Local Food Safety Collaborative Listening Session...
Transcript of Local Food Safety Collaborative Listening Session...
Elizabeth A. Bihn, Laura Pineda-Bermúdez, and Lindsay Springer Cornell University, Department of Food Science, Geneva, NY 14456
August 13, 2019
Local Food Safety CollaborativeListening Session Report
LFSC Listening Session Report 1
Table of Contents
Executive Summary ............................................................................................................................................ 2
Introduction .............................................................................................................................................................4
Areas of Discussion Based on the Needs Assessment Survey .................................................. 6
Materials and Methods ..................................................................................................................................... 6
Participant Recruitment ............................................................................................................................... 7
Analysis ................................................................................................................................................................8
Results ........................................................................................................................................................................8
Local Food Producer Participants ...........................................................................................................8
Markets Serviced by Local Food Producers ....................................................................................... 15
Food Safety Impact on Food Operations ............................................................................................ 19
FrequencyofFoodSafetyInfluenceonDecisionMaking ............................................................ 20
FoodSafetyTrainingAttendance ............................................................................................................. 21
AssessingRisks ................................................................................................................................................ 23
WorkerTrainingandChallenges ............................................................................................................... 24
GrowerSpecificDiscussionsonWater,SoilAmendments, Self-Audits and Farm Food Safety Plans ............................................................................................. 25
ProcessorSpecificDiscussionsonAllergens, FoodSafetyPlans,andFoodProcessingLocations ....................................................................... 27
ChallengestoAdoptingFoodSafetyPractices ................................................................................. 28
Resources Requested and Needed ........................................................................................................ 30
Discussion ................................................................................................................................................................. 33
Acknowledgments ............................................................................................................................................... 39
References ................................................................................................................................................................40
Appendix A ...............................................................................................................................................................41
Appendix B ...............................................................................................................................................................49
LFSC Listening Session Report 2
Executive SummaryFood is a basic human need. Once people can meet this basic need, many people will tailor their food
choices to meet other goals such as optimizing nutrition, enjoying novel foods, and supporting their
local economy. Interest in locally produced foods has generated opportunities for many growers and
processors. Local food producers have become integral members of communities and stimulated
economic growth in both urban and rural areas. As with all food producers, it is critically important
that the food they produce be safe. Their understanding and implementation of food safety practices
has both health and economic impacts for their customers and consumers.
In 2017, the Local Food Safety Collaborative (LFSC) Needs Assessment Survey was developed and
distributed to local food producers throughout the United States of America (U.S.) to determine
their food safety attitudes, knowledge, practices, and barriers to implementation. Between March
and July 2018, a series of listening sessions in each region of the country (Northeast, Southern,
North Central, Western) were conducted with local food producers by Cornell University and Local
Food Safety Collaborative personnel to gather further insights regarding food safety and expand on
information learned from the Needs Assessment Survey. There was a grower and processor
listening session in each region with an additional Spanish-language session in the Western Region,
with 81 total participants.
The grower and processor participants produced a variety of commodities and products,
representing the diversity seen in local foods. Their operations ranged from small to large with the
largest two groups represented grossing either between $0 and $24,999 or $25,000 and $250,000.
Listening session participants self-identified across many of the USDA designated categories and
supplied all food distribution channels, ranging from direct-to-consumer to national food suppliers.
Specific percentages of market sales depended on the individual, but some local food producers
serviced only one market while others serviced as many as nine. The regional proportions of market
sales are included in this report.
When asked about their food safety perceptions and impacts on their food businesses, local food
producer participants had a wide range of viewpoints. Some participants positively attributed food
safety practices to an increase in quality and confidence in their product, while others were not
sure that certain practices actually made a difference in safety but noted that implementing the
practices required a high-level investment of time and resources. There was concern that some
required practices were not science-based or addressing real risks, while other risks were ignored
by both audits and regulations. There was confusion about terms such as risk assessment and hazard
analysis, including what they are intended to do and how they were to be implemented.
This inconsistent understanding extended to food safety practices.
Based on listening session discussions, there are food safety practices related to worker training,
water use and quality, soil amendments, recordkeeping, and sanitation that should be adopted
LFSC Listening Session Report 3
by local food producers. For instance, worker training programs are not always implemented. It
seems this may be because some local food producers employ non-traditional work forces where
traditional worker training programs are difficult to establish either because of interpersonal
relationships, non-traditional payment schemes, or other situations. Worker training is not the only
area though, water use and recordkeeping challenges were also discussed. Although Subpart E of the
Food Safety Modernization Act (FSMA) Produce Safety Rule currently has delayed implementation,
water quality is still a concern for many growers including water testing costs and access to
laboratories within their geographic areas. There also was widespread confusion in recordkeeping
requirements and the conflation between the FSMA requirements, buyer requirements, and third-
party audit requirements.
Barriers to adopting food safety practices included time, cost, and labor as well as perceived lack of
resources and insufficient access to technical assistance. Local food producers want resources with
examples of good food safety practices being implemented on different size and type operations,
including templates for recordkeeping and standard operating procedures. Some requested
resources already exist, highlighting the need for more effective dissemination of information.
Local food producers want and need technical assistance from individuals they trust and who have
the expertise and experience to answer their questions competently. The valued relationship and
subject-matter knowledge are imperative for those assisting growers and processors. The concern
was raised in multiple listening sessions of those providing technical assistance not having an
enforcement role or role in enforcement agencies, due to perceived liability reasons. Local food
producers expressed frustration in the complexity of food safety requirements at the local, state,
federal, and industry levels and outlined their need for them to be clearly shared. Many local food
producers had suggestions for ways to improve outreach and their ability to implement practices.
These ranged from better communication tailored to their operations, products, and commodities
to mentorship programs involving more experienced growers and processors from similar type
operations. The key was having access to high quality information, competent technical assistance,
and financial resources to support both their understanding and implementation of food safety
practices to reach compliance with regulations and industry standards.
Highlights• All food distribution channels are supplied by local food producers.
• There are food safety practices that need to be adopted by local food producers.
• Food safety requirements are complex and need to be clearly shared.
• Local food producers want and need additional food safety resources.
• Local food producers want and need experienced and competent technical assistance.
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IntroductionThere are individuals who grow and/or process food for their surrounding local markets,
contributing to regional food systems in every state in the nation. The local food movement is
an expanding trend in which consumers and retailers purchase foods grown or produced locally,
usually within a limited geographic range. There are many reasons why people “buy local” including
a desire to know where and how food is grown or made as well as reducing the carbon footprint
in the food system (Martinez et al., 2010). This local food movement has gained significant traction
since the turn of the millennia. Direct-to-consumer sales from farms were worth $1.2 billion in 2007
and by 2015, the Local Food Marketing Practices Survey reports that U.S. farms sold $8.7 billion in
food directly to consumers, retailers, institutions, and local distributors (USDA NASS, 2016).
Although this increase includes additional markets beyond direct-to-consumer sales, it is an
indication that the local foods movement is expanding. The majority of farm businesses that market
locally are small to medium in size, and tend to be diversified in produce and value-added food
offerings. As a whole, the majority of local food producers rely on direct-to-consumer markets
through on-site sales or farm markets that create unique economic models tailored for surviving on
tight profit margins. Despite direct-to-consumer sales represented only 0.4% of agricultural food
sales from 2002-2012), these farm and food enterprises represent growing entrepreneurial business
systems that fortify local economies through agritourism, rural employment, and sustainable food
systems (Low et al., 2015).
Since local food producers are providing food for consumers, it is important that they be aware
of food safety principles and practices so that the foods they produce are safe and public health
is protected. Some local food producers may sell into markets that do not have food safety
requirements or they may be exempt from food safety regulations. For instance, growers may not
feel the pressure to implement food safety practices if their fruit and vegetable buyers are not
requiring them to implement Good Agricultural Practices (GAPs) or other food safety practices.
In addition, small farms and small processing operations may not be subject to the 2011 Food Safety
Modernization Act (FSMA). The FSMA legislation has multiple parts, two of which address the main
activities of local food producers. FSMA requirements outlined in 21 CFR Part 112, “Standards for the
Growing, Harvesting, Packing, and Holding of Produce for Human Consumption,” also known as the
Produce Safety Rule (PSR), give the FDA regulatory oversight for covered fruits and vegetables that
are commonly consumed raw. The PSR details standards for employee training, health and hygiene,
agricultural water, soil amendments, wild and domesticated animals, and buildings and sanitation.
Whether or not a farm is subject to FSMA Part 112 depends on farm size, which is determined by
gross income where product is being sold. Very small farms with average gross sales under $25,000
(based on a three-year rolling average, adjusted for inflation) are deemed exempt from the FSMA
regulation. The PSR outlines qualified exemption status to those who gross under $500,000 (based
on a three-year rolling average, adjusted for inflation) and sell more than 50% of their produce to
qualified end users within 250 miles or the same state. For processors, 21 CFR Part 117 “Current Good
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Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food” is
also known as the FSMA Preventive Controls for Human Food Rule (PCHFR). The PCHFR is intended
to ensure the safe manufacturing, packing and holding of food products for human consumption.
Under the PCHFR, a qualified facility is either a very small business averaging less than $1,000,000
(based on a rolling 3-year average) in sales of human food plus the market value of human food
manufactured, processed, packed, or held without sale (e.g., held for a fee), or a facility to which both
of the following conditions apply: During the 3-year period preceding the applicable calendar year,
(1) the average annual monetary value of the food manufactured, processed, packed or held at such
facility that is sold directly to qualified end-users exceeded the average annual monetary value of
the food sold by such facility to all other purchasers; and (2) the average annual monetary value of all
food sold during the 3-year period preceding the applicable calendar year was less than $500,000,
adjusted for inflation (Food and Drug Administration, 2018).
While the majority of local food growers and processors may be deemed exempt or qualified from
FSMA legislation based on gross sales and local distribution channels, the FSMA legislation may
motivate more markets and their buyers to increase food safety requirements on their suppliers
(Bihn, Springer, & Pineda-Bermudez, 2019). For example, local food producers may be required by
buyers to have a third-party audit to ensure they are compliant with FSMA. Even though compliance
can only be determined through an inspection by regulatory agency personnel, some audits are
being updated to include FSMA requirements as a way for the market and buyers to have confidence
that their suppliers are following FSMA requirements. Local food business owners may experience
challenges to meeting food safety requirements including the costs for additional personnel time,
technical assistance, infrastructure improvements, and additional resources needed to implement
practices. An economic simulation by Adalja and Lichtenberg (2018) found that produce growers’
cost burden associated with FSMA compliance was substantially driven by farm size. Increasing farm
size by a factor of ten decreased the cost per acre by 45-90%, illustrating the vast difference in cost
burden to small farms in comparison to larger ones (Adalja & Lichtenberg, 2018).
In order to better understand and assist local food producers with food safety implementation,
the Local Food Safety Collaborative (LFSC) in collaboration with personnel from Cornell University
and the National Farmers Union developed and distributed a national Needs Assessment Survey for
local food producers with a focus on processors and fruit and vegetable growers. Using the results
of this survey, a series of listening sessions were organized to verify and further clarify needs by
providing local food producers an opportunity to discuss their food safety knowledge, challenges to
implementation, and needs for additional resources.
LFSC Listening Session Report 6
Areas of Discussion Based on the Needs Assessment Survey
• What do local food producers currently understand about food safety?
• How are local food producers currently implementing food safety practices?
• Where are the gaps in knowledge about food safety practices among local food producers?
• How do local food producers obtain food safety information?
• What are challenges to implementing food safety practices, including those required by the
Food Safety Modernization Act?
• What resources do local food producers want and need to help them implement food
safety practices?
Materials and MethodsA series of nine, two-hour, listening sessions were conducted between March and July of 2018 in
four different states, one in each region (Northeast, Southern, North Central, and Western) of the
U.S. as established by the FDA and USDA National Institute of Food and Agriculture (NIFA) through
the National Food Safety Training, Education, Extension, Outreach, and Technical Assistance
Grant Program. One grower and one processor listening session was held in each location, with
an additional grower listening session conducted in Spanish in the Western Region. The listening
sessions were conducted as a follow up to a national Needs Assessment Survey distributed to fruit
and vegetable growers and small-scale processors beginning on June 20th, 2017. The listening
sessions were conducted to both determine if the needs assessment survey results were accurate
and expand the understanding around specific food safety topic areas. The needs assessment
survey provided foundational information regarding local food producers’ food safety knowledge,
motivations, practices, and challenges to implementing food safety programs in their operations.
