Health as an emerging value in the construction of quality of berries in Huelva (Spain)

Introduction

The province of Huelva, in southeast Spain, is home to one of the main berry-exporting enclaves in Europe. Occupying over 12,000 hectares, berry cultivation is this area is characterised by the intensive use of industrial materials, capital and waged labour and is heavily inserted into global value chains. In line with general trends, quality has become a strategic element of berry production in Spain and, in recent years, private quality certifications have been introduced to many farms, often at the behest of large supermarket chains. As the notion of quality has become more and more established, new practices and values have driven changes in the organisation of production and work. Within this process, health is a key, and ever more important, value.

During the last 5 years, health as a value has been mobilised by the agroexporting sector along two dimensions. For one, marketing strategies emphasise the health qualities of berries – ‘little health pills’– to create a differentiated brand (Reigada et al., 2021). Second, in terms of quality certifications, priority is given to those that have a strong focus on consumers’ health. As with other territories and crops, the notion of food safety and its associated meanings – risk and hygiene control – has become a key attribute for the promotion of Huelvan berries on the global market. However, the importance given to these two dimensions contrasts with a disregard for the health of the female workers that pick and handle the fruit. In this respect, we cannot ignore that efforts to ensure food safety for consumers can negatively impact the welfare of female workers.

From a perspective concerned for the health and welfare of female migrant workers, this article aims to contribute to a rebalancing of this neglect by examining how ‘healthiness’ is constructed as an emergent value of berry quality. The empirical analysis draws on two main sources: the quality standards that cultivators must implement to acquire Global G.A.P. certification, a privately run programme, and the experience of female workers recruited through guest worker programmes in their countries of origin – in this case, women who travel each year from Morocco to work in the agricultural campaigns.

In order to situate and define the object of study, the article starts with a description of the methodology and the key theoretical and contextual issues. At a conceptual level, the research draws primarily on the political economy approach to agriculture, convention theory and research on quality standards, health and work. Subsequently, the article presents the results of an empirical analysis of how health or healthiness is constructed in private quality standards by addressing a number of key issues: the social meanings and principles that configure the notion of health used by Global G.A.P. in the area of production and work, how practices related to food safety and the health of female workers are oriented and legitimated, the processes of standardising both production and the female workforce, and the asymmetries and contradictions that result from the regulation of quality. The article finishes by drawing some general conclusions.

Methods and materials

The research was carried out using a qualitative approach based on in-depth interviews and an analysis of standard documentation. As our aim was to analyse the practices, relations and meanings encapsulated in the particular conception of health proposed in the Global G.A.P. quality standards, we conducted interviews with four types of social actor: quality managers/supervisors responsible for human resources and occupational risk prevention in various agricultural companies and cooperatives operating in the area, health professionals based at local health centres, workers in local social organisations and professional associations charged with intercultural, socio-health and labour mediation, and, female seasonal migrant workers.

The fieldwork was conducted over two phases, from April 2019 to April 2020 and between March and July 2021. The analysis draws on 21 interviews that focused specifically on health and 15 interviews carried out for an earlier study on agricultural companies’ quality strategies (Reigada et al., 2021), which was part of the same R&D project. The mobility restrictions imposed in Spain between March 2020 and May 2021 due to the COVID-19 pandemic meant that some of the interviews with company managers/supervisors, health professionals and social and professional organisations had to be conducted online. In relation to quality standards, we conducted an in-depth review and analysis of each of the Global G.A.P. Integrated Farm Assurance standards documents related to the area of health and safety.

Globalisation, quality governance and value chains

Health as a value and the notion of risk: Polysemy and inequality

As we have already pointed out, the principles of civic and industrial coordination in quality certifications in the fruit and vegetable sector (Ponte and Gibbon, 2005) are articulated in the centrality of food safety as a fundamental aspect of health as a value. This is evident Global G.A.P’.s Integrated Farm Assurance (IFA), where, in the introduction, it states that the standard ‘offers several benefits to producers’, the first of which is ‘reducing food safety risks in primary production’. ²

In the berry sector in Huelva, producers are very aware of the importance of food safety when it comes to defining what healthy means for consumers. Ernesto Sabariego, ³ quality manager for one of main cooperatives in the area, expressed this very clearly: ‘A healthy product is a product that generates no doubts whatsoever for a consumer when they take in their hand’.

