The Pennsylvania State University

The Graduate School

Department of Agricultural Economics, Sociology, and Education

IMPLEMENTATION OF GOOD AGRICULTURAL PRACTICES FOOD SAFETY

STANDARDS ON MID-ATLANTIC STATES

AND NEW YORK PRODUCE FARMS

A Dissertation in

Agricultural and Extension Education and International Agricultural Development

by

Roshan Nayak

© 2016 Roshan Nayak

Submitted in Partial Fulfilment

of the Requirements

for the Degree of

Doctor of Philosophy

December 2016

The dissertation of Roshan Kumar Nayak was reviewed and approved* by the following:

John C. Ewing

Associate Professor, Agricultural and Extension Education

Dissertation Advisor

Chair of Committee

Edgar P. Yoder

Professor of Agricultural and Extension Education

INTAD Advisor

Luke F. LaBorde

Associate Professor of Food Science

Connie D. Baggett

Associate Professor, Agricultural and Extension Education

Director of Graduate Studies

*Signatures are on file in the Graduate School

iii

ABSTRACT

In the wake of multistate outbreaks and subsequent economic cost and health causalities,

food industry stakeholders formulated policies for their produce suppliers. The U.S. Food and

Drug Administration’s guidance on Good Agricultural Practices (GAPs) have been the basis for

most of the industry initiated GAP certifications or audit processes. In this food safety regulatory

setting, a third-party audit is a critical tool to ensure neutral and impartial assessment of safety

standard compliance by the produce growers. Growers reported audit burden when they have to

meet multiple duplicative standards and GAP audits. In response to the growing audit burden, the

United Fresh Food Safety and Technology Council harmonized GAP standards. The Produce

GAPs harmonized food standards are accepted by major food retailers and auditing agencies.

In this given scenario, which recognizes the undeniable significance of GAPs in

preventing microbial contaminations of produce, it is not always the case that growers were able

to have successfully implemented GAPs on their farms and pass the audits. Therefore, it

becomes necessary to assess the areas of frequent GAP noncompliance along with the barriers

that growers are facing in implementing GAP programs. The study employed “evaluation and

monitoring” stage of a policy cycle model and a mixed method approach to assess the

implementation GAPs of harmonized food safety standards by the produce growers of Mid-

Atlantic states and New York. The primary purpose of the study was to identify the food safety

standards of frequent noncompliance, aspects of noncompliance, barriers to GAP implementation

and risk assessments, and GAP information sources.

Produce USDA GAPs harmonized audits (field operations and harvesting) for the 2013-

14 growing season were treated as a principal on-farm evaluation tool. Audits from Delaware,

Maryland, New Jersey, New York, Pennsylvania, and Virginia were accessed and analyzed to

iv

identify standards as well as criteria of GAP noncompliance. Based on the findings from the

analysis of 166 audits, a paper survey was designed and administered to 212 USDA harmonized

GAPs certified growers of those six states. In total 116 usable mail surveys were analyzed to

validate the findings from the audits, identify challenging food safety standards, and assess the

barriers to GAP compliance and risk assessments.

Analysis of audits and surveys produced both confirmatory and contradictory findings.

The across-validated evidence pointed to problematic food safety standards that included having

a food safety policy for subcontractors, documentation of corrective actions, policy for glove use,

workers’ compliance with hygienic practices, and writing water management plan and testing

procedures. There were no significant differences in the proportions of growers who rated

complying with food safety standards as a challenging task in states such as Pennsylvania, New

Jersey, and New York. Time and cost were two significant constraints for GAP incorporation.

Preparing a risk assessment plan and understanding auditors’ expectations were major barriers to

carrying out risk assessments on the farms.

Survey respondents mostly obtain GAP information from Cooperative Extension, sell

their produce to resellers and expressed their intention to renew their GAP certificate annually.

Findings of the study have implications for Extension and outreach agencies to improve and

tailor on-farm food safety programming. Emphasizing and prioritizing the problematic

requirements in food safety programs, Extension can better assist the growers to successfully

implement GAP programs on their farms and prepare them for the audit. Further study is

necessary to determine the effect of farm size, marketing channels, and barriers on GAP

compliance.

Key Words: Food Safety Standards, GAPs, Mid-Atlantic States, Extension, Produce Growers

v

TABLE OF CONTENTS

Page

List of Figures……………………………………………………………………………. vii

List of Tables…………………….………………………………………………………. viii

Acknowledgements………………………………………………………………………. x

Chapter 1 Introduction…………………………………………………………………… 1

Foodborne Illness Outbreaks………………………………………………………... 1

On-Farm Food Safety Practices……………………………………………………... 5

Third-Party Audits…………………………………………………………………... 8

Harmonization of GAPs Food Safety Standards……………………………………. 10

Areas of Research Concern…………………………………………………………. 13

Purpose and Objectives ……………………………………………………………... 15

Study Assumptions …………………………………………………………………. 16

Study Limitations…………………………………………………….……………… 16

Organization of Dissertation………………………………………………………… 17

Chapter 2 Review of Literature…………………………………………………............... 18

On-Farm Contaminations…………………………………………………………… 18

Preventive Measures………………………………………………………………… 20

Risk Assessments……………………………………………………………………. 22

Compliance with GAPs……………………………………………………………... 24

Theoretical Framework……………………………………………………………… 29

Policy cycle…………………………………………………………………....... 30

Monitoring and evaluation………………………………………………. ……. 33

Produce USDA GAPs Harmonized Audit Process………………………….………. 34

Summary ……………………………………………………………………………. 38

Chapter 3 Methodology.…………………………………………………………………. 39

Research Design…………………………………………………………………...... 39

Population and Sample……………………………………………………………… 40

Document Analysis…………………………………….……………………………. 41

Data collection……………………………………………………………….…. 41

Data analysis………………………………………………………………….… 43

Survey Analysis …………………………………………………….………………. 44

Instrumentation…………………………………………………………………. 44

Survey sample………………………….…………………………………….…. 46

Data collection………………………………………………….………………. 46

vi

Data analysis…………………………………………………………………… 48

Summary……………………………………………………………………….……. 50

Chapter 4 Results………………………………………………………………………… 52

Objective 1: Identify Areas of Frequent GAP Noncompliance Through Analysis of

Produce USDA Gaps Harmonized Audits for Field Operations and

Harvesting of Mid-Atlantic States and New York….…………………….…. 53

Objective 2: Describe the Aspects of Field Operations and Harvesting Harmonized

Food Safety Standards and Criteria of Noncompliance……………………... 68

Objective 3: Identify the Challenging Harmonized GAP Audit Standards for

Growers of Mid-Atlantic States and New York Using Mail Survey………... 83

Objective 4: Determine the Source of GAP Information, Barriers to Implementing

GAPs and Carrying Out Risk Assessments on the Farms...………………… 100

Summary………………………………………………………………………….…. 113

Chapter 5 Discussion, Conclusions, and Recommendations……….……………………. 115

Discussions……………………………………………………………………….…. 115

General Questions…………………………………………………….………… 115

Field Production...……………………………………………………………… 117

Harvesting………………………………………………………………………. 119

Transportation……………………………………..……………………………. 120

Risk assessments….………………………………..…………………………… 120

Other survey findings.…………………………….……………………………. 121

Conclusions...………………………………………………………………………... 125

Implications for Extension……………………………………………………… 127

Food safety culture……………………….……………………………….……. 129

Food Safety Modernization Act………………………………………………... 131

Recommendations for Future Studies………………….……………………………. 133

Summary……………………………………………….……………………………. 137

References……………………………………………………………………………… 139

Appendix A: Field Operations and Harvesting Harmonized Standards……….….….… 154

Appendix B: Overall Count Tables for PA, DE, MD, NJ and NY……….…….……… 158

Appendix C: Survey Proportional Test Results………………………………….……... 159

Appendix D: Survey Questionnaire ……………………………………………….…… 162

Appendix E: Growers’ Comments……………………………………………………... 166

Appendix F: INTAD Study- JIEE Manuscript….………………………...…………..... 168

Appendix G: Survey Questionnaire for INTAD Study………………………………… 194

vii

LIST OF FIGURES

Figure 1.1. Contributing factors to produce safety concerns……………………….............. 3

Figure 1.2. Food supply chain under regulated system………………………….……......... 9

Figure 1.3. Parameters used in preparing Harmonized GAP standards……….…................. 12

Figure 2.1. Policy cycle model……………...………….……………………………........... 31

Figure 3.1. Research design comprising of qualitative and quantitative approach………… 40

Figure 4.1. CAN and IAR frequency chart for field production…………………………… 55

Figure 5.1. Overall result chart showing implications for Extension………………………. 130

Figure 5.2. Aspects of food safety culture……………………………………………...…... 132

viii

LIST OF TABLES

Table 2.1. List of Standards Under Major Sections of Field Operations and Harvesting…… 36

Table 2.2. Risk Assessment Requirements……………………….…………………………. 37

Table 3.1. Produce USDA Gaps Harmonized Audits for The Growing Season 2013-14...… 42

Table 3.2. Certified Growers, Respondents, and Percentage………………………………... 48

Table 4.1. Produce USDA GAPs Harmonized Audits for the growing season 2013-14……. 53

Table 4.2. Frequency of CAN and IAR by standards for New Jersey………………………. 57

Table 4.3. Frequency of CAN and IAR by standards for New York………………………... 59

Table 4.4. Frequency of CAN and IAR by standards for Pennsylvania………….…………. 61

Table 4.5. Frequency of CAN and IAR by standards for Delaware………………………… 62

Table 4.6. Frequency of CAN and IAR by standards for Maryland………………………… 64

Table 4.7. Proportional Difference Test Table………………………………………………. 65

Table 4.8. Risk Ratio Table for Worker Education and Training…………………………… 66

Table 4.9. Risk Ratio Table for Sampling and Testing……………………………………… 66

Table 4.10. Risk Ratio Table for Workers Health/Hygiene and Toilet/Handwashing

Facility……………………………………...................................................................... 67

Table 4.11. Risk Ratio Table for Vehicles, Equipment, Tools and Utensils………………... 67

Table 4.12. Certified Growers, Respondents, and Percentage…………………….….……... 83

Table 4.13. Characteristics of Produce Growers by the Produce they grow……….………... 84

Table 4.14. Market Where Grower Sell Their Produce……………………………………... 85

Table 4.15. Reliability of Scales Measuring Produce Growers’ Challenge to Meet Food

Safety Standards…………………………………………………………………………

86

Table 4.16. Challenging Food Safety Standards related to Food Safety Plan.……………… 87

Table 4.17. Challenging Food Safety Standards related to Documentation………………… 88

Table 4.18. Challenging Food Safety Standards related to Employees’ Training.…………. 89

Table 4.19. Challenging Food Safety Standards related to Water Management……………. 90

Table 4.20. Challenging Food Safety Standards related to Cleaning Procedures…………… 90

Table 4.21. Challenging Food Safety Standards related to Harvesting policy……………… 92

ix

Table 4.22. Challenging Food Safety Standards related to Transportation.………………… 92

Table 4.23. Challenging Food Safety Standards related to Risk assessments………………. 93

Table 4.24. Rating of the Challenge to Comply with Other Food Safety Standards………... 94

Table 4.25. Ranking of Overall Challenging Standards………………………………….…. 95

Table 4.26. Test of Association for Produce Type and Writing Procedures for Cleanliness

and Proper Functioning of Shipping Units……………………………………………. 98

Table 4.27. Test of Association Between Produce Type and Writing a Policy on On-Farm

Trash Handling………………………………………………………………………… 99

Table 4.28. Amount of Information from Various Sources………………………………… 100

Table 4.29. Barriers to Implement GAPs…………………………………………………… 102

Table 4.30. Chi-Square Test of Association Between Time and Challenge to Comply Food

Safety Standards………………………………………………………………………… 103

Table 4.31. Chi-Square Test of Association Between Cost and Challenge to Comply Food

Safety Standards………………………………………………………………………… 104

Table 4.32. Chi-Square Test of Association Between GAP resources and Challenge to

Comply Food Safety Standards………………………………………………………… 106

Table 4.33. Chi-Square Test of Association Between GAP knowledge and Challenge to

Comply Food Safety Standards………………………………………………………… 108

Table 4.34. Barriers to Carry out Risk Assessment………………………………………… 109

Table 4.35. Chi-Square Test of Association Between Challenge to perform a pre-harvest

risk assessment and barriers to carry out risk assessments …………………….……… 111

Table 4.36. Chi-Square Test of Association Between Challenge to Conduct a Water

System Risk Assessment and Barriers to Carry Out Risk Assessments ………………. 112

Table 4.37. Chi-Square Test of Association Between Challenge to Write a Risk

Assessment Plan on Domestic and Wild Animal and Risk Assessment Barriers……… 113

x

ACKNOWLEDGEMENTS

I would like to extend my science gratitude to my academic advisor and committee chair

Dr. John Ewing for his continuous support and cooperation of my Ph.D. research. I would like to

gratefully thank Dr. Edgar Yoder, Dr. Luke LaBorde, and Dr. Connie Baggett for their guidance.

I would like to thank Dr. Joan Thomson for her guidance and encouragement. My sincere thanks

also goes to Ms. Jenifer Dougherty and Mr. Ken Peterson of USDA-AMS for their assistance in

obtaining audits and Mr. Jeffrey Stoltzfus and Ms. Lee Stivers of Penn State Extension for their

help with surveying growers. I would also like to thank Terra Ingram for her administrative

support. In addition, I thank my parents, family members, friends, and colleagues. I could not

have accomplished this achievement without their support.

1

Chapter 1

Introduction

Foodborne Illness Outbreaks

Foodborne disease is one of the major public health concerns in the World. The World

Health Organization (WHO) estimates that each year millions of people die worldwide with

foodborne diseases due to microbiological contamination food and water (WHO, 2014). The

Centers for Disease Control and Prevention (CDC), which monitors and investigates multistate

outbreaks, reports that one out of every six Americans is affected by foodborne illnesses

resulting in approximately 3000 deaths each year (CDC, 2016a).

The investigations of multistate foodborne outbreaks linked numerous cases of

hospitalization and deaths to consumption of contaminated produce (CDC, 2016b). Foodborne

disease associated with fresh fruits and vegetables has increased greatly during the years 1970 to

1990 (Lynch, Tauxe, & Hedberg, 2009). Furthermore, the Center for Science in the Public

Interest (CSPI) has reported that during 2002 and 2011, 17% of total outbreaks and 23,748

illnesses were due to produce related outbreaks (CSPI, 2014).

Food items can be contaminated with disease-causing pathogens at any stage within the

food supply chain, from farm to fork. The following paragraphs offer a brief account of

foodborne illness outbreaks linked to produce in recent years in the U.S. and the sources of

contaminations for each. Recently, a multistate outbreak was attributed to Escherichia coli O157

(STEC O157) contaminated alfalfa sprouts produced by Jack & Green Sprouts of River Fall,

Wisconsin (CDC, 2016d). Consumption of cucumbers contaminated with Salmonella resulted in

six deaths and 204 hospitalizations in 2015-16 (CDC, 2016c); and the 2014 Salmonella outbreak

2

associated again with cucumbers infected 275 people in 29 states of the U.S. (Angelo et al.,

2015).

In 2013, 631 cases were reported due to the outbreak linked to produce contaminated

with Cyclospora cayetanensis parasite (CDC, 2013a). In the same year, another 84 individuals

were infected with Salmonella again linked with contaminated cucumbers (CDC, 2013b). Trace-

back investigations for the source of Salmonella outbreak associated with cantaloupe in 2012

linked the outbreak origin to farms in Indiana. This highly publicized outbreak infected 261

individuals and in a few cases even caused deaths (CDC, 2012b). In 2011-12, another multistate

outbreak of Listeriosis linked to the whole cantaloupe grown in Colorado infected 147

individuals in 28 states of the U.S. The trace-back investigations of the source of contamination

led to Jensen Farms where Listeria monocytogenes were isolated from samples, equipment, and

cantaloupes from the farm packing facility (CDC, 2012a).

The increase in cases of foodborne illness outbreaks might be attributed to numerous

factors. Consumers are increasingly acknowledging the benefits of fresh fruits and vegetables in

their diets as a good source of vitamins, micronutrients, and fiber. Per capita consumption of

fresh fruits and vegetable has been increasing in the U.S. (Pollack, 2001). Fresh fruits and

vegetables are commonly consumed either raw or semi-processed, which increases the chances

of direct exposure of pathogenic microbes to the human body if produce is already contaminated.

Figure 1.1, below, depicts the multitude of factors that might have contributed to the

growing concerns over outbreaks of foodborne illnesses associated with produce as described in

Gravani (2009). Reported outbreaks, which are affecting increasingly large number of people,

have been linked to domestically grown as well as imported produce. In addition, the changing

nature of agriculture and the food supply chain in the global food system might have also

3

contributed to food safety concerns. Moreover, events such as increasing number of multistate

outbreaks, identification of new human pathogens on produce, and reports of inefficient pre-and

post-harvest handling contribute to the growing concern over produce safety.

