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Produce Safety Alliance to run out of funding by fall 2019

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The Produce Safety Alliance (PSA) – a federally funded group that has been helping fresh produce growers navigate the complex new mandates of the Food Safety Modernization Act (FSMA) Produce Rule since 2010 – is running out of money.

And while certain provisions of the Produce Safety Rule have been delayed by as much as four years, the group may not be around long enough to help industry meet those new requirements. 

With funding for the program being expected to expire by September 2019, the biggest impact of the funding shortfall will likely be on the smallest farm operations, which will have to comply with the produce safety mandates starting Jan. 26, 2020. Large farms have already been required to comply with the rule in January 2018.

While those small farms (defined as not having made more than $250,000 in the past three years) will have more time to comply with the rule, they also have fewer resources to put toward implementing food safety, said Betsy Bihn, senior extension associate in the Department of Food Science at Cornell University who is also director of the Cornell-based PSA and the National Good Agricultural Practices (GAPs) program.

“Bigger farms have more people, they can have a food safety specialist on staff that helps them implement practices and that makes sure that practices get done,” she said. “But the smaller farms, they have less people, they make less money. And one of the things we excel at is really working with farmers and responding to their request for information.”

Furthermore, if PSA does not find funding beyond September 2019, the group will not be able to assist industry with implementation of those Produce Safety Rule provisions that have been extended even further into the future, Bihn said.

“The soil amendment application to harvest interval is reserved in the rule,” she said. “It means at some point later, FDA is going to come out and release that section when they have more information, so that probably won’t be out by 2019.”

Additionally, FDA has decided to extend compliance dates for agricultural water provisions of the produce safety by four more years to consider ways to simplify the microbial quality and testing requirements built into the water provision.   

“So, there are still things that won’t be done by the time our funding runs out,” she said. And without the PSA, industry will not have the same support it has found so far in preparing for the mandates, Bihn stressed.

“We promote dialogue between regulatory personnel and growers. We promote creating of educational materials to help growers understand what the expectation is, to help clarify some of those gray areas. And right now, guidance is not out. So, when guidance comes out, there’ll probably be more questions about that,” Bihn added.

This concern is shared by those in industry who benefit from the PSA’s varied support activities, many of whom gathered on Feb. 27-28 at a Produce Safety Rule Water Summit in Covington, Ky. organized by the alliance.

“FDA requires that each farm have someone who has been trained to the PSA curriculum. If there is no PSA to offer certificates, I’m not sure what will happen,” said Jennifer McEntire, vice president of food safety and technology at United Fresh Produce Association, in a Feb. 27 email to IEG Policy.

A good bang for the buck

A joint effort involving Cornell University, FDA and USDA, the Produce Safety Alliance was established in 2010 to provide produce farmers and other groups with fundamental, on-farm food safety knowledge, education and materials to assist with implementation of FDA's new produce safety mandates.

Originally, PSA was tasked with establishing the curriculum for standardized national produce safety training program for fresh produce growers, as farms are required to have at least one person that has received training under FSMA's produce safety curriculum.

In completing that charge, PSA conducted a four-year process involving the creation of 10 working committees of 178 members and eight focus groups that collected training preferences from 89 produce grower representatives.

 “Since we were funded in 2010, I think our productivity has been pretty amazing. I think we've used our funding efficiently and to the best benefit of the produce industry. We make sense for an investment dollar to help growers implement food safety practices.” Betsy Bihn, director of the PSA and the National Good Agricultural Practices (GAPs) program.

 

After establishing the curriculum and aligning it with the final Produce Rule requirements in 2015 and 2016, the alliance also branched out to provide various other support, outreach and education services. Most notably, the alliance created two types of training courses: one for growers and one Train-the-Trainer Course designed to prepare educators to deliver the PSA Grower Training Course to produce growers and become PSA Trainers.

The alliance has also held three soil summits, focusing on the application intervals for untreated Biological Soil Amendments of Animal Origin (BSAAO) – the section that’s marked as delayed within the Produce Safety Rule. With FDA conducting a formal risk assessment of that provision, the soil summits were designed to allow growers and other stakeholders share information on this process and ensure that FDA understands both how produce farms use untreated BSAAOs and what challenges growers face in implementing practices to reduce risks.