Such concern for food safety has to be framed within the context of continuous outbreaks of food-borne illness related to the consumption of contaminated produce and which, to an extent, is an inherent problem of the intensive agricultural model (Stuart, 2008). It is paradoxical, therefore, that the food safety practices aimed at protecting consumers by minimising their risk of contamination also result in fruit and vegetable producers having constant feelings of lack of safety and vulnerability. This locates quality management, once again, in a framework of uncertainty and risk that establishes a clear hierarchy between winners and losers (Ponte, 2009). As such, quality control exacerbates the asymmetries that characterise global agrifood chains (Ponte and Gibbon, 2005).

In 2013, a study by the French N.G.O. Générations Futures was disseminated in Spain by the Fundación Vivo Sano [Healthy Living Foundation]. The report concluded that almost every strawberry that had been analysed – almost all from Huelva – contained toxic residues and of them, 78.3% contained endocrine disrupting pesticides. ⁴ As France is one of the main importers of Spanish berries, the publication of the study forced the sector to implement a series of actions and measures to bolster the safety and reputation of its products, many of which are now an integral part of production. Daniel Gálvez, who had spent 20 years working in consulting and four as a quality manager in the Extra Fruit Group, was clear about the local impact of campaigns exposing illnesses related to food consumption. He stated that ‘there is always something like that, some public outcry or another, well, so they [producers] are very aware of the issue’. ⁵ Ernesto Sabariego expressed it as follows:

it’s not something isolated, it’s something continuous, something continuous that we have to fight against with all the tools we have. [ . . . ] When a smear campaign is conducted, you have to conduct a counter campaign. [ . . . ] it’s done constantly. Because, we are forced to, not just to be above suspicion, like Caesar’s wife, but also to demonstrate it.

Although the need to guarantee food safety means controlling the entire agrifood value chain, food safety essentially focuses on the control of three processes: harvesting, through the implementation of Good Harvesting Practices (GHP); product handling and packing, through Good Handling Practices (GHP); and fumigating, which is concerned with ensuring that the Maximum Residue Level (MRL) for pesticides is respected. The purpose of these processes is to guarantee consumers’ health against microbiological and chemical threats. And, of the three, two of the processes also involve the standardisation of female seasonal workers (Busch, 2000).

Thus, in this context, female workers, their bodies and their practices are configured as potential contaminating agents and they are made responsible for guaranteeing product safety. This aspect of the Global G.A.P’.s IFA standards is specified in control point AF3 Hygiene, where it states: ‘people are key to the prevention of product contamination’.

For this reason, its objective is to implement hygiene standards that guarantee food safety, establish procedures that deal with identified risks and provide appropriate training. This includes standards being written down and hygiene instructions displayed in places that are clearly visible to everyone. These norms include the following: everyone must wash their hands and cover any skin cuts; smoking, eating and drinking are only permitted in designated areas; any contamination of products with bodily fluids must be reported immediately; the use of suitable protective clothing where activities might pose a risk of product contamination. Furthermore, fulfilment of the hygiene standards requires the notification of any infections, including any signs of illness such as vomiting, jaundice or diarrhoea. The standards state that ‘these workers shall be restricted from direct contact with the product and food-contact surfaces’. As we analyse further in the following section, it is significant that section AF4 ‘Workers’ health, safety and welfare’ does not include any control points related to infections, lack of welfare or illness that female workers might suffer due to agricultural work. Neither does it address the corresponding compliance criteria that evaluate the evidence on rest, medical attention or appropriate care. As Moraes and Cutillas (2014) have observed, in private quality standards ‘a worker’s condition as healthy or sick is only relevant in relation to the product they handle. The product, as such, must be protected from the sick worker’ (p. 204, authors’ translation).

If food safety aims to protect against risk, we show that risk is unequally shared, such that work and workers are neglected. This is further compounded by the new hygiene standards that regulate food, drinks, handwashing, bodily fluids, make-up, clothing, earrings and hairpins in the workplace. These standards lead to greater control and disciplining of the everyday lives and bodies of female workers (Torres and Pérez, 2021). In addition, the focus on guaranteeing food safety for consumers influences the health and welfare of female workers. For example, hygiene measures, such as the prohibition of gloves, aim to make sure that cosmetics are not used on fingernails, that hands are washed, that touch sensitivity for handling produce is maintained and to avoid the transfer of glove residue to the fruit. Lucía Ruíz, a quality manager in Moreno Strawberries, explained that

before gloves were preferable, now they [producers] don’t want gloves, because the . . . with gloves you don’t know if they have washed their hands, if not . . . I don’t know if they have their nails painted, if they have a cut. With hand washing you see everything.

