Food Protection Trends - May/June 2024 - 163

Safety and PCHF Rules. Separate mailings of the survey link
were sent between August and December 2019 on behalf of
NECAFS to the FSPCA list of PCHF course lead instructors
in the 13 NECAFS network states and district. A total of 75
responses were received; 6 responses were excluded because
it was unclear whether they were part of the target audience,
and 11 responses were excluded because the respondents did
not live or work in the Northeast and thus would not provide
an accurate perspective of the target audience. Partially
completed surveys were analyzed question by question to
determine whether the results merited inclusion.
After completion of the initial survey, we found that a low
number of responses from regulators (n = 11) who work directly
with SVS food processors provided a limited perspective
from this group. Therefore, we conducted a follow-up
survey sent exclusively to regulators. The questions included
in the survey were identical to those in the first survey
except for those asking about challenges observed during
inspections and those specifically directed to FSPCA lead
instructors. We sent this survey exclusively to state regulators
located in NECAFS network states that were listed in the
Association of Food and Drug Officials (AFDO) Directory
of State and Local Officials (1). Each was asked to participate
in the study and/or provide contacts in field offices for others
with knowledge of the PCHF Rule and who would be willing
to complete the survey. In the United States, most state
food safety agencies contract with the FDA to enforce FDA
regulations, including all those in the Northeast except for
Delaware, New Hampshire, and Rhode Island (30).
The list of contacts was reviewed and refined to 75
individuals confirmed as meeting the required criteria.
The link to the survey was initially sent by email in June
2021, followed by four reminders: two in July and then two
more in August specifically targeting regulators in states
from which we had not received responses or who had
been recommended to us after the initial email recruitment
campaign was completed. Of the 43 responses received, 6
responses were excluded because they were not actually
a regulator or did not live or work in the Northeast, thus
yielding 37 usable surveys. Of these, 5 surveys were partially
completed and analyzed question by question to determine
whether the results merited inclusion.
To avoid duplication of data, regulators who responded to
the first survey were removed from the dataset before analysis.
Hereafter, respondents to the initial survey are called food safety
communicators, whereas those responding to the follow-up
survey are called regulators. The University of Vermont Institutional
Review Board for Human Participants deemed both
surveys to be exempt from review (study 00000460).
RESULTS
Background of survey respondents
Survey responses revealed varying expertise and levels
of involvement on PCHF issues among both food safety
communicators and regulators. Table 1 shows professional
titles and activities in which food safety communicators and
regulators work with SVS food processors. Respondents
could select more than one response. Among food safety
communicators, more than a third identified as commercial
consultants (35%), followed by university extension
educators (33%). Shared kitchens and copackers (15%)
and, to a lesser extent, retail food operations (6%), buyers
or distributors (6%), process authorities (4%), insurance
companies (2%), and commercial laboratories (2%)
accounted for the remaining categories. Nearly half of
respondents (46%) self-identified as lead instructors for
the FSPCA PCHF curriculum, of which 43% and 38%
coidentified as a consultant or an extension educator,
respectively. All 37 regulators responding to the follow-up
survey stated they were either currently employed or recently
retired from state agencies charged with enforcing food safety
regulations, of which 32 stated that they perform facility
inspections, reviews, or audits (data not shown).
Most food safety communicators (62%) indicated that
they conduct one-on-one or small-group advice or assistance
activities to help SVS food processors comply with the
PCHF Rule, with about half of those indicating it was their
main responsibility (Table 2). Among those who did not
advise or assist processors (38%), most indicated that they
refer questions to others. Among regulator respondents, a
combined total of only 38% indicated that they offer advice
and assistance to SVS food processors as their main or partial
job responsibility. Among the 62% of regulators who do not
provide direct assistance or advice, most forward questions
to others with more expertise.
At least one respondent from each of the surveys was
located or worked with processors located within each of
the 12 NECAFS network states. None of the respondents
were from Washington, D.C. Pennsylvania, New York, and
Massachusetts were the most frequently reported locations
by food safety communicators, and Pennsylvania and
Vermont were the most common locations of regulator
respondents (Table 3). When food safety communicators
were asked in which state or district the food processors
they work with are located, Pennsylvania, New York, and
Massachusetts yielded the most responses (Table 4). It
is apparent that some food safety communicators work
with processors in multiple states, as evidenced by a
higher number of responses compared with the number of
respondents and the written comments mentioning outof-state
work in Ohio, Wisconsin, Utah, Florida, Oregon,
Arkansas, Iowa, and California and more broadly in the
southern United States, nationally, and internationally. In
contrast, regulators worked exclusively with processors in
their own states, as would be expected given the boundaries
of their state jurisdictions.
Table 5 presents a summary of the types of food products
with which food safety communicators and regulators have
May/June Food Protection Trends 163
Food Protection Trends - May/June 2024

Table of Contents for the Digital Edition of Food Protection Trends - May/June 2024