Two sets of scripted questions were developed in collaboration with LFSC partners, one for growers
and one for processors. These questions were asked to participants to further define what types
of training, education, and technical assistance would be most useful and needed as well as their
experiences and challenges with implementing food safety practices. Script development helped to
ensure data collected from each listening session could be compared and contrasted through data
analysis, though each group took the conversation in slightly different directions as was anticipated
due to individual group dynamics. The scripts for each listening session are provided in Appendix A.
Before beginning the listening session, each group was provided a Pre-Listening Session Survey to
inform our research and also help guide discussion. The Pre-Listening Session Surveys are provided
in Appendix B.
LFSC Listening Session Report 7
The listening sessions were deemed exempt from review by the Cornell Institutional Review Board
for Human Participants, ref: protocol #1803007851 on March 16, 2018.
Figure 1 – The Northeast (green), Southern (yellow), North Central (blue), and Western (orange) centers for Food Safety territories, as established by the
FDA and USDA National Institute of Food and Agriculture.
Participant RecruitmentThe listening sessions were advertised through the Local Food Safety Collaborative network as
well as through National Farmers Union’s relationships and communication networks. Each
location within the region was selected based on the ability to successfully recruit groups of both
growers and processors to participate. Recruitment goals were to have between 5-15 people in
each group. Challenges to recruiting participants included participants agreeing to participate but
then not attending, weather challenges that impacted travel, recruiting in small communities which
necessitated allowing people to participate even though they were not currently growing in order
to avoid damaging relationships, and recruiting individuals that knew each other so listening session
discussions and data collected may have been influenced by these relationships. As a result, some of
the listening sessions were smaller than anticipated and some of them were larger than anticipated.
A participant stipend was paid to help cover participant time and travel expenses.
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AnalysisAll listening sessions were recorded with notes taken on paper and electronically. The recordings
were transcribed and translated, in the case of the Spanish-language listening session. The
transcribed listening sessions were coded using a qualitative data analysis software, ATLAS.ti 8.
A deductive analysis approach was used based on the research questions and listening session
structure to analyze the responses to specific questions. Additionally, an inductive analysis
approach was used to identify patterns in responses that went beyond the scope of the listening
session questions. For example, the participants brought up examples of how they felt more or
less supported than other groups without a specific question being posed. When the same themes
occurred across multiple listening sessions, inductive analysis was used to capture this information
so it could be added to the outcomes. The initial themes were identified by similar wording,
described feelings, or experiences that were repeated amongst listening sessions by participants.
ResultsLocal Food Producer ParticipantsThere was a total of eighty-one participants, with some food producers identifying as both growers
and processors and attending both regional listening sessions. Part of the selection criteria for
listening session participants was to have the majority of their food sales (all or greater than
50%) within 275 miles of their operation. Demographic data was collected from listening session
participants through a pre-session survey. In part of this survey, participants were allowed to
select from the nine different USDA categories including USDA Organic, limited resource, socially
disadvantaged, new and beginning, veteran, woman farmer, registered with a farm and track
number through USDA Farm Service Agency, Natural Resources Conservation Service (NCRS)
Cooperator, and Plain Sect farmer. In a few cases, more than one person came from an operation,
but only one pre-session survey was filled out in these cases. The charts below depict the number of
participants per listening session who identified with each category, including not identifying with
any. Participants were allowed to select more than one category. Providing this information was
voluntary, anonymous, and optional so some participants chose not to submit a pre-session survey.
Demographic information for the Western Region Spanish-speaking growers was not collected.
LFSC Listening Session Report 9
Growers
Figure 2 – Western Grower Identifiers, n=6
Figure 4 – North Central Grower Identifiers, n=10
Figure 3 – Northeast Grower Identifiers, n=8
Figure 5 – Southern Grower Identifiers, n=15
USDA Organic Limited Resource Woman Farmer
New & Beginning Registered with a Farm & Track # Socially Disadvantaged
NRCS Cooperator Veteran Plain Sect None
The grower listening sessions had a wider range of self-identification across the USDA categories
than the processor listening sessions, except for those reporting from the Western Region.
Participants were allowed to select more than one category. Five out of six participants in the
Western Region listening session identified as only USDA Organic, with one participant not
identifying with any of the categories. The Northeast Region listening session had at least one
participant identifying with each of the categories except Plain Sect; more than half of the
participants identified as woman farmers and half identified as new and beginning or USDA Organic.
The North Central Region grower listening session participants had more than half registered with a
farm and track number through USDA Farm Service Agency and half as USDA Organic. The Southern
Region listening session had at least one participant to identify with each of the categories or
registrations except veteran, with six participants not identifying with any category.
1
1
1 3
7
66
3
2
6
5
3 5
4
33
6
3 4
1
5
4
3
11
5
LFSC Listening Session Report 10
Figure 6 – Annual Gross Food Sales for Growers, by Listening Session
In the grower listening sessions, there was a varied mix of the annual gross food sales by region;
each region had participants within 3 or 4 different brackets. In the Northeastern Region, the
majority of participants’ annual gross food sales were in the $25,000 to $250,000 range.
There were three participants who grossed between $0 and $24,999, two who grossed over
$1,000,000 and one who grossed between $250,001 and $499,999. The North Central Region
listening session had a similar mix as the Northeastern Region, with four participants grossing
$25,000 to $250,000, three in the $0 to $24,999 range, two grossing over $1,000,000 and one
grossing between $250,001 and $499,999. The Southern Region grower listening session had a
majority of participants grossing under $24,999; this may be because some participants have not
had a growing season yet. In the Western Region listening session, two participants grossed over
$1,000,000 and two participants grossed between $500,000 and $1,000,000, one participant in the
$25,000 to $250,000 range and one below $24,999. The Western Region Spanish-speaking listening
session had four participants grossing under $24,999, four between $25,000 and $250,000 and one
participant grossing between $500,000 and $1,000,000. If these listening sessions are representative
of the regions, there will be some states with more growers subject to the PSR sooner than others,
with differing proportions of qualified exempt growers.
38%
85%
30%17%
44%
50%
8%
40%
17%
44%
13%
8%
10%
33%
11%25% 20%
33%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Northeastern Southern North Central Western Western-Spanish
Annual Gross Food Sales for Growers, by Listening Session
$0-$24,999 $25,000-$250,000 $250,001-$499,999 $500,000-$1,000,000 over $1,000,000
LFSC Listening Session Report 11
Figure 7 – Percentage of Food Sold Within 275 miles of Farm for Growers
There was variation in where grower sales were occurring. Only the North Central Region had a
majority of their sales within 275 miles of their facility. The Western Region listening session had
half of the participants sell less than 50% of their food within 275 miles of their farm; based on the
introductions during the listening session, these growers had most of their sales beyond 275 miles
of their farm. The Southern and Northeast had participants who were not yet selling anything.
This may account for the Southern and Northeast Region participants’ answers of no food sales
within 275 miles of the farm since they were not selling anything. The intention of the question
was to capture those who were selling beyond 275 miles but instead it seems to have captured
those who were not yet in production.
70%
40%33%
63%
33%
30%
13%17%
13%
44%13%
50%13% 11%33%
13% 11%
0%
20%
40%
60%
80%
100%
North Central Southern Western Northeast Western-Spanish
Growers:Percent of Food Sold Within 275 miles of Farm
All Greater than 50% Less than 50% None
LFSC Listening Session Report 12
Processors
Figure 8 – Western Processor Identifiers, n=3
Figure 10 – North Central Processor Identifiers, n=6
Figure 9 – Northeast Processor Identifiers, n=9
Figure 11 – Southern Processor Identifiers, n=9
USDA Organic Limited Resource Woman Farmer
New & Beginning Registered with a Farm & Track # Socially Disadvantaged
NRCS Cooperator Veteran Plain Sect
Each regional listening session for processors included participants who identified as woman
farmers, limited resource, USDA Organic, and new and beginning. All Western Region listening
session participants identified as new and beginning, with the Northeast and the Southern Regions
having over half of their participants identify a new and beginning. The Southern Region listening
session participants reported the most diversity across the categories with at least one participant
who identified with each of the categories or registrations. This information indicates that listening
session participants self-identified across many of the USDA identified categories.
1
1 1 1 2
3
2
54
2
232
22
3 4
1 1
1
1
1 5 2
LFSC Listening Session Report 13
Figure 12 – Annual Gross Food Sales for Processors, by Listening Session
In each regional listening session, participants’ annual gross food sales varied. Five of nine
participants in the Northeastern Region and two of three participants in the Western Region
listening session had their annual gross food sales within the $25,000 and $250,000 range.
The Northeastern Region had additional participants in both the $0 to $24,999 range and over
$1,000,000 range. The Western session’s third participant was in the $0 to $24,999 range as well.
The majority of the North Central participants had their annual gross food sales within the $250,001
to $499,999 range, with the next largest groups being $25,000 to $250,000 and $0 to $24,999,
respectively. A majority of Southern session participants had their annual gross food sales within
the $0 to $24,999 range, which includes processors who had not begun selling their product yet.
There were a few participants in the Southern listening session with annual gross food sales in the
$250,001 to $499,999 range. If these listening sessions are representative of the regional gross food
sales, there will be some states with more processors subject to the PCHFR sooner than others,
with differing proportions of qualified exempt facilities.
33%
83%
17%
33%
56%
33%
67%
17%
50%
11%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Northeastern Southern North Central Western
Annual Gross Food Sales for Processors, by Listening Session
$0-$24,999 $25,000-$250,000 $250,001-$499,999
$500,000-$1,000,000 over $1,000,000
LFSC Listening Session Report 14
Figure 13 – Percentage of Food Sold Within 275 miles of Facility for Processors
For the processors, each region had a majority of their sales within 275 miles of their facility.
The listening session participants in the Western and Northeast Regions had all of their sales
either within 275 miles or 50% of their sales within that same range. The North Central Region
had only one participant who sold less than 50% of their food within 275 miles of their facility.
As mentioned previously, some of the listening session participants were new and beginning farmers
and processors; in the case of the Southern Region listening session, although three participants
identified that either none of their sales or less than 50% of their sales were within 275 miles, these
participants may not have been in operation at the time the listening session occurred and had no
sales. The major markets for the food processors across listening sessions were direct to consumer,
wholesale, small retail, other processors, and regional or national food suppliers.
50%
33%
67%
44%
33%
33%
33%
56%
17%
22%
11%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
North Central Southern Western Northeast
Processors:Percent of Food Sold Within 275 miles of Facility
All Greater than 50% Less than 50% None
LFSC Listening Session Report 15
Markets Served by Local Food ProducersBoth growers and processors were asked to list their markets and provide a percentage of their
sales that went to those markets. Sixty-nine respondents filled out this part of the survey but
16 respondents did not provide percentages. These participants were denoted with an asterisk (*)
in figures 14, 15, and 16. The major markets for the growers across listening sessions were direct
to consumer, wholesale, and regional or national food suppliers. However, in comparison to the
processors, there was a greater diversity of markets within regions for the growers. Among both
processors and growers, direct to consumer is the major market across the regions, but there are
some local food producers who are predominantly selling into the wholesale market with access to
markets beyond local.
Figure 14 – Western Regional Listening Session Percentage of Market Sales
Local food producers in the Western region had a diversity of markets, with some producers
only selling to a single market, while some selling to as many as five. Main markets that this region’s
producers sold to included direct to consumer, small retail, wholesale, and regional or national
food suppliers. There was a greater diversity of markets between the Western region’s producers
than among other regions’ producers. A few producers exclusively sold direct to consumer, others
exclusively to regional or national food suppliers, and one exclusively to wholesale. The additional
markets that these participants sold to included USDA food commodity program, online/catalog,
aggregate entities, direct to institution, emergency food assistance providers, and processors.
