Food Protection Trends - July/August 2023 - 324

rule had not yet to be finalized at the time the research was
conducted (early 2022), so it might have been hard for
growers to devote much time to implementing the practices,
but large growers may have already implemented traceability
systems to meet buyer requirements (20). The Food
Traceability Final Rule was published by the Food and Drug
Administration on November 17, 2022.
Ironically, those who were required by law to take the PSA
training were the least likely to find it useful. More than half
of the participants in the study managed farms that were
GAP certified to meet buyer requirements-often the requirements
of processors, an auction house, or intermediated
markets. These growers tended to operate larger farms, were
more likely to be covered by FSMA, and thus, were required
to attend the training. Many of them considered the PSA
training a refresher but otherwise not very impactful, because
they were already implementing needed practices. However,
those who were not required to take the course, because they
operated qualified exempt farms or farms not covered by the
PSR, were more likely to find the training useful. These growers
tended to operate smaller farms that relied primarily on
direct-to-consumer markets, which do not require food safety
practices. In the previously mentioned NCR FSMA Center
follow-up survey, frequency of on-farm food safety change
was compared among farms of each FSMA coverage status
(fully covered, partially covered including qualified exempt,
not covered, and unsure). The fully covered (larger) growers
made food safety practice and infrastructure changes at the
second-lowest rate of all growers, at 71% (6). The only group
that made fewer changes were the growers who do not grow
covered produce (those not covered by the PSR), 63% of
whom made a change. In contrast, 86% of people from farms
that were eligible for a qualified exemption and 81% of those
from farms that were not covered by FSMA because they
sold less than $25,000 of produce annually reported making
a change to food safety practice, infrastructure, or equipment
in the year after attending training (6).
The participants shared several food safety improvements
they hope to make on their farms but mentioned that time,
money, and personnel were limiting factors. These changes
and barriers were consistent regardless of the number of years
after training, as noted by comparing the interview results
with an NCR FSMA Center one-year follow-up survey (6).
As one grower called it, these were " forever projects. " One
might have expected growers to make easy improvements,
such as to hygiene practices, in the first year after training
and later make the harder or more expensive changes, such as
replacing equipment or improving infrastructure. However,
these interviews showed that even four to six years after
attending the training, many participants had not yet made
the more difficult changes that they would like to make, such
as improving pack shed structures. There were exceptions to
this, as two growers mentioned making improvements every
year, especially as the farm made more profit.
324 Food Protection Trends July/August
In a 2018 study, the U.S. Department of Agriculture
(USDA) Economic Research Service estimated the cost for
produce growers to comply with the PSR. Large farms with
sales over $3.45 million would incur a compliance cost of
about 0.3% of the value of produce sales annually. Medium
sized farms ($500,000-$700,000) would spend about 4.2%.
Small farms ($250,000-$500,000) and very small farms
($25,000 and $250,000) were estimated to incur annual costs
of 6.0% and 6.8%, respectively (4). More targeted research
should be done to determine, first, why exempt farmers are
adopting requirements stipulated in the PSR, and second,
how much it is costing them to do so. This voluntary adherence
to food safety practices may be an indicator of growing
awareness of food safety risks associated with fresh produce
and a commitment on the part of farmers to protect consumers
from foodborne illness. In addition, exempt farmers may
be adopting food safety practices for their own risk management
or in response to market pressure (2).
Labor shortages were also an ongoing concern. The situation
may have been challenging before but was exacerbated by
the COVID-19 pandemic, as highlighted in an article in The
Produce News (9). In addition, research study participants
did not mention the need for further education as a barrier
to making further on-farm food safety changes. The NCR
FSMA Center one-year follow-up survey also noted that lack of
knowledge or need for technical assistance were less common
barriers (6). Therefore, going forward, extension services and
state departments of agriculture or health may need to focus on
relationships with growers and addressing the barriers of lack
of time, money, and labor, rather than on education.
CONCLUSIONS
Participants remember key information they learned at
the PSA trainings they attended four to six years ago and
have implemented changes that were within their available
resources. The training was effective in teaching food safety
concepts to growers, especially those who had not previously
participated in food safety training. Recognizing that the
primary barrier to making on-farm food safety changes is
not a lack of education but rather the lack of time, money,
and labor, additional advocacy needs to be made to support
sustainability in the fruit and vegetable industry.
The authors were expecting to see more robust changes
in relation to infrastructure (packing sheds, handwashing
stations, etc.). However, many growers were still listing the
same changes that were noted from growers one year after
training. This is because the major barriers, including time,
money, and personnel challenges, still exist. Although the
authors are extension educators whose tendency is to address
these challenges by creating tools to save time and money,
such as spreadsheets, forms, or templates, this research
showed growers were more likely to request an educator's
time than tools and were more likely to use the many existing
tools that had been personally recommended to them.
Food Protection Trends - July/August 2023

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