Figure 1.1. Contributing factors to produce safety concerns (from Gravani, 2009)

Incidences of outbreaks have been a major concern not only for public health reasons but

also for the economic and social cost that are incurred. Griffith, Mullan, and Price (1995) listed

the economic and social costs linked to food safety. Economic costs include expense associated

with treatment, investigation, legal activity, and diminished business activity. Business cost

includes loss of productivity, expenses incurred due to produce recall, loss of demand,

destruction of produce, investigation time, administrative, and remedial costs. There are also

social costs, such as disability, pain, grief, and anxiety. As per the U.S. Department of

Agriculture (USDA), each year foodborne illnesses cost $15.6 billion (CDC, 2016a). The exact

Food safety concerns linked to produce

Number of produce

outbreaks

Number of people

affected

Produce outbreak

proportion

Wide variety of fresh produce Micro-

biological agents

Domestic and imported

produce

Changing food supply

chain

4

estimation of such incidences is often not possible because many cases of foodborne illness

associated with consumption of fresh produce go undetected or not reported.

Food safety hazards can be physical, chemical, or biological. Biological hazards

(microbial pathogens), similar to chemical and physical hazards, can contaminate produce at any

stage of food supply chain. Biological hazards include contamination due to pathogenic microbes

such as bacteria, viruses, and parasites. A variety of microbial pathogen may cause

contamination of produce and these pathogens responsible for foodborne outbreaks usually can

survive extensive periods of transportation or storage before they reach the consumer. Tauxe

(2002) identified bacteria as one of the major causative agents of produce contamination linked

to numerous foodborne illness outbreaks in the U.S.

The growing food quality and safety concerns prompted the food industry to introduce

preventive measures to control food from various potential hazards. Hazard Analysis Critical

Control Point (HACCP) is a set of proactive measures adopted by food industries to address food

safety concerns. The purpose of HACCP is to reduce the risk of food contamination from

potential hazards at Critical Control Points (CCPs) within food production and processing

facilities. According to Notermans, Gallhoff, Zwietering, and Mead (1995) “CCPs are defined as

points, procedures, etc. at which a hazard can be eliminated or reduced to acceptable levels” (p.

89).

The established HACCP criteria for controlling microbial pathogens and other hazards

can be elaborated in three steps (Notermans, Gallhoff, Zwietering, & Mead, 1995). Step one

refers to the compilation of a list of food item specific hazardous micro-organisms. The second

step includes quantitative assessment of potentially hazardous microbial growth and determining

an acceptable level of microbes. The third step refers to taking corrective measures if

5

unacceptable microbe counts are observed in food. In other words, these three steps emphasize

establishment of controlling factors and describe the process of hazard identification, evaluation,

and control action. The very first step to identify the source of contamination is to evaluate the

possible food vehicles for pathogens causing outbreaks.

Before the introduction of HACCP, the safe production of food was regulated by

ordinances and monitored by local and international bodies. There were chances that unsafe or

contaminated products might be missed from inspections under those regulations. That situation

called for the introduction of Good Manufacturing Practices (GMP). This concept of GMP, later,

expanded to HACCP, introduced safety criteria for specified CCPs in food production and

processing facilities. HACCP has been used as an instrument to ensure a controlled environment

for food safety (Mortimore & Wallace, 1998). The process steps under HACCP are can

significantly reduce biological contaminants (LaBorde, 2011). On the other hand, reduction of

biological agents to an acceptable level from fresh produce requires multiple preventive

measures at more than one process step. Therefore, Sperber (2005) and Soon, Manning, Davis,

and Baines (2011) questioned the appropriateness of HACCP principles to significantly

eliminate biological hazards from produce on the farms (as cited in LaBorde, 2011).

On-Farm Food Safety Practices

Investigation reports on produce related outbreaks by CDC traced sources of

contamination to farms where the farm setting and practices might have caused the

contamination (CDC, 2016a). Practices such as cleaning and irrigating with contaminated water,

poor handling and processing practices, use of contaminated and untreated manures, lack of

adequate storage infrastructure, and less efficient regulatory systems contribute to creating a

high-risk environment (WHO, 2015). Lynch et al. (2009) expressed concern over the greater

6

likelihood of food contamination during produce field production, initial processing, and final

preparation phase.

The concept of Good Agricultural Practices (GAPs) has evolved with the growing

concerns over food quality, safety, and sustainability raised among the consumers, retailers,

governments, processors, and growers (FAO, 2003). Moreover, the incidences of foodborne

illness outbreaks and subsequent investigations linking the source of contamination to farms

have mobilized the adoption of GAPs. GAPs have been assessed as an effective measure to

reduce the risk of produce contamination on the farms. Once produce is contaminated with

disease-causing hazards, it becomes difficult to disinfect them. Therefore, preventive measures

such as GAPs are more desirable than corrective actions when outbreaks occur.

According to FAO (2003), “GAP applies available knowledge to addressing

environmental, economic and social sustainability for on-farm production and post-production

processes resulting in safe and healthy food and non-food agricultural products.” Apart from

meeting the regulatory requirement of the government or private retailers, GAPs also ensure

quality and safety of produce, create new market opportunities, and improve farm workers’

health and working environment (FAO, 2008). There are major economic benefits to the

growers, such as economic risk reduction and increased opportunity for market access (Rejesus,

2009).

In 1998, the U.S. Food and Drug Administration (FDA) in partnership with the U.S.

Department of Agriculture (USDA) released guidance for the food industry to minimize

microbial food safety hazards for fresh fruits and vegetables (USFDA, 1998). Although the guide

offers a broad range of guidelines for growers to address risk areas in farming practices through

implementation of GAPs and GMPs, specifically it focuses on microbial hazards and risk

7

reduction not risk elimination. The primary purpose of GAP guidance is to reduce the possibility

of microbe contaminations associated with practices application of raw manure or improperly

treated compost, contaminated agricultural or processing water, unhygienic practices by farm

workers, and poor sanitary facilities. The FDA’s GAPs guide is based on the following eight

principles (Gravani, 2009, p. 109):

Principle 1: The prevention of contamination is favored over reliance on corrective measures

once contamination has occurred.

Principle 2: Use of GAPs in those areas of farm practices where growers have a degree of

control while not increasing risks to the food supply.

Principle 3: Anything that comes in direct contact with fresh produce has the potential of

contaminating it.

Principle 4: The source and quality of water can be the indicator of contamination when water

directly comes in contact with produce.

Principle 5: Manure or municipal bio-solids should be managed properly in farm practices to

minimize contamination.

Principle 6: Appropriate standards on worker hygiene and sanitation should be implemented

during production, harvesting, packing, and transportation.

Principle 7: Follow all food safety regulations (local, state, and federal) or standard

agricultural practices.

Principle 8: Accountability in all steps of agricultural environment for a successful food safety

program.

8

Third-Party Audits

The frequent occurrence of multistate outbreaks and subsequent economic cost and health

causalities have prompted governments and food retailers to impose food safety regulations on

produce growers. Food retailers and supermarkets formulated food safety standards for their

produce suppliers that are more or less aligned with FDA’s GAPs guidance. Thus, FDA’s GAP

guidelines have been the basis for most of the industry initiated food safety policies for growers

(Petersen, 2009).

Compliance with GAPs standard ensures that produce growers have taken appropriate

food safety measures on their farms as indicated in the GAP guidance to minimize the risk of

produce contamination. In this regard, a third-party audit is critical to ensure neutral and

impartial assessment of safety standard compliance. Russell (2000) defined third-party audit as

an audit “performed by an audit organization independent of the customer-supplier relationship

and is free of any conflict of interest” (as cited in Petersen, 2009, p. 323). Third party audits

serve as a tool for retailers and other produce buyers to verify that the produce they purchase has

been grown under an established GAP program.

In 1999, Safeway Inc. introduced the requirement of third-party audits for its produce

suppliers. Their audit requirements were initially limited to high-risk produce, but later expanded

to all fruits and vegetables. Another evidence of the growing importance of Third-Party

Certificates (TPC) and GAPs is that in 2006, the USDA Agricultural Marketing Service (USDA-

AMS) announced the requirement of TPC from produce suppliers for their feeding assistance

programs to ensure that GAPs and GMPs were being followed by the suppliers (as cited in

Petersen, 2009). Produce retailers of Pennsylvania are more likely to demand their suppliers to

9

provide evidence of growers’ GAP compliance in the form of TPCs (Tobin, Thomson, LaBorde,

& Bagdonis, 2011).

TPCs by third-party auditors are unbiased proof of GAP compliance. In general, auditors,

experts in verifying standard food safety practices on the farm, are responsible for certifying

farms. TPC ensures produce which is coming out of farms have the lowest possible chance of

microbe contaminations and hence, is safer for consumption. Popular certification bodies such as

Global G.A.P, International Food Services (IFS), and USDA-AMS have adopted the principles

woven into the GAP framework as the basics of auditing criteria.

Jahn, Schramm, and Spiller (2003) presented a certification system (Figure 1.2) that can

be applicable to various food safety certification systems, where growers are positioned as first-

party and produce retailers as the second-party. More detail on the audit process is provided in

the theoretical framework section of chapter 2.

Figure 1.2. Food supply chain under regulated system (from Jahn, Schramm, & Spiller, 2003)

10

Audit standards and requirements vary among auditing firms and the retailers to which

growers supply their produce. However, growers make the final decision of choosing the

appropriate third-party certifier (Rejesus, 2009). In other words, growers supplying to various

retailers have to meet different certification standards, thus creating a potential audit fatigue

situation for growers. Describing reasons for audit fatigue Koch (n.d.) stated that in the absence

of a standardized certification process, it as one of the major challenges for produce suppliers to

meet different buyers’ requirements with single a single audit. Growers suffer audit fatigue by

meeting the food safety requirement of multiple buyers by going through multiple audit

processes and allocating time and resources. In other words, audit fatigue arises due to multiple

duplicative standards and GAP audits. GAPs harmonization initiative and Global Food Safety

Initiative (GFSI) were two initiatives taken to harmonize food safety standards (Gorny, n.d.).

Harmonization of GAPs Food Safety Standards

To reduce audit fatigue, the United Fresh Food Safety and Technology Council planned

to harmonize GAP standards that lead to Produce GAPs Harmonization Initiative by the effort of

stakeholders across the supply chain (“Harmonized food safety,” 2013). The initiative began in

2009 with an idea that one audit by any credible third party would be acceptable to all produce

buyers and thus reducing the audit burden on growers (Gombas, 2010, 2013). Reflecting on the

goal of the Harmonization Initiative, the Food Safety Magazine reported that:

The goal of the Produce GAPs Harmonization Initiative is one audit by any credible third

party, acceptable to all buyers. To achieve this goal, the Initiative developed food safety

Good Agricultural Practices standards and audit checklists for pre- and post-harvest

operations, applicable to all fresh produce commodities, all sizes of on-farm operations

11

and all regions in the U.S., and has made them available for use by any operation or audit

organization at no cost. (“Harmonized food safety,” 2013, para. 3)

The proposed produce rules under the Food Safety Modernization Act (FSMA) are

largely in compliance with harmonized standards. Since that initiative, buyers are increasingly

accepting and encouraging their suppliers to adopt harmonized food safety standards (Gombas,

2013). Produce buyers that are accepting harmonized standards include Wegmans, Costco,

H.E.B, Kroger, SAFEWAY, Subway, Sysco, and many other buyers. On the other hand, the

agencies that are performing GAPs audits using harmonized standards include Global G.A.P.,

NSF, SCS Global Services, SGS, and Equicert. The USDA is among the organizations that carry

out GAP audits using produce harmonized standards. Ken Petersen, head of USDA-AMS’s Fruit

and Vegetable Program audit section, advocates that:

USDA played an active role in helping the industry develop sound harmonized GAPs and

GHPs (Good Hygiene Practices) produce standards. We were also among the first to

perform audits using the Harmonized Standards, which helps ensure that American

produce food safety criteria are met. Many retailers specifically request harmonized

GAPs audits, so we work with fruit, vegetable and specialty crop suppliers of all sizes to

verify their on-farm practices meet or exceed the standards, and we’ve seen many

growers successfully migrate to the harmonized audit. (Gombas, 2013, Where We Are

section, para. 11)

Figure 1.3, below, shows the proposed parameters for the harmonizing of GAPs audit

standards. One of the major parameters of harmonization was that the standards should be

consistent with FDA’s GAPs guidance. The other parameters emphasized how standards should

be of science-based, attainable, auditable, and verifiable; scalable to all size farm operations; and

12

freely accessible to buyers, sellers, and auditors. More specifically, the two parameters in

particular –1) applicability of standards to all the North American operations and 2) their

appropriateness for the regional- and commodity-specific food safety needs– were the basis of

this study’s research hypotheses.

Figure 1.3. Parameters used in preparing Harmonized GAPs standard (from Gombas, 2013)

Over the years, the number of farms audited with USDA harmonized GAPs standards

have increased. Completing an audit could be a sound investment for the business. A food safety

plan that has been created as a response to GAP compliance can help the farm to keep sanitized

and manage records. In addition, GAPs Harmonized plan is a comprehensive management plan

that acknowledges maintenance of documents of standard food safety implementation and

practices as a sign of a robust and a credible food system. The theoretical framework section of

Harmonization of GAP Standards

Consistent with

FDA's GAPs guide Applicable

to North American operations

Risk-based and

Science-based

FDA's regulations on physical

Hazards

Operations of all sizes

Regional and

Commodity-Specific

needs

Acceptable by

customers

Freely accessible

13

this study provides an overview of the USDA Produce GAPs Harmonized audit standards as well

as the criteria for obtaining certification.

Areas of Research Concern

For a safer food supply and a viable economy, produce growers are increasingly

encouraged by outreach programs and the retailers to adopt GAPs on their farms and apply for

TPC. The GAPs guidelines recommend growers to change some of their traditional agricultural

practices that may enhance the risk of produce contamination. One of the key objectives for

implementation of GAPs and passing an audit is that produce growers are taking all necessary

steps to minimize the risk of produce contamination to ensure that produce is safe for

consumption.

On the other hand, in this given scenario that recognizes the undeniable significance of

GAPs in reducing the chances of microbe contaminations of produce, it is not always the case

that growers have been able to successfully implement GAPs on their farms and pass the audits.

In other words, even though growers are increasingly valuing GAPs, they are not consistently

practicing GAPs on their farms (Lewis Ivey, Lejeune, & Miller, 2012). Gravani’s (2009)

argument further articulates the disconnect between knowledge and action:

Although most growers and packers are now aware of the importance of food safety

and the need to reduce the microbial hazards and risks associated with the growing,

harvesting, and packing of fresh fruits and vegetables, implementation remains

inconsistent (p. 115).

Assessment of these inconsistencies is vital for successful implementation of GAP programs.

Moreover, identification of particular food safety standards where such inconsistencies exist will

help experts, educators, and risk communicators to strategize their outreach programs to assist

14

produce growers efficiently. Successful implementation of GAP programs requires identification

of challenging food safety standards. These are areas of food safety where growers are

unsuccessful in complying with GAP standards; they relate to preventive controls, risk

assessments, traceability, documentation, and record keeping. Limited studies are available that

specifically assess on-farm implementation of the Harmonized GAPs standards or identify

standards that are difficult to comply with by the produce growers of Mid-Atlantic States and

New York.

Moreover, identification of areas of frequent GAP noncompliance needs to be studied

along with the factors for contributing to difficulties that growers are facing in implementing

GAPs. Interventions are necessary for educational and other supportive agencies to prepare

produce growers to specifically address those issues before applying for an audit. Growers’

failure to implement GAP guidelines necessitates a discussion on the barriers or challenges that

growers are facing with regard to GAPs implementation. A better understanding of areas of

GAPs noncompliance and growers’ on-farm challenges to implementing GAPs will help food

safety program planners and policy enforcing agencies to come up with strategies to accomplish

their programming/policy objectives.

In the context of Extension’s food safety programming, evaluation findings often do not

offer significant information on the standards that growers may find challenging when

attempting to comply with the requirements. Accordingly, existing programs may not be

effectively preparing participating produce growers to adopt GAPs on their farms. Analysis of

evaluations of Penn State Extension’s food safety programs for the 2013 growing season

provided sparse evidence to explain growers’ GAP implementation barriers (Nayak, Tobin,

Thomson, Radhakrishna, & LaBorde, 2013).

15

This study begins with the premise that the GAP standards where growers often fail to

comply with the requirement can be identified from GAPs audit reports. Programs that identify

challenging standards and improve their curriculum addressing those standards will better

prepare produce growers to implement GAPs effectively. On the other hand, the experience of

produce growers who have already been through the auditing process may also be useful in

informing the efforts of educators aimed at better preparing growers for certification.

This current study intends to determine challenging food safety policy requirements and

communicate them to outreach (Extension) and certifying agencies. Scarce evidence on

problematic produce safety standards prompted this study to evaluate the on-farm

implementation of GAPs food safety standards using auditors’ on-farm observations to food

safety standards and produce growers experience with GAP implementation.

Purpose and Objectives

This study was an attempt to strengthen food safety communication between audit

agencies and produce growers by taking their perspectives into account. The consistency of

evidence from the GAP harmonized audits and from the produce growers themselves would be

vital to the whole concept of GAP adoption.