Three participants who responded only marked the markets but did not provide percentages,
so each market that was identified was assigned an equal percentage.
0%
20%
40%
60%
80%
100%
Span
ish Grower
Span
ish Grower
Span
ish Grower
Span
ish Grower
Span
ish Grower*
Span
ish Grower
Span
ish Grower
Span
ish Grower*
Span
ish Grower
Englis
h Grower
Englis
h Grower
Englis
h Grower
Englis
h Grower
Englis
h Grower
Englis
h Grower
Processor
Processor
Processor*
Western Regional Listening Session Markets
Direct to Consumer Wholesale Small Retai l
Aggregate Entities Regional or National Food Suppliers Direct to Institution
USDA Food Commodity Program Emergency Food Assistance Providers Online/catalog
Processors Export
LFSC Listening Session Report 16
Figure 15 – Northeast Regional Listening Session Percentage of Market Sales
Northeast local food producers supplied a variety of markets, with one participant selling to
only one market and others selling to as many as five. The majority of these producers sold
direct to consumer, with other major markets including regional or national food suppliers,
online/catalog, aggregate entities, small retail and wholesale. One participant identified online/
catalog as their only market, and another identified direct to consumer as their only market.
Additional markets that a few producers sold to included emergency food assistance providers,
direct to institution, and processors.
0%
20%
40%
60%
80%
100%
Grower
Grower
Grower
Grower
Grower
Grower*
Grower
Grower
Processor
Processor
Processor
Processor
Processor
Processor
Processor
Processor
Processor
Northeast Regional Listening Session Percentage of Market Sales
Direct to Consumer Wholesale
Small Retai l Aggregate Entities
Regional or National Food Suppliers Direct to Institution
USDA Food Commodity Program Emergency Food Assistance Providers
Online/catalog Processors
Export Not for Sale
LFSC Listening Session Report 17
Figure 16 – Southern Regional Listening Session Percentage of Market Sales
Southern food producers also participated in a wide variety of markets. A few participants selected
eight and nine different markets. Seven participants did not provide any information about their
market sales and 12 participants who responded only marked the markets but did not provide
percentages, so each market that was identified was assigned an equal percentage. It is possible
that these participants were new and beginning and had not started operation of their facility at a
commercial level yet. The majority of the participants who responded identified direct to consumer
as a main market for their products, with many indicating that it was their only market. Other
markets that were consistently identified by participants were wholesale, small retail, aggregate
entities, processors and regional or national food suppliers. One participant identified their church
as a major market of their sales.
0%
20%
40%
60%
80%
100%
Grower*
Grower*
Grower
Grower*
Grower*
Grower*
Grower*
Grower
Grower*
Grower
Processor
Processor*
Processor*
Processor*
Processor*
Processor*
Processor
Southern Regional Listening Session Percentage of Market Sales
Direct to Consumer Wholesale
Small Retai l Aggregate Entities
Regional or National Food Suppliers Direct to Institution
USDA Food Commodity Program Emergency Food Assistance Providers
Online/catalog Processors
Export Give Away
LFSC Listening Session Report 18
Figure 17 – North Central Regional Listening Session Percentage of Market Sales
North Central local food producers also have a wide diversity of markets to which they supply.
Only one participant from the processors listening session did not identify direct to consumer
as one of their markets; all but one processor identified small retail as one of their markets. All
the participants in the grower listening session identified direct to consumer as a market. Other
significant markets that were identified across listening sessions in the North Central region were
wholesale, aggregate entities, regional or national food suppliers, direct to institution, small retail,
and other processors.
0%
20%
40%
60%
80%
100%
Grower
Grower
Grower
Grower
Grower
Grower
Grower
Grower
Grower
Grower
Processor
Processor
Processor
Processor
Processor
Processor
North Central Listening Session Percentage of Market Sales
Direct to Consumer Wholesale
Small Retai l Aggregate Entities
Regional or National Food Suppliers Direct to Institution
USDA Food Commodity Program Emergency Food Assistance Providers
Online/catalog Processors
Export
LFSC Listening Session Report 19
Food Safety Impact on Food OperationsGrowers
There was a range of internal and external food safety impacts felt by growers and expressed in
the regional listening sessions. An internal impact identified was change in thinking surrounding
how they run their operation and problem-solving in regards to food safety. External impacts felt
by growers included changing requirements and increases in time and cost required in order to
comply with state, buyer, and federal food safety requirements. Growers identified changing buyer
requirements that resulted in increased pressure to take part in different auditing schemes and
comply with the FSMA PSR even if they are exempt or grow non-covered produce. This pressure
impacts their access to regular markets. A frustration expressed was that there was no consistency
between the audits being requested by their markets and often the markets required different audits
with different demands.
A positive impact felt by growers and processors was their confidence in the safety of their products
and marketing advantage in implementing food safety practices. Some growers felt that they were
able to access more markets or were more appealing to buyers. The difference between thinking
food safety had a positive impact versus a negative impact seemed to be related to region based
on the way growers have felt pressure from their state or from buyers. This pressure seemed to
vary depending on the size of their operation, the commodities grown, and how long they have
been in operation. One Northeast listening session participant mentioned how much easier it was
for them to change their way of thinking and operating because they were new to the operation in
comparison to their father, who had been farming for much longer.
Processors
When asked about how food safety impacts their food processing business, processors had a variety
of answers, ranging from negative to positive. In the Western and North Central regional listening
sessions, the processors noted that the documentation requirements posed a significant challenge
and impact in their operations. A few of the participants only had one or two employees, including
themselves, which they stated made the recordkeeping difficult to do during production. Concerns
shared regarding recordkeeping in one-person operations included worker safety issues and product
safety and quality issues due to multi-tasking challenges. Examples included having to stop in the
middle of processing to write down measurements for pH levels and temperatures. Participants stated
they monitor these parameters during production but the mandated times at which they needed
to be documented created a break in the flow of processing which participants felt increased other
risks. Positive impacts of food safety on food processing businesses identified by participants included
knowing more about the control points in their product, having increased access to markets, and
confidence in the safety of their product. Processors in the Southern Region listening session described
food safety as having a positive impact on the quality of their product.
LFSC Listening Session Report 20
Across the regional listening sessions, small-scale processors had trouble finding resources available
for their type of operation or for their specific products in order to be in compliance with regulatory
requirements. Examples of operations include grain milling, mushroom processing, and shared
commercial kitchens, amongst others. Not only were the available resources not applicable, but
trusted sources had a difficult time providing clear answers to questions at times. Navigating unclear
requirements was a major impact for processors looking to expand their operations, startup new
food businesses, and for beginner processors. Processors noted that food safety also impacts the
procedures within their facility, such as cleaning and sanitizing procedures, validation procedures,
and production processes. Additionally, processors acknowledged a change in their perspective and
behaviors that came along with a greater knowledge of food safety. Participants identified cost of
food safety compliance, whether it was for FSMA or for a third-party audit, as a significant impact
but many noted that they viewed that cost as an investment in their businesses.
Frequency of Food Safety Influence on Decision Making When asking local food producers how often food safety influences decision making in their food
businesses, participants across listening sessions answered in very similar ways. Both growers
and processors stated that food safety and produce safety constantly influenced their decision
making, even though its impact was variable. Specifically, in the grower listening session for the
North Central and Northeastern Regions, a few participants stated that produce safety influenced
their decision making less frequently because of the commodities they grew or because food
safety was so ingrained in their regular decision making that they did not consider it explicitly.
Many participants across the regional listening sessions would bring up issues of quality in their
products and how food safety was always a factor in their decision making due to its impact on the
quality of the product. Within these conversations, accountability, liability, and responsibility also
were cited as motivations for keeping food safety on the forefront of their decision making.
Processor responses provided additional aspects of food businesses that were influenced by food
safety including money allocation, production processes, equipment purchases, set-up and flow of
the kitchen, batch size, and ingredient purchasing.
Growers stated that food safety influenced their decision making in different ways depending on
their role on the farm and in what types of activities they were participating. An example given by
growers was pre-harvest activities, such as pruning and thinning, where practices represent less of a
food safety risk than harvest activities, where produce is directly contacted resulting in higher risks.
Equipment selection and ease of cleaning were identified by growers as important considerations
influenced by food safety.
In two regional listening sessions for growers, the importance of food safety in their decision-
making in regards to their markets was highlighted. One participant mentioned how important food
safety became when interacting with new markets; the example provided was how their food safety
practices were considered in whether a buyer would engage in business with them. In a different
LFSC Listening Session Report 21
listening session, their consumers’ health and safety was emphasized as a motivator for having food
safety at the forefront of their decision making. This participant explained how their major market
was direct to consumer via farmers markets; having a direct relationship with their consumers
affected the way they prioritized food safety in their operation.
A trend throughout several grower listening sessions and all processors across all the regions was
the focus on the regulatory component associated with food safety. A motivator for implementing
food safety practices was to pass an audit or to be in compliance with regulations. These motivations
were echoed in regions with participants who have had more of an interface with auditors,
inspectors, and other regulatory officials.
Food Safety Training AttendanceGrowers
The majority of listening session participants have attended a food safety training,
with a smaller proportion in each of the sessions having attended a Produce Safety Alliance (PSA)
Grower Training. The majority of participants in the Western, Southern, Northeast, and North
Central regional listening sessions had attended food safety training. All the participants in the
Spanish Western listening session had participated in food safety training.
The participants in both listening sessions in the Western region had concerns about the
qualifications of those who provide trainings. They felt that the instructors did not have enough
knowledge of farming or best practices in the industry. The English-language session had
participants who felt that the trainers did not know how to talk to farmers in a way that would
encourage adoption of food safety practices. However, they felt trainings were more valuable
than resources, particularly if there was no explanation of how to use the resources. The Spanish-
language session had participants who had asked for examples of how to implement practices from
the trainers, but the trainers never followed-up despite assurances that they would. These concerns
were not present in all regions. In the Northeast, the growers felt the trainers were approachable
and felt like they were a dependable resource to ask operation-specific questions. In the Southern
regional listening session, a food hub was named as an organization who put on an excellent GAP/
GHP training that left the attendees feeling confident and prepared to apply the concepts learned
about in their operation.
When asked to specifically reflect on the Produce Safety Alliance Training, thoughts varied.
The growers who had been audited, in the Western and North Central regions, mentioned that
the training was not as helpful to them, some stating it was repetitious or too introductory but
they found the training did contain helpful ‘gems’ explaining nuances or tricky parts of the rule.
An example provided by growers was the description of agricultural water and the importance of
quality for its intended use and whether it would touch produce directly. Newer growers or growers
with smaller operations in the North Central region highlighted how helpful the water module was
LFSC Listening Session Report 22
in their understanding; however, they also mentioned that the water module was very technical and
could have easily gone over their heads depending on the instructor. Overall, participants
did feel like the training was worth their time, although some wished it could be shorter.
The templates included in the PSA Grower Training were cited as a useful resource by participants
for documentation and food safety plan development. A difficulty in asking participants about
their training experiences is that some have been to so many different trainings that they had
trouble remembering what aspects pertained to which trainings.
Suggestions for improvement of future trainings identified by growers included tailoring the
training to a specific commodity group or tailored to the size of their operation. Participants
across the regional listening sessions emphasized the difficulty in applying the information to their
operation due to the ambiguity of the PSR. Growers suggested having trainers with more practical
knowledge about farming.
Growers in the North Central region identified a pre-test as something that they would appreciate
in order to know what sections in which they were weakest prior to the material being presented.
A continuing education format to the trainings was also mentioned as something these participants
would appreciate, in order to stay up-to-date. This was also mentioned as a useful potential
resource by the Spanish-speaking growers in the Western Region listening session. The North
Central participants also stated that examples about the scalability of food safety practices,
discussions on commodity flow within an operation, and the impacts of structural design and
infrastructure would be helpful.
