A new report released by the U.S. Department of Agriculture (USDA) provides insight into how food safety practices vary among U.S. fruit and vegetable growers and the costs associated with them.
The study, Before Implementation of the Food Safety Modernization Act’s Produce Rule: A Survey of U.S. Produce Growers, was conducted prior to the implementation of the "Produce Rule," part of the Food Safety Modernization Act (FMSA), which has yet to fully take effect. The Produce Rule was the first on-farm U.S. Food and Drug Administration (FDA) regulation for produce to be sold and consumed raw in the United States and set specific disease-preventive requirements governing a wide range of practices. Some requirements of the the Produce Rule are already in effect for larger growers, but the last compliance deadline for smaller growers is January 2020. These deadlines do not include compliance dates for water requirements that have been unofficially proposed through 2024.
Before the rule's implementation, the USDA Economic Research Service (ERS) teamed with the USDA’s National Agricultural Statistics Service (NASS) to survey produce growers about their food safety practices. Based on this survey data, the USDA provides the first update of national food safety practices since 1999, before microbial contamination of produce became widely recognized and researched. The report also reveals work yet to be done in training and implementation of food safety practices, as implementation of the Produce Rule moves forward.
The survey was conducted in two parts with the U.S. fruit and vegetable industry and focused on grower activities related to food safety, including third-party audits, measured costs, personnel qualifications and training, water application, manure products, animal contamination and harvesting, equipment, tools, buildings, and sanitation.
What Did the Study Find?
Growers’ rates of adopting food safety practices vary by coverage and size category. At the time of the survey, many growers who would be covered by the Produce Rule already had some food safety practices in place. Of these, larger growers had adopted food safety practices at higher rates than smaller growers. Because growers with higher sales generally operated more produce acres, the share of acres on which food safety practices were in place far exceeded the share of growers who implemented food safety practices.
Small farms required more change than large farms to meet the standards set by the Produce Rules. At the time of the survey, many farms that would be covered by the Produce Rule needed to make some changes to meet the standards. On average, smaller farms needed to make more changes than larger farms. Even growers who engaged in a particular food safety practice may not have performed it to the specifications of the Produce Rule. For example, some growers who tested water did not test as often as required by the Produce Rule or did not use a test standard that met the rule's requirements.
Both growers who would not be covered and who would have a qualified exemption used some food safety practices. Some growers who would not be covered by the rule and would not be required to adopt new food safety practices had done so anyway. However, as a whole, this group was the least likely to have food safety practices in place. It was not uncommon for growers with a qualified exemption to the Produce Rule to have more food safety practices in place than growers of the same size who would be covered.
Larger growers spent more than smaller growers on the food safety practices measured in this report. Survey results provide a general idea of how much growers spent on some food safety practices already in place—which should not be interpreted as the cost to meet the standards of the Produce Rule or a complete measure of costs for food safety practices. Very large growers ($5 million or more in annual sales) covered by the Produce Rule spent about 16 times the amount on food safety practices as growers not covered by the rule. Audited growers spent more than growers without audits on the food safety costs measured in this report. The costs for audited growers served as an imprecise proxy for expenses for growers who may already have had sufficient, or nearly sufficient, food safety practices to meet the standards of the Produce Rule.
Audited growers spent on average about 2 to 10 times more on measured costs than growers without audits, depending on their size coverage category. The lower costs for those without audits indicated a probable need to implement additional food safety practices to meet the Produce Rule's standards.