The group’s water summit, which takes place in Kentucky this week, is another opportunity for growers, regulatory personal, industry representatives, educators, and researchers to increase understanding and work collaboratively to develop ideas that support risk reduction related to water.

“I think we are a really important resource,” said Bihn, stressing that PSA has been able to accomplish much by organizing its small staff to work efficiently.

Run through a cooperative agreement administered by USDA and funded by FDA, the program currently operates on funding that allows for a little more than seven staff positions, five of whom are regional extension associates.

And even with such limited staffing, the group has found ways to produce educational materials, conduct numerous training and mentoring sessions, establish a lead trainer evaluation process, support outreach through summits, set up collaborations across the country with regional centers and the state departments of agriculture.    

“Since we were funded in 2010, I think our productivity has been pretty amazing,” she said. “I think we used our funding efficiently and to the best benefit of the produce industry. … I think we make sense for an investment dollar to help growers implement food safety practices.”

PSA has been speaking to FDA about the possibility of extending funding and there have been discussions suggesting that the agency might be able to find funding to maintain a couple of these positions for possibly another year beyond 2019. However, this would be a very short-term extension, Bihn noted, and would only allow the program to operate at the bare minimum of its capacity.

“It would likely result in all the regional extension associates – which are really the content experts being cut from the PSA,” Bihn noted.

PSA also coordinates the lead trainer process and maintains the databases for the lead trainer process.

“That work, from an administrative standpoint, would still go on because I think that’s pretty core to what we do, but we would not have the funding to maintain that expertise across the nation,” Bihn explained.

“The team we have is very small, but they are very nimble and responsive, and they are experts on the rule. But if you get down to just a few people who can coordinate the program and administer pieces of the program, you are really going to lose that overall effectiveness. It will really be just a maintenance crew … and that’s not really as productive as people have come to expect from us.”

The group now is looking for alternatives in addition to raising the issue with FDA. One possibility is that PSA could be funded through the Farm Bill, Bihn said. The group is also seeking advice on the issue from the produce industry.

“We’ll take funding from whoever will give it,” Bihn said.

In the meantime, however, the group will continue to work on the objectives laid out in the cooperative agreement. One goal for the group in the coming months is to set up a PSA online training course for growers who can’t make it to a course in person.

But in the best possible scenario, the alliance should be fully funded for another five years, which would allow the group to support industry through the entire implementation of the Produce Rule agricultural water standards, Bihn said.

And that is not because she sees the alliance as a job program for herself or her PSA team members, but because she sees the group as a “critical resource” for industry.

“We really dedicate the time and the energy in understanding the Produce Safety Rule in ways that other people don’t have time to do,” she said. “Our group is dedicated to understanding, and explaining and conveying that information. And I think that is important for an industry that has not been regulated before. And when you think about the first implementation date happening this year and then our funding running out next year, I think it will be a big loss if we go away.”

States recognize the value of PSA

Bob Ehart, a senior policy and science adviser at the National Association of State Departments of Agriculture (NASDA), shares that sentiment.

The alliance, he said, provides a critical education element for FSMA implementation that will help not just industry, but also the states as they start implementing the mandates of the new Produce Safety Rule.

“FSMA is kind of an experiment,” he said. “We are saying that we are going to prevent foodborne illnesses and we are going to learn things while we are out, doing our on-farm readiness reviews, while we are doing inspections. We are going to find things and if we don’t share them with other farmers, similar things could occur again and we are not really preventing them.”

PSA can certainly assist in that respect and help ensure that as the provisions of the rule continue to be implemented,  such previously unknown findings can get publicized better among all stakeholders that are applying the rule, he noted.  And it is fair to expect that as provisions of the rule continue to be implemented, more curriculum development will be needed, he said.

“There is a clear connection between prevention and education that we should not be short-selling,” Ehart stressed.  

NASDA members also believe in the value of the PSA and will try to advocate for the program to be funded for an extended period, Ehart said. And he also expressed hope that FDA would be able to find funding to extend the PSA funding.

“My hope would be that as a food safety requirement, it would be funded by FDA,” he said.

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