Processors
The participants in the processor listening sessions were more certain of what food safety
trainings they had attended. Due to the variety of products produced by the processors, the types
of training they had attended varied widely. All participants but one attended food safety trainings
in the North Central and Southern listening sessions. Trainings identified included ServSafe,
Acidified Foods, Good Agricultural Practices, Good Manufacturing Practices, Preventive Controls
Qualified Individual (PCQI), PSA Train-the-Trainer, Hazard Analysis Critical Control Point (HACCP),
state allergen training, Better Process Control School, extension product development course,
and food handlers permit.
ServSafe was identified by processors in the North Central regional listening sessions as good
but basic. ServSafe was said to not translate well into the processing world but more towards
restaurants. One processor expressed frustration at having taken a high-level commodity-specific
training course and the state still requiring ServSafe when it was at a lower standard. These
participants were also required to attend an allergen training course provided by their state.
North Central processors also commented that it was difficult to find HACCP trainings that were
not geared towards the dairy industry and that they wished there was more of a focus on other
commodities. A big concern for the processors in the Northeast listening session was the complex
LFSC Listening Session Report 23
technical information of the PCHFR and not enough guidance for their operations, particularly if
they did not fit the standard scenarios presented in trainings. They commented that there was not a
beginning food safety course geared towards processing at a commercial level.
The Western Region listening session participants did not know the name of the trainings they
had attended, but stated that they were fairly useful in learning how to fill out different reports
and understanding the regulations. Their complaint was about state or county permits focused on
aspects within a facility without considering the product being produced. The example provided was
regarding a county requirement to have water accessibility, but the processor had concerns about
its location within his flour processing facility, due to the proximity of water to his final product.
In the Southern Region listening session, a participant cited the FSPCA PCQI training as being very
beneficial in a small business operation because of the required plan-writing aspect. However,
they explained that the cost of attending was high; the cost included registration, lodging and travel
expenses. This participant opted with hiring a consultant to audit their process as a way around the
cost. Another participant had not attended due to the cost.
Assessing RisksGrowers
In the Southern Region listening session, three of seventeen people said they did conduct a
formal risk assessment explicitly. In the other regional listening sessions, growers were vague or
unsure of whether their risk assessment process was formal enough. During these conversations,
there was a sense of confusion in what a risk assessment entailed. In the Western Region listening
sessions, both English and Spanish-speaking growers often associated risk reduction with risk
elimination. The concept of identifying risks then prioritizing the risks to address within their
operation based on the specifics of their processes was understood by some but not all participants
in the listening sessions.
Processors
There was confusion in the listening sessions between hazard analysis, HACCP, and whether either
one was required by the regulations to which they were subject. All participants in the Western
and North Central listening sessions knew what a hazard analysis was. Seven of nine participants
in the Northeast and three of nine participants in the Southern listening sessions knew what a
hazard analysis was. Although knowledge of a hazard analysis varied across listening sessions,
only five of the 27 participants had conducted a hazard analysis.
LFSC Listening Session Report 24
Worker Training and ChallengesParticipants were asked what types of people worked on their operations, in an attempt to elucidate
why so many local food producers answered “N/A” in the Needs Assessment Survey when asked
about worker training. In the pre-session surveys, participants were asked first if they had any
other workers on their operation besides themselves. Secondly, they were asked to list the types of
labor on their operation if they did have other workers. There were participants across the listening
sessions that would say that they had no other workers besides themselves but put types of labor
such as family, neighbors, and volunteers. For the grower listening sessions, family and local labor
were consistently cited as the most-used category of labor. Another notable source of labor used
less frequently were migrant workers or contract workers in all regional listening sessions.
Additionally, when asked specifically about worker training, it was common for people to include
‘not formally’ or ‘informally’ when saying whether they trained their workers or not. Participants
would often explain that these interactions with their workers are conversations about being on the
same page. Some responses revealed a concern about telling people things they already know or
insulting them by asking them to wash their hands (i.e., insinuating they are not clean people).
Growers
The English-speaking growers in the Western regional listening session, noted a preference towards
local labor due to training constraints and worker retention. They compared their operations to
large operations with the capacity to train workers in larger volumes and the large impact in terms
of the time it takes to train workers has on their operation; they placed great value in training their
workers but also emphasized their need to be efficient in doing so. A few growers stated using
contract labor to work for short periods of time and how it took a comparable amount of time to
train them. In this regional listening session only workers with specific roles were trained formally.
The Spanish-speaking growers in the Western regional listening session cited contract workers as
sometimes knowing more about industry practices than they themselves knew, due to the amount
of exposure the workers received as they traveled from operation to operation.
For growers with diversified operations, they were training their workers on a semi-constant
basis throughout the growing seasons as the crews rotated through new crops. The North Central
regional growers echoed the difficulty in training smaller-sized worker cohorts throughout the
growing season. Southern grower listening session participants also had family as a main source
of labor but also added church members and volunteers. In some cases, harvested crops were
shared with those that helped to harvest. There was one participant in the Southern regional
listening session who indicated using contract labor on their operation while the rest of
participants used local labor and family with family being used by 12 of 15 participants. The
Northeastern growers had a diversity of workers including family, local labor, and H2A. There
was some discussion about the requirement to train labor if they were not specifically involved in
LFSC Listening Session Report 25
harvesting. The Northeastern session had a few participants who were contract growers. They were
not sure where their responsibility to train workers ended if they did not harvest the produce they
were contracted to grow.
Processors
When processors were asked if they had a training program, most of them did not. Only four of
nine Northeastern processors indicated they had a training program for their workers and as a
group, the Northeastern processors had the largest diversity of types of workers including H2A,
client producers, co-farmers, neighbors, friends, and fellow co-packers. Western and North Central
processors had only local labor in addition to themselves, where Southern processors had family,
contract labor, and local labor in addition to themselves.
Grower Specific Discussions on Water, Soil Amendments, Self-Audits and Farm Food Safety PlansWater Source, Testing and Management
Growers across listening sessions had questions about the water requirements in the PSR, how their
operation and production would be impacted, and logistics of water testing and sampling, including
locating the nearest water testing laboratory. The growers in the Western Region Spanish-speaking
listening session were interested in knowing how to read water test results and how to properly
sample water. The Western Region English-speaking growers were feeling pressure from their state
to change their water sources and were not sure if this was due to PSR requirements. Participants
also expressed concern towards the hold-time requirement and being able to transport samples
in time if having to rely on the postal service. Growers in the Northeast were concerned about the
paperwork that might be required by the PSR and the water requirements will add too much work
to proving a water source is safe that may not even be used during a specific growing season. The
North Central growers were concerned that the water testing will prove to be a financial burden and
they were interested in a cost-share program for those that have shared water sources. When asked
explicitly, participants across listening sessions wanted resources on water.
Types of water being used on farms was variable. In the Western Region, participants used surface
water sources such as streams, rivers, canals, ponds, reservoirs, and stored water via dams; they also
used well water and municipal water. In the North Central region, participants used surface water
sources such as streams, rivers, canals, rainwater catchment systems; they also used municipal and
well water. The participants in the Southern Region listening session used surface water sources
such as rainwater catchment systems, spring water, and ponds; they also used municipal and
well water. In the Northeastern Region listening session, participants used surface water sources
such as ponds, rainwater catchment, streams and rivers; they also used well and municipal water.
Rainwater catchment systems were used across the Southern regional listening session as main
LFSC Listening Session Report 26
sources of water and by two participants in each the North Central region and the Northeast region.
Spring water was also used in the Southern session by a participant which resulted in an additional
discussion about whether this source was surface or ground water.
Use of water during postharvest handling was also variable as was the use of sanitizers in
postharvest water. Twenty-four growers indicated using postharvest water in some capacity.
Of the seven growers who identified using a dump tank, there were only two who said they used
a sanitizer. These two growers also said they used single pass water in addition to a dump tank.
There were more participants using sanitizer when washing their produce with single-pass systems.
The participants in the Northeast listening session felt comfortable using sanitizers in their water
and did not want any resources. The participants in the North Central listening session were
interested in getting more information about sanitizers. Detailed discussions about postharvest
water use and sanitizers did not happen in the other three regional sessions.
Soil Amendments
Across listening sessions in all regions, the most commonly used soil amendment was compost.
It was not specified if this compost was commercially made with a validated process or if it was
made on-premises. Participants in a few of the listening sessions, especially those who either
had neighbors with animals or had animals on their operations, requested more information on
validated processes for proper composting. Other commonly used soil amendments across the
listening sessions were cover crops, vegetative waste, manure, chicken pellets, and fish emulsion.
The differences in listening session use of particular soil amendments were influenced by whether
participants were organic-certified or not.
Self-Audits
The majority of listening session participants agreed that they would benefit from guidance
and/or a class on how to conduct a self-audit. For example, some growers from the Western and
North Central listening session participants appreciated the help that organic certifiers and HACCP
certifiers were able to give them after walking through their operation and identifying areas of
improvement. The participants were adamant about the person providing the assistance not have
an enforcement role. The participants in the Northeast Region listening session stated that they
would appreciate this sort of guidance but others chimed in stating that their state already has a
similar program.
Farm Food Safety Plans
The Northeast and Western Region Spanish-speaking grower participants were the only ones
where the majority of participants had developed a food safety plan for their operation. Six of nine
Northeast growers had a written farm food safety plan, while the Western Region Spanish-speaking
LFSC Listening Session Report 27
growers were part of a cooperative incubator organization, which had an umbrella farm food safety
plan for all of their participants. In other regional listening sessions, participants mentioned it
was something they were interested in developing or it was something that was currently being
developed for their operation. When asked how the participants with current farm food safety plans
had come to develop them, they cited state and extension officials, existing food safety plans from
other operations, and food safety trainings with templates had been helpful resources.
Processor Specific Discussions on Allergens, Food Safety Plans, and Food Processing LocationsAllergens
In all the processor listening sessions, the majority of participants knew what the eight major
allergens were. Ways of handling allergens within their facility were specific cleaning and sanitizing
schedules, spatial segregation of allergens within processing and holding areas, and excluding the
allergen from their facility altogether. There were processors in the Northeastern listening session
who utilized shared commercial kitchens and were particularly concerned about the issue of
allergens and cross-contact. At least one participant in all listening sessions but the Southern region
used a shared kitchen or processing area. As part of a state-specific certification, the Northeastern
processors had to take a course on allergens.
Food Safety Plans
Processors across listening sessions were asked if they had a food safety plan. In the North
Central Region, all participants had one. In the Western Region, two of three participants had a
plan. In the Southern Region, two participants did not, one was in the process of writing it,
and the six others had a food safety plan. In the Northeastern Region, there were four participants
who had a food safety plan, with an additional participant who was in the process of writing one.
Two participants were not sure what a food safety plan was and two did not have one at any stage
of development. In the Northeast and North Central processor listening sessions, more participants
had a recall plan than a food safety plan. Processors in the North Central Region listening session
stated that they required their suppliers to provide them with a food safety plan. Participants across
the processing listening sessions felt pressure from buyers or as a requirement for third-party
audits to have a food safety plan.
Food Processing Locations
Across the processor listening sessions, there was a variety of locations where food processing
occurred. The majority of Southern participants processed their product in a home kitchen,
with two participants utilizing a processing facility outside of their home. The Western participants
used shared commercial kitchens or a processing facility outside of their home. A third of North
LFSC Listening Session Report 28
Central participants processed their product in a not-shared commercial kitchen, in a processing
facility outside of their home, and in a shared commercial kitchen. The Northeastern Region had
the largest diversity of locations, with two participants utilizing both a co-packer’s facility and a
shared commercial kitchen. The other locations where processing occurred for the Northeastern
participants included a processing facility outside of their home, home kitchen, not-shared
commercial kitchen, and one participant used a shared food business incubator space.
Challenges to Adopting Food Safety PracticesGrowers
Three themes that emerged as challenges were time, labor, and costs. In all regional sessions but
the Western listening sessions, growers specifically cited time as a challenge in adopting produce
safety practices. Although the Western growers did not specify a lack of time as a challenge, in both
English and Spanish language sessions, they explained that recordkeeping was difficult to balance
during production. The North Central growers echoed this idea. Some English-speaking growers
in the Western regional session felt that nothing they did was ever enough to satisfy requirements.
