Private Bureaucracy

Interesting NY Times story today on the regulations faced by farmers. It notes that some of the most burdensome come, not from the government, but from private retailers like Whole Foods and Costco. These companies have their own long lists of rules that farmers who sell to them must follow, and their own teams of inspectors to enforce them:

Farmers to some extent have gotten used to the requirements and see the benefit for their businesses of creating a culture of food safety. But they complain that the rules are onerous, particularly the tediousness of documenting virtually anything that happens on the farm. Much of that documentation at Indian Ladder goes in the 13 logs kept in the packinghouse.

If something is not logged, the saying on the farm goes, it did not happen.

Mr. Ten Eyck says some of the requirements are impractical. The safety plan at Indian Ladder, for example, calls for someone to check the orchard each morning for mouse and deer droppings and address the problem before picking begins. The worry is that the droppings could get attached to a worker’s shoe, get tracked onto a rung of a ladder, end up on a worker’s hands and then on the apples.

Mr. Ten Eyck says the requirement was “ridiculous” in practice — the equivalent of finding an earring in the orchard — so Indian Farms came up with an alternative to scouring the orchard every morning. “We have trained the guys only to grab the rails of the ladder,” he said.

The safety planning comes with accountability: The farms are audited, usually twice a year — once planned and again as a surprise. The audits are in-depth, as the inspector examines the entire farm operation, including employee hygiene, labor laws and fertilizer application. The auditor also checks if everyone on the farm has received proper training. And they check the logs, too.

The rules can be pretty specific, banning fake eyelashes (they can drop into food) and specifying certain types of wedding bands that can be worn (they can get caught in equipment). The distance between vehicles and crops is closely monitored (exhaust fumes are harmful). And chewing gum is prohibited because it could contaminate the produce.

This is also my experience. My job is essentially to help my clients deal with one set of government regulations, and those regulations specify a lot of things that I have to do. Sometimes they specify the table of contents of my reports, for example. But I find those rules less burdensome than the ones imposed by my own employers. And while the historic preservation rules I work with have been essentially the same for twenty years, the corporate rules get more invasive and oppressive every year.

Bureaucracy is not a problem of the government – or, if you prefer, a solution adopted by the government – but a tendency of our whole society, to which businessmen are no more immune than public officials. If something goes wrong, write a set of rules that, if followed, will keep it from happening again. To insure the rules are followed, make up some forms to be filled out, log books to be written in, quarterly reports summarizing the contents of the forms. Hire inspectors to check up. And presto, the problem is solved or reduced, at a cost that, cummulatively, is crushing the joy out of work in our world.