The primary purpose of the study was to assess on-farm implementation of GAPs

harmonized food safety standards for field operations and harvesting by produce growers. The

study focused on various aspects of GAP implementations that included the frequency of

corrective actions for an individual harmonized GAP standard, the criteria of noncompliance,

growers’ experience with GAP implementation with relationship to farm locations, commodity

type, and barriers to GAP adoption and carrying out risk assessments. The objectives that guided

the study were as follow:

16

1. Identify areas of frequent GAP noncompliance through analysis of produce USDA

Harmonized GAP audits for field operations and harvesting of Mid-Atlantic States:

Pennsylvania, Delaware, Maryland, New Jersey and Virginia including New York;

2. Describe the aspects of field operations and harvesting harmonized food safety standards

and criteria of noncompliance;

3. Identify the most challenging GAPs harmonized food standards for growers of Mid-

Atlantic states and New York using a mail survey;

4. Determine sources of GAP information and barriers to implementing GAPs and carrying

out risk assessments on the farms.

Study Assumptions

The study was based on three key assumptions as follow:

Assumption 1: An audit is a key evaluation tool to identify deficiencies in GAP

compliances.

Assumption 2: Farm operations audited by agencies other than USDA such as GLOBAL

G.A.P. and SCS Global Services share identical characteristics with the

USDA audited farms in terms of farm practices, needs, and challenges.

Assumption 3: The frequency of corrective action required for a GAP harmonized food

safety standard during the auditing process is positively associated with the

challenges that growers face to comply with that standard.

Study Limitations

The study only focused on the farm operations that were audited by the USDA. The

addition of farm operations audited by other agencies might have added more variation to the

dataset, particularly for states having small sample sizes. Moreover, due to small sample sizes

17

from MD, VA, and DE, the researcher was not able to compare survey findings among these

states. Therefore, non-probabilistic sampling might be a study limitation and impose restrictions

on generalizing the findings to the entire population of harmonized GAP certified growers. The

audit analysis included farms that were audited for the growing season of 2013-14. On the other

hand, the survey was administered to growers audited for the growing season of 2015-16. The

study recognizes the process of validation and comparison of findings from two samples audited

in two different seasons might be a study design weakness.

Organization of Dissertation

Chapter 1 provides the basis for third-party audits and harmonization of GAPs food

safety standards supported by a narration on the background information related to the

occurrences of foodborne outbreaks associated with fresh produce and sources on contamination

linked to farm practices. This chapter introduces the areas of research concern and defines the

study purpose, objectives, assumptions, and limitations. Chapter 2 focuses on review of the

literature covering multiple topics relevant to the study such as on-farm contamination of

produce, preventive measures, risk assessment, and GAP compliance as determined from survey

research results. Chapter 2 also describes the theoretical model as well as the produce USDA

GAPs harmonized audit process.

Chapter 3 defines the research design adopted in the study. This chapter also focuses on

document analysis, survey instrumentation, population, sample, survey administration and

analysis. Chapter 4 presents all the data analysis results under each of the study objectives.

Chapter 5 discusses the study results and provides study conclusions. This chapter specifically

emphasizes the implication of study findings for Cooperative Extension programming and offers

further research recommendations.

18

Chapter 2

Review of Literature

The Center for Science in the Public Interest (CSPI) reported the occurrence of 23,857

cases of foodborne illness due to 428 outbreaks related to produce and produce dishes between

1990 and 2003 (DeWaal & Barlow, 2004). Reviewing foodborne illness outbreak trends in the

U.S. from 2004 to 2013, the CSPI reported that produce caused more illness with higher number

outbreaks (other than multi-ingredients) than any other food category (Fisher, Bourne, &

Plunkett, 2015). Furthermore, over the period of ten years, between 2004 and 2013, produce

alone caused 629 outbreaks resulting in more than 20,000 cases of illnesses. The same report

also indicated that an average number of diseases per outbreak was largest for produce-related

outbreaks. However, when considering pound for pound fruits and vegetables are safest for

consumption; and seafood, poultry, pork, and beef were riskier of illness than produce (Fisher,

Bourne, & Plunkett, 2015).

On-Farm Contaminations

North Carolina Cooperative Extension report briefly highlighted three separate case

studies of foodborne illness outbreaks associated with produce: (1) cantaloupe in May 2002, (2)

green onions in 2003, and (3) the highly-publicized spinach outbreak in 2006 (Rejesus, 2009).

The spinach outbreak in 2006 was associated with contamination due to Escherichia coli (E.

coli) O157:H7. The investigation into the cause of the outbreak identified bacteria in the

irrigation water sample and animal feces on the ranch. Produce in the pre-and post-harvest

environment on the farms can be contaminated by numerous agents such as soil, wind, manure,

19

water, dust, wildlife, farm equipment, and most importantly workers’ handling of produce

(Hajmeer & Crozier-Dodson, 2012).

In 1996, an outbreak of E. Coli O157:H7 resulted in infections and diseases,

hospitalizations, and even three cases of hemolytic-uremic syndrome in Connecticut and Illinois.

The investigation linked mesclun lettuce from a single produce grower as the source of the

outbreak. The field investigation also revealed that water might be the likely source of E. Coli

O157:H7 contamination of lettuce. The investigation team observed multiple potential sources of

contamination on the farm that included chickens having access to both lettuce field and adjacent

beef cattle operations, recirculation of wash water, no hand washing facilities, no use of gloves

by workers, and boxes reused for lettuce (Hilborn et al., 1999).

Buchat and Ryu (1997) provided a brief account of pre-harvest practices that promote

produce contamination by pathogenic microorganisms such as Listeria monocytogenes,

Salmonella, and pathogenic E. Coli. Microbes present in irrigation water, manure, or untreated

sewage contribute towards produce contaminations. Untreated sewage with human pathogen if

used as fertilizer may more likely contaminate produce. Irrigation water contaminated with

human waste may be a source of pre-harvest contamination of produce on the field (Wachtel,

Whitehand, & Mandrell, 2002).

Beuchat (1996) listed sources of microbial contamination during pre-harvest practices.

These sources include feces, soil, irrigation water, water used to apply fungicides and

insecticides, green or inadequately composted manure, air (dust), wild and domestic animals,

insects, and human handling (as cited in Beuchat & Ryu, 1997). Regarding the contact of non-

root produce to ground, Beuchat and Ryu (1997) stated that “whatever the case, soil on the

surface of fruits and vegetables may harbor pathogenic microorganism so that remain viable

20

through subsequent handling to the point of consumption unless effective sanitizing procedures

are administrated” (p. 461). For example, Listeria can be found in soil, vegetation, water, and

pressing equipment on the farm, and raw fruits and vegetables are the medium of listeria

distribution in food supply (Harris, 2002; as cited in Hajmeer & Crozier-Dodson, 2012).

Detection of microorganisms on produce is often challenging. The type and levels of microbe

contamination depend on commodity types and level of post-harvest processing (León, Jaykus,

& Moe, 2009).

Preventive Measures

Prevention of produce contamination is vital in outbreak control efforts. Development

and implementation of Good Agricultural Practices (GAPs) are the first steps to control

contamination of produce with foodborne illness pathogen. GAPs are the prerequisite for the

development of Hazard Analysis Critical Control Point (HACCP) (Delazari, Riemann, &

Hajmeer, 2006). Preventive measures should be prioritized to control produce contamination

rather than a responsive measure. However, implementation of preventive measures is not an

easy task. Powell, Jacob, and Chapman (2011) asserted that “it remains a challenge to compel

food producers, processors, distributors, retailers, foodservice outlets and home meal preparers to

adopt scientifically validated safe food-handling behaviors, especially in the absence of an

outbreak” (p. 817).

Produce growers have a vital role in the prevention of contamination of produce.

Growers’ on-farm decisions to reduce risks of microbial contamination have implications on the

health of consumers. Cited in Powell et al. (2011) the U.S. Government emphasized that food

safety as the primary responsibility of food producers even in the presence of inspectors’

supervision of compliance. Bihn and Gravani (2006) suggested that “growers need to carefully

21

evaluate every phase of their [farming] operation and develop specific food safety plan

(program) that addresses the hazards and risks that are present” (as cited in Gravani, 2009, p.

108). Therefore, it is important for produce growers to make decisions wisely and understand the

consequence of produce contamination due to their practices on society and also benefits of

adopting standard food safety practices.

GAP knowledge and positive attitude are crucial factors for effective implementation of

food safety program on produce farms. Lewis Ivey, Lejune, and Miller (2012) studied the

relationship between GAP perceptions and practices and reported inconsistencies. However, their

study found a positive correlation between GAP familiarity and GAP implementation among

growers mostly producing fresh vegetables for market. Angelillo, Viggiani, Rizzo, and Bianco

(2000) assessed positive attitude toward foodborne disease control and preventive measures in

food handlers. However, observed food safety practices of food handlers were not consistent

with their attitude.

Gilling, Taylor, and Taylor (2001) described a behavioral HACCP adherence model that

links awareness and attitude to behavior. Identifying self-efficacy and motivation as the

characteristics of individual’s attitude, they further described lack of self-efficacy and motivation

as barriers to HACCP principle adherence. Determining barriers to complying with HACCP

principles and food safety programs in the dairy industry, Karaman, Cobanoglu, Tunalioglu, and

Ova (2012) recognized the lack of knowledge and program cost as the key barriers to

implementation of standards.

22

Risk Assessments

Risk assessments are key components of GAPs Harmonized Food Safety Standards.

Rowe (1977) provided a general definition of risk as the probability that something undesirable

will happen (as cited in Harwood, 2000). Douglas (1992) defined risk as “the probability of an

event combined with the magnitude of the losses and gains that it will entail” (p. 40). The term

“probability” has been an integral component in studies that quantify characteristics of risk. On

the other hand, the qualitative aspects of risk emphasize the component of uncertainty in

combination with some sort of damage, an uncertain outcome from an activity (Kaplan &

Garrick, 1981). In the context of multistate outbreaks, the risk of foodborne illness can be

explained by the risk of getting sick or hospitalized or even dying as a result of consumption of

contaminated food. Lammerding and Fazil (2000) argue that “the risk of foodborne disease is a

combination of likelihood of exposure to a pathogen in food, the likelihood that exposure will

result in infection or intoxication, and subsequently illness and severity of the illness” (p. 147).

Growers are required to perform and write pre-harvest and water system risk assessments

to comply with standards regarding risk assessments. Such assessments include identification of

the source of physical, biological and chemical hazards and written procedures to address the

potential risk of produce contamination due to the hazards. Limited literature is available that

specifically focused on establishing relationship between growers’ perception of risk and food

safety behavior. Keraita, Drechsel, and Konradsen (2008) studied the farmers’ health risk

perception with the relationship to use of contaminated water in vegetable farming in Ghana.

Their study indicated that even though farmers were aware of health risks associated with the use

of contaminated water, their risk reduction practices were largely influenced by growing pressure

from media and authority.

23

Bihn, Smart, and Hoepting (2013) advocated that produce growers have the responsibility

to recognize the risk associated with their farm practices and should address those risks by

adopting food safety practices. Isin and Yildirim (2006) studied the effect of farmers’

perceptions of the harmfulness of pesticide use on their farm practices. Their study indicated

farmers who perceive pesticides as harmful to the environment were more sensitive to their

practices. Cary and Wilkinson (1997) in developing a regression model conclude that

perceptions of profitability and personal environmental concerns as key factors to explain

farmers’ conservation behaviors.

Growers carry their personal beliefs on the risk associated with their on-farm practices,

and it can be argued that these perceived risks influence their on-farm actions. Growers’ personal

beliefs of risks may potentially influence how they evaluate the risk associated with their on-

farm practices. Their low levels of perceived risk may indicate that growers possess a false sense

of security regarding their on-farm practices (Tucker & Napier, 1998). At the same time, auditors

also hold a set of beliefs about the risk associated with farm practices and what growers should

do in response to minimize the possibility of produce contamination.

Inaccuracies and inconsistencies in auditors and growers’ risk perceptions and assessment

may hurt the purpose of the GAP certification program. For an effective implementation of risk

assessment programs, there needs to be consistencies in perceived risks by the auditors and

produce growers. Effective communication between growers and auditors may reduce the

underestimation or overestimation of risk in assessments. Inconsistencies in risk evaluations may

stand as an obstacle to GAP certification process.

24

Compliance with GAPs

Studies were conducted to assess growers’ compliance with food safety practices in

several states of the United States. The general methodology in these studies were self-report

surveys. Hultberg, Schermann, and Tong (2012) developed a survey based on Food and Drug

Administration’s (FDA) GAP guidelines to measure Minnesota vegetable growers’ compliance

with GAPs. In that self-reporting survey, the majority of the respondents indicated

implementation of GAPs with regards to workers’ health and hygiene, access to safe and clean

drinking water for workers, workers’ food safety training, having a Standard Operating

Procedures (SOPs), sanitization of containers, and cleanliness of farm tools. Their study also

identified deficiencies in a few areas of GAP practices such as treatment of water used for

washing and cleaning, keeping the animals out of fields, and regular cleaning of harvesting tools

as per food safety policy.

Rangarajan, Pritts, Reiners, and Pedersen (2002) surveyed New York fruits and vegetable

growers to assess their manure, compost, and on-farm water quality management practices with

federal guidelines. Similar studies were conducted in six New England States (Cohen,

Hollingsworth, Olson, Laus, & Coli, 2005) and in seven states across the U.S. (Jackson et al.,

2007). Ellis et al. (2005) conducted a similar study in Iowa using observation and interviews

with farmers.

Cohen, Hollingsworth, Olson, Laus, and Coli (2005) surveyed fruit and vegetable

growers in six states of New England. Water from wells were major drinking and irrigation water

sources in those surveyed farms. Around one-third of surveyed farms were unaware of testing

drinking water and a majority of their survey respondents had not tested irrigation water for

coliform. More than 90% of the respondents to the survey did not use sanitizers for water used

25

for washing produce. The majority of the respondents reported that they usually to always wash

their harvest and storage containers before use. Additionally, the majority of the growers handled

food with bare hands. The study showed high adoption of GAPs among the growers of New

England.

Jackson et al. (2007) conducted a comprehensive survey and assessed the growers’ and

packers’ familiarity with the GAPS and implementation of GAPs in Florida, Texas, California,

Georgia, Michigan, New York, and Arizona. Growers were knowledgeable with GAPs

irrespective of their age. Growers recognized the importance of hygienic practices, but the major

obstacles were associated cost and perceived level of difficulty of the policy. Resources such as

supplies and cost were among the major barriers to providing handwashing facilities in the field.

The study showed that GAP awareness is positively related to the likelihood of growers provide

handwashing and toilet facilities to workers (Jackson et al., 2007).

The general belief is that conventional washing and sanitization procedures are enough to

reduce microbial level to a safe level. However, these procedures are not sufficient to ensure

produce safety by entirely reducing microbes on the produce. Condition of contaminations,

interval between contamination and washing, attachment in inaccessible sites, formation of

biofilms, internalization of bacteria within produce are the factors that limit the efficiency of

washing to reduce microbes (Sapers, 2001). Growers should have a basic understand of those

factors while writing a water management plan for their food safety plan.

Bihn et al. (2013) studied the irrigation water sources and management practices by

produce growers of New York and indicated the absence of information related to the quality of

water used in many farm operations. Their study showed that during the growing season,

growers utilize water from various sources such as surface water (pond, stream, and lakes),

26

municipal water and underground or well-water. The majority of their survey participants who

use surface water for irrigation apply the water overhead increasing the risk of produce

contamination. Furthermore, a minor percentage of respondents, who used overhead delivery

method for irrigation, tested surface water for generic E. Coli.

Assessment of water quality through testing is vital for water risk assessment. Bihn et al.

(2013) supported that testing of water is an integral component of water management risk

assessment. Produce growers can make informed management decisions based on the testing

results. In that same survey, growers were asked about having adjacent lands that pose a risk.

Interestingly, almost half of the respondents did not answer the question. Their survey findings

showed a majority of the growers did not have a food safety plan in place. Korslund (2014)

interviewed stakeholders to assess the importance of a food safety plan for small fruits and

vegetable growers of Minnesota. This study also identified barriers to developing and

implementing food safety plans. Those barriers included amount of time, increased cost,

increased paperwork, access to information about food safety plan.

Harrison et al. (2013) surveyed food safety practices on small- and medium-sized farms

and farmers’ market. A slightly majority of their survey respondents indicated animal access to

their agricultural production area. Their survey revealed growers use of the surface, well or

rainwater to irrigate their crop and some growers using untested well-water to wash produce.

Survey respondents used a variety of sanitizers such as mild detergent, liquid soap, 50% bleach

solution, 20:1 water to bleach solution, Sulphur/citric solution, ammonia and water, and

household cleaner with bleach, which touched produce. One-third of the responded always

cleaned the containers carrying produce to the market between uses.

27

Becot, Nickerson, Conner, and Kolokinsky (2012) studied the cost and time associated

with implementing GAPs on the farms of Vermont. Their study found that the GAP adoption

cost ranged between $37 to $54 per acre and approximately 7hr of work per week to meet the

GAP requirements. Becot et al. (2012) also mentioned that regional supermarkets such as

Hannaford, Price Chopper, and wholesale distributors are asking growers for GAP certification.

