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


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


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.


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


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.


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.


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.


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.


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


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


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


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


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


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


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


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


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






Export Give Away


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






Export


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.


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


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


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


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.


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


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


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


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


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


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.


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


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


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.


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.


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


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.


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.


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


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


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.


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


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.


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)


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?


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?


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.


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.


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?


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?


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_________________

local food safety collaborative listening session...

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