Implementation challenges of the food safety modernization act: Evidence from a national survey of produce growers

The Produce Rule implementing the Food Safety Modernization Act establishes on-farm standards for agricultural water, animal-based soil amendments, domesticated and wild animal intrusion, employee health and hygiene, and building and equipment sanitation. Many produce growers fear that the Rule will require extensive operational changes that may hamper their competitiveness. We use data from an original national survey of fruit and vegetable growers to estimate current usage of food safety practices-and thus the likely extent of change-required by the Produce Rule among growers falling into the size classes specified by the Rule, among growers self-identifying as sustainable, and among growers of different types of crops (vegetables, berries, fruits and tree nuts). We find that the Rule will require changes in all food safety practices for at least some produce growers. The greatest degree of change affects a handful of food safety practices: water sampling and testing, field inspections, building sanitation, equipment and tool sanitization, and recordkeeping. Additionally, small and sustainable growers lag behind larger and conventional growers in adoption of many of the food safety practices required by the Produce Rule, such as sampling and testing, field inspections, employee sanitation and hygiene, and recordkeeping.