Their survey showed that GAP certified growers were different from non-certified in terms of

farm size, number of employees, and direct sale of produce to consumers, supermarkets, and

wholesale markets.

Certified growers tend to have large farms and sell relatively less directly. In other words,

a non-certified grower usually sells a higher portion of produce directly to the consumers.

Regarding the barriers to certification, their study reported reasons for growers not to seek GAP

certification. That included, they were selling to buyers that do not require certification and

secondly, their gross selling was not more than $500,000 (FSMA exempt criteria). On an average

GAP-certified farms required two people for record keeping, a total of 7hrs/week. Audit cost was

higher for vegetable growers than apple growers. Similar studies were also conducted by

Hardesty and Kusunose (2009) for leafy green and Wood and Thornsbury (2005) for fresh

strawberries.

LGMA, a voluntary program, was introduced by a group of leafy green handlers of

California in response to E. Coli outbreak associated with Spinach. Hardesty and Kusunose

(2009) surveyed leafy green growers of California to measure LGMA compliance cost. The

study reported an overall increase in cost for compliance with LGMA. The modification of

practices to comply with LGMA cost growers averaged $13.60 per acre.

28

Hamilton et al. (2015) studied the barriers to implementation of GAPs in the vegetable

farms of Minnesota. Farm visits further validated their survey findings. Finding of their study

showed the existence of inconsistencies between self-reporting of GAP incorporation and actual

incorporation to their farm practices. A major inconsistency was observed in growers’ practices

on keeping animals and pests out of farm packing and storage areas. Findings showed a

significant difference between growers’ claim of providing hygienic food handling environment

to farm workers and available records or logs to support that claim and to present to the auditors

during the audit process. The majority of the farms required their employees to wash hands

before starting work. However, the on-farm survey showed 30% of farms had hand washing

signs in their restrooms.

Panisello and Quantick (2001) identified potential technical barriers to implementing

HACCP principles that included the illusion of control, the persistence of old habits and attitude

of personnel, lack of time, lack of motivation and supervision, documentation (paperwork), and

difficulties in verification and validation of HACCP. Lichtenberg and Page (2016) studied the

prevalence and cost associated with the implementation of food safety practices by leafy green

and tomato growers in Mid-Atlantic states, under produce safety rule of FSMA. The majority of

their survey participants were from Pennsylvania, New Jersey, and Maryland. Their study

focused on the cost associated with replacing containers for each harvesting year, employees’

training, facility for sanitation, testing of soil amendment were studied with regards to Produce

safety rules.

Lichtenberg and Page’s (2016) survey showed that the tomato or leafy green growers

selling directly to consumers are more likely to wash their produce. The majority of the

respondents of Mid-Atlantic states inspected and monitored their field for wildlife activities as

29

well as washed containers before harvesting. With regards to specific food safety standards,

produce marketing channels has no or less effect of on either growers’ compliance with wildlife

monitoring or sanitizing containers used for harvesting. The tomato and leafy green growers of

Mid-Atlantic who sell a higher proportion of their produce to retailers and restaurants are more

likely to test water and soil amendments. Under FSMA, produce growers with a gross income of

between $25, 000 and $500,000 and selling more than 50% of their produce directly to end-user

(qualified) are exempted. Lichtenberg and Page (2016) argued that even though very small and

small-scale farmers might be exempted from FSMA, produce buyers may still require their

suppliers to improve food safety practices.

Marine, Martin, Adalja, Mathew, and Everts (2016) studied GAP knowledge and

implementation of GAPs by the vegetable producers of Mid-Atlantic states (Maryland and

Delaware). Their study highlighted a lower GAP certification among fresh produce growers.

Lewis Ivey et al. (2012) reported that university representatives and government regulators

influence producers’ management decisions regarding produce food safety. Tobin, Thomson,

LaBorde, and Radhakrishna (2013) studied factors affecting Pennsylvania growers’ decision on

food safety practices. Their study reported that customer requirements motivated them to adopt

GAPs.

Theoretical Framework

The global food system has been transformed significantly over the years. The way in

which foods have been produced, processed, packed, and transported has changed as well as

consumers’ food habits and preferences. Quality, as well as the safety of food items, have

become important attributes of food system regulatory frameworks. Private sectors are playing a

key role in shaping the global food system with quality and safety regulations (Fulponi, 2006).

30

Food standards are required to ensure quality and safety of food from production to delivery

processes. In this regulatory setting, GAP certification has become a tool for product safety.

With much publicity from outreach agencies and growing pressure from produce retailers to

incorporate GAPs into farm practices, inconsistencies were reported.

To explore the areas where GAP noncompliance was frequently reported, the standards

that produce growers find challenging to comply, and the barriers to GAP implementation, this

study adopted the monitoring and evaluation stage of policy cycle framework.

Policy Cycle. The implementation of on-farm adoption of GAP standards is the focal

point of this assessment study. Policy cycle theories have been widely accepted in the field of

policy research. Jann and Wegrich (2006) briefly narrates theory and the stages of the policy

cycle. The number of stages and sub-stages of policy making process depends on the complexity

of the policymaking process and the context in which policy is evolved. However, a typical

policy cycle framework consists of four chronologically ordered stages (Barkenbus, 1998). The

policy process starts with the first stage of agenda setting or problem identification followed by

policy formulation as the second stage. The policy formulation stage leads to policy

implementation and subsequently to the monitoring and evaluation stage (Figure 2.1).

Policy cycle framework has been adopted to design and implement agricultural policies

(van Tongeren, 2008). Havelaar et al. (2007) adopted policy cycle model to study food safety

policymaking process. The series of events related to incidents of foodborne illness outbreaks,

growing food safety concern among food supply stakeholders, promotion of food safety

practices, regulations and certification of compliance provided a scope to assess these events

through the lenses of policy cycle stages. The starting point of the policy cycle is agenda setting

or problem recognition. The burden of foodborne illness on population and society as described

31

Evaluation Tools

Analysis of Audits

o Violations of Standards

o Aspects of violation

Surveying Produce Growers

o Challenging standards

o Barriers to GAP implementation

o

o Extension Programming

o Audit Agencies

in the introductory paragraphs of chapter 1 provide policymakers a solid basis for setting up

preventive agenda to address the issues.

Policy Cycle Framework

Setting up agenda involves the majority of the stakeholders, which include institutions,

retailers, wholesalers, growers, cooperatives, auction houses, and consumers. The next stages of

policy making - policy formulation and implementation are complex processes. Formulation of

policies does not guarantee efficient and effective adoption. Therefore, it is crucial for the policy

makers to have an execution plan. Specification of program details, allocation of resources, and

decisions are the three core components of policy implementation (Jann & Wegrich, 2006).

To ensure supply of safer food in the U.S., the FDA intended to put in place a

comprehensive system as HACCP. The government recommended food sectors to take quality

control measures in the form of HACCP (Fulponi, 2006). However, the applicability of all

Policy Formulation

Policy Implimentation

Monitoring and

Evaluation

Problem Recognition

Imp

lica

tio

n

Figure 2.1. Policy cycle model (adopted from Barkenbus, 1998; Jann & Wegrich 2006)

32

HACCP principles in pre-harvest practices was questioned. Hajmeer and Crozier-Dodson (2012)

stated that:

The implementation of a true HACCP system at pre-harvest may not be achievable as it is

on the postharvest side. This is primarily because of the nature of an open environment at

the field/farm level, where the control of hazards is more challenging compared to more

restricted settings. Implementation of all HACCP principles may not be achievable at pre-

harvest either. (p. 104)

Initiatives were taken to address the issue of foodborne outbreaks linked to produce both

domestically produced or imported. That included Produce Safety Initiative in 1997 and the

release of guidance for industry for fresh fruits and vegetables (USFDA, 1998) and fresh-cut

fruits and vegetables (USFDA, 2008). The FDA, to address the E Coli O157:H7 outbreaks linked

to fresh and fresh-cut lettuce, introduced Lettuce Safety Initiative. Commodity Specific Food

Safety Guidelines for the Melon Supply Chain was introduced in 2005 in response to reduce the

risk of melon contamination. The Leafy Greens Marketing Agreement (LGMA) metrics program

was initiated in California (Hajmeer and Crozier-Dodson, 2012).

The increasing concern of society on issues affecting food safety on regulatory bodies,

integration of global financial markets with food companies, and growing purchasing power of

consumers contributed to the development of private voluntary standards (Fulponi, 2006).

Retailers’ involvement in rulemaking can be viewed in two angles, first as their motive to reduce

risk and liability cost and secondly, their intention to hold or gain consumers’ confidence

(Havinga, 2006). Citing Picciotto (2002) and Scott (2002), Havinga (2006) mentioned that

standard setting, monitoring of compliance with standards, and enforcement of standards are the

three key components of regulation. Private standards by retailers can be regarded as self-

33

regulation, which “implies that private sectors are regulating the behavior of their organization,

its members, or associates without government involvement” (Havinga, 2006; p. 517). Havinga

(2006) also confirmed that the suppliers who supply to many supermarkets with different food

safety policies are struggling to meet individual supermarket’s requirements.

Suppliers have to cope and perform in this regulatory environment introduced by

government and retailers. Produce suppliers have to bring changes in their practices such as the

way food is produced, processed, packed and transported to buyers. In the European context,

Hammoudi, Hoffmann, and Surry (2009) claimed that the framework in which regulations were

formulated by the private retailers had incentives for retailers as well as for the suppliers. In

other words, compliance with regulations may provide a competitive advantage and create a

market opportunity. On the other hand, non-compliance may result in an exit from the current

produce market. A firm that does not meet the standard requirements may lose the market

opportunity. Private standards are designed to improve safety assurance and tap market access

and opportunities.

One of the advantages of harmonization of regulations or GAP standard is the acceptance

by the majority of supermarkets. As a result of harmonization of standards, produce buyers may

more likely to pressurize produce suppliers to comply with regulations. The supermarkets see it

as advantageous both for them as well as for their suppliers.

Monitoring and evaluation. Findings from the monitoring and evaluation stage of

policy process were intended to provide feedback and connect to the policy formulation stage.

Policy continuation, modification or termination are the consequence of assessments showing

whether or not policy goals and objectives are met. Although data is important in all the stages of

34

the policy cycle, farm level data are valuable indicators to the success of policy, and testing the

hypotheses laid during the policy formulation stage.

Data from the farm level provides opportunities for periodic assessment of

policy/programs. van Tongeren (2008) characterizes that agricultural policy data should be

“relevant, objective, transparent, accurate, and comparable over time and space, accessible and

timely” (p. 33). This assessment study employed audit analysis and a survey as two key

evaluation tools. Evaluation data were in the form of auditors’ on-farm observations and input

from the certified growers. The two sources of information provided cross-validated evidence on

challenging GAPs harmonized food safety standards for the growers of the Mid-Atlantic States

and New York.

Evidence of policy success in the context of GAP harmonized audits can be in terms of

increasing the number of produce growers applying and successfully passing GAP harmonized

audits and ultimately reduction in the number of foodborne outbreaks associated with fresh

produce. USDA estimates showed that “the total number of illnesses attributed to USDA-

regulated products fell more than 12 percent from 2009 to 2015” (Vilsack, 2016). Although GAP

certifications are voluntary, an increasing number of growers are applying for certification, and

that indicates the growing acceptance among the producers.

Produce USDA GAPs Harmonized Audit Process

USDA’s Specialty Crop Inspection (SCI) Division audit programs verify compliance to

field operations, harvesting, and post-harvesting harmonized food safety standards. This study

focuses on the field operations and harvesting harmonized food safety standards. A typical GAP

audit process comprised of two events. First the trained auditors visit the farm and observe

practices on the farms and packing houses. In the second event, auditors verify the food safety

35

plan, Standard Operation Procedures (SOPs,) and documents showing adherence with food

safety plan and SOPs (Critzer & Wszelaki, n.d.). The produce GAPs harmonized food safety

standards checklist (USDA Harmonized Checklist, 2013) provides details of audit requirements.

Auditors verify farm operation’s compliance with reference to the checklist questions. The audit

checklist has three major sections: general questions, field production, harvesting, transportation

(Table 2.1). All questions under the checklist are assessed with the following terms:

1. Compliant (C): This refers to operation meets harmonized standards.

2. Corrective Action Needed (CAN): This term applies when the farm operation does not

meet the standard criteria. However, the noncompliance does not refer to an immediate

health or food safety risk.

3. Immediate Action Required (IAR): Labeling a question with “IAR” refers to non-

conformance of the standard requirement(s) that is assessed as an immediate food safety

risk.

4. Questions in the checklist that are not applicable to the operation are assigned as “Not

Applicable” (N/A).

The auditors are required to document their comments or explanations on each assessed

question as CAN and IAR. For each question answered as CAN or IAR, the auditor fills out a

Corrective Action Report referring to the harmonized GAP guidance. Furthermore, auditors may

also be responsible for providing explanations to clarify complaint status or clarify their

assessment as N/A. According to the standard criteria, none of the questions corresponding to the

field operation and harvesting should be reported as IAR. In other words, reporting of IAR to any

question will lead to failure of harmonized audit. Food safety criteria stress upon having a

written food safety policy and compliance with the policies, assigning people with role,

36

responsibility and resources, documentation for traceability and recall program, and compliance

with labeled instructions for the use of agricultural chemicals. Appendix A lists all the

harmonized GAP standards for field operations and harvesting and the policy requirements.

Table 2.1

List of Standards Under Major Sections of Field Operations and Harvesting

Section General

Questions Section

Field

Production Section Harvesting Section Transportation

1.1 Management

Responsibility

2.1 Field History

and

Assessment

3.1 Pre-harvest

Assessment

4.1 Equipment

Sanitation

and

Maintenance

1.2 Food Safety

Plan

2.2 Worker

Health/

Hygiene and

Toilet/

Handwashin

g Facilities

3.2 Water/Ice

1.3 Documentatio

n and Record

Keeping

2.3 Agricultural

Chemicals /

Plant

Protection

Products

3.3 Containers,

Bins and

Packaging

Materials

1.4 Worker

Education and

Training

2.4 Agricultural

Water

3.4 Field

Packaging

and

Handling

1.5 Sampling and

Testing

2.5 Animal

Control

3.5 Postharvest

Handling

and

Storage

1.6 Traceability 2.6 Soil

Amendments

1.7 Recall

Program

2.7 Vehicles,

Equipment,

Tools and

Utensils

1.8 Corrective

Actions

1.9 Self-audits

37

After the complete assessment, the auditor tallies the audit by filling out a score sheet that

records numbers of C, CAN, IAR, and NA’s for each section of the audit to make decisions on

the growers’ status on GAPs compliance. To pass an audit, growers need to comply with at least

80% of the questions that were not assessed as NA.

Apart from those mandatory criteria of compliance, USDA acceptance requirements also

put a significant emphasis on assessment of risk linked with farm operations. Table 2.2 lists the

risk assessment requirements under the produce GAPs harmonized food safety standards. If

farming operation fails to pass the audit in the auditor’s first visit to the farm, the growers will

have another opportunity to address any problems that the auditor found during the audit process.

After the grower takes the appropriate corrective action, he or she can schedule a follow-up

audit.

Table 2.2

Risk Assessment Requirements

Question Requirement

2.1.1 The food safety plan shall, initially and at least annually thereafter, evaluate and

document the risks associated with land use history and adjacent land use, including

equipment and structures.

2.4.2.1 An initial risk assessment shall be performed and documented that takes into

consideration the historical testing results of the water source, the characteristics of

the crop, the stage of the crop, and the method of application

2.5.1 The operation has a written risk assessment of animal activity in and around the

production area.

2.6.1 The food safety plan shall address soil amendment risk, preparation, use, and storage.

3.1.1 A pre-harvest risk assessment shall be performed.

38

Summary

The review of literature focused four aspects of on-farm food safety issues: 1) Sources of

produce contamination, 2) food safety regulations, 3) growers’ compliance and 4) certification

for GAPs. An abundance of literature identified sources of produce contamination and linked

them to farm practices and to farm settings. Researchers agreed that preventive measures in the

form of GAPs are effective in minimizing produce contamination. Many authors on the topic of

food safety regulations tend to favor GAP adoption and certification. At the same time, studies

on the barriers to GAP compliance more frequently concentrated on cost and time as a burden.

Many studies that used mail surveys as a tool to collect data on produce growers’

adherence to GAPs, primarily relied on self-reporting of practices. Serval of those studies

discovered inconsistencies in reporting and actual practices. However, those studies did not

provide any reasons for such inconsistencies. Contamination due to water and manure were very

often discussed in a significant number of studies. Limited studies were available that focused on

on-farm food safety practices by Mid-Atlantic produce growers.

39

Chapter 3

Methodology

Research Design

This study employed a triangulation approach to answering the research objectives and to

further validate the findings across different methodologies. Triangulation is a widely-accepted

approach in mixed method studies, where qualitative and quantitative methods are combined to

confirm findings (Creswell & Miller, 2000). Analysis of produce USDA Good Agricultural

Practices (GAPs) Harmonized audits and mail survey of harmonized GAP certified produce

growers served as two methodological tools to assess on-farm implementation of GAPs

standards. Triangulation offers opportunities to study a phenomenon in different methodological

perspectives (Denzin, 1978) and it can also be used for a broad understanding of the topic

(Olsen, 2004).