The Spanish-speaking growers felt that it was difficult to meet the minimum standard, which is
continuously rising, without more support. All of these issues have a time component that impacts
the ability of local food processors to complete food safety tasks.
Labor was mentioned by participants in all listening sessions as a challenge to adopting produce
safety practices. Growers spoke about the difficulty in training smaller crew sizes throughout the
growing season and about labor retention issues; for these reasons, some growers preferred local
labor. This idea goes along with the lack of time also cited by growers across listening sessions,
specifically oriented towards the paperwork and documentation aspect of audits and FSMA.
The other side of labor that was talked about by growers across listening sessions was the contrast
between small, family-owned farming businesses and large businesses with the ability and
employees to form specific departments solely focused on food safety. This discussion of labor
expanded into recordkeeping and how it requires personnel time to complete. Many growers
said that they did not have the funds to hire somebody to do the work that goes along with
recordkeeping. A grower in the Northeastern listening session noted that they had been doing the
“right things” on their operation but had not been documenting their practices. Others spoke about
the time required to do this documentation took away from essential farming activities.
Cost was characterized in different ways across listening sessions. The Southern listening session
participants explicitly identified that costs included testing, equipment, training, infrastructure and
supplies used in their operation. This cost of compliance was explicitly described as coming along as
a result of a change in practices. Another participant in the Northeastern session noted
upgrading refrigeration units to include temperature tracking devices could also prove to be
expensive. Participants in this listening session also mentioned how helpful a grant was in
purchasing new plastic bins for holding produce. Another example of expense of compliance
LFSC Listening Session Report 29
cited was transportation and vehicle requirements, specifically in terms of ease and ability to
clean and sanitize.
Infrastructure and equipment were cited as a challenge to adopting food safety practices in the
Northeastern, Southern, and Spanish-speaking Western listening sessions. The participants in
the Northeastern session cited facilities for handwashing or toilets as a future necessary upgrade
that will put pressure on them. Participants in this listening session voiced their concern about
retrofitting older buildings. They have felt that food safety practices had been doable up until this
point, but their concern is about the regulation changing and making it so these upgrades will not
be enough to comply.
Change was also cited as a big challenge to adopting produce safety practices by some regional
listening session participants. The Northeastern and Southern participants specifically noted the
change in mindset and change in cultural practices brought about by adopting new food safety
practices as a source of frustration and difficulty.
Processors
Expense was cited as a main challenge to adopting food safety practices across processor listening
sessions. The processors explained that the expense of adoption included time devoted to
recordkeeping, cost of redundant audit certificates, and cost of attending trainings. For many, the
amount of recordkeeping is overwhelming, as they are one or two-person operations. Time devoted
to recordkeeping significantly impacts the amount of time available to dedicate to processing which
puts a strain on their business. The processors in the Northeastern Region listening session felt
unsupported by the current grant structure; people felt discouraged from writing grants and felt
that small-scale growers had more funding opportunities available than they did as small-scale
processors. These processors noted that operating at a such a small-scale is sometimes prohibitive
financially. For the Southern listening session participants, certifications, audits, and FSPCA PCQI
trainings were specifically pointed out as expensive. Many had not attended the PCQI training due
to the cost but the participants who had, noted how beneficial it was to their business.
Another important challenge cited across listening sessions was difficulty in receiving information
from trusted sources. This includes trouble finding technical assistance, being unable to get direct
answers about how their operation will be impacted by new regulations and what requirements are
applicable to them. Processors mentioned being on government listservs but that the information
was not specific to them or buried in a very large document they did not have the time to read.
They also cited navigating government websites as a challenge (i.e., the information is not easy to
find). In the North Central region, there was frustration around the need to visit multiple websites
in order to find relevant information about their operation. Participants in the majority of listening
sessions noted that the information that they do receive is never consolidated in one location.
LFSC Listening Session Report 30
Southern and Western listening sessions participants mentioned that sometimes technical experts
were unresponsive or difficult to reach. The North Central participants cited communication
from their state and from federal agencies, particularly email, as unclear and not tailored to
their needs. Processors mentioned that oftentimes they would not be aware of a requirement
until they were inspected or audited. In the Northeastern and North Central listening sessions,
the processors felt that there was inconsistency in the requirements between state, federal, and
industry requirements, which placed a burden on them without having the proper information,
communication, and assistance to navigate the various requirements and audit schemes. Processors
in the Western region cited that this lack of information prevented them from diversifying and
expanding. Processors in the Northeastern Region cited that this lack of information greatly
limited market access. A concern expressed by the Southern listening session participants was
that government funding cuts were going to limit the in-person resources that were already
scarce. Southern processors mentioned instances where they would call a county office and they
would get transferred to multiple individuals but never get the answer they needed. A participant
explained how they would go to a neighboring state extension office for assistance due to the lack
of accessibility of their own state’s personnel. Additionally, Southern and North Central participants
expressed concern about the people providing technical assistance nearing retirement age.
Processors in the Western and Northeastern Regions noted that they had a difficult time finding
resources and technical assistance for operations that were unusual or that produced unique
items. The repeated frustration was that the current agencies only have models for very specific
operations, normally larger in size, and that the resources available are not easily adapted to
different size operations or products. The processors expressed how difficult it was to get a
straightforward answer on how the rule may apply to their operation due to the variability and
flexibility in interpretation.
The North Central and Southern processors had a similar difficulty to growers with worker training
and listed it as a challenge to adopting food safety practices. These processors felt it was difficult to
convey a meaningful message to their workers of why food safety practices are important to follow
and how specific processes contribute to food safety. The Southern processors cited diversity in
learning needs as a possible contributor due to the diversity of age, background, and learning styles
of their workers. The North Central processors felt that their workers not following procedures
adequately was a big challenge.
Resources Requested and NeededGrowers
Technical assistance was requested by all growers across listening sessions. This includes assistance
with paperwork, grant writing, and help with tailored information about FSMA compliance for their
operation. Growers expressed frustration in navigating the different buyer, county, state, and federal
requirements. Other widely requested resources include crop-specific information and resources
LFSC Listening Session Report 31
that can be adapted to size of operation. The crop-specific information requested ranged for every
stage of development to processing of the crop as well as how food safety risks were impacted
along the way. Resources that could be adapted to the size of operation were requested, specifically
in demonstrating examples of food safety implementation and risk mitigation. Case studies were
suggested as a good way to convey this information.
The Southern Region listening session participants cited difficulties with their local federal
organization offices (e.g., local USDA Farm Services Agency offices) lacking information,
communication, and resources suitable for them. The growers mentioned having difficulties
receiving guidance in locating resources and programs specific to their size. They expressed
frustration at not knowing what programs and resources were available to them. Additionally, it
was stated that the offices near them were lacking size-appropriate rentable equipment for their
size operations; the equipment was available for larger operations. The participants in this listening
session were aware of differences in the help available to farmers in neighboring states and counties.
In the North Central and Western regional listening sessions, a change in the way the certifications
or audits were administered was listed as a need. Many growers across listening sessions felt
overwhelmed by the redundancy in the requirements that do not overlap exactly, putting an
additional burden on them. A suggestion was to change the system to a tiered-system or have more
congruency between audits at the state and federal levels. Many growers across listening sessions
cited difficulties with buyers requesting FSMA documentation even though the operations were
exempt or had future compliance dates. This tiered, FSMA-based certification system for smaller
growers was a suggestion to prove adherence to food safety practices on a level more attainable
for their operations. A few participants also suggested the idea of farmer to farmer mentorship and
networking. The growers requesting this specified that it could be farmers with more experience
being audited and inspected as well as operations that have good examples of food safety
practices being implemented. This could include farmer field days and tours. Similarly, growers
suggested having a sit-in for newer or smaller growers to be present during an operation’s audit in
order to get a feel for what it would be like on their own operations. One last resource requested
that had some mixed reception was an app-based assistance for recordkeeping or for cloud storage.
Many growers also emphasized that if this was a resource developed, that it should not be the
way the industry is moving indefinitely, because a change to digital-based technology would place
another burden on them.
Growers in the Western Spanish-speaking, Southern and Northeastern listening sessions
requested more frequent trainings. The Western Spanish-speaking participants requested more
frequent, shorter and subject-specific trainings for them and their workers to stay up-to-date with
food safety concepts. Northeastern participants cited a difficulty with seasonal trainings due to
year-round production.
Growers across listening sessions requested financial assistance in some way. Assistance requested
included funding in the form of grants; the North Central and Spanish-speaking Western growers
LFSC Listening Session Report 32
specifically requested cost-share for water testing of shared water sources. The Western Spanish-
speaking participants also requested help with funding for consultants, audits, plan writing, and a
size-based audit. The Northeastern growers requested funding for supplies and infrastructure.
Processors
The main requested resource by processors across the listening sessions was technical assistance
and easily accessible and understandable information about the regulation. In all the regional
listening sessions, participants wanted a greater availability of trustworthy people in the regulatory
agencies (e.g., county, state, federal) that can convey consistent information and help tailor
adjustments to fit the operations’ needs.
In the Western and Northeastern listening sessions, the technical assistance requested was
characterized as people familiar with how the rules would be enforced to help them navigate
the system. The Northeastern processors want to be able to plan ahead and grow their
businesses. Resources requested include a roadmap to plan business expansion that includes
tiered requirements from a financial perspective, a small food processors scheme, and a short,
interdisciplinary course on developing a food business that could include information on accessing
markets, food safety, website creation, and ways to bring together specialists in their field.
Assistance in grant-writing was also specifically requested in this region.
Similar to the Northeastern processors, the Western processors requested a scalable template for
food safety plan writing and a guide to how to modify infrastructure and plan for inspections on
smaller, home operations. The participants in the Western regional listening session also requested
assistance in developing solutions to mitigate identified risks. They also requested science-based
evidence to prove changing practices does, in fact, make a difference on risk mitigation.
In the Southern and Western listening sessions, a higher level of advocacy for small-scale processors
was requested on both the legislative and commercial sectors. They wished for more farmer and
processor input in legislation, so small businesses have a voice. The Southern processors requested
more frequent, low-cost, and hands-on trainings. Additionally, these processors requested a region-
specific resource network that they could access easily. The Northeastern and Southern regional
processors were interested in local mentorship or networking opportunities between managers of
similar operations.
Participants in the North Central Region processor listening session had the challenge of having
workers not following procedures. These participants requested continuing education for both
themselves and their workers, covering topics about food safety but with compelling reasons
for why and how changing practices impact food safety in their operations. Additionally, the
participants requested continuing education to stay up-to-date with changing regulations in their
industry. The processors in this listening session reiterated that the information they were currently
receiving from their state and federal agencies was not in an efficient or clear manner.
LFSC Listening Session Report 33
It was mentioned in both Southern and Northeastern listening sessions that there was lack of
internet access in some of their regions. It was requested to include off-line resources or a public
space with internet availability to access these resources. The processors were asked if there
was any confusion about the Preventive Controls for Human Foods Rule and if they wanted any
additional information. All participants, across listening sessions, except for one participant wanted
more information and resources.
DiscussionAll food distribution channels are supplied by local food producers.The listening sessions confirmed that growers and processors are supplying diverse food
distribution channels of all sizes. It was clarified during the listening sessions that it is highly variable
how often these channels are supplied. Most local food producers are supplying local markets most
of the time, but there were local food producers who sell almost all of their products into wholesale
markets that supply market channels that reach far beyond local markets. This highlights the
importance of supporting these local food producers in education and implementation of food safety
practices because they impact all markets.
It should be noted that the FSMA regulations may impact products that local producers grow and
process. Some of the growers stated they were planning on switching exclusively to commodities
not covered by the rule. Growers in different listening sessions contrasted their difficulty in
adapting to changing regulations and increased requirements to larger operations’ ease. A common
complaint was lack of labor, financial resources, and time to do what was required, whereas
participants saw larger operations as having the capacity to hire employees and consultants in order
to reach compliance without impacting their day-to-day production.
