From the Field: Challenges and Opportunities in On-Farm Food Safety
By Zachary Herrnstadt, M.Sc.
Most of us do not lose sleep over whether Escherichia coli-tainted romaine lettuce was in last night’s dinner salad, even during a major recall of contaminated produce. Perhaps we should. The truth is that even those of us lucky enough to avoid an uncomfortable night in the bathroom or time in the hospital during 2018’s outbreak of E. coli in romaine lettuce or the 2006 outbreak in spinach continue to be affected by on-farm food safety. Foodborne illness outbreaks not only place a large financial burden on our healthcare system (to the tune of $164 billion per year) but can also spell financial ruin for farmers. Once an outbreak has been publicized, trust in an entire industry can be jeopardized—just ask any lettuce farmer.
As a response to outbreaks of foodborne illnesses, President Barack Obama signed the Food Safety Modernization Act (FSMA) in 2011. FSMA, which takes a proactive rather than a reactive approach to food safety, gives the U.S. Food and Drug Administration (FDA) the ability to mandate food safety measures at the farm level for fruit and vegetable production, commonly referred to as Good Agricultural Practices (GAPs).
According to preliminary survey and focus group data conducted by the Center for Healthy Communities (CHC), a majority of participating farmers are unaware of the existence of FSMA or are uncertain about how it affects them. In addition, although most farmers recognize the importance of on-farm food safety and have implemented a variety of GAPs on their farms, few have created an on-farm food safety plan. Just as concerning is that many small farms are not always following certain on-farm food safety GAPs. For example, a multi-state study assessing food safety practices of 128 small farms involved in direct-to-consumer sales at farmers markets found that 45 percent do not wait the required 120 days between application of manure and harvest of produce, 51.8 percent allow domesticated animals to have access to production areas, and only 66.8 percent provide farm staff access to restrooms and proper handwashing facilities.
Enter EASY GAP
To help address the above issues, CHC partnered with the California State University, Chico College of Agriculture to create an on-farm food safety training program called Enhancing Agricultural Safety Year-Round: Good Agricultural Practices (EASY GAP). The overarching goal of the program is to provide farmers with the tools and resources necessary to more easily develop on-farm food safety plans. The program consists of pre-assessment and post-verification on-farm audits (conducted by an EASY GAP team member), online access to Standard Operating Procedure (SOP) templates, log templates, and the EASY GAP video series, as well as free water tests conducted by an accredited lab and appropriate food safety-related signage (e.g., handwashing instructions to post in restrooms used by employees, visitor hygiene, and illness policies). EASY GAP team members are available for technical assistance throughout the duration of the program. Materials are split into 12 sections (Introduction to EASY GAP, Why Food Safety Is Important, Marketing Food Safety, Food Safety Plan and Self-Verification, Employee Hygiene, Traceability and Recall, Land Assessment, Soil Amendments, Water Source and Use, Pesticides and Herbicides, Crop Handling, and Conclusion: Compiling Your Food Safety Plan).
Insights from Farm Visits
As mentioned earlier, the EASY GAP team conducts an initial farm visit with each program participant followed by additional visits and communications over the duration of the program. Below, we describe some of the challenges and opportunities encountered during these visits and interactions.
Addressing on-farm food safety can be stressful for farmers. During the initial visit, the farmer works through a pre-assessment with an EASY GAP team member. The pre-assessment walks the farmer through all the requirements that must be satisfied to become GAP certified. While this initial farm visit is vital for a number of reasons, the most important is that opening up one’s farm to share agricultural practices with an outsider can (understandably) be a stressful experience. Recognizing and respecting this dynamic while assuring the farmer that this process is not about judgment, but rather an opportunity for collaboration, will go a long way toward achieving results.
Always be on the lookout for ways to make on-farm food safety a less stressful experience for the farmer. For example, EASY GAP team members quickly discovered that most farmers appreciated having printouts of all project materials even though they are all available online. Something as simple as providing these printouts can make a big difference.
Consumer and buyer demand motivates farmers. Time and again, farmers pointed to buyer and, ultimately, consumer demand as the most powerful motivation to create an on-farm food safety plan as well as adopt additional GAPs. The farmers with the most developed on-farm food safety plans prior to beginning EASY GAP were those that had received pressure from buyers to do so.
Most farmers are already doing more than they think to address on-farm food safety. While the pre-assessment process can be stressful for farmers, most are relieved to discover that they have already implemented many of the necessary GAPs on their farms. As with any large task, the realization that one is closer to the goal than initially thought can make the process less overwhelming. By the end of the pre-assessment, most EASY GAP farmers realize that there are only a few areas within the operation that need to be addressed to become compliant.
Age matters. Farmers nearing retirement age expressed a lack of motivation in adopting new on-farm food safety practices. This lack of motivation stemmed primarily from frustration with FSMA, skepticism that small and midsized farms would actually be audited under FSMA, and, to a lesser degree, feeling overwhelmed and confused by the FSMA implementation process. One farmer participating in EASY GAP indicated that he was considering retiring earlier than planned due to his frustration with what he believed to be excessive regulations:
You put [FSMA requirements] on top of sub-shed water district reports, nitrogen management plans, organic management plans, county pesticide applications and reports, county burn permits, Department of Weights and Measures certificates, market applications, and load lists, plus all the regular accounting and tax paperwork—it is way overboard. I will probably cease farming in 2 years. The time and stress involved with the paperwork has removed the little bit of enjoyment that was farming.