However, working without gloves causes damage to the hands. Marisa Villalba, a doctor in a local health centre, commented that seasonal female Moroccan workers suffered from skin irritations and that their hands were often ‘in bits because they can’t work with gloves’.

In terms of the context of the pandemic that covered part of the fieldwork, while it did not appear to have led to the introduction of any new control points, at least in relation to the main standards, it did cause more intense monitoring of hygiene standards, as well as raising the possibility of the companies being asked for their COVID Contingency Plan.

In general, however, the new landscape of quality certification has profoundly transformed the production of berry cultivation (Pedreño and Ramírez, 2021):

the spirit of quality adopts all of the forms of a civilising process. The quality of the product implies ‘civilising’ productive procedures in terms of hygiene, keeping work spaces immaculate, sanitation, cleaning, order, predictability, systematisation, etc. Indeed, in the form of quality protocols, the entire productive space has become inundated with ‘good manners’ manuals. (p. 16, authors’ translation)

Among producers and managers, there was strong consensus in relation to the advantages that these transformations have brought to productive spaces. From their perspective, there has been a shift from a dirty, chaotic and disordered past to a hygienic, ordered, clean, safe and controlled present. This view is rooted in discourses of technical-scientific knowledge, as expressed by Ernesto Sabariego:

Here, even the cat smoked. The workers in the packing house stopped working and they ate right there in the middle of the plant, or on that stairs that you just went up [ . . . ], with their aprons on, chaos, basically. Not chaos, what was normal at the time. Today, you think about it and it was total chaos, in terms of the habits at lunch time, no ban on smoking.

In this civilised and risk-free landscape, immigrants are uncivilised and threatening. In this respect, we found racialised discourses on the cultures and habits of workers from the Maghreb and sub-Saharan Africa. In particular, that it is difficult to instil them with good hygiene practices, which activates the dirty-savage/clean-civilised dichotomy. These ideas are evident in the following exchange between Javier Tempranillo, a quality manager in a family business, and Francisco López, a co-op manager, as they spoke about the Global G.A.P. AF3 Compliance Criteria:

Yes, yes, yes. Yes. Above all, that, that refers, most of all, to the aprons, so that the aprons are a little clean, so that they don’t come with the aprons . . . Because many female Moroccans they come with the aprons . . . ‘Chiquilla [young girl, condescending in this context], wash it or . . . ’

eh, they put the boots in the washing machine, the boots, to wash the boots that have soil on them. I mean, behaviour and ways of doing things that really destroy the housing. But, because of what he was saying, there is a huge cultural change, it is such a huge leap from those countries, that area. ⁶

As we have shown throughout this section, within the framework of quality standards, the conceptualisation of the value of health is markedly neoliberal and only concerned with individuals in their facet as consumers. However, the centrality given to consumption has consequences in terms of neglecting workers’ welfare and health (Carton de Grammont and Lara Flores, 2010; Moraes and Cutillas, 2014) – which we analyse further in the following section. At the same time, this also calls into question the construction of consumers as agents that are worried about all the dimensions of quality. As Roseberry (1996) has pointed out, emphasising product safety and health creates an illusion of healthy consumption, which in turn conceals the economic, labour, social and environmental costs of this production model.

Health as a value and the notion of welfare: Paradoxes and limitations

Along with hygiene and food safety, the quality conventions contain other aspects of the notion of health such as risk, safety and welfare, but this time linked to the workplace. If quality conventions related to consumption entail asymmetries of information between social actors (Ponte, 2009) and an unequal distribution of risk, this imbalance is accentuated in the context of occupational health. This seems evident in the fact that the private quality standards do not have specific modules on occupational health for seasonal agricultural workers. The very few control points related to this aspect of work that they do have are included in broader modules and, in some cases, only address the health of female seasonal workers indirectly.