Both processor and growers mentioned that they are not proceeding with business expansion
because they are worried about food safety requirements and regulations. Since there is confusion
and misunderstanding about what regulations require, it is not clear if local food producers are
correct to delay or decide to not expand their operations. It does clearly indicate the need to
provide more information and assistance, particularly in places where there is an interest in
economic development. A lack of assistance could be leading to lost economic opportunities at a
local, state, and national level as well as food insecurity by limiting local food production. Since local
food producers are supplying all market channels this could have an impact beyond local markets.
LFSC Listening Session Report 34
There are food safety practices that need to be adopted by local food producers.Based on these discussions with both growers and processors, it is clear some basic food safety
practices are not being adopted. Many growers are not training people who are on their farms
contacting fresh produce but it seems they are not training people because they do not consider
some people working on their farm as “workers”. It may also be because the people working on their
farm are not directly hired and paid for the work they do, making it unclear that they need trained.
There also may be concern about disrupting interpersonal relationships, such as by providing
training the grower is insinuating people are not smart enough to know when to wash their hands or
are somehow dirty so they need to be told to wash their hands. This issue of worker training is much
more complex for growers that do not hire traditional labor or that have relationships beyond the
farm with those who are harvesting or packing produce on their farms.
The challenges to implementing food safety practices on the farm go beyond worker training
and extend to many other areas including water, soil amendments, sanitation, and wildlife.
Thoughts about implementing water testing brought many challenges out during the listening
sessions. Finding laboratories that do the required analysis and are close enough to meet the
six-hour hold time are wide-spread concerns. Add to these the time and cost associated with
water sampling, including collection, transportation, and cost of analysis as well as the frustrations
regarding the resources devoted to testing water sources that may not be used every year.
Even though the water implementation dates for FSMA PSR compliance have been delayed, it has
not delayed pressure from buyers or the pressure growers feel to be doing something.
Some processors felt like required recordkeeping practices only created an illusion of food safety
while actually increasing risks. The reason they stated was that some recordkeeping requires
them to interrupt processing which interrupts their flow and their monitoring of key steps.
Growers felt similarly by pointing out that recordkeeping takes away time from essential farm
activities. Local food producers also felt like some things that are defined as risks are not risks,
while things they think are risks are not addressed. Some of this seems linked to confusion about
what a risk assessment or a hazard analysis is and what it is intended to do. They worry about
liability if they find something when they do have a risk assessment. One grower provided this
thought “I mean for me, it’s triaging every day; like what’s a real problem and what’s the fake
problems. 90 percent of FSMA is fake.” This perception that FSMA is not based on science or real
risks is a concern.
The challenges local food producers face in terms of implementing food safety practices also
impacts their preparedness and ability to be compliant with FSMA requirements. Common
challenges expressed by listening session participants were a lack of information surrounding
regulatory requirements, a concern that regulators would not be knowledgeable about typical
farming practices, the need for technical assistance to understand how their operation will be
affected, and how they can become compliant with regulatory requirements. The ambiguity in
LFSC Listening Session Report 35
the regulation contributes to the questions local food producers have about what applies to their
operation and what does not. Growers spoke about the difficulty in adhering to expectations that
were perceived to be written by regulators who did not have adequate knowledge of farming or of
the challenges faced by small producers. Participants deemed these requirements unreasonable.
This critique of regulatory personnel not understanding farming practices or the farm environment
was contrasted by comments about organic certifiers. Growers expressed feelings of being
supported by the organic certifiers in a way they do not feel about other inspectors. This highlights
two things. Growers seem willing to have people assess their level of compliance with standards,
in this case organic standards, but they want the people assessing them to be knowledgeable and
trustworthy. It is important to point out that organic standards are voluntary and that organic
growers may be different than conventional growers, but as has been discussed multiple times
during this report, the issue of relationship building and professional competence once again is
highlighted as critical to local food producers reaching regulatory compliance.
Food safety requirements are complex and need to be clearly shared.It seems no one would argue with the statement that FSMA food safety requirements outlined in
the PSR and PCHFR are complex, so it is not surprising that participants in the listening sessions
found them to be confusing. Many participants have signed up for listservs, visited web pages, and
put effort into trying to learn what is required, but the information is difficult to understand and not
tailored to their needs. Processors expressed frustration that government listservs push information
out in large emails that they feel unprepared or unable to access the information because of limited
time and because they are not certain the time will be well invested if the email really does not
contain information that is relevant to them. Growers requested that the rule requirements be
stated in simpler terms and presented in easy to understand checklists or fact sheets. Growers did
acknowledge there are fact sheets, but the key take away is that the growers feel the complexity
of the information makes it difficult to understand and follow. As an indication of the level of
uncertainty, listening session participants were asked if they were subject to the either of the
FSMA rules and across both the grower and processor listening sessions, there was confusion and
uncertainty among participants as to whether or not their operations were subject to the PSR or the
PCHFR. In some listening sessions, there were a few that were certain they were subject to one of
the rules, but in other listening sessions no one was certain. Some participants did not even know
about the rules.
Participants also expressed the feeling that the laws and regulations are arbitrary as it is difficult
to know if they are science-based. Even for participants who expressed a willingness to implement
regulatory requirements, they were not confident that they knew what was expected. It was also
made clear that many felt their operations, both farms and processing, included situations and
practices that were not “standard”. This increased confusion about how to properly implement
required practices, because their operations did not fit the examples that have been provided.
LFSC Listening Session Report 36
The confusion is not just with FSMA requirements. Depending on what state or commodities the
local food producers grow or process, they are covered by varying levels of regulation, audits,
and inspections. Sometimes they confuse FSMA requirements with organic certification, county
requirements, state requirements, or buyer requirements. It can even go beyond food safety
since sometimes there are requirements from state departments of health, local soil and water
conservation districts, Natural Resources and Conservation Service (NRCS), or Occupational Safety
and Health Organization (OSHA). This is a real and significant challenge, particularly for very small
local food producing operations where there are one or two operators. Trying to be compliant with
regulations at the local, state, and national level is complex and confusing, especially when it is
unclear where there is overlap. Again, it is not that local food producers do not want to comply with
regulations, it is that there is no good way to know all of the regulations to which they are subject.
There is definitely a need for more resources and trainings, but access to these is also a concern.
Trainings have provided clarity for some local food producers, but processors feel priced out of
trainings. As of June 2019, the cost of a FSPCA Preventive Controls Qualified Individual (PCQI) course
offered in the US ranged from $500-$1295, with an average cost of $700; some courses provided
discounts for in-state processors or processors belonging to specific organizations. Growers
have been able to attend PSA trainings because the cost is significantly lower due to funding from
programs such as the State Produce Implementation Cooperative Agreement Program (CAP) grants
and support from the Produce Safety Alliance that can provide trainers. Some processors noted they
felt less supported than growers because they are aware of grant programs that are helping growers
attend trainings and put practices into place.
Local food producers want and need additional resources.When challenges to understanding and implementing food safety practices were discussed during
the listening sessions, three main categories emerged including time, cost, and personnel.
Resources were identified that could overcome some of these challenges and increase the ability
of local food producers to understand and implement food safety practices and regulatory
requirements. These resources included educational materials and financial assistance.
The suggestion was a clearinghouse or “new farmer portal”, where resources could be found and
guidance could be provided. This type of website could also have similar aspects to some organic
certifier websites where local food producers could upload documentation directly to their
servers. Templates of documentation and Standard Operation Procedures (SOPs) examples were
requested as well. It is important to note that some of these resources are already available,
but these participants did not know it. This is a very relevant point. The information is not useful if
intended users cannot find it easily. The Northeast Center to Advance Food Safety has developed a
clearinghouse much like the “new farmer portal” that was described. It is not tailored to new farmers
specifically but was created to collect information in a central location so everyone could have easy
access to it.
LFSC Listening Session Report 37
Local food producers also identified the need for financial assistance to help access training as
well as implementing food safety practices. As mentioned earlier, PCQI courses can be very
expensive for both the training fee as well as travel related to attending the training. Participants
in the processor listening sessions expressed that these costs resulted in them not attending
the training. Financial assistance to reduce this burden would allow more local food producers
to attend training that would improve their understanding and ability to implement food safety
practices. Grants or cost-share funding would also help local food producers purchase equipment
that is made of materials that are easier to clean and can be sanitized or make infrastructure
modification that would be necessary for improving food safety programs. In some cases, there
are already government programs providing assistance such as having equipment available to rent,
but the equipment that is purchased for these programs is not appropriate for small scale farming.
The equipment available are large tractors and implements that are too big to use on small farms.
Investing in size-appropriate equipment for small farms is one way current government programs
can be modified to assist local food producers.
Regional groups had both differences and similarities. Our sample size per region is too small to
say for certain if responses were related to region or just to the specific group attending each
listening session. It is clear that there were differences among the groups in how they felt food
safety impacted their operation and their expressed feelings about food safety during the listening
session including what resources they identified as being needed and wanted. These differences
seemed to be present in both the grower and processor listening sessions leaving the impression
that location of the listening session did impact certain attitudes that were expressed. It may be that
the local resources or market pressures are different, resulting in different attitudes. This important
understanding, that groups have very different attitudes about food safety, should be considered by
educators and those working with these groups. It is critically important to understand where local
food producers are in terms of their attitudes and understanding so that educational approaches,
outreach activities, and resources can be tailored to be effective.
Local food producers want and need experienced and competent technical assistance.Although technical assistance, including trainers, could be viewed as a resource, it has been given
its own section due to the importance listening session participants gave to this particular topic
during the discussions. Local food producers shared several examples of how inexperienced and
incompetent trainers resulted in poor training and had a negative impact on their attitude and
motivation to implement practices. Trainers who were unable to effectively answer questions also
contributed to participants’ uncertainty about how science influenced the development of practices
because they were unable to effectively cite research or explain how the practices reduced risks.
On the other hand, there were multiple individuals specifically named throughout the listening
sessions from every region who were viewed as experienced and competent. These people served
as important and trustworthy resources for information. These individuals came from university
LFSC Listening Session Report 38
extension, state government, and non-government organizations. Listening session participants
valued and respected these individuals because they were knowledgeable and accessible. They
knew the science and regulations, but they also knew how to apply the information to participants’
operations. They could answer questions in a straight-forward manner and they were available when
additional questions surfaced. Listening session participants also talked about the relationships
they developed with these people. The relationships formed resulted in these people knowing about
local food producer operations and being able to help tailor food safety practices to fit their needs
in a way that educational materials cannot. Some listening session participants expressed concern
about what would happen when their point-person retired. Would the position be refilled? Would it
be refilled with someone who had the same experience or the same priority of working with them as
their current resource?
After the listening sessions, the individuals specifically named during the listening sessions
as providing valuable training and technical assistance were contacted to collect background
information. These individuals had varied backgrounds in both industry and university research
positions, product development, and experience advising growers and processors across
commodities. Many of these individuals had experience teaching and all of them had been involved
in a food-related industry for over 20 years. Based on their backgrounds and the comments from
the listening session participants, their education and experiences have likely resulted in them
being competent. It seems clear they would not be easily replaced by just any other person so the
concern of what happens after these people retire is valid. This concern is compounded because of
current funding streams that do not support the development of people to replace them. Federal
grants often provide funding for 3 years with no long-term stability to support salary that would
allow individuals to develop this expertise. Universities often do not give new faculty extension
appointments since the tenure track process does not reward extension efforts. Additionally, non-
government organizations often have low pay with very little health care and retirement benefits,
so it is difficult to retain knowledgeable people in long-term positions. New funding for states
through CAP grants have resulted in many new hires, but it will take years for these new hires to
develop the expertise needed, and most of these people are in regulatory positions.
It is also relevant to discuss growers and processors that are not yet aware they even need access
to good trainers and technical assistance. There is still a need to conduct outreach to raise
awareness for the need for food safety training with many growers and processors. In the Needs
Assessment Survey results, it was shown that many local food producers had confidence in their
food safety decision making despite having no training in food safety. Some grower listening session
participants stated that food safety does not impact their business because they had the ability to
grow safe, quality product before the regulations and requirements. This may be true but it may
also be an indication that growers are assuming they understand how to identify all food safety
risks in their operations with no formal training or that they have no food safety risks. This type of
confidence is contrasted by other listening session participants that described how education and
training was imperative in their understanding of what to look for when thinking about food safety
LFSC Listening Session Report 39
within their operation and how it influenced so many of their decisions and processes. Local food
producers also emphasized the importance of their employees, including themselves, understanding
the reasoning behind their company policies relating to food safety. This contrast is likely due to the
fact that most of the listening session participants had gone through training where many of the
Needs Assessment Survey respondents had not. Again, there is a need to raise awareness of available
food safety trainings and encourage both growers and processors to attend. In general, both
groups of local food producers found the trainings they had attended to be useful. Once local food
producers have been trained, they express the value that it brings to their decision making.