The research design followed a qualitative and a quantitative methodology in a sequence

as a strategy to evaluate the implementation of GAPs Harmonized standards in six states.

Analysis of produce USDA GAPs Harmonized audits was the initial and significant step to

initiate the inquiry. The evidence from the audit analysis provided a solid basis for further

inquiry and to develop a survey to understand growers’ perspective on GAP implementation and

barriers.

The purpose of adoption of two methodologies to study a single phenomenon was to

validate and increase the credibility of findings. Hussein (2009) presented a typical example of

triangulation that combined qualitative and quantitative methods as a data validation measure.

The author argued that triangulation surely help to increase internal consistency and

generalizability of the study as well as increase the confidence on the credibility of study

40

conclusions. This study is a methodological triangulation, and more specifically between-method

triangulation also called across-method triangulation (Denzin, 1978).

The rationality for an across-method design was to take on-site observation and growers’

experience on GAP implementation into consideration. In this research design, audits were used

as a tool to evaluate on-farm GAP compliance— the observation aspect (Figure 3.1). On the

other hand, surveys were intended collect information directly from the certified produce

growers— the experience aspect of GAP compliance. Data in these two forms was assumed to

capture the key aspects of GAP compliance: on-farm observation and experience. This study

hypothesized consistencies in both the forms of data collection.

Population and Sample for Audit Analysis

The target population of the study was Harmonized GAP certified produce growers of

Mid-Atlantic states such as Delaware, Maryland, New Jersey, and Pennsylvania including New

York. The farm operations that were audited for field operations and harvesting harmonized

standards by various auditing agencies such as USDA, GLOBALG.A.P., and SCS Global

Figure 3.1. Research design comprising of qualitative and quantitative approach©

Growers

Survey Audit Analysis

On-Farm

Observation

On-Farm

Experience

Across -Method

Validation

Qu

ali

tati

ve &

Qu

an

tita

tive

Meth

od

s

Qu

an

tita

tive M

eth

od

41

Services constituted the population of this study. Finding of this study might also be inferred to

farm operations audited for GAP and Good Handling Practices (GHP).

The study sample constituted of farm operations audited by USDA for GAPs harmonized

food safety standards (field operations and harvesting). The reason for selecting USDA audited

farms as a study sample was because of accessibility to the audits and the contact information of

certified growers (USDA, 2016). Selection of USDA audited farm operations as study sample

could further be supported by the argument that it was one of the earlier agencies that adopted

harmonized standards for GAP audits.

Document Analysis

Document analysis is one of the established methods of the qualitative research (Corbin

& Strauss, 2008, as cited in Bowen, 2009). In this study document analysis was conducted on

redacted produce USDA GAPs harmonized audits. In the absence of evidence on growers’

compliance with the harmonized food safety standards, audits were assumed to be a rich source

of information to initiate this evaluation study. Analysis of audits provided information on

specific food safety standards where growers are frequently failing to comply with the

requirements.

Data collection. Redacted produce USDA GAPs harmonized audits for the growing

season 2013-14 were accessed from the USDA Agricultural Marketing Service (AMS) (USDA,

2016). Accessed audits were for Mid-Atlantic states: Pennsylvania, New Jersey, Delaware,

Maryland, Virginia, and New York. In total 166 (N) redacted audits for field operations and

harvesting were accessed from the six states. Since no information was available on the number

of audits performed in West Virginia, no West Virginia audits were accessed from USDA for

that period. This study did not include West Virginia.

42

Table 3.1 shows the complete list of states, and the corresponding number of accessed

GAPs harmonized audits for field operations and harvesting. The prime reason to include New

York as a Mid-Atlantic state in this study was to increase the variation in the data since relatively

large number of audits (n=67) were accessed for New York.

Table 3.1

Produce USDA Gaps Harmonized Audits for The Growing Season 2013-14

State Number of Accessed Field Operations and Harvest Audits

Delaware 6

Maryland 8

New Jersey 36

New York 67

Pennsylvania 40

Virginia 9

West Virginia Not Available

Total States 166

A typical produce USDA Harmonized GAPs food safety standard checklist, in addition to

food safety standard requirements and verification criteria, also contains pertinent information

related to the farm operation and commodity. Such information includes audit date, farm

location, business mailing address, audit date, description of farm operation, company name,

other contractors’ name, audited commodity, and total acres covered by the audit. This additional

information was redacted from the audits before they were shared for this research. The accessed

audits contained information related to audit summary, auditors’ on-farm observation and

comments, corrective action reports, auditors’ name, and field office address.

43

Data analysis. In the first stage of analysis, audits (N=166) were systematically reviewed

to identify food safety standards for which Corrective Action Needed (CAN) or Immediate

Action Required was reported. Document analysis procedures included sorting out audits where

at least one CAN or IAR was reported on the checklist. The number of CANs and IARs were

counted for each section and sub-sections under all major sections: general questions, field

production, harvesting, and transportation. Results were presented in percentage and graphical

format to identify standards for which maximum noncompliance were reported.

Results were grouped for individual states and collectively for all the six states. This

study utilized the frequency or the count of CANs combined with IARs as a parameter to

determine frequently violated or non-complied standard or GAP area. In other words, GAP

standard requirements with a maximum number of CANs and IARs were labeled as the standard

of frequent violations. Microsoft Excel® (2016) software was used to create tables and charts to

describe the frequencies of CANs and IARs.

Each standard requirement has single to multiple aspects for compliance. Thus, in order

to better understand all aspects of noncompliance relative to the standard requirements, auditors’

comments and observations to questions were carefully reviewed. This step included analysis

and comparison of auditors’ comments to violations relative to a single standard across different

farms and states. Consistencies and variations in reasons for noncompliance were the two

principal criteria adopted while reviewing the comments. Since these audits were redacted, no

information was available related to farm commodity and farm location. Therefore, findings

from the audit analysis were not intended to link to any particular product or a farm operation.

Proportional tests were performed to determine if the proportion of audited farms in each

state is significantly different from other states with respect to reported noncompliance to a

44

section in the audit checklist. There are in total 22 sections under four sections such as general

questions, field production, harvesting, and transportation. Proportions were calculated by

counting the number of farms where CAN or IAR was reported for a particular section within a

state.

Proportion (π) =Number of farms where CAN and IAR e reported for an individual section for a state (nπ)

Total number of farms audited for that state (n)

One of the conditions of a proportional test is that the cell counts should be greater or

equal to five (nπ ≥ 5). In other words, for this test analysis, in any given state, the number of

farms where CAN or IAR for a section was reported should be greater than or equal to five to

perform proportional test analysis. Based on this condition, four sections were identified for

which the farm counts were either greater than or equal to five. Those four sections were 1.4, 2.2,

2.7, and 4.1; and all were from New Jersey and New York. Therefore, z-test of proportion was

performed for those four standards and two states: New Jersey and New York.

Furthermore, in order to determine the likelihood to observe GAP noncompliance on the

farms of a state relative to other states, risk ratios were calculated. Risk ratio tests were

performed for all the sections of the audit checklist for the farms of Pennsylvania, New Jersey,

and New York. The reason for selecting Pennsylvania, New Jersey, and New York was that in

these three states relatively large number of farms were audited compared to Delaware and

Maryland. In none of the farms of Virginia either a CAN or an IAR was reported.

Survey Analysis

Instrumentation. In order to measure growers’ experience with implementation of

Harmonized GAPs standards on their farms, a four-page survey questionnaire was developed

(Appendix D). Questions on the survey were primarily based on the findings from the audit

45

analysis. The purpose of the survey was to assess the implementation of harmonized GAPs

standards by certified growers in terms of how challenging it was for them to comply with the

food safety standard requirements, barriers in GAP implementation and carrying out risk

assessments, commodity they grow, marketing channel, source of GAP information, and their

intention to be certified annually.

Survey development procedures intended to capture maximum aspects of GAP

compliance. However, multiple questions measuring related standards were combined create to

one questions to reduce overlapping of questions and keep the questionnaire length short for

growers to respond. The questionnaire was validated for face and content validity by a panel of

experts. The questionnaire was further reviewed by a food safety Extension educator and a

harmonized GAP certified produce grower. Their feedback was incorporated to improve the

readability, validity, and clarity of the questions.

Growers were asked to rate food safety standards on how challenging it was for them to

comply with the harmonized food safety standard requirements on a challenge Likert-type scale.

The Likert scale ranged from “not at all challenging” to “very challenging” with a mid-point of

“moderately challenging.” Along with the five options, growers were also provided with an

additional option of “NA” (Cohen et al., 2005) in case a standard was “not applicable” to the

farm operation. In total 27 questions were asked related to various food safety standards under

nine separate sections. These sections were: (1) food safety plan, (2) documentation, (3)

employees’ food safety training, (4) water management, (5) cleaning procedures, (6) harvesting

policy, (7) transportation, (8) risk assessments, and (9) other standards.

Additionally, the survey also focused on other key aspects of food safety practices such

as barriers in implementing GAPs and carrying out risk assessments, and GAP information

46

sources. Multiple options were provided with the questions identifying barriers including an

open-ended option to specify other unlisted barriers. For further insight into concerns associated

with on-farm risk assessments, the survey included an additional open-ended question.

Questions were also related to the amount of GAP information growers are obtaining

from various sources that included USDA GAPs user’s guide, Cooperative Extension, online

sources etc. The amount of information obtained from various sources was measured on a five-

point, Likert-type scale ranging from “none” to “a great deal of” with a midpoint of “a fair

amount of” information. Growers were asked to indicate the type of produce they grow such as

fruits, vegetables or both and the market where they sell their produce. At the end of survey,

growers were asked to specify their intention to renew their USDA GAPs harmonized

certification annually. The survey for the growers was reviewed and determined as exempt

research by the Institutional Review Board (IRB) at the Pennsylvania State University on March

07, 2016 (study#00004552). Data collection procedures were in accordance to the approved IRB

protocol.

Survey sample. The sample frame of the survey included the harmonized GAPs certified

produce growers for field operations and harvesting in the Mid-Atlantic states comprising of

Pennsylvania, Virginia, New Jersey, Delaware, and Maryland, as well as New York. These

growers were audited by the USDA for GAP Harmonized food safety standards between May

2015 and November 2015. The survey sample size of this study was 212.

Data collection. Mailing addresses of all those growers were accessed from the USDA-

AMS website and LVF 2016 onion growers list of Pennsylvania. Mailing addressed were

verified using the United States Postal Service address lookup tool to reduce sample frame error.

Separate lists with verified farm addresses were created for individual states. The study followed

47

modified Total Design Method proposed by Dillman (1991) with four contact points. Surveys

were mailed to 212 produce growers of Mid-Atlantic states and New York in the month of

March 2016. A cover letter explaining the background and purpose of the study, a consent form

describing their right as a study participant, and a prepaid envelope were also enclosed along

with the paper survey. Surveys were tracked using unique tracking numbers.

Out of the 212 surveys, 7 were not delivered because of mailing address error, which

represented sample frame error of approximately 3.3%. After three weeks, reminder postcards

were sent to all the non-respondents to increase the response rate (Rangarajan et al., 2002) asking

growers to complete the surveys or request another blank survey from the researcher. On the

seventh week, blank surveys were sent to all the non-respondents; and one week later the second

reminder postcards were mailed. Surveys were collected from the last week of March through

mid-June 2016. In total 120 surveys were returned and the majority of them were returned during

the first three weeks of administration of surveys. The advantages of using mail surveys as data

collection method include: (1) Mail surveys are not subjected to interview bias; (2) Anonymity

of respondents can be ensured; and (3) Respondent can complete the survey at their own pace

(Pennings, Irwin, & Good, 2002).

The overall survey response rate was 58.5%, which was higher than other similar studies,

for example, response rates were 21% for Becot et al. (2012), 32% for Hultberg et al., (2012),

and 49% for Cohen et al. (2005). Table 3.2 shows the number of surveys mailed to harmonized

GAPs certified growers and respective response rate for each state. The majority of respondents

were from Pennsylvania (n=55) and New York (n=37); and the number of USDA audited

growers were relatively higher in these two states. The highest response rate was for

Pennsylvania with 61.1%.

48

Table 3.2

Certified Growers, Respondents, and Percentage

State Number of Surveys Mailed Number of Surveys Returned Response Rate (%)

Pennsylvania 90 55 61.1

New York 62 37 59.7

New Jersey 34 17 50.0

Maryland 13 5 38.5

Virginia 9 4 44.4

Delaware 4 2 50.0

Data analysis. Out of 120 returned surveys, four surveys were assessed as unusable for

data analysis purpose as those surveys were either incomplete or with highly skewed responses.

Therefore, 116 surveys were analyzed using statistical software IBM SPSS® version 24.

Reliability tests were performed and Cronbach’s alpha values were calculated for questions

related to growers’ challenge to comply with food safety standards. Descriptive statistical

analysis was utilized to examine the distribution of growers’ responses to each variable. Analysis

of data included calculation of frequencies and percentages of growers’ responses to individual

question. Cross-tabulations were also performed to determine the distribution of respondents by

the produce they grow, the market growers sell their produce, and source of GAP information

with respect to states. Such descriptive analyses utilized pair-wise deletion of cases.

For questions that measured growers’ challenges to implementing food safety standard

requirements on Likert-type scales, categories of “moderately challenging” and “very

challenging” combined to create a new category “moderate to very challenging.” Similarly, the

categories of “not challenging” and “slightly challenging” combined to create a new variable

“not to somewhat challenging.” Thus, the three new categories for data analysis were: (1) “not to

49

slightly challenging”; (2) “somewhat challenging”; and (3) “moderate to very challenging.” The

purpose of such combination was for the easiness of discrete data analysis and to increase the

number of count on each cell in cross-tabulation. Standards for which relatively higher

percentage (≥ 25%, a cut-off set for the study objective) of respondents indicated “moderate to

very challenging” were identified as most challenging standard requirements. The underlying

hypothesis of this study was that the growers are most likely to fail to comply with the standards

they rate as moderate to very challenging to comply. Descriptive analysis identified major GAP

barriers including barriers to perform risk assessments on the farms and major GAP information

sources.

Discrete analyses were performed that included z-test for proportional differences,

Pearson Chi-square test of association, linear-by-linear association, and non-parametric test for

correlation (Cramer’s V). In order to verify whether the most challenging standards were

consistent among the states, z-score test for proportions were performed for two states at a time.

Since the number of respondents were higher for Pennsylvania, New Jersey, and New York, z-

tests were performed specifically for these three states. In other words, z-tests of proportions

examined if the percentage of growers indicating a food safety standard as “moderate to very

challenge” was significantly differed in those three states.

The advantages of the proportional test are that: it minimizes the effect of sample size on

test statistics and assist in determining the direction of proportional difference. The assumption

of z- test statistics was that proportions were asymptotically normally distributed. The null

hypothesis under z-test was that the proportions of respondents rating a food safety standard as

moderate to very challenged was not significantly different between any two states. Pearson Chi-

square test of associations were used to examine the association between items measuring

50

growers’ challenges to meet the audit food safety standard requirements and farm commodity

type. Contingency tables were created for the food safety standards that were significantly

associated with produce type (at significant levels of .05 and .10).

GAP barriers were also tested for independence with questions on challenge to comply

with food safety requirement. Similarly, barriers to performing risk assessments were

specifically tested with questions on the challenge to comply with risk assessment standards.

Chi-square test of association does not take the ordering of the rows or columns into account.

Thus, linear by linear association values were calculated to examine linearity of relationships

taking the ordering of variables into consideration.

Furthermore, in order to test the strength of relationships between two variables

(nominal), Cramer’s V values were also calculated. All test statistics such as Pearson Chi-square

test of association, linear-by-linear association, and Cramer’s V were reported at significant level

of .05 and .10. Pairwise deletion procedure was followed for discrete data analysis.

Summary

The study adopted an across-method design to evaluate the implementation of

harmonized GAPs food safety standards on the farms of Mid-Atlantic and New York produce

farms. Produce USDA GAPs Harmonized audits were analyzed primarily as a qualitative method

to assess deficiencies in GAP compliances. On the other hand, a mail survey was administrated

as a primary quantitative method on USDA harmonized GAP certified produce growers of Mid-

Atlantic states and New York. Noncompliance to GAP standards were compared for different

states.

51

Survey questions were based on the findings from audit analysis. Survey collected

information related to challenging food safety requirements, barriers to complying with GAPs

and carrying out risk assessments, commodity type, produce marketing channels, source of GAP

information, and their intention to renew certificate annually.

Objectives 1 and 2 focused on the analysis of audits. Whereas, objectives 3 and 4 focused

on the analysis of mail surveys. Descriptive and correlational tests were utilized to analyze the

data depending on the study objectives. Correlational tests were primarily non-parametric. The

population of this study comprised of all produce growers of Mid-Atlantic states and New York

audited for field operations and harvesting harmonized food safety standards by various

certifying agencies. Results from audit and survey analysis were validated, interpreted, and

inferred to study population.

