Food Protection Trends - May/June 2018 - 157

ally in the U.S., consumption of produce has been reported
to contribute to 46% of the foodborne illnesses and 23% of
the deaths (23). The highest percentage of illnesses has been
attributed to leafy vegetable commodities (22%) (23). Produce-containing foods were the source of approximately half
of norovirus outbreaks, with an identified simple food vehicle
during 2001-2008 (18), and the second most frequent food
source for E. coli O157:H7 outbreaks during 1982-2002
(34). In the 2009-2013, CDC National Outbreak Reporting
System (7), 29% of the outbreaks were attributed to produce - fruits, vegetables, grains and sprouts. It is not always
clear from some of these outbreaks what could be specifically
attributed to on-farm contamination versus home or retail/
foodservice. However, 2012 CDC surveillance data reflected
583 documented illnesses from seeded vegetables (e.g., cucumbers, tomatoes) and row crops (e.g., leafy greens) versus
the 1,504 illnesses reported in 2015 (8, 9) that likely occurred prior to retail or consumer preparation. Furthermore,
with no action, the FDA estimated that the over 900,000
domestic foodborne illness cases attributed to produce
that would be covered by the rule would not be expected
to decrease substantially (46). Foodborne illness outbreak
investigations provided evidence to support the development
of risk-based preventive strategies to minimize food safety
risks and regulatory oversight for implementation, using
GAP on-farm food safety strategies as the foundation.
The Food Safety Modernization Act (FSMA) was signed
into law in 2011 (45) and directed the FDA to enact 7 food
safety rules. One of these, the Produce Safety Rule (PSR),
mandated a federal standard for the growing, harvesting,
packing and holding of produce for human consumption
(45). The PSR specifically identified the Produce Safety
Alliance (PSA) developed training curriculum (or equivalent) as the required training that all farmers would need to
comply with the FSMA-PSR. This training, aligned with the
PSR requirements, has the principles of Good Agricultural
Practices from growing to packing as its foundation. Prior
to FSMA, growers implemented voluntary GAP programs,
which were administered by state agencies, USDA, and/or
private auditing firms and were usually mandated by buyer
requirements. There are state programs (e.g., RI, MA),
and nationally recognized programs (Harmonized, USDA
GAP/GHP).
Because small local and regional food systems were
most challenged by food safety and food safety regulation,
Congress included a Qualified Exemption (QE) for small
growers in the Act. Growers who generate between $25,000
and $500,000 in total annual food sales and sell the majority
(> 50%) of their produce to qualified end users - direct
to consumers, or to retail, restaurants, supermarkets that
are within the same state or within 275 miles of their farm
- qualify for the exemption. Additionally, growers with
produce sales less than $25,000 would not be covered by the
PSR (45). The U.S. Census of Agriculture estimates that 96%

of fruit and vegetable farms in the New England (NE) region
have gross sales under the qualified exemption threshold
of $500,000 (43), thereby potentially meeting the PSR
requirement for QE and not being required to attend PSA
training (or equivalent).
However, buyers can require compliance with the rule
and/or an on-farm, third-party audited GAP program. A
study of VT growers found that the primary motivation to
become GAP certified was buyer requirements (88%), with
fewer growers citing the need to assure their customers of
the safety of their food (6%) and/or plans for expanding
market access (6%) (1). There would appear to be little
incentive for "exempt" farmers to learn about and implement
produce safety practices unless their buyers require it.
However, farmers need to adopt practices that protect
consumers. Consumers are aware of issues that shape
their produce purchasing decisions (3) and they react to
outbreaks by reducing their consumption and purchases
of the affected commodities, resulting in both immediate
and long-term economic losses for the industry (6, 24).
One of the factors influencing consumer choices about
purchasing local produce is food safety. Many consumers
perceive local (and often organic) produce to be safer than
non-local, conventional produce (2, 11, 12, 48). Between
2007 and 2012, 25 states saw both the number of farms
and the amount of land in farms decrease, while only 10
states, including the 6 New England states, saw both of these
numbers increase (41). Between 2002 and 2007, the value
of products to consumers sold to consumers by RI farmers
alone through direct market channels (e.g., farm stands,
Community Supported Agriculture (CSAs), and farmers'
markets) grew by 42% (31). In a 2013 survey of market
managers across the United States, over 60% indicated
that there was an increase in customer traffic and annual
sales (36). While market growth appears to have slowed
since 2012, direct marketing of farm products through
farmers' markets continues to be an important sales outlet
nationwide, with a national count of farmers' markets in
2017 at close to 8,700 (37). Direct-to-consumer sales have
helped smaller farms maintain economic viability (12, 20).
Smaller NE farmers could leverage market share with a
specific audience because of the food safety perceptions and
anecdotal experiences of consumers, but all farmers need to
adopt practices that protect the consumer. However, there
have been few studies to assess farmers' knowledge and onfarm implementation of food safety procedures that could
lie outside the regulatory framework, and no recent studies
have specifically targeted New England farmers.
The majority of NE farms will be either uncovered by,
or exempt from, the current PSR regulation; however, the
adoption of science-based, scale-appropriate on-farm food
safety prevention strategies to minimize risks is important
for all farmers, regardless of size and regulatory mandate.
Educators have little information regarding the on-farm

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