In Global G.A.P’.s Integrated Farm Assurance there is only one module (AF4) that addresses this area: Worker’s Health, Safety and Hygiene. AF4 has five control points: health and safety, training, hazards and first aid, protective clothing/equipment and worker welfare. Although the intention is to focus on people and not the product, a reading of the introduction to the module shows that its primary concern is efficient farm management and safety.

By reviewing the aspects that the control points deal with we can examine the approach taken to the construction of ‘health’ as a value of work quality. AF4 addresses the evaluation of workplace risk, the development of preventive procedures and the training of workers in relevant areas of work and safety. Health and associated concepts – safety and welfare – are defined and addressed on the basis of the identification of possible emergencies and hazards related to farm machinery and vehicle traffic, electricity, moving machine parts, fire, dust, excessive noise, extreme temperatures, applications of organic fertiliser and new plant protection products, among others. This vision is corroborated by the fact that only a single control point is dedicated to first aid (first aid kits and training) and that training for occupational risk prevention is contracted out to external services.

Conceptualising ‘healthy’ in the framework of workplace risk reflects how private quality certifications have integrated the standardised systems for the prevention of occupational risk that are dominant in other sectors. Global G.A.P. checklists, control points and compliance criteria are made up of homogeneous and closed points that follow the standardisation processes of industrial coordination (Raynolds, 2004; Thévenot, 1995). Furthermore, they sustain the limited and neoliberal conception of health that we have already pointed out. In the rest of this section, we examine some of the main contradictions resulting from the articulation of the social and cultural values that they mobilise and the exchange value linked to the labour market (Narotzky and Siniscalchi, 2014). This is to say, the practical implications of socially defining health as a value of work quality within the framework of the capital accumulation strategies of private quality standards.

First, because quality standards are designed as a means to respond to workplace accidents, emergencies or other contingencies and also to transmit an image of safety in such circumstances, this impedes any qualitative assessment of the health of female workers that have been contracted in their home countries for seasonal work in Huelva. Insofar as the implementation of a quality certification and its underlying values is seen as compatible with the inherent inequalities of intensive agriculture, much of the health problems these workers suffer remain beyond its scope. In opposition to the discourses of safety, protection and welfare that quality standards stress, local healthcare and social workers spoke of pain, over-exertion, injuries and dehydration. In this respect, the fieldwork found that health problems related to work conditions were particularly common. On the one hand, workers suffered from musculoskeletal pain, particularly lower back (lumbalgia) and neck (cervicalgia) pain from the postural stress associated with hand-picking strawberries and handling heavy loads. On the other hand, they frequently experienced exhaustion from the arduous pace of work and headaches from the high greenhouse temperatures. Furthermore, allergies and skin problems from contact with plants, pesticides and other toxic agrochemicals were common. ⁷ Marisa Villalba, a doctor in a local health centre, explained the impact of work conditions on health:

It’s a lot of hours and very hard work, they come with injuries, they come with injuries, [ . . . ] injuries to the arms, on the under-side of the arms, from picking up boxes, they have bruises, everything. Their bodies, a lot of the time, if it rains, they get soaked, they wear a load of t-shirts, everything dripping wet, and, and doubled over in pain, many cases of dehydration, hands in bits because they can’t work with gloves, they can’t even drink.

The first three health problems are the most common. Apart from not being explicitly covered in the concept of occupational risk and hazard prevention set out in the G.A.P. quality standards, they are not recognised as work-related health problems. In the agricultural companies, who manage quality control in the supply chain (Ponte and Gibbon, 2005), the managers and supervisors implement these quality principles in the organisation of work and production. During the fieldwork, we could observe how these local agents tend to naturalise the illnesses experienced by workers, which they considered to be normal and inherent to this type of work. Laura Aldomar, a supervisor in a large company who was responsible for female workers recruited through the guest worker programme, explained: ‘that’s just the way it is, there just isn’t any other way to pick the fruit. That’s what we try to explain, that back pain is . . . it’s the work posture. There’s nothing to be done’. Ahmed Tazi, a member of a mediation team from the Plan for Ethical, Work and Social Responsibility (Plan de Responsabilidad Ética, Laboral y Social (PRELSI)) at Interfresa, the strawberry growers’ association, shared the following view on the issue:

The day they don’t turn up for work, well, you go to the health centre in Lucena and you’ll find a huge queue. ‘What’s wrong with you?’ ‘Well, it hurts me here. It hurts me here . . . ’ It’s . . . the truth is, sometimes I understand the attitude of the doctors, they’re fed up . . . [ . . . ] Look, I’ve even gone to the Lucena Health Centre to clear it out a bit. There were a hundred women! Did any of them have anything serious? Not one, not one! [ . . . ] You can’t be going to see the doctor for such nonsense!

