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New USDA Survey to Measure Food Safety Practices

Why grower participation is vital to success

The Food Safety Modernization Act (FSMA) was signed into law in January 2011, affecting all stages of the food production and marketing supply chain, including the on-farm regulation of produce. In September 2015 the final version of the Preventative Controls rule (titled “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventative Controls for Human Food”) was published in the Federal Register, and the final version of the Produce rule (“Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption”) was released on November 27, 2015.

While the Produce and Preventative Controls rules (among others) are well along in the rulemaking process, there are guidance documents and implementation strategies still to come. For this reason, fruit and vegetable growers and processors have a rare opportunity to raise understanding of food safety practices in their industries as the rules and guiding documents move through the federal rulemaking process.

FSMA’s Impact
The USDA’s Economic Research Service (ERS) is looking into FSMA’s impact on the fruit and vegetable industry. Since data on the types of food safety practices currently in use within the produce industry is very limited, ERS is seeking detailed information from U.S. growers and postharvest operators through surveys being conducted by the USDA’s National Agricultural Statistics Service (NASS).

Previously, the only national data on food safety practices was from a 1999 NASS survey, the year the U.S. Food and Drug Administration first began publishing Good Agricultural Practices recommendations for handling produce. Needless to say, the produce world has undergone many major changes since then, especially with respect to food safety. Although significant progress has been made in implementing produce safety practices, the NASS surveys will provide a baseline to better understand the full impact new federal food safety requirements will have on growers and handlers.

Jim Gorny, vice president for food safety and technology for the Produce Marketing Association, acknowledges both the need for such a survey, and the necessary sharing of information by industry members. “Produce industry participation in this survey is encouraged and critically important to provide an accurate snapshot of current industry food safety practices,” he says.

Participation, Privacy & Confidentiality
For growers, NASS has added questions about food safety to the already scheduled Chemical Use surveys which will go out to 10,900 growers, divided between 2015 and 2016, with fruit producers receiving surveys in 2015 and vegetable growers in 2016. As usual with the Chemical Use surveys, a NASS representative will visit the business to conduct the survey in person.

A separate NASS survey for postharvest practices has been developed for use in late 2015 and early 2016 for all produce; this survey, however, will be conducted by mail and go out to 2,200 firms. Joseph T. Reilly, NASS’s administrator, encourages produce operations to take advantage of this opportunity “to provide a more complete picture of the food safety practices” currently in use within their businesses.

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The Food Safety Modernization Act (FSMA) was signed into law in January 2011, affecting all stages of the food production and marketing supply chain, including the on-farm regulation of produce. In September 2015 the final version of the Preventative Controls rule (titled “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventative Controls for Human Food”) was published in the Federal Register, and the final version of the Produce rule (“Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption”) was released on November 27, 2015.

While the Produce and Preventative Controls rules (among others) are well along in the rulemaking process, there are guidance documents and implementation strategies still to come. For this reason, fruit and vegetable growers and processors have a rare opportunity to raise understanding of food safety practices in their industries as the rules and guiding documents move through the federal rulemaking process.

FSMA’s Impact
The USDA’s Economic Research Service (ERS) is looking into FSMA’s impact on the fruit and vegetable industry. Since data on the types of food safety practices currently in use within the produce industry is very limited, ERS is seeking detailed information from U.S. growers and postharvest operators through surveys being conducted by the USDA’s National Agricultural Statistics Service (NASS).

Previously, the only national data on food safety practices was from a 1999 NASS survey, the year the U.S. Food and Drug Administration first began publishing Good Agricultural Practices recommendations for handling produce. Needless to say, the produce world has undergone many major changes since then, especially with respect to food safety. Although significant progress has been made in implementing produce safety practices, the NASS surveys will provide a baseline to better understand the full impact new federal food safety requirements will have on growers and handlers.

Jim Gorny, vice president for food safety and technology for the Produce Marketing Association, acknowledges both the need for such a survey, and the necessary sharing of information by industry members. “Produce industry participation in this survey is encouraged and critically important to provide an accurate snapshot of current industry food safety practices,” he says.

Participation, Privacy & Confidentiality
For growers, NASS has added questions about food safety to the already scheduled Chemical Use surveys which will go out to 10,900 growers, divided between 2015 and 2016, with fruit producers receiving surveys in 2015 and vegetable growers in 2016. As usual with the Chemical Use surveys, a NASS representative will visit the business to conduct the survey in person.

A separate NASS survey for postharvest practices has been developed for use in late 2015 and early 2016 for all produce; this survey, however, will be conducted by mail and go out to 2,200 firms. Joseph T. Reilly, NASS’s administrator, encourages produce operations to take advantage of this opportunity “to provide a more complete picture of the food safety practices” currently in use within their businesses.

 

To those worried about contributing sensitive information, both NASS and ERS will safeguard the privacy of all participants. Responses are kept strictly confidential, as required by federal law. Data collected from the NASS produce surveys will be provided to ERS, the lead agency for the project, without any information that could identify a particular operation. Further, any results published by ERS will be in aggregate form, ensuring no individual producer or operation can be identified.

Survey responses will provide information on food safety practices, costs, and the characteristics of each operation. These will be large surveys to capture the diversity of the produce industry in terms of commodities, regions, and firm size.

Going Forward
Without documented knowledge of where the industry’s food safety efforts were before the implementation of FSMA, it will be difficult to measure its impact. Some operations may already have food safety practices in place that exceed anything FSMA will require; others may have a great deal more to do once compliance becomes mandatory. Of course, some operations may not be covered by the rule or will have a qualified exemption based on size and marketing channels.

For these reasons, it is vital to gather as much data as possible from growers nationwide. “With the final Produce Safety rule published last year, this is the best chance for the produce industry to get a baseline assessment of where our food safety practices are today,” confirms David Gombas, senior vice president of food safety and technology for United Fresh Produce Association. “We’ve made strong investments in food safety since 1998, but we know we still have a ways to go. I encourage all fresh produce companies that are contacted to participate in this confidential survey to provide candid answers, not wishful thinking. We all know change is coming; please help the USDA find out where we are now,” he says.

How the Data Will Be Used
Data collected from the surveys will be used in a number of ways, from documenting the many changes in food safety practices since 1999 to examining the expected costs of FSMA compliance, as well as estimating its overall effect on the produce industry.

Other results include identifying the most crucial areas for future research and training efforts, and ensuring policymakers, trade organizations, and produce companies have the most up-to-date information to make decisions that could impact their businesses and the industry as a whole.

In addition, the survey will document and give credit to industry members for the food safety practices and protocols already in place, demonstrating how proactive the industry has been since the last data was collected 16 years ago. This is an opportunity to get a “pre-FSMA” look at produce food safety practices before the final FSMA rules must be implemented.

Results will provide a basis from which to move forward, to guide research, training efforts, and FSMA policy for the guidance documents and implementation strategies still to come. There are open-ended issues in the current draft rules (such as soil amendments, etc.) which will benefit from the survey’s results to provide input for these discussions.

In conclusion, the upcoming NASS/ERS survey’s success is dependent on widespread acceptance and participation by the produce industry. Not only will results provide valuable data on food safety practices throughout the perishables industry, but they will raise awareness of FSMA’s final rules and upcoming implementation.

Fresh fruit and vegetable suppliers have a stake in the survey’s success and can gain immeasurably through their participation.

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