October 2019 - 13

viable in the modern market, " the ag
economists wrote.
David J. Goldenberg, a food safety
and security training coordinator with
the University of
California-Davis'
Western Institute
for Food Safety
and Security,
trains many
growers on the
Produce Safety
Rule.
Goldenberg
DAVID J.
said he's had
very little " pushback " from the growers,
although he admitted not all were
GOLDENBERG
taking the changes well.
" I think a lot of it is just common
sense and a lot of good agricultural
practices, " said Goldenberg. " The only
area I really see where people have a bit
of pushback, is the water testing. "
Growers who use municipal water
for irrigation just need a letter from
their provider documenting that the
water has been treated. Untreated
groundwater needs to be tested for E.
coli annually, but growers with wells in
the same area may be able to share tests,
Goldenberg said. Surface water used for
irrigation needs to be tested at least five
times annually.
The ERS economists reported that
growers were uncertain of the exact
requirements, and that the adoption of
practices meeting the rule requirements
wasn't shaky.
" In a 2015-16 USDA survey, 71%
of growers who used untreated
groundwater in the field tested it at least
once annually, as currently required
by the (Produce Rule), while only 15%
who used untreated surface water in the
field tested it at least five times annually,
as required by the (Produce Rule), "
according to the study.
Goldenberg shares the inspection form
with the growers who take his classes.
" I'm often asked in my trainings,
'What are the inspectors going to do?
What are they going to say? What are
they looking for?' " Goldenberg said.
The form itself seems straightforward.
" It's more of a question and answer
format - if the rule says, 'X,' show me
'X.' If the rule says 'Y, " show me 'Y.' "
The smallest growers have little
to prove in order to qualify for an
exemption from the rule.
" If they are $25,000 or under in
their sales, then all they have to do is
show their financial records and show
that they're under the threshold, and
then they're off the hook, " Goldenberg
said. Income/expense records, sales
records and tax paperwork could be
used to document the size of the farm,
he said.
The ERS ag economists wondered
whether farms would be subdivided
just to take advantage of the leastdifficult
rules. " Exemptions for
small growers allow for the unique
arrangements surrounding marketing
directly to consumers, restaurants, or
retailers, but it is uncertain whether
growers would restructure their
businesses to claim these exemptions, "
they wrote.
FGN | OCTOBER 2019 | 13
Goldenberg said growers of all sizes that
he trains are generally able to comply with
the rules that apply to their operations.
" They may say - and what I hear -
'I have to do more record keeping?'
Because they do have OSHA or other
state regulations, " he said. " Yes, they
may have to do more records than
what they normally do. But they
would keep them out of hot water,
too, in that they're following the
law, but also you would assume they
would want to sell a product that is
not going to make people sick. I don't
know that these standards are all that
difficult or onerous to meet. If they
are in food production, they would
want to produce good food that's safe
and wholesome. "
The ERS economists reported some
growers " lamented that excessive and
ever-changing food safety standards
and intensive recordkeeping distract
from their core business of growing
produce. " But, " many were willing to
make investments that they believed
reduced food safety risks and satisfied
buyers' requirements, " they wrote.
A wait-and-see approach has been
in part possible due to the limits of
enforcement activity. Goldenberg said
there are only 16 food safety inspectors
to serve an estimated 23,000-28,000
produce growers in California.
But he argued that playing wait and
see wasn't a good decision.
" They're all independent
individuals that have run businesses
their own way, and I understand
that, " Goldenberg said. " And now
you've got a governmental agency
that says you're going to run it this
way. I understand the pushback. But
what's the alternative? Putting out
some bad product, getting people sick
and then being sued as a business, or
potentially, if they were aware they
had a problem, going to jail? I don't
think that's a good alternative. "
He said most growers find
compliance is within reach, even if
there is an expense.
" Everybody that walks out of my
training feels good that they can comply.
Now, that doesn't mean that they don't
have to make any changes to anything,
but I don't think it's that onerous. " FGN
October 2019

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