Food Protection Trends - May/June 2021 - 271

extremely important when training an audience whose native
language is not English (9). The authors suggest that the use
of illustrative resources, such as videos, charts, or pictures,
can convey information without language use. The authors
also suggest that trainings limit the use of food safety jargon
(words such as bacteria, contamination, and hygiene) by
replacing them with terms that are more familiar to produce
workers (such as germs) (9).
Low posttest scores for module 4 (Wildlife, Domesticated Animals, and Land Use) and module 6 (Postharvest
Handling and Sanitation) are of particular concern because
animals and sanitation practices have been linked to produce outbreaks. For example, deer feces in the growing
environment were the source of contamination in the 2011
E. coli O157:H7 outbreak linked to strawberries in Oregon
(8). The importance of postharvest handling and sanitation
was reported in the 2011 multistate outbreak of Listeria in
cantaloupe (24). In the final FDA environmental assessment
report for this outbreak, FDA reported that the facility had
recently acquired and installed equipment previously used
for another raw agricultural commodity (potatoes) and that
this equipment could not be easily cleaned and sanitized.
In addition, the facility's floor was constructed in a way that
prevented adequate cleaning and sanitizing.
Within 1 year of completing the PSA Grower Training
Course, 67% of growers made a food safety practice change
related to wildlife or domesticated animals. If there is
reasonable probability that animal intrusion will contaminate
produce, §112.83(a) of the FSMA PSR requires that those
areas used for growing covered produce be monitored as
needed during the growing season and immediately prior
to harvest. Practices commonly used to conserve natural
resources and encourage wildlife can appear to conflict
with on-farm food safety practices. Comanagement among
wildlife, the environment, and a produce farm provides a
way to address complex farm management needs through
a mutually beneficial approach. Many physical decoys and
chemical applications used to deter or repel wildlife work
only temporarily, after which the wildlife return. Although
the FSMA PSR is clear in its mandate that no produce that
has been in contact with animal fecal matter is to be harvested
for human consumption, the FSMA PSR, as of May 2020,
lacks final ruling on the application standards for untreated
biological soil amendments of animal origin (BSAAO)
(28). The FDA has delayed rule enforcement until a risk
assessment and additional research about the effectiveness of
integrating appropriate application intervals to protect public
health have been conducted (27). To help the FDA develop
appropriate guidance on BSAAO, Soil Summits were held in
Geneva, NY (March 2017), Houston, TX (December 2017),
and Atlanta, GA ( January 2018 and September 2019) (18).
The produce industry provided information and insights to
inform the process of clarifying the reserved part of the PSR
regarding application intervals for untreated BSAAO (18).

This process is to ensure that FDA has a good knowledge of
how untreated BSAAO are used on produce farms and of
the issues growers face in implementing practices to reduce
risks (27). A fact sheet was developed by FDA in 2019 to
clarify FDA's definition of BSAAO, how and when they can
be applied, and where to find relevant requirements within
the PSR. In addition, a stand-alone course about BSAAO was
held in Altoona, IA, in fall 2019 (27).
The low posttest scores for module 6 (Postharvest
Handling and Sanitation) provide evidence that more
education is needed about this topic. The importance of
postharvest handling and sanitation for plant disease control
has been researched for decades among the horticulture
community. Boyette et al. (1993) explain that " Pathogens
brought into the packing house along with the produce will
contaminate all working surfaces quickly. Decay-causing
organisms attached to the tank walls, grading belts, brushes,
and other surfaces can remain viable for months " (4). The
authors of this paper suggest that time, labor, monetary
investment, infrastructure, and equipment design are
barriers to improving postharvest handling and sanitation,
as observed during human food inspections under the
Preventive Controls for Human Foods Rule. In a report
by FDA in October 2019, in the United States there were
516 full-scope FSMA Human Food Preventive Control
Inspections, which resulted in 157 no action indicated
(meaning no action required), 172 voluntary action
indicated, and 64 official action indicated. Three of the
five most frequent citations related to food handling and
sanitation practices were (i) 21 CFR 117.165(b) (Sanitation
Controls Verification Procedures: Establish & Implement);
(ii) 21 CFR 117.145(a) (Process Controls; Monitoring
Procedures: Establish & Implement); and (iii) 21 CFR
117.145(a) (Sanitation Controls Monitoring Procedures:
Establish & Implement) (6). Within the postharvest setting,
postharvest monitoring and sanitation to prevent and
eliminate crop disease are well practiced. Still, foodborne
pathogens do not manifest in physical crop damage, making
it harder for growers to prioritize food safety in their daily
routine. The self-reported behavioral change data indicate
that 37% of participants are implementing new or different
practices for monitoring on-farm facilities.
On average, respondents' lowest pretest and posttest
scores were for module 7 (How to Develop a Farm Food
Safety Plan). The module contained two of the top five most
missed questions (22 and 24, Table 3). Confusion over
question 22 may have stemmed from the fact that the PSA
Grower Training has an entire module that covers how to
develop a farm food safety plan but the FSMA PSR does
not require that a farm have a written food safety plan (16).
It is suggested, however, that having a written plan can help
growers become more organized and focused when it comes
to produce safety and can help with preparing for buyer
requirements and third-party audits (16). The behavioral

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