52

Chapter 4

Results

Chapter 4 presents results from the audit and survey analysis. Objectives 1 and 2 focus

audit analysis results. On the other hand, objectives 3 and 4 present mail survey analysis results.

Objective 1 identifies Good Agricultural Practices (GAPs) standards for which Corrective

Actions Needed (CAN) or Immediate Action Required (IAR) were frequently reported in

individual Mid-Atlantic state and New York. Additionally, objective 1 presents proportional

difference and risk ratios of GAP noncompliance. The overall frequency table for each standard

and state is presented in Appendix B.

Objective 2 determines the various aspects of GAP noncompliance. Instead of presenting

results separately for the individual state as in Objective 1, Objective 2 emphasizes each standard

and section of audit checklist and presents overall findings by combining audits from all the six

states. Objective 3 identifies most challenging food safety standards for growers. Whereas,

objective 4 determines obstacles to GAP implementation and carrying out risk assessments,

sources of GAP information, and growers’ intention to renew their GAP certificate annually.

53

Objective 1: Identify Areas of Frequent GAP Noncompliance Through Analysis of Produce

USDA Gaps Harmonized Audits for Field Operations and Harvesting of Mid-Atlantic

States and New York

Out of 166 farms audited for field operations and harvesting harmonized GAPs food

safety standards by the USDA in six states during 2013-14 growing season, 71 (42.8%) audits

reported at least one CAN or IAR (Table 4.1). Objective 1 focused specifically on these 71 audit

checklists to identify standards for which frequency of CANs and IARs were relatively higher.

In Virginia, none of the produce suppliers were asked to take corrective or immediate

action to meet the food safety standard requirements, therefore, not included in this study. In all

the audited farms of Maryland and around 80% farms of New Jersey required actions to comply

with food safety standards. Results are presented in an order of New Jersey, New York,

Pennsylvania, Delaware, and Maryland.

Table 4.1

Produce USDA GAPs Harmonized Audits for the Growing Season 2013-14

State Number of Audits Field

& Harvest Audits

Number of Audits with

CANs or IARs Percentage

New Jersey 36 29 80.6

New York 67 23 34.3

Pennsylvania 40 9 22.5

Delaware 6 4 66.7

Maryland 8 8 100.0

Virginia 9 0 0.0

Total States 166 71 42.8

54

Results for New Jersey

Out of 36 farm audits from New Jersey, in 29 (81%) audits at least 1 CAN or IAR was

reported. The review of audit checklists indicated that CANs were reported in all four major

sections: general questions, field production, harvesting, and transportation. New Jersey had a

relatively highest proportion of farms (n=4; 11%) that failed to pass the audit. In three of those

four farms that failed to pass the audit, auditors observed noncompliance related to field

production food safety standards that posed imminent food safety risks. Analysis of audits

indicated that, for a single farm operation or a audit in New Jersey, the highest number of

reported CANs and IARs was 25.

For general questions section, in 24 farm operations (66.67%), noncompliance was

reported for the standard 1.4.3, which requires that the subcontractors are held to the relevant

food safety standards. Review of auditors’ comments for this standard showed that the majority

of farms had no documentation or records indicating subcontractors were held to the same food

safety standards as the farm employees. The next most frequent noncompliance (f=6; 16.67%)

under general questions were for the standard 1.5.4, which requires farms to have written policy

on water testing procedures and actions that need to be taken based on water testing results.

As can be seen in Figure 4.1, the highest number of violations for field production

practices in New Jersey was reported for standard 2.2.9 (f=9; 25%). Standard 2.2.9 mandates a

glove use policy be in place if gloves are used by the workers in field production. However,

corrective actions were recommended for the violations of standard 2.2.9 because auditors

observed workers using gloves in the field and the farm glove use policies did not provide

information regarding usable gloves and glove suppliers. In addition, CANs were also required

for standards related to vehicles, equipment, tools and utensils. For example, CAN frequency for

55

both 2.7.1 and 2.7.2 was 4 (11%). On those farms, auditors found no records listing equipment

and items used for harvesting, and/or records indicating farm equipment, vehicles, and utensils

were in good repair.

IAR Standard 2.2.2 2.2.5 2.2.6 2.7.5 2.2.15

f 1 1 1 1 2

Figure 4.1. CAN and IAR frequency chart for field production

Regarding agricultural water, in three farms there were no water management plans or

records indicating testing procedures were in compliance with the policy. As mentioned earlier, 3

farms failed to pass the audits because auditors assessed violations to field production standards

requirements that posed imminent food safety risk. In two separate farms, auditors reported

violations regarding standard 2.2.15 as they observed food handlers eating, spitting, drinking, or

smoking near harvested produce increasing the risk of produce contamination. In both the cases,

auditors asked farm operators to take immediate actions to prevent the risk of produce

contamination.

0

2

4

6

8

10

2

1 1 1 1 1

9

1

2

3

2

1 1

2

1

2

1

2

3

2

4 4

3

1

3

2

Standards

CAN and IAR Frequency of Standards for Field Production

n=36

56

The number of food safety standard violations reported under harvesting was relatively

low when compared to field production and general questions. In three farms, auditors noticed

farm operations were noncompliant with written policy regarding storage of harvesting

containers (standard 3.31). Containers were stored in areas, which were not designated for

containers as per the policy. Standard 4.1.1 was violated more frequently (f=5; 14%) on the

farms of New Jersey compared to other standards related to transportation. Standard 4.1.1

requires farm operations to have written policy and procedures and a checklist to verify

cleanliness and functionality of shipping units. However, those five farms had no records or

written procedures to comply with 4.1.1.

Summary for New Jersey

Results from New Jerseys showed that under the general question category, questions

were related to food safety standards for subcontractors were violated relatively on more farms

(Table 4.2). Workers glove use policy was the standard next to policy for subcontractors where a

relatively higher number of farms fail to comply with the requirement. The other standards

where corrective actions were more frequently required on the farms of New Jersey were related

to water testing procedures and having a policy on cleanliness and functionality of shipping

units.

57

Table 4.2

Frequency of CAN and IAR by standards for New Jersey (n=36)

General Questions Field Production Harvesting Transportation

Standard f Standard f Standard f Standard f

1.3.1 1 2.1.1 2 3.3.1 3 4.1.1 5

1.4.1 2 2.2.2* 1 3.3.3 1 4.1.3 2

1.4.2 1 2.2.5* 1 3.4.1 1

1.4.3 24 2.2.6* 1 3.4.2 1

1.5.1 1 2.2.7 1 3.4.4 1

1.5.2 2 2.2.8 1 3.4.7 1

1.5.4 6 2.2.9 9 3.5.1 2

1.6.1 2 2.2.11 1 3.5.2 1

1.6.2 2 2.2.12 2

1.7.1 2 2.2.14 3

1.8.1 2 2.2.15* 2

1.9.1 2 2.2.16 1

2.2.17 1

2.2.21 2

2.3.4 1

2.4.2.1 2

2.4.3.1 1

2.4.3.2 2

2.4.3.3 3

2.5.2 2

2.7.1 4

2.7.2 4

2.7.3 3

2.7.4 1

2.7.5* 2+1

2.7.6 2

Note. *Indicates standards with reported IAR.

58

Results for New York

Produce USDA GAPs harmonized audits were reviewed to identify the most frequently

violated GAPs harmonized food safety standards in New York for the growing season of 2013-

14. Out of 67 audits, in 23 (34.3%) at least 1 CAN was reported. The frequency was relatively

higher for 1.4.3 (f=4; 6%) among the requirements under general questions (Table 4.3), but

significantly less frequent than farms of New Jersey. In three farms auditors asked growers to

take corrective actions as there were no records indicating farm personnel received food safety

training required as per 1.4.1.

Under field production section, the highest number of CANs and/or IARs were reported

for 2.2.5, 2.2.13 and 2.7.1, with a frequency of three for each standard (Table 4.3). Standard

2.2.5 requires that toilet and washing stations be maintained in a clean and sanitary condition. In

three farms, corrective actions were needed to comply with the requirements of 2.2.13, which

needed farm operations to have a policy on using of hair covering. Similarly, on three farms

auditors found no lists identifying equipment, vehicles, tools, utensils and other items that may

pose a produce contamination risk (standard 2.7.1).

Results showed that two farms failed to pass the audits where IARs were reported as

auditor observed noncompliance to standards 2.2.5 (f=1) and 2.2.17 (f=1). Standard 2.2.5 focuses

on proper maintenance of toilet and wash stations and 2.2.17 ensures availability of drinking

water for field employees. Moreover, those were the same farms with a maximum count of

CANs (f=7) for any single audited farm of New York.

As can be seen in Table 4.3, the CAN frequency was two for standards: 3.3.1, 3.4.1,

3.4.4, and 3.4.7 under the category of harvesting. Noncompliance with 3.3.1 and 3.4.1 was

because farm operators had no written policy regarding storage of harvest containers (standard

59

3.3.1) and managing damaged or decayed produce (standard 3.4.1). Standard 3.4.4 focuses on

cloth use policy to clean produce and whereas, 3.4.7 requires a written policy on packing

material contacting soil. On the other hand, 4.1.1 was the standard for which the frequency of

CAN was relatively higher (f=5) than any other standard in any category in the New York audits.

Standard 4.1.1 requires farm operations to have a policy, written procedures, and a checklist to

verify cleanliness and functionality of shipping units.

Table 4.3

Frequency of CAN and IAR by Standards for New York (n=67)

General Questions Field Production Harvesting Transportation

Standard f Standard f Standard f Standard f

1.1.3 2 2.2.5 2+1* 3.1.1 1 4.1.1 5

1.2.2 1 2.2.7 2 3.3.1 2

1.4.1 3 2.2.9 1 3.3.3 1

1.4.3 4 2.2.12 1 3.4.1 2

1.5.2 1 2.2.13 3 3.4.4 2

1.8.1 1 2.2.17 1* 3.4.7 2

1.9.1 1 2.3.4 2 3.5.1 1

2.4.1.1 1

2.4.1.2 1

2.4.2.1 1

2.4.3.2 1

2.4.3.3 1

2.5.2 1

2.6.2 1

2.7.1 3

2.7.2 2

2.7.6 2

Note. * Indicates reporting of IAR.

60

Summary for New York

The number of GAPs harmonized audited farms were less in New York than New Jersey.

In New York, around 34% of the audited farm operations, corrective actions were required to

meet the harmonized food safety standards. For the audited farms of New York, the most

frequently violated standards were 4.1.1 and 1.4.3. In other words, five out of 67 farms were

required to take corrective actions to ensure cleanliness and functionality of shipping units

(4.1.1) whereas in four out of 67 farms corrective actions were required farms to have a policy

on subcontractors’ compliance with farm food safety policy (1.4.3).

Results for Pennsylvania

Out of 40 farm audits from Pennsylvania, 7 (18%) corrective actions were required. None

of the audited farms in Pennsylvania for the growing season 2013-14 required immediate action

to comply with standards or failed to pass the audit. All the audited farms during that year were

in compliance with GAPs harmonized food safety standards acceptance criteria to pass the

audits. In other words, all the 40 audited farms meet the USDA acceptance criteria for GAPs

harmonized certification. For the seven audits where at least one CAN was reported, the highest

number of CANs identified from a single farm operation of Pennsylvania was six.

As can be seen in Table 4.4, the highest number of CANs for a single standard was

reported for 2.7.2 (f=3), which refers to a good condition of farm equipment, vehicles, tools, and

utensils that come into contact with produce. Such violations were primarily because of use of

wooden bins. The frequency of CAN for each food safety standards 1.9.2 and 2.4.1.1 was two. In

those cases, auditors asked growers to have procedures for self-audits (1.9.2) and have a written

description of the water system and its flow available on the farms (2.4.1.1). The CAN frequency

for other standards listed in Table 4.4 was one.

61

Table 4.4

Frequency of CAN and IAR by Standards for Pennsylvania (n=40)

General Questions Field Production Harvesting Transportation

Standard f Standard f Standard f Standard f

1.4.3 1 2.2.15 1 3.2.5 1 4.1.1 1

1.8.1 1 2.2.21 1 3.3.4 1

1.9.1 2 2.3.3 1

2.4.1.1 2

2.4.1.3 1

2.4.3.1 1

2.7.2 3

Summary for Pennsylvania

Results showed that the majority of the audited farms required no corrective action to

comply with field operation and harvesting harmonized food safety standards. However, on the

farms (n=7) where corrective actions were required, the most frequently violated standard was

2.7.2, which is related to maintenance of farm equipment, vehicle, utensils, and tools.

Results for Delaware

Out of six farm audits from Delaware, in four (67%) audits corrective actions were

required to meet the GAPs harmonized food safety standards. The frequency of standards where

corrective actions was required for a single farm operation ranged from five to 32 CANs. Two

out six farms failed to pass the audits, where IARs were reported for noncompliance to standards

2.2.6 and 2.2.15. Table 4.5 shows the list of GAPs harmonized standards and corresponding

CAN and IAR frequency identified from four audits. A single audit with 32 CANs and two IARs

contributed to the majority of standard noncompliance presented in Table 4.5.

62

Table 4.5

Frequency of CAN and IAR by Standards for Delaware (n=6)

General Questions Field Production Harvesting Transportation

Standard f Standard f Standard f Standard f

1.1.1 1 2.2.2 2 3.3.1 1 4.1.1 1

1.1.2 1 2.2.6* 2 3.4.4 1 4.1.3 1

1.2.1 1 2.2.9 2 3.4.6 1

1.3.1 1 2.2.10 3 3.4.7 1

1.3.2 1 2.2.11 3

1.4.1 1 2.2.12 1

1.4.2 1 2.2.14 2

1.4.3 2 2.2.15* 1+1

1.5.2 2 2.2.16 1

1.5.4 2 2.2.21 1

2.3.5 1

2.4.2.1 1

2.4.3.1 1

2.4.3.2 1

2.4.3.3 1

2.5.1 1

2.5.2 2

2.6.1 1

2.6.2 1

2.7.1 2

2.7.2 1

2.7.3 1

2.7.4 2

2.7.6 2

Note. *Indicates reporting of IAR.

63

The CAN and IAR frequency for most of the standards were either one or two, except for

2.2.10 and 2.2.11 (f=3). Standard 2.2.10 and 2.2.11 are related—and address protective cloth use

policy and storage of protective clothing and tools, respectively. For standards 1.4.3, 1.5.2, 1.5.4,

2.2.2, 2.2.6, 2.2.9, 2.2.14 2.5.2, 2.7.1, 2.7.4, and 2.7.6, the frequency of CAN and IAR was two;

and the noncompliance was largely for field production related requirements.

Summary for Delaware

Relatively fewer farms were audited in Delaware for the 2013-14 growing season.

Noncompliance with a majority of standards on the audit checklist from a single farm

significantly contributed to the overall findings from Delaware. Noncompliance was relatively

frequent (f=3) for standards 2.2.10 and 2.2.11 that ensure protective clothing be maintained and

stored properly. IARs were reported for 2.2.6 and 2.2.15.

Results for Maryland

In total, eight redacted harmonized GAP audits were accessed for Maryland and

analyzed. Results showed that out of eight audits, in six (75%) at least for one standard,

corrective action was required. In none of the audits from Maryland IAR was reported. The

number of food safety standard violations for a farm operation ranged from one to five. In three

out of eight farms, corrective actions were needed for farms to comply with the requirement of

the standard 1.8.1, which requires produce suppliers to document corrective action procedures

(Table 4.6).

In two audits, the auditors observed noncompliance with standard 2.4.3.2, which requires

farms to test water as directed by the water risk assessment plan and the prevailing regulation for

the commodity. Noncompliance regarding the written policy on water testing was because farm

64

operations tested irrigation water from wells annually and surface water bi-annually. Similarly,

two farms were noncompliant to 2.7.4, which addresses taking preventive measures to control

physical hazards.

Corrective actions were also required for standards related to harvesting. Such

noncompliance was due to absence of written policies for damaged and decayed produce (3.4.1),

no specific written procedures for harvesting of produce that contacted with the ground (3.4.2),

and procedures did not include the addressing of and removal of physical hazards (3.4.3).

However, frequency of CAN for such noncompliance was one.

Table 4.6

Frequency of CAN and IAR by standards for Maryland (n=8)

General Questions Field Production Harvesting Transportation

Standard f Standard f Standard f Standard f

1.2.2 1 2.2.4 1 3.4.1 1 4.1.1 1

1.6.2 1 2.2.15 1 3.4.2 1

1.8.1 3 2.2.21 1 3.4.3 1

2.4.3.2 2

2.7.2 1

2.7.4 2

Summary for Maryland

In higher percentages of audited farms (75%) of Maryland, corrective actions were

required and in none of the farms immediate actions were required to comply with the food

safety standards. Standard 1.8.1 was the most frequently violated standard in Maryland that

requires documentation of corrective actions. The highest number of CANs for a farm was five.

Under the major category of field production, two produce suppliers were not in compliance with

2.2.3.2 and 2.7.4.