It is possible people can innately have the knowledge needed or have developed the knowledge
through experiences outside of training, but it is unlikely these experiences have been specific to
FSMA regulations. As science advances, having access to trainers and technical experts who have
the most up-to-date information and are capable of effectively sharing that information will benefit
both local food producers and food safety.
Lastly, some local food producers stated that change is hard. This is true no matter what the
effort, but it is especially true for a topic such as food safety where there is evolving science, new
regulations, variable buyer requirements, and many practices that need to be implemented in
complex growing and processing environments with small profit margins. Reducing barriers to
change by providing information that is science-based with explanations of how the practices
reduce risks, access to experienced and competent trainers and technical experts, and supporting
local food producers through match-grants, economic incentives, and training stipends are all
things mentioned by local food producers that could have a positive impact.
AcknowledgmentsThe authors would like to thank the growers and processors who participated in the listening
sessions and shared their thoughts on food safety including specific details and experiences
from their own operations. We would also like to thank our colleagues at the Local Food Safety
Collaborative for helping us recruit participants and select listening session locations. We appreciate
the contributions of Cara Fraver and Chelsea Matzen including note taking during listening sessions
and Connie Fisk for last minute edits. Finally, we would like to acknowledge the National Farmers
Union (NFU) for funding this effort.
LFSC Listening Session Report 40
ReferencesAdalja, A., Lichtenberg, E. (2018). Produce grower’s cost of complying with the Food Safety
Modernization Act. Food Policy, 74, 23-38.
Bihn, E., Springer, L., & Pineda-Bermudez, L. (2019). Local Food Safety Collaborative Needs
Assessment Survey Report. Unpublished report, Cornell University, Geneva, NY.
Food and Drug Administration. (2018). Guidance for Industry. Food Safety Modernization Act;
Determination of Status as a Qualified Facility Under Part 117: Current Good Manufacturing
Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food and Part 507:
Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls
for Food for Animals. Retrieved from: https://www.fda.gov/media/97796/download
Low, S. A., Adalja, A., Beaulieu, E., Key, N., Martinez, S., Melton, A., Perez, A.,… Jablonski,
B. B. R. (2015). Trends in U.S. Local and Regional Food Systems, AP-068. U.S. Department
of Agriculture, Economic Research Service, January 2015. Retrieved from:
https://www.ers.usda.gov/webdocs/publications/42805/51173_ap068.pdf?v=0
Martinez, S., Hand, M., Da Pra, M., Pollack, S., Ralston, K., Smith, T., Vogel, S., … Newman, C. (2010).
Local Food Systems: Concepts, Impacts, and Issues, ERR 97. U.S. Department of Agriculture,
Economic Research Service, May 2010. Retrieved from: https://www.ers.usda.gov/webdocs/
publications/46393/7054_err97_1_.pdf?v=0
USDA NASS, 2015 Local Food Marketing Practices Survey: Report Highlights. (2016). United State
Department of Agriculture National Agricultural Statistics Service Census of Agriculture.
Retrieved from: nass.usda.gov/Publications/AgCensus/2012/Online_Resources/Local_Food/
index.php
LFSC Listening Session Report 41
Appendix AGrower Listening Session ScriptIntroduction
I’d like to start this session by thanking everyone for joining us! We truly appreciate the time you’re
giving us today to share your thoughts on produce safety and farming. Just to be clear, produce
safety involves identifying the biological, chemical, and physical hazards that exist on the farm and
working to reduce the risk of produce contamination. Because biological hazards, such as harmful
bacteria, viruses, and parasites are the most prevalent forms of produce contamination causing
foodborne illnesses and they represent the main basis of the Food Safety Modernization Act Produce
Safety Rule, we will be focusing on the way you control biological hazards in your farm operation
in our discussions today. You should feel comfortable to discuss things you do to control chemical
and physical hazards as well but we just want to be clear that our questions will be more focused on
biological hazards.
The goal of this listening session is to clarify findings from a national needs assessment survey that
was conducted by the Local Food Safety Collaborative- a group that strives to create food safety
education resources and tools for farmers that supply local markets. We are conducting 4 sets of
listening sessions in each region of the country to hear how growers address produce safety on their
farms and what they need to enhance produce safety.
We are researchers and extension educators. I will be facilitating the discussion and my colleague
will be taking detailed notes to make sure we are collecting all the information you are sharing.
We will also be recording this conversation. Individual comments will not be attributed to any
individual. The recording just allows us to review comments if our notes are unclear.
Listening sessions are conducted specifically to hear your opinions so that we may develop the tools
and resources you need to better incorporate produce safety into your farm operation’s culture.
So, today you have an opportunity to express what you need to help better incorporate produce
safety on your farm.
To facilitate this discussion and to ensure we are consistent with every group we visit, I have an
outline to follow. For this reason, there may be moments when we wander off topic, but I will
need your help to bring it back to these discussion topics to make sure you have an opportunity
to share your thoughts about these food safety topics. We will also be asking you to reference the
questionnaire we gave you when you sat down.
Feel free to be candid… there is no need to sugar coat your responses. We want to know what you
really think about the topics we’ll discuss.
LFSC Listening Session Report 42
When we’re all done, we will combine your collective comments into a summary report without
any personal identifying information. Nothing in this report will indicate specifically who said what
during the session.
We have a limited amount of time to talk, so I’ll try to move quickly… there are some things
that will help…
Relax/we want to be as informal as we can
There are no wrong answers – it’s your own opinions that matter.
I don’t plan to ask you for any personal information, other than some introductory
information – your name, farm name or other personal details so that everyone in the
groups knows a bit about each other. None of this will appear in the final report, only basic
demographic information.
Everyone will be asked to participate because each of you brings something different to the
discussion. Please respect each other and differing opinions.
One discussion at a time. (Please avoid interruptions, side conversations, asking other
participants questions)
Speak up for the microphones – audio taping for our reference. After we review our notes and
prepare the report, we will erase/destroy the recording.
I’m hoping you can turn off your cell phones, blackberries and other electronic devices during
our discussion.
If you have questions on what a question means or about a term please ask us to clarify.
When we get through the outline, we may have some time for other areas if you want to
add to the discussion.
Let’s start by quickly introducing ourselves:
Please tell us…
• Who you are?
• Where you are from?
• How would you describe your farm, the crops you grow and your business? (CSA? Farmer’s
Market participant? Farm stand? Unique cultural needs? Other?)
• Do you feel that produce safety currently impacts your farming business? How? (Sales & markets,
audits, why you do what you do)
LFSC Listening Session Report 43
Produce Safety Questions
You know your own farm better than anyone else, do you feel you are able to identify food safety
risks on your farm? Can anyone share a specific example of a food safety risk on their farm that they
manage for?
If yes, do you identify risks in any formal way on your farm? Do you assess risks once per year or just
as you go? Do you ever write anything about risks down or discuss them with others in terms of how
your operation is run?
Would you benefit from guidance or a class on how to conduct a self-audit?
Have you ever attended a produce safety training? This could include GAPs, PSA, Family Farmed or
local extension training on produce safety?
If yes – was the training you attended valuable/worth your time/did you gain knowledge?
If you attended a PSA Grower Training did you find it useful? Did it feel applicable to your
operations and size? Would you change anything about the course to better suit your needs?
Do you wish you had attended anything or received any information before attending the
PSA Grower Training? Is there any kind of follow-up guidance or information you’re looking for
after the trainings?
If no – why not? Not available? Not on your radar?
How often does produce safety influence your decision making on the farm?
Let’s have a show of hands, how many of you have developed a farm food safety plan?
If yes – probe respondents on where/when/who/how they came to develop their plans
If no – why not? Is there a need for assistance in developing farm food safety plans?
Looking at the little survey we gave you, can you share what you put down for who works on
your farm? Possible responses: Just them, family, migrant labor, local labor, others?
Do you have a worker training program on your farm? Does it include training in food
safety principles?
If no – why not?
If yes – what food safety principles do you cover?
The FSMA PSR makes a distinction between soil amendments that are derived from animals,
Biological Soil Amendments of Animal Origin, and non-animal derived amendments.
Please look at the survey we gave you… what types of soil amendments are you all using?
LFSC Listening Session Report 44
Follow up… what category do they fit into in terms of BSAAO and other FSMA terms?
The FSMA regulation also distinguishes between treated and untreated biological soil amendments
of animal origin. To be considered “treated,” the soil amendment needs to go through a validated
process to reduce the amount of pathogens in it. Again, looking at that survey, are you using treated
or untreated soil amendments?
Follow up depending on responses: Are you familiar with what a validated process is?
Do you know when you need to clean and sanitize your tools?
Once again, take a look at the survey in terms of your water sources… What sources of water are you
using during the growing season to grow food?
Follow up: Do you ever test the water you are using? How?
Do you know how to take a water sample? Would you appreciate a training or guidance
document on this?
Do you know how to use sanitizers in your water?
If there is a food safety risk that occurs during the growing season from animals – how do you
document that risk to remember during harvest? If at all.
Is there information you need to understand the risks some animals pose and how timing of their
presence alters that risk?
What kind of records and documentation do you keep on your farm? Is there a reason you keep
certain records and not others?
Do you think food quality and food safety are related?
What do you think are the biggest challenges to adopting produce safety practices?
Unaided responses:
• Not sure which ones to do first
• Financial limitations (money)
• Personnel time
• Don’t know, don’t care
• Still mad I have to do this
If yes, do you think there are resources that could address or help you overcome these challenges?
What kind/type of resources?
How should resources be targeted to best assist small/local growers? What are the issues with
current trainings available?
LFSC Listening Session Report 45
Many people in our survey listed expense of compliance as a major reason for not adopting
food safety practices – if you feel this way as well, what kind of expense does compliance mean on
your farm?
Do you think you will be subject to FSMA PSR?
How do you know if you are subject?
Any concerns about the rule?
Any concerns about being compliant with the rule?
Is there any information you need to better understand the rule, understand if you are subject
or understand how to be compliant?
How often do you look for new information when it comes to food safety? Where do you look
to find trainings?
Are you a member of any associations or do you attend any conferences to learn more about
farming? If yes, which ones?
Processor Listening Session ScriptIntroduction
I’d like to start this session by saying thank you to everyone for joining us! We truly appreciate the
time you’re giving us today to share your thoughts on food safety and processing. Just to be clear,
food safety refers to identifying the chemical, physical, and biological hazards in your food operation
and working to reduce the risk of food contamination.
The goal of this listening session is to clarify findings from a national needs assessment survey that
was conducted by the Local Food Safety Collaborative - a group that strives to create food safety
education resources and tools for food processors that supply local markets. We are conducting 4
sets of listening sessions in each region of the country to hear how processors address food safety in
their facilities and what they need to enhance food safety.
We are researchers and extension educators. I will be facilitating the discussion and my colleague
will be taking detailed notes to make sure we are collecting all the information you are sharing.
We will also be recording this conversation. Individual comments will not be attributed to any
individual. The recording just allows us to review comments if our notes are unclear.
Listening sessions are conducted specifically to hear your opinions so that we may develop the tools
and resources you need to better incorporate food safety into your operation.
So, today you have an opportunity to express what you need to help better incorporate food safety
in your food processing operation.
LFSC Listening Session Report 46
To facilitate this discussion and to ensure we are consistent with every group we visit, I have an
outline to follow. For this reason, there may be moments when we wander off topic, but I will need
your help to bring it back to these discussion topics to make sure you have an opportunity to share
your thoughts about these food safety topics.
Feel free to be candid… there is no need to sugar coat your responses. We want to know what you
really think about the topics we’ll discuss.