Not only are the women’s pains not normal, they are ‘nonsense’ because there is nothing wrong with them. On this basis, their health complaints are naturalised and minimised, medicated and quietened with painkillers as Ahmed went on to explain: ‘So, what does the doctor do? Well, he gives them paracetamol and sends them home. But, to be honest, I don’t understand it’. It is revealing to observe how the process of medicalisation (Foucault, 1990; Illich, 1975) individualises symptoms and responsibility for a health problem that is, in reality, a result of social inequality.

For their part, the female workers learn to incorporate health problems as a cost of work. In interviews, they talked about becoming gradually ‘used to’ the pain. However, given the material conditions of their lives and the necessity to prioritise income, this was more a surrender to circumstances than any consent (Mathieu,1985) to the naturalisation and minimisation of their health problems. Fátima Asad, who was 30 years old, explained that the main problem she had when she first started working in the strawberry fields in Huelva was adapting to the type of work. She said that the back pain she felt during the first 15 days was so bad that she cried until she got used to it. She was not the only informant that emphasised how unbearable the pain was in their first campaign.

As mentioned earlier, the notion of health encompassed in quality standards only addresses the prevention of occupational risk and, therefore, invisbilises the structural nature of some of these risks. Extreme heat in the greenhouses and contact with pesticides and other toxic products are a few examples of risks that appear in module AF4. The role of occupational risk training, required by the standards, and its relationship to processes of medicalisation and neoliberalism should also be considered. For example, it was believed that headaches caused by workplace conditions could be eased by training. Gema Lucena, an occupational health and safety manager in one of the agroexporting companies explained:

The temperature in the greenhouse goes up. So, in the [quality] evaluation and, apart from giving talks practically every week, because we always specify that they wear long-sleeved tops, preferable made of cotton, keep the head covered and hydrate a lot.

By insisting on adequate clothing for high temperatures and good posture to avoid musculoskeletal issues, health problems are individualised and responsibility for dealing with them is transferred to the female seasonal workers, just the same as we observed in module AF3 in relation to the food safety standard. For their part, the women who actually suffer these problems told us that they tend to alleviate pain with medication and by covering their heads with a bandana or cap.

At the same time that the standards exclude prevalent health problems and conceal the structural nature of costs, they regulate health from an androcentric perspective. Bain (2010) argues that, in Global G.A.P., the use and application of pesticides is only regulated for workers that handle them, which are usually male, and not for those exposed to their effects, such as female seasonal workers that pick and pack the fruit. In our fieldwork in Huelva, we found correspondence with Bain’s analysis in frequent observations of eye irritations among the female workers. Other activities included in the Global G.A.P. risk prevention standards, such as the operation of machinery, vehicles and electricity, are also masculinized. As such, the quality standards reproduce, as Bain (2010) has observed, sexual inequality in the agroexporting sector.

The androcentric perspective that predominates the health and prevention quality standards also fails to consider that health problems are differentiated on the basis of the sex-gender composition of the workforce. They overlook the fact that pesticides have a greater effect on women because they accumulate in fat tissues and women have, on average, 15% more body fat than men (Valls, 2018). Apart from the need to limit the use of insecticides, Valls, an endocrinology expert, also stresses the need for ongoing monitoring of people’s health. In the case of agricultural work, the study and treatment of ill effects from toxic products or work conditions is impeded by high rates of labour rotation, temporary work and absence of long-term follow-up.

It is also necessary to consider that, outside of working hours, the emergency room of the local health centre is the only available healthcare service. In the best of circumstances, this service can only provide palliative care. ‘We usually prescribe analgesics because it’s the only thing we can do for them from the emergency service’, explained Elena González, a doctor. Using a somewhat bitter tone, Marisa Villalba, another doctor, said: ‘you even, in emergencies, when they come, one after another, and another, sometimes you fall into the laziness of “ok, come on, jab. Jab, jab, jab”’. A union representative from Huelva en Lucha [Huelva in Struggle] argued that the lack of access to therapeutic healthcare and adequate follow-up leads to chronic pain:

And the issue with . . . mostly muscular and . . . and that, is really unbelievable. [ . . . ] They only thing they do is give you pills and they don’t examine you properly to see what’s wrong. And then you get chronic pains, well . . . well for your whole life. And, that’s what it’s like for everyone who works in the fields.