65

Proportional and Risk Ratio Tests

Proportional and relative risk (risk ratio) tests were performed to examine if reporting of

noncompliance to food safety standards statistically differ among states and also to determine the

strength of the association between those two variables. As can be seen in Table 4.7, the

proportional differences for three sections such as 1.4, 2.2, and 2.7 between New Jersey and New

York were statistically significant. In other words, the proportions of farms where

noncompliance were reported related to worker education and training, their health and hygiene,

farm equipment and other tools used for field production were significantly higher for New

Jersey compared to New York. However, no significant difference was observed in the

proportion of farms between those two states regarding noncompliance with standards related to

equipment sanitation and maintenance.

Table 4.7

Proportional Difference Test Table

Questions Section

New

Jersey

New

York

Proportional

Difference z

Score

p

Value

n1𝜋1 n1 n2𝜋2 n2 𝜋1- 𝜋2

Worker Education and

Training 1.4. 24 36 6 67

0.58 6.15 0.00*

Workers

Health/Hygiene and

Toilet/Hand Washing

Facility

2.2. 11 36 7 67

0.20 2.56 0.011*

Vehicles, Equipment,

Tools and Utensils 2.7. 15 36 5 67

0.34 4.18 0.00*

Equipment Sanitation

and Maintenance 4.1 6 36 5 67

0.09 1.44 0.15

Note. n1𝜋1 ≥ 5 and n2𝜋2 ≥ 5

*p <.05

66

Results from risk ratio tests showed that the chances of observing noncompliance to

standards related to worker education and training were significantly greater in New Jersey than

Pennsylvania (z=3.30, p<0.05) and New York (z=4.93, p<0.05) (Table 4.8). On the other hand,

when farms were compared between Pennsylvania and New York, the ratio was not significant.

Regarding standards related to sampling and testing, it was almost 13 times more likely to

observe noncompliance on the farms of New Jersey than in New York (Table 4.9).

Table 4.8

Worker Education and Training (Section 1.4)

Note. “+” indicates count noncompliance, “-” indicates count of compliance

* p <.01

Table 4.9

Risk ratio table for Sampling and Testing (Section 1.5)

Note. “+” indicates count noncompliance, “-” indicates count of compliance

Farm operations were compared regarding their noncompliance with standards related to

workers’ health and hygiene, and toilet and handwashing facility (section 2.2) and vehicle,

equipment, tools, and utensils (2.7). The results showed that for both the sections, the likelihood

State + - PA NY

Risk

Ratio z p CI

Risk

Ratio z p CI

NJ 24 12 26.67 3.30 0.00* 3.80 - 187.26 7.44 4.93 0.00* 3.35 - 16.53

PA 1 39 0.28 1.20 0.23 0.04 - 2.24

NY 6 61

State + -

NY

Risk Ratio z p CI

NJ 7 29 13.028 2.45 0.01 1.67 - 101.79

NY 1 66

67

of observing noncompliance was greater on the farms for New Jersey than on the farms of

Pennsylvania and New York. As can be seen in Table 4.10, the likelihood of observing

noncompliance with worker health and sanitation facility standards on the farms of New Jersey

was 12 times more than Pennsylvania and two times more than New York. Similarly, it was

approximately 5.5 and 3.6 times as likely to observe noncompliance with the standards related to

vehicle, equipment, tools, and utensils on the farms of New Jersey than Pennsylvania and New

York, respectively (Table 4.11).

Table 4.10

Workers Health/Hygiene and Toilet/Hand Washing Facility (Section 2.2)

Note. “+” indicates count noncompliance, “-” indicates count of compliance

Table 4.11

Vehicles, Equipment, Tools and Utensils (Section 2.7)

Note. “+” indicates count noncompliance, “-” indicates count of compliance

* p <.01

State + - PA NY

Risk

Ratio z p CI

Risk

Ratio z p CI

NJ 11 25 12.22 2.46 0.01 1.66- 90.04 2.93 2.46 0.01 1.24 - 6.89

PA 1 39 0.24 1.36 0.17 0.031 - 1.87

NY 7 60

State + - PA NY

Risk

Ratio z p CI

Risk

Ratio z p CI

NJ 15 21 5.56 2.91 0.00* 1.75-17.63 5.58 3.63 0.00* 2.21- 14.12

PA 3 37 1.01 0.01 0.99 0.25- 3.98

NY 5 62

68

Objective 2: Describe the Aspects of Field Operations and Harvesting Harmonized Food

Safety Standards and Criteria of Noncompliance

General Questions

Management responsibility. Standards on management responsibility were to ensure

that farm operations have a food safety policy in place, designated an individual with a primary

responsibility of implementing the plan, and also have a policy describing disciplinary actions

for food safety policy violations. Results showed that all the audited farm operations had a food

safety policy. Review of auditors’ comments provided multiple criteria of noncompliance with

management responsibility standards. They were as follow:

1. Food safety plan was not signed by senior management.

2. Management responsibility standard requires a 24-hour contact information of persons

responsible for food safety emergencies and provide resources needed to implement and

maintain the food safety plan. The written policy did not include provision for the

absence of key personnel on the farms and did not contain resources needed to implement

food safety plan on the farm.

3. Incomplete documentation of policy outlining disciplinary actions for personnel violating

food safety policies.

Food safety plan. The two standards under food safety plan focus on three aspects of

compliance. These aspects are: (1) identification of farm locations and products, (2) plan should

address all sort of hazards and preventive measures, and (3) periodic review of food safety plan

and documentation of procedures. Results from audits revealed that noncompliance was related

to keeping records showing annual review of the plan, documenting plan review process, and the

inclusion of potential food safety hazards and controlling measures.

69

Documentation and recordkeeping. Standards under the category require farm

operations to document and keep records for each food safety standard requirements, keep them

readily accessible, and also retain them for a minimum of two years. Violations of these

standards were because documents were not available for inspection or records were missing.

Worker education and training. Standards related to training and education ensure

personnel not only should receive food safety training, but also the training should be adequate to

their work responsibility, including the sub-contractors (if applicable for the operations). In other

words, standards confirm farm personnel training and adequate training. As described in

objective 1, education and training of workers was the area where numerous deficiencies were

reported. Records are the only evidence to ensure workers and subcontractors have received

adequate food safety training. However, review of audits showed that irrespective of workers

receiving of food safety training or not, corrective actions were proposed as the farm operations

were unable to present training records of their farm personnel at the time of inspections,

particularly for subcontractors.

Sampling and testing. The requirements under the section of sampling and testing focus

on four aspects. These aspects were: (1) a written sampling protocol for microbial testing, (2)

keeping of all test results, (3) documentation of testing procedures, and (4) actions to be taken

based on test results. In order to increase the credibility of test results, GAPs harmonized

standards requires tests should be performed in Good Laboratory Practices (GLP) certified labs.

Results showed the absence of sampling protocol, testing procedures, and post-test actions were

the criteria of noncompliance.

Traceability. The food safety standards related to traceability programs focus on two key

aspects, documentation of traceability program and a successful performance of a trace back and

70

trace forward exercise at least annually. Violation of documentation requirement was either due

to no traceability program in place or inconsistency in documentation and actual practice. For

example, an auditor stated that:

“Food Safety manual states index cards will be attached to pallets to enable traceability.

Auditee states nothing is kept with the product, …is told where the product is from when

it's delivered.”

Violations of trace back and trace forward exercise were due to farm operations having no

records indicating the exercises were performed.

Corrective actions. This standard requires farm operations to document corrective

actions as well as keep records as evidence to show what procedures were performed to comply

with the respective food safety standards. Review of comments to corrective actions showed that

operations had no written policy on corrective actions or incomplete documentation, or no

records were available showing corrective actions were taken.

Field Production

Field history and assessment (2.1). This standard ensures that farm operations should

carry out an assessment of adjacent land use or land use history and documented. Violations of

the standard on the two farms were primarily because risk assessments of land use were not

performed.

Worker health/hygiene and toilet/handwashing facilities (2.2). This is one of the most

important section of GAPs harmonized standards that covers multiple aspects of food safety

practices. These practices and standards are linked with works’ health and their hygienic

practices in the field, toilet and hand washing facilities on the farms, and their maintenance.

71

Corrective actions or immediate actions are required when farm operation have no policy or non-

adherence with the policy.

2.2.2. This policy requires farm employees as well as the visitors which include the

contractors and auditors in the field to comply with established hygienic practices. The reported

violations to the standard were due to non-compliance by the farm employees and the failure of

operations to reinforce the policy on farm visitors (including the auditors).

2.2.5. The sanitation standard requires farms to maintain the cleanliness and sanitation of

toilet and hand washing facilities. Noncompliance was related to maintenance of hand washing

facilities such as no wash water, no paper towel, or no hand washing soap, and water leakage

from basin.

2.2.9. This standard warrants farm operations to have a glove use policy if workers

should use gloves in the fields. As described in objective 1, violation to 2.2.9. was reported in 12

separate farms. Audits from those 12 farms were reviewed to study the various aspects of the

violations to glove use policy. Glove use policy is required to describe “how and when gloves

are to be used, cleaned, replaced and stored.”

Farm operations had either no glove use policy or the policy was incomplete. Auditors

also observed inconsistencies between the glove use policy and compliance by the workers. For

example, employees were wearing gloves, while there was no glove use policy available for

review. In a few cases, the policy did not specify the use and storage of gloves and workers used

reusable gloves whereas the policy required single use gloves.

72

2.2.10. This standard requires protective clothing to be managed in a way that to avoid

food products from the risk of contamination. The farm had no policy on maintenance of

protective clothing including gloves.

2.2.11. Under this policy, farm operations are required to designate an area for storage of

protective clothing. Corrective actions were required when auditors observed no specified

storage area. In one case, auditors observed worker take harvest knives home after the work day.

2.2.12. This standard requires workers to comply with company policy and regulation on

wearing or bringing personal items into production areas. However, the reported violations to

this standard were either due to the company had such policy or the worker did not comply with

the policy.

2.2.13. This policy entails company employees to comply with the policy on hair

covering. However, noncompliance with the standard was due to no such policy regarding hair

coverings.

2.2.14. Companies should have a policy on the storage of worker’ personal belonging and

their compliance with the policy. Auditors’ observations showed that the majority of such

violations were because workers’ non-compliance with the policy on storing personal belonging

at a designated storage area rather than not having a policy on this. In this case, it could be

argued that not having a policy on storage was not a problem on the farms, but workers’

compliance with the food safety policy was a concern.

2.2.15. This standard ensures workers in fields comply with hygienic practice policy that

restricts practices such as smoking, chewing, eating, drinking, urinating, defecating or spitting in

the field. Policies were in place. However, CANs were reported for signs of non-compliance of

the policy by the farm workers in the field.

73

2.2.16. Company policy should specify a break area situated at a place not posing a food

safety risk. The auditors observed that the break area was in the production areas and more

importantly violations were because employees violated policy related hygienic practices

(standard 2.2.15), increased the risk of the produce being contaminated with such practices.

2.2.17. Drinking water should be made available and easily accessible to farm personnel.

In addition, drinking water should meet drinking water standards. Produce suppliers had either

incomplete policy or they did not comply with the drinking water policy. In other words, auditors

observed that the drinking water policy did not state the source of water and sanitation

procedures for utensil used for drinking. In the other case, the water which was made available

for employees was assessed as non-potable.

2.2.21. This standard requires farm operations to make a first-aid kit accessible to farm

employees. The violations regarding the standards were reported as there were no first-aid kits

available in the field or in the vehicles used for farm operations and farm workers were unaware

of the location of the first-aid kit.

Agricultural chemicals/plant protection products (2.3). The food safety standards

under the category of agricultural chemical address various aspects of chemical use on farm

fields. Review of auditors’ observations showed that corrective actions were required for

violations in four areas such as the use of the chemical by uncertified personnel, incomplete

policy, no written procedures for chemical disposal, and non-compliance with the water use

policy. The incomplete water use policy applies to water use policy that did not clarify the source

of water. On the other hand, non-compliance with water use policy refers to cases where even

though the water testing results were inconsistent with the policy, water was still used for the

chemical application.

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Agricultural water (2.4). Water system description (2.4.1). The standards related to

water system description require farm operations to have a description of the entire water system,

the source of water should be in compliance with accepted regulations, and ensure that water

used in agriculture purpose is not in any way cross-connected with system carrying human

waste. Violations of this standard were related to (1) absence of description of the water system,

(2) incomplete description of the water system, and (3) water from well tested for the presence of

Coliform.

Water system risk assessment (2.4.2). Farm operations should carry out and document an

initial risk assessment of water resources including types of crops and method of water

application. Audits revealed that violations were related to three key aspects: (1) no water system

risk assessment carried out by the company, (2) no record showing initial risk assessment, and

(3) risk assessment did not address potential food safety hazards.

Water management plan (2.4.3). The standards under water management plan call for

farm operations to have a written plan documenting risk mitigating procedures, water testing

procedures, and moreover, compliance with the water testing procedures as described in the

water management plan. The reported violations in relationship to the risk mitigating plan were

due to the farm operations had either no water risk mitigating plan or the plan did not address all

assessment measures.

Regarding water testing procedures, noncompliance was due to the absence of water

testing procedures at farms or the procedures were not comprehensive, including in a couple of

cases, the frequency of water testing annually was not adequate. Similarly, corrective actions

were also reported to address the food safety standard related to implementing water testing

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program as there was no testing program (water management plan) or implementation of testing

program was not consistent with the plan.

Animal control (2.5). Food safety standards under the category of animal control

identify domestic and wild animal activities in the field and adjacent field as a food safety risk.

The standard requirement is that farm operations to comply with three key aspects of animal

control such as: (1) having a written assessment of animal activity, (2) routinely monitoring and

recording of animal activities, and (3) taking preventing or corrective actions to reduce the risk

of food contamination due to animal activities.

Documentation of corrective actions or preventing measures were violated in none of the

farms of Mid-Atlantic states or New York. However, the corrective actions were required in two

areas of animal control measures that included no written risk assessment and monitoring

schedule and no records for animal activities in and around the field. In other words,

noncompliance with monitoring of animal activities was due to either farms had no records

showing animal activities were routinely monitored or the records were not consistent with the

monitoring schedules.

Soil amendments (2.6). The requirements under soil amendments address the food safety

risks associated with handling and managing of animal-based amendment and soil amendments

with raw or incomplete treated manures. Both standards require farm operations to maintain

records showing the use of soil amendments were in compliance with prevailing regulations.

Results showed that absence of records showing compliance and incomplete records were two

criteria for noncompliance.

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Vehicles, equipment, tools and utensils (2.7). This is another section under the major

category of field production with six sub-sections, where noncompliance was relatively more

frequent. Auditors’ observations were reviewed to assess all aspects of such noncompliance.

2.7.1. The standard entails farm operations to develop a list identifying all farm

equipment, tools, vehicles, utensils and other items that might pose a food safety risk. Corrective

actions were primarily required in those farm operations having no such list identifying farm

equipment or the lists were incomplete.

2.7.2. This standard requires the listed items under the sub-section of 2.7.1, which come

in contact with produce, should be maintained in good repair so that they would not become a

source of produce contamination. Farm operations are also required to maintain records as a

proof of compliance with the standards. Results showed required corrective actions in 11 farms,

one of standards with a major noncompliance concern.

Auditors’ comments were evaluated to determine the basic themes for classification of

violations. Those themes were as follows:

(1) No records were available on the farms showing compliance with the policy;

(2) Records were incomplete, for example, operation logs had no entries;

(3) No policy on cleaning and maintenance of certain farming items, for example, farm

operation policy did not address how frequently trucks and knives were cleaned;

(4) Farm equipment was not in good repair condition; and

(5) Improper use of equipment or utensils by the workers posed food safety threat (lack

of proper food safety assessment). For example, use of crates and wooden bins on the

farms were assessed by the auditors a food safety threat as wooden bins could not be

sanitized or farm utensils were used by workers for personal belongings.

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2.7.3. and 2.7.4. These two standards address the risk of produce contamination due to

chemical and physical hazards mainly from glass and brittle plastic, respectively, by farm

equipment, vehicle, tools and other items. All the comments to the violation of standard on

chemical hazards showed that farm operations had no policy stating the sanitation and storage

procedures of farm equipment, especially the knives. On the other hand, violations of the

standard on physical hazards were reported as auditors observed noncompliance with glass and

brittle plastic policies. For example, harvest vehicle had shattered and cracked windows on a

farm operation and was assessed as a source of physical hazard and evidence of noncompliance.

2.7.5. The standard requires sanitizing and cleaning procedures should not pose a food

safety risk by using potable water and avoiding cleaning and sanitizing procedures near food

products and farm equipment. The number of farms where violations were reported to this

standard was relatively low compared to other food safety policies under vehicle, equipment,

tool and utensils. However, in few cases where corrective actions were required, the review of

auditors’ comments revealed that the sanitizers or soaps used for sanitizing or cleaning were not

labeled as approved for contact with food surface.

2.7.6. This standard entails farm operations to have a written water tank cleaning policy

as well as compliance with the policy. Corrective actions were needed for having a written policy

and to comply with the policy. However, in majority of the cases, the companies had no written

procedures for cleaning the water tanks that included hand washing reservoirs and fertilizer

tanks.