While many older farmer participants expressed the concerns expressed above, younger and beginning farmers tended to be more tech-savvy and willing to modify and/or adopt additional on-farm food safety practices. Considering the varying levels of comfort utilizing technology (e.g., email, tablets, computers), it may be beneficial to tailor future on-farm food safety tools to specific farmer demographics rather than taking a one-size-fits-all approach.
Confusion and frustration regarding FSMA agricultural water requirements. Preparing for FSMA requirements for agricultural water continues to be a major challenge for EASY GAP participants. During farm visits, farmers expressed frustration that the details of these requirements were not yet settled upon. Some questioned whether the requirements would ever actually be enforced. Others, especially those using surface water for irrigation, expressed concern about the time and cost involved in gathering water tests. There was also confusion among farmers about when testing of irrigation water is required under FSMA. For instance, a number of growers were uncertain whether testing was necessary if irrigation water does not touch the edible portion of the crop.
Technical language. Language surrounding certain on-farm food safety topics (e.g., water testing protocol) can be intimidating and highly technical. One of the major drivers for creating EASY GAP was to make the concepts addressed within FSMA and GAPs more accessible for farmers and farmworkers to ease the process of creating on-farm food safety plans. This was achieved through a variety of methods including grouping information into sections or training modules. Each module contains written materials such as SOPs and logs, and an accompanying video that walks the farmer through the specific on-farm food safety topic. EASY GAP farmers indicated that while the program is a step in the right direction, the language within EASY GAP was still too technical at times. To address this concern, the EASY GAP team is working to “soften” the language of programmatic materials without losing content. Including experts in translating scientific language into language more accessible to the general public may benefit future food safety projects.
EASY GAP Videos Prove a Helpful Tool
The overarching goal of EASY GAP is to provide farmers with the tools and resources necessary to more easily develop on-farm food safety plans. Farms that have completed the EASY GAP pre-assessment on-farm visit are given access to the EASY GAP video series. All 12 sections of EASY GAP are accompanied by a video providing detailed guidance regarding GAP implementation and step-by-step instructions on how to use the SOPs and logs. To assess effectiveness of the videos, a pre- and post-video survey was conducted. Respondents consisted of farmers and members of farm families, and were recruited at regional farmers markets as well as through the CSU, Chico College of Agriculture. All respondents watched the EASY GAP video series, then completed an online pre-survey. Respondents were asked whether they learned about various food safety-related topics (e.g., FSMA, GAPs, what is needed in a food safety plan, self-verifications, third-party audits, what causes foodborne illnesses) as well as whether the videos were organized and presented accessibly. Changes were made to the videos based on feedback from survey participants. Participants were then asked to watch the updated videos and take a post-video survey. Several themes emerged from the surveys:
• Videos can be a useful food safety tool. Overall, participants found the videos to be a useful tool to convey on-farm food safety information to farmers. This sentiment was shared across respondents of all ages and backgrounds. For example, one younger farmer found the videos useful and believed their father would as well: “These videos were concise and clear. I feel like my dad (an older farmer) would use them and understand them.”
• The pace of the videos is important. After viewing initial drafts of the videos, participants indicated feeling overwhelmed by the large amount of information being presented. For example, one participant suggested slowing the pace of the videos. “I think it’d be helpful if either the audio and/or the video transitions could be slowed down. When the video screen changes four-plus times in 10 seconds or less while the talking is going pretty fast, it seems slightly overwhelming.” To address this issue without eliminating essential information from the videos, we reduced the number of video transitions (fewer still images over the same period) and reduced or eliminated movement from still images of photos and documents. These changes appeared to help, although this led some participants to wonder if the updated videos moved too slowly: “I definitely think these videos have important information for farmers and their employees to be aware of. These new videos were definitely presented in a more organized fashion than the previous ones. And are an improvement. Clear, concise, organized, and easy to follow and understand (a little slow-paced for my taste, but I think it’s good).”
• Translations of all materials will be necessary. Considering the high number of migrant farmworkers and farmers in California and the U.S., translations (especially into Spanish) of EASY GAP written materials and videos are necessary. However, due to lack of time and resources, translations were not completed.
Spending a year out in the field provided many insights into the relationship between farmers and food safety. Most importantly, farmers take pride in the food they grow. They know that following GAPs is important, not only because it keeps the food supply safe, but also because it is an asset to their business. As FSMA implementation continues and more farms are required to come into compliance, it is important to recognize that every farm operation is unique and each on-farm food safety plan will look different.
To support farmers as they create on-farm food safety plans, a multi-faceted approach consisting of online resources and individualized outreach will be vital. Although farmers are never excited about another layer of administrative work, this year of outreach has shown that they are committed to food safety and welcome quality, streamlined resources to help navigate the food safety landscape.
The author would like to acknowledge Stephanie Bianco, Patrick Doyle, Sheila McQuaid, and Naomi Stamper for providing feedback for this article and for their roles in creating and implementing EASY GAP.
Zachary Herrnstadt, M.Sc., is a food safety specialist at the Center for Healthy Communities, California State University, Chico.
1. Fortin, ND. 2003. Food & Drug LJ 58:565.
4. Bianco, S, et al. 2016. J Acad Nutr Diet 116(9):A53.
5. Harrison, JA, et al. 2013. J Food Prot 76(11):1989–1993.