When we’re all done, I’ll combine your collective comments into a summary report without any
personal identifying information. Nothing in this report will indicate specifically who said what
during the session. We will include basic demographic information.
We have a limited amount of time to talk, so I’ll try to move quickly… there are some things
that will help…
Relax/we want to be as informal as we can.
There are no wrong answers – it’s your own opinions that matter.
I don’t plan to ask you for any personal information, other than some introductory
information – your name, business name or other personal details, so that everyone in the
groups knows a bit about each other. None of this will not appear in the final report.
Everyone will be asked to participate because each of you brings something different to the
discussion. Please respect each other and differing opinions.
One discussion at a time. (Please avoid interruptions, side conversations, asking other
participants questions)
Speak up for the microphones – audio taping for our reference. After we review our notes and
prepare the report, we will erase/destroy the recording.
I’m hoping you can turn off your cell phones, blackberries and other electronic devices during
our discussion.
When we get through the outline, we may have some time for other areas if you want to
add to the discussion.
LFSC Listening Session Report 47
Let’s start by quickly introducing ourselves:
Please tell us…
• Who you are?
• Where you are from?
• How would you describe your food processing business, the foods you make and your business?
• Do you feel that food safety currently impacts your food processing business? How? (Sales &
markets, audits, why you do what you do)
Food Processor Questions
Have you ever attended any food safety training; This could include HACCP, Food Safety
Preventative Control Alliance, Good Manufacturing Process (GMPs), Better Process Control School,
or local extension training on food safety?
If yes – was the training you attended valuable/worth your time/did you gain knowledge?
If no – why not? Not available? Not on your radar?
Do you think food quality and food safety are related?
Does food safety influence your decision making for your food processing business?
If yes – how often does food safety influence your decision making?
Do you know what allergens are? (The big 8: Wheat, Soy, Eggs, Milk, Peanuts, Tree Nuts,
Fish, and Shell fish)
How do you handle allergens in your processing, if present?
Do you know what cleaning and sanitizing methods are necessary or work best for your
facilities materials?
Follow up: What are key considerations when selecting detergents and sanitizers?
You know your own operation better than anyone else, do you feel you are able to identify risks to
food safety in your facility?
Have you ever heard of a hazard analysis?
If yes – have you ever done one for your facility?
Follow up: What were some hazards you identified if you did a hazard analysis?
LFSC Listening Session Report 48
Let’s have a show of hands, how many of you have developed a food safety plan?
If yes – probe respondents on where/when/who/how they came to develop their plans.
If no – why not? Is there a need for assistance in developing food safety plans?
Do you have a worker training program in your processing facility? Does it include training in the
principles of food hygience and food safety?
If yes – what principles do you cover?
If no – why not?
How do you ensure that food safety practices are carried out in your food processing facility? (Info
on feedback or monitoring)
When, if ever, do you interact with a food safety specialist or processing authority?
Do you have a scheduled process for each product you make?
What kind of records/documentation do you keep in your facility?
Do you find there are challenges to adopting food safety practices?
If yes – what do you think is the biggest challenge to adopting food safety practices?
Unaided responses:
• Not sure which ones to do first
• Financial limitations (money)
• Personnel time
• Don’t know, don’t care
• Still mad I have to do this
If yes – do you think there are resources that could address/overcome these challenges?
What kind/type of resources?
How often does food safety influence your decision making for your food processing business?
Do you have a recall plan and have you tested it?
Do you have markets or distributors that are asking you to have a food safety plan?
Do you think you will subject to the FSMA PC rule?
Any concerns about the rule?
Any concerns about being compliant with the rule?
LFSC Listening Session Report 49
Appendix BThe Grower Pre-Listening Session Survey begins on the next page. The Processor Pre-Listening
Session Survey follows.
Grower Pre-Listening Session Survey
Please take a moment to answer the questions below. This will help us as we move through the listening session.
Approximately what percentage of your food is sold within 275 miles of your farm?
o None of it o Less than 50% o More than 50% o 100%- All of it
What is your farm’s and/or food facility’s average annual gross SALES of food for people (e.g. dairy, meat, fruits, vegetables, etc.) and animals (e.g. hay, corn, etc.)?
Remember, food includes anything that people and animals eat.
o $0-$24,999 o $25,000-$250,000 o $250,001-$499,999 o $500,000-$1,000,000 o Over $1,000,000
Please indicate the percentage of sales to each market in the column on the left, the total should add up to 100% ______ Direct to Consumer (CSA, U-pick, on-farm market, local farmers market, or other) ______ Wholesale (domestic) ______ Small retail entities (specialty food shops, restaurants) ______ Aggregate entities (such as food hubs, cooperatives, produce auctions) ______ Regional or national food suppliers (grocery stores or wholesale clubs) ______ Direct to Institutions (such as hospitals, prisons, child care) ______ USDA foods -commodity program ______ Emergency food assistance providers (food banks, meal programs, distribution provider) ______ Online/catalog/mail order ______ Processors ______ Export- Wholesale or direct buyer outside the United States ______ Other, please specify: 100% TOTAL
Do you or your farm (or food business) identify with any of the following categories or registrations within the USDA?
Check all that apply. o Limited Resource - A person with direct or indirect gross farm sales not more than $173,900
(for FY2017) in each of the previous two years AND a person with a total household income at or below the national poverty level for a family of four or less than 50 percent of county median household income in each of the previous two years.
o Socially Disadvantaged- A farmer or rancher who is of a socially disadvantaged group whose
members have been subjected to racial, ethnic, or gender prejudice because of their identity as a member of a group, without regard to their individual qualities. Those groups include African Americans, American Indians or Alaskan natives, Hispanics, and Asians or Pacific Islanders. o New and Beginning - Have not operated a farm or ranch, or have operated a farm or ranch for not more than 10 consecutive years.
o Veteran- A person who served in the United States Army, Navy, Marine Corps, Air Force, and
Coast Guard, including the reserve components thereof, and who was discharged or released therefrom under conditions other than dishonorable.
o Woman Farmer- A person who identifies as a female or woman farmer. o Registered with a Farm and Track # through USDA Farm Service Agency (FSA) - Registered
farms are eligible for programs administered by FSA such as, farm loans, crop insurance, and disaster assistance compensation. A Farm # is also required for programs through the Natural Resource Conservation Service.
o USDA Organic- A labeling term that indicates that the food or other agricultural product has
been produced through approved methods. The organic standards describe the specific requirements that must be verified by a USDA-accredited certifying agent before products can be labeled USDA organic. Overall, organic operations must demonstrate that they are protecting natural resources, conserving biodiversity, and using only approved substances.
o NRCS (Natural Resources Conservation Services) Cooperator - Those individuals or
organizations (governmental or nongovernmental) that assist NRCS with providing conservation- related services are known as NRCS Conservation Cooperators.
o Plain Sect Farmer- A farmer who is a member of any of various Protestant groups who wears
distinctive plain clothes and adheres to a simple and traditional style of life excluding many conveniences of modern technology.
Please take a moment to answer the questions below. This will help us as we move
through the listening session. Pre-Harvest Production Practices 1a. Do you have workers on the farm besides you? o Yes o No
1b. If yes, are they…. o Family o Migrant labor o Local labor o Other: Please explain________________
2. What kind of soil amendments do you apply on your farm? Check all that apply. o Manure- what kind? o Bone or Blood Meal o Compost o Chicken pellets o Vegetative Waste o Agricultural Teas o Chemical/synthetic fertilizers (mixtures of N & P, etc.) o Fish Emulsions o Other, please list: 2. What sources of water do you use during agricultural production? Check all that apply. o Ponds o Rainwater catchment systems o Lakes o Well Water o Reservoirs o Municipal o Stream/Rivers/Canals o Stored Water, please describe: o Other, please describe: Post-Harvest Production Practices 3a. Do you wash any of the produce you harvest on your farm? o Yes o No
3b. If yes is it: o Single Pass o Dump Tank (communal; co-mingled)
3c. Do you use sanitizer in washing/cooling water? o Yes o No
4. Do you have written standard operating procedures (SOPs) for cleaning and sanitizing any washing equipment and other food contact surfaces? o Yes o No
Processor Pre-Listening Session
Please take a moment to answer the questions below. This will help us as we move through the listening session.
Approximately what percentage of your food is sold within 275 miles of your facility?
o None of it o Less than 50% o More than 50% o 100%- All of it
What is your farm’s and/or food facility’s average annual gross SALES of food for people (e.g. dairy, meat, fruits, vegetables, etc.) and animals (e.g. hay, corn, etc.)?
Remember, food includes anything that people and animals eat.
o $0-$24,999 o $25,000-$250,000 o $250,001-$499,999 o $500,000-$1,000,000 o Over $1,000,000
Please indicate the percentage of sales to each market in the column on the left, the total should add up to 100% ______ Direct to Consumer (CSA, U-pick, on-farm market, local farmers market, or other) ______ Wholesale (domestic) ______ Small retail entities (specialty food shops, restaurants) ______ Aggregate entities (such as food hubs, cooperatives, produce auctions) ______ Regional or national food suppliers (grocery stores or wholesale clubs) ______ Direct to Institutions (such as hospitals, prisons, child care) ______ USDA foods -commodity program ______ Emergency food assistance providers (food banks, meal programs, distribution provider) ______ Online/catalog/mail order ______ Processors ______ Export- Wholesale or direct buyer outside the United States ______ Other, please specify: 100% TOTAL
Do you or your farm (or food business) identify with any of the following categories or registrations within the USDA?
Check all that apply. o Limited Resource - A person with direct or indirect gross farm sales not more than
$173,900 (for FY2017) in each of the previous two years AND a person with a total household income at or below the national poverty level for a family of four or less than 50 percent of county median household income in each of the previous two years.
o Socially Disadvantaged- A farmer or rancher who is of a socially disadvantaged group
whose members have been subjected to racial, ethnic, or gender prejudice because of their identity as a member of a group, without regard to their individual qualities. Those groups include African Americans, American Indians or Alaskan natives, Hispanics, and Asians or Pacific Islanders. o New and Beginning - Have not operated a farm or ranch, or have operated a farm or ranch for not more than 10 consecutive years.
o Veteran- A person who served in the United States Army, Navy, Marine Corps, Air
Force, and Coast Guard, including the reserve components thereof, and who was discharged or released therefrom under conditions other than dishonorable.
o Woman Farmer- A person who identifies as a female or woman farmer. o Registered with a Farm and Track # through USDA Farm Service Agency (FSA) -
Registered farms are eligible for programs administered by FSA such as, farm loans, crop insurance, and disaster assistance compensation. A Farm # is also required for programs through the Natural Resource Conservation Service.
o USDA Organic- A labeling term that indicates that the food or other agricultural
product has been produced through approved methods. The organic standards describe the specific requirements that must be verified by a USDA-accredited certifying agent before products can be labeled USDA organic. Overall, organic operations must demonstrate that they are protecting natural resources, conserving biodiversity, and using only approved substances.
o NRCS (Natural Resources Conservation Services) Cooperator - Those individuals or
organizations (governmental or nongovernmental) that assist NRCS with providing conservation- related services are known as NRCS Conservation Cooperators.
o Plain Sect Farmer- A farmer who is a member of any of various Protestant groups
who wears distinctive plain clothes and adheres to a simple and traditional style of life excluding many conveniences of modern technology.
1. Do you have workers in your food processing facility besides yourself? o Yes o No
If yes, are they….
o Family o Migrant labor o Local labor o Other: Please explain_________________
2. Where does your food processing occur? Check all that apply. o Home Kitchen o A Processing Facility that I Manage Outside my Home o Co-packer’s Facility o Commercial Kitchen that is NOT shared o Shared Commercial Kitchen
o Other: Please explain_________________
3. Do you have a food safety plan?
o Yes o No o Not sure, what is a food safety plan?
4. What factors do you keep track of during food manufacturing and/or product storage? Check all that apply.
o pH o Cooking Temperature o Brix o Water Activity o Cooling Time o Cooking Time o Refrigerator Temperature o Sanitizer concentration o Cleaning and Sanitizing Schedules o Other: Please explain_________________