals testing for pesticide residues don’t understand the rationale for testing, or assume someone higher up the chain of command will double-check their work. Central food safety campaigns often conflict with day-to-day monitoring at the local level, draining local funds for “special” investigations. New food safety bodies that are created at the central level have no real impact at the county-level. Poor information flows between local and central food safety authorities lead to the development of standards that are out of touch with conditions on the ground. And local officials don’t want to experiment because of the unstable policy environment at the centre. I think there are lots of good people trying to address food safety, but the system is failing them.
TL: Do you think food safety scandals are helping to instigate the right reforms?
JY: Yes, I think because of the scandals the government now has the political will to force massive restructuring efforts. In 2003, a complete overhaul of the food safety system was seen as too difficult because several ministries had interests in regulating food safety, which is why you had a multi-agency model. Now, in 2013, we are moving forward with a single agency model. The scandals have kept food safety on the agenda, so I think we will continue to see lots of change in this sector. It is, after all, according to the latest PEW survey, one of the top three governance concerns among people in China (after corruption and inequality).
TL: What do you make of the most recent re-organisation of food safety in China?
JY: This is the fifth government restructuring of regulatory duties in the last decade with market access requirements established in the early 2000s, the creation of the State Food and Drug Administration-led system in 2003-2004, the demotion of the SFDA in 2008, the new food safety law in 2009, and now the creation of the China Food and Drug Administration. It is notable that they are trying to develop a single agency food safety model and streamline the bureaucracy. A single agency model is the step in the right direction, but it also looks as if they are trying to centralise the system, which entails a different reform process. A centralised system offers some benefits because it does clarify lines of authority and reduce coordination costs. You can address fragmentation by forcing everyone to follow central-level directives, but you lose a great deal of information because you develop a system based on a single viewpoint. Most scholars hold that you should have a single food safety agency, but for constantly evolving problems like food safety, authority should still be dispersed at multiple levels so that regulators can respond quickly to emerging risks, and can develop their own strategies.
Centralisation doesn't address the fundamental problem, which is how to create a system in which all levels of government are actively participating in governance, each with a delimited sphere of authority. Under China’s current framework, local governments are permitted to implement central level policies according to local conditions, but local rules cannot contravene central directives.
Moreover, a number of local officials I spoke with in 2011 highlighted how they were hesitant to invest heavily in any food safety approach because policies were likely to change at the central level. It looks like they were right.
I am not advocating for full-fledged decentralisation either because the central government does have an important role to play. The key is to establish a common food safety standard, but then allow each sub-national unit to implement and create their own systems of surveillance that best fits their local conditions. What I propose is a multilevel system, where a central governing body would audit provincial food safety systems, and ensure that local rules are compliant with national laws.
TL: Can the models of food safety in the EU or US be replicated?
JY: I think that the EU in particular has a very interesting model. The EU food safety system operates under a framework referred to as “a common standard for a common market,” which sets a threshold level of food safety that everybody must meet in order to circulate food in all European markets. Countries are allowed to go above that threshold as much as they want, but they have to at least abide by a minimum standard. I think it promotes a degree of innovation and learning, which is much more flexible than the current centralised model in China.
China has been studying the EU model for quite some time, and has been trying to adopt certain aspects of the EU system. What is apparent is that China likes the idea of having a centralised food safety authority, but for political reasons is not too keen on delegating increased food safety authority to the provinces. That being said, there are new inter-provincial arrangements being developed, which will prove interesting to watch.
TL: Do you think the structure of the food industry makes food safety more difficult in China?
JY: Yes, because the Chinese production context is incredibly complex. You have several million farmers with thousands of traders that sell to a host of wholesale markets, and then distribute to a range of processors, supermarkets, and wet markets throughout the country. This makes traceability near impossible and supply chain management extraordinarily challenging. In Europe you have a professional class of farmers that operate large, well-managed farms, which are integrated with established supply chains, and are subject to rigorous quality assurance protocols.
In China, most farmers cultivate on less than one hectare of land. They receive minimal training in cultivation techniques. One might hope that testing of products occurs somewhere down the supply chain, but it is not that common.
The easy answer, the answer that everybody gives is 'well, then just get rid of these small farmers, and make them operate in larger production units', but it isn’t that simple. You have a development problem; many of these small farmers depend on their land to survive. As a result, the government experimented with vertically integrating farmers in industrial production chains. However, pushing everyone in the direction of industrialised agriculture without a strong regulatory framework to monitor food safety creates huge risks.
This is exactly what happened in the dairy sector, and led to the melamine crisis of 2008. Small farmers were vertically integrated into large dairy companies that did not have the capacity to provide sufficient oversight for a large, fragmented production base.
TL: Do you think a stronger crackdown, and tougher regulations, would be a good solution?
JY: In some respects, yes, because you do have a problem where individuals are blatantly breaking the law, or violating standards, because they would rather pay a fine than implement new safety measures. But it’s really a double-edged sword. In an ideal regulatory system, you want to use crackdowns and tougher regulations as a last resort. First, a system should try to facilitate learning and innovation, and encourage producers to develop their own food safety protocols. If problems still emerge, then you should put these producers on a watch list and subject them to increased government oversight. Only when non-compliance persists should you begin talking about crackdowns and imprisonment.
The problem with starting with strong crackdowns and tougher regulations is that it puts everybody on edge. Everyone tries to meet the letter of the law, rather than develop systems and ways to actually mitigate food safety risks. For complex issues, like food safety, you want to have enough flexibility in the law, so people can respond to emerging situations and incorporate new knowledge. That is why I'm worried about these new crackdowns and discussions about imprisoning people - it seems entirely too punitive.
John Yasuda is a postdoctoral fellow at the University of Pennsylvania's Centre for the Study of Contemporary China.