This trend towards chronic pain is an externalisation of workforce health costs to the domestic and family economies of the seasonal migrant workers (Décosse, 2008) – in this case from Morocco. It is also a further expression of the process of externalising the costs of reproducing the current agrifood model and how the separation of the domestic sphere and the labour market sustains the seasonal migrant worker programmes in agriculture (Burawoy, 1976).

In addition to these limitations, there are other implications of the standardised and strictly delimited procedure for evaluating health: the tendency to only focus on the verification of the formal functioning of work conditions (training in occupational risk, existence of first aid kits). This idea can be illustrated by examining the criteria established in module AF4.5.4 of Global G.A.P., which deals with living quarters:

The on-farm living quarters for the workers are habitable and have a sound roof, windows and doors, and the basic services of drinking water, toilets, and drains. In the case of no drains, septic pits can be accepted if compliant with local regulations.

The quality standards set out control points for habitable living quarters (sound roofs, windows and doors, drinking water, adequate sanitation) –not always met (Women’s Link Worldwide, 2019)– as well as safe transport to the workplace. However, the focus on essential facilities, such as habitable spaces and basic services, means that the scope of the problems faced by female migrant seasonal workers is neglected. These problems include difficulties with living conditions on the farms (cohabitation and sociability, isolation, food and drinking supplies), work schedules, administrative issues, telephone coverage and language barriers. This formalist and homogenising approach also ignores the lack of wellbeing related to the emotional health of the female workers. ⁸

The situation created by the COVID-19 pandemic only worsened these problems and caused even more issues for emotional health. Apart from the difficulty of accessing health centres in person, the shift to telephone appointments was problematic for many workers due to poor mobile coverage in the area, language barriers and disruption to mediation programmes. Like all crises, this makes the contradictions of the system that cause these issues even more visible. In agreement with Roseberry (1996), it reveals that the emphasis placed on offering products that are safe and beneficial creates an illusion of healthy consumption that conceals the economic, labour, social and environmental costs of the production model.

What health, and healthy for who? Some final thoughts on a value in ascendance

By articulating the value of health in the quality conventions in the Global G.A.P. standards with the health problems affecting seasonal female migrant workers, this study has explored the meanings, limits and imbalances produced around this value. To the extent that health-related standards focus on responding to consumer concerns about product safety, but are only partially concerned with working conditions, we have seen how health is unevenly distributed among the parties involved. Within the hierarchy of winners and losers that convention theory identifies, the cost of quality control is transferred first to producers and subsequently to female workers, reinforcing the power relations in the governance framework of local agrifood chains.

The analysis shows that the expansion of a discourse that emphasises food and product safety, risk control, cleanliness and hygiene is closely paired to a conception of female workers as potential agents of contamination. This conception implies a requirement to standardise female workers at two levels. First of all, by conceiving them as a key factor in guaranteeing food safety; their presence in the workplace must be homogenised. Second, by disciplining and controlling their bodies and activity through the imposition of hygiene standards that seek to safeguard the product. Apart from female workers being made responsible for guaranteeing product safety, this means that health problems are only contemplated when the product is threatened by contamination. In addition, some of the standards have a negative impact on health.

On the other side, by exploring the sphere of work-related health, we also identified other limitations in the quality standards. First, the health of the women who pick and handle the fruit occupied a marginal position in the standards. Second, the analysis also illustrated how the approach to occupational risk impedes any qualitative evaluation of female workers’ health and excludes many health problems associated with working conditions. At the same time, there is a tendency to naturalise and minimise the health problems experienced by seasonal migrant workers. Healthcare often consisted of medicalising and individualising symptoms, providing palliative and superficial care that leads to chronic pain, only focusing on the verification of formal work conditions and the regulation of health from an androcentric perspective.

Connecting the production of meaning to the material production of food permits us to observe the contradictions and limitations inherent in this notion of health. Similarly, the bureaucracy, standardisation and formalism that quality certification demands – in order to make Huelvan berries acceptable on the international market – actually prevents it from making an effective and equitable commitment to the protection of health as advertised to consumers.