Harvesting

Pre-harvest assessment and water/ice. The major section harvesting covers food safety

practices related to pre-harvest assessment, use of water and ice, containers, bins and packaging

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materials, field packaging and handling, and postharvest handling and storage. Almost all the

audited farms of Mid-Atlantic states and New York were in compliance with the standards on

pre-harvest risk assessment and policy on water and ice use. In other words, review of audits

showed that all the audited farms performed a pre-harvest risk assessment on their farm as per

food safety plan and documented the procedures. There was one farm where corrective actions

were required since there was no documentation showing the assessment had been performed.

The policies on water and ice use for produce address multiple aspects of food

contamination. First and foremost, the operation should have a water use Standard Operating

Procedures (SOPs) showing: water that comes in contact with produce should meet potable water

quality standards; in cases where water is re-circulated, it should be treated with approved

antimicrobial; proper maintenance of water-delivery system; and if product is susceptible to

microbial infiltration, the SOP should also report monitoring of temperature of water used to

wash produce.

Corrective actions for the violation of standards related to water and ice use for produce

were not reported on the farms, except for one farm, where the company’s SOP did not address

monitoring of water temperature for produce, which was susceptible to microbial infiltration.

Containers, bins and packaging materials. The food safety standards regarding the use

of containers, bin and packaging material on the farms cover four key areas that could cause

produce contaminations. Those four areas are storage of containers, inspection of containers,

criteria for acceptable containers, and restriction of the use of harvesting containers for other

purposes.

Policies were violated relatively more on the farm in the area of storage of containers

than the other three areas. Policy on storage of harvesting containers requires farm operations to

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have written policy on storing containers at an appropriate area. Review of auditors’ corrective

action comments showed that violations were majorly due to non-compliance with the written

policy and in a couple of cases there was no written policy citing storage areas for harvesting

containers. For example, citing CAN for non-compliance to storage standards, an auditor

commented as:

“policy states harvest containers will be stored off the ground and within the confines of

a pest control program. Bins are stored outside directly on the ground.”

In none of the farms of the Mid-Atlantic states and New York, corrective action was

required to comply with the standards on inspection of harvesting containers as farm operations

had container inspection policy in place and containers were maintained appropriately as per the

policy. Policy regarding the use of acceptable harvesting containers also needs a written policy

on types of containers appropriate for the product and on-farm compliance with the policy.

However, the violations were only reported for not having a written policy in place. On the other

hand, regarding the policy of prohibiting the use of harvest containers for other purposes all the

audited farm operations had a written policy except one.

Field packaging and handling. The seven requirements under the section of field

packaging and handling address issues related to decayed produce, harvesting of produce

contacting soil, assessing and removal of physical hazards, produce cleaning material, packaging

materials, storage of packaging, and policy on packing materials contacting soil. The standard on

the harvesting of decayed or culled produce focus on three aspects: (1) a written policy showing

that decayed produce is not harvested, (2) employees’ training, and (3) compliance with practice.

However, all the reported violations were related to the absence of a written policy citing

decayed produce should not be harvested or culled. Policy on the harvesting of non-root crop

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contacting soil also requires a written policy, employee training, and compliance. Similar to the

violations of policy on decayed produce, corrective actions were also required when there was no

written policy on the procedures to be followed when on non-root crops come into contact with

the ground.

3.4.3. The standard requires farm operations to develop procedures to inspect and remove

physical hazards from fields. The only violation reported on the audits showed that farm

operation had no such procedures to address detection and removal of physical hazards.

3.4.4. The standard on the use of cleaning materials requires farms operations to have

procedures to reduce cross contamination if clothes, towels, or other cleaning materials are used

to wipe produce. Corrective actions were required in farms to have a policy on the type and

procedure on the use of cleaning materials such as cloths and paper towels. For example, paper

towels were used to wipe produce, and there was no policy stating paper towels were acceptable

and the procedure to prevent cross-contamination.

Packaging materials. In none of the farms, auditors observed the packaging materials

were either inappropriate or unsuitable for product increasing the food safety risk. In one

occasion noncompliance was observed, where the wooden crates were stored in a manner that

was assessed to increase the risk of food contamination.

Deficiencies were observed for policy on permitting packing material to contact with soil.

The standard requires farm operations to have written policies on whether or not packing

materials are permitted to come in contact with the ground, and also workers on the farm should

comply with the policies. Auditors’ observations to the standard were reviewed and the finding

showed that in all the cases where corrective actions were required had no written policies on

whether packing materials were allowed to contact with the ground.

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Post-harvest handling and storage. The standards under the section of post-harvest

handling and storage address three key aspects of food safety: (1) post-harvest handling, (2)

cleanliness and maintenance of materials, and (3) storage. Employees should be in compliance

with the written policy on the safe handling of harvested produce ensuring that handling manner

does not result in contamination. Corrective actions were required when auditors assessed that

employees’ food handling behaviors as the potential source of produce contamination. In other

words, employees’ noncompliance to the harvest handling policy was the only reason for the

violation.

The two other aspects of food safety require the farms to have a policy on proper

cleaning, sanitized, and maintenance of material that come in contact with harvested produce and

storing of harvested produce in a separate area away from chemicals used for other farm

practices. Review of audits revealed that almost all the audited farms of Mid-Atlantic and New

York were in compliance with the policies on cleanliness and maintenance of materials and

storage of harvested produce, except in one case where employees used harvest baskets for

carrying personal belongings and therefore, corrective action was required.

Transportation (Field to Storage or Packinghouse)

Three food safety standards under the major category of transportation exclusively

emphasize maintenance and sanitation of farm equipment. The standards for cleanliness of

shipping unit require operations to have written procedures and verification checklist for

cleanliness and functionality of shipping units including maintenance of refrigeration units. As

stated in objective 1 of the study, a relatively large number of cases of noncompliance was

reported for the standard on cleanliness and functionality of shipping units. Such noncompliance

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was due to no written cleaning or maintenance procedures, records (checklist) of compliance

with procedures or both. For example, one observation on the farm states:

“operation uses designated trucks to transport product from field to storage, but does

not have written procedures or records to verify cleanliness and functionality of those

shipping units.”

During the auditing process, in none of the farms, the auditors assessed the unloading and

uploading procedures increased the chances of causing damage to the produce and infiltration of

the microbes to the damaged produce. Standard on trash handling and transporting require farm

operations to develop trash handling and transporting procedures in such a way that that the

procedures followed on the farm do not pose food safety risk. The absence of trash handling and

transporting procedures and more importantly, noncompliance with the procedures were found to

be the primary reasons for reported CAN.

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Objective 3: Identify the Challenging Harmonized GAP Audit Standards for Growers of

Mid-Atlantic States and New York Using Mail Survey

Response Rate

The Table 4.12 presents the number of produce growers from each Mid-Atlantic state and

New York who responded to the mail survey. The highest number of respondents were from

Pennsylvania (n=53, 45.7%). Next to Pennsylvania was New York (n=35, 30.2%) and New

Jersey (n=17, 14.7%), respectively. Returned surveys from each of those three states were more

or less in proportion to the number of surveys mailed to produce USDA harmonized GAP

certified grower in those respective states. Respondents from the states of Maryland, Virginia,

and Delaware constituted 9% (n=11) of the total number of respondents.

Table 4.12

Certified Growers, Respondents, and Percentage

State Respondents Percentage

Pennsylvania 53 45.7

New York 35 30.2

New Jersey 17 14.7

Maryland 5 4.3

Virginia 4 3.4

Delaware 2 1.7

Total 116 100%

Characteristics of Produce Survey Respondents

Produce type. Table 4.13 shows a cross-tabulation of respondents from different states

and the type of produce they grow. The majority of the total respondents were vegetable growers

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(n=53, 46.1%) and 55% (n=29) of those vegetable producers were from Pennsylvania.

Approximately 28% of the respondents (n=32) indicated that they only grow fruits, and around

40% (n=13) of them were from New York.

Around 24% (n=28) of the total respondents indicated that they grow both fruits and

vegetables and half of them (n=14; 50%) were from Pennsylvania. Two respondents indicated

that they neither grow fruits or vegetables, but grow herbs. For New Jersey, the majority of the

respondents were vegetable producers. Out of the four respondents from Virginia, half of them

(n=2) were vegetable producers, one fruit grower, and one produced both fruits and vegetables.

Three out of five respondents from Maryland were fruit producers and the remaining two

produced both fruits and vegetables.

Table 4.13

Characteristics of Produce Growers by the Produce they grow

Produce Type Pennsylvania New

York

New

Jersey Virginia Maryland Delaware Total

Fruits only 9 13 6 1 3 0 32

(27.8%)

Vegetables

only 29 10 10 2 0 2

53

(46.1%)

Fruits and

Vegetable 14 11 0 1 2 0

28

(24.4%)

Other 0 1 1 0 0 0 2

(1.7%)

Total 52 35 17 4 5 2 115

(100%)

Produce marketing channel. Answering the question related to how they sell their

produce, respondents indicated that they sell their produce directly to supermarkets, restaurants,

consumers at farm stands, at Farmers markets, at produce auctions, through cooperatives, and to

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resellers. Respondents also sold their produce at multiple locations and through multiple

channels. As can be seen in Table 4.14, resellers and direct sales were the two most used

channels for growers to sell their produce. The majority of respondents (n=84, 73%) indicated

that they sell their produce through resellers and around 68% of the respondents (n=78) indicated

that they directly sell their produce. Five respondents mentioned that they also use other channels

to sell their produce that included food markets, retail store front, CSA, and farm sell “PYO” and

farm stand.

Table 4.14

Market Where Grower Sell Their Produce (Total = 115)

Sales Frequency Percentage (%)

Resellers 84 73.0

Direct Sale 78 67.8

Cooperatives 45 39.1

Produce auctions 38 33.0

Other 5 4.3

Challenging Food Safety Standards

Scale reliability. Growers were asked to rate GAPs harmonized food safety standards in

terms of how challenging it was for them to comply with the standards using a five-point Likert

scale. GAPs harmonized food safety standards were logically placed under eight topic areas of

harmonized audits. Each topic areas were represented by three items or standards. In order to

evaluate logical placement of standards under each section, tests were performed for scale

reliability and Cronbach’s α value was calculated for all eight topic areas. While calculating

Cronbach’s α values, data sub-setting was performed to exclude respondents who indicated that

the standards were not applicable “NA” to their farm operations. Cronbach’s alpha values for all

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eight topics were greater than .70, a typical benchmark value accepted in basic research

(Nunnally, 1978). Table 4.15 lists the sections and corresponding Cronbach’s alpha values.

Table 4.15

Reliability of Scales Measuring Produce Growers’ Challenge to Meet Food Safety Standards

Topic (3 items for each topic) Cronbach’s α

Food safety plan .79

Documentation .87

Employees’ training .78

Water management .83

Cleaning procedures .82

Harvesting policy .79

Transportation .88

Risk assessments .83

Food safety plan. Writing a food safety plan, keeping records for it, and writing and

implementing policies and procedures in the plan were the items represented under the topic of

food safety plan. For almost 50% of the respondents, both the writing and keeping records for

food safety plan were “moderate to very challenging” (Table 4.16). Around 34% (n=38) of the

respondents indicated writing and implementing a food safety plan and procedures such as glove

use policy was “moderate to very challenging.”

87

Table 4.16

Challenging Food Safety Standards Related to Food Safety Plan

Food safety plan Total

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

n % n % n %

Writing a food safety plan 112 23 20.5 34 30.4 55 49.1

Keeping records for a food

safety plan 116 29 25.0 30 25.9 57 49.1

Writing and implementing

policies and procedures in

plan (glove use policy)

112 39 34.8 35 31.2 38 33.9

Documentation.

Growers were asked to rate food safety standards related to documentations

documentation of corrective actions, self-audit procedures, and trace back and forward exercise.

Almost 34% (n=38) of the respondents rated documenting and carrying out trace back and

forward exercise as “moderate to very challenging” (Table 4.17). The percentage of respondents

that rated documenting corrections actions as “moderate to very challenging” (n=33, 29.2%) was

5% higher than documentation of self-audit procedures (n=28, 24.3%). In addition, a majority of

the respondents (n=64, 55.7%) indicated that documenting self-audit procedures were not to

slightly challenging.

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Table 4.17

Challenging Food Safety Standards Related to Documentation

Documentation Total

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

n % n % n %

Documenting corrective

actions 113 49 43.4 31 27.4 33 29.2

Documenting self-audit

procedures 115 64 55.7 23 20.0 28 24.3

Documenting and carrying

out a trace back and

forward exercise

113 46 40.7 29 25.7 38 33.6

Employees’ training. Food safety standards related to employees’ training such as

keeping records, documenting employees receiving food safety training and ensuring that

employees are adequately trained were least challenging. Approximately 70% and 63% of the

total respondents indicated that keeping employees’ training record and ensuring their employees

are sufficiently trained were not to slightly challenging, respectively (Table 4.18). Even though

more than half of the respondents (n=65, 56%) rated making sure their employees follow

hygienic practices as not to slightly challenging, around 27% of them (n=31) indicated such

requirement was “moderate to very challenging” to comply.

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Table 4.18

Challenging Food Safety Standards Related to Employees’ Training

Employees’ training Total

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

n % n % n %

Ensuring that employees

are adequately trained in

food safety

116 73 62.9 26 22.4 17 14.7

Making sure that

employees follow hygienic

practices

116 65 56.0 20 17.2 31 26.7

Keeping records that

document employees

received food safety

training

115 91 79.1 15 13.0 9 7.8

Water management. Among the three food safety standards related to water

management, the highest number of respondents (n=37, 34.9%) rated writing and implementing

a water management plan “moderate to very challenging” to comply (Table 4.19). Similarly,

28.3% of the respondents (n=30) indicated writing water testing procedures as “moderately to

very challenging.” However, for the majority of respondents (n=80, 72.7%) finding a Good

Laboratory Practices certified water testing lab was “not to slightly challenging.”

Cleaning procedures. Produce growers rated the challenge to implementing food safety

standards related to cleaning procedures. The majority of the respondents indicated that all the

three standards such as keeping equipment, vehicle, tools, and utensils in good repairs (n=83,

72.2%) and using proper cleaning and sanitizing procedures (n=72, 63.7%) not to slightly

challenging (Table 4.20). Around 21% (n=23) rated writing a disciplinary policy for food safety

violations as moderate to very challenging.

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Table 4.19

Challenging Food Safety Standards Related to Water management

Water management Total

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

n % n % n %

Writing and implementing

a water management plan 106 46 43.4 23 21.7 37 34.9

Writing procedures for

water testing 106 53 50.0 23 21.7 30 28.3

Finding a water testing

laboratory that is certified

to be following “Good

Laboratory Practices”

110 80 72.7 14 12.7 16 14.5

Table 4.20

Challenging Food Safety Standards Related to Cleaning procedures

Cleaning procedures Total

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

n % n % n %

Keeping equipment,

vehicle, tools and utensils

in good repair

115 83 72.2 18 15.7 14 12.2

Using proper cleaning

and sanitizing procedures 113 72 63.7 25 22.1 16 14.2

Having a disciplinary

policy for any food safety

violations

112 67 59.8 22 19.6 23 20.5

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Harvesting policy. Produce growers were asked to rate three food safety standards

related to harvesting policy based on how challenging it was for them to meet standard

requirements. The majority of the respondents indicated writing and implementing a policy

regarding the cleanliness of harvesting container (n=66, 58.4%) and a policy on preventing non-

root crop contacting ground (n=61, 63.5%) not to slightly challenging (Table 4.21). Compared to

those two harvesting policy requirements, relatively higher number of respondents (n=27,

24.5%) rated writing a policy on identifying potential food safety hazards and plan to control

them as moderate to very challenging.

Transportation. On the survey questionnaire three standards under the section of

transportation were rated. Growers rate how challenging it was for them to write procedures for

cleanliness and proper functioning of shipping units, preparing a checklist for cleanliness, and

writing a policy for trash handling procedures. For all the three standards, more than 65% of

respondents indicated meeting the standard requirements were not to slightly challenging (Table

4.22).

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Table 4.21

Challenging Food Safety Standards Related to Harvesting policy

Harvesting policy Total

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

n % n % n %

Writing and implementing

a policy regarding

cleanliness of harvesting

containers

113 66 58.4 29 25.7 18 15.9

Writing a policy regarding

preventing non-root crop

produce from contacting

the ground after harvest

96 61 63.5 19 19.8 16 16.7

Writing a policy that

identifies potential food

safety hazards during

harvesting and how you

plan to control them

110 49 44.5 34 30.9 27 24.5

Table 4.22

Challenging Food Safety Standards Related to Transportation

Transportation Total

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

n % n % n %

Writing procedures for

cleanliness and proper

functioning of shipping

units and preventing

damage to produce before

loading onto truck

111 73 65.8 23 20.7 15 13.5

Preparing a checklist to

verify cleanliness of

shipping units 109 72 66.1 26 23.9 11 10.1

Writing a policy for how

trash should be safely

handled and kept out of

fields

112 77 68.8 23 20.5 12 10.7

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Risk assessments. Growers were asked to rate the challenge to comply with three food

safety standards related to carrying out risk assessments on their farms. The majority of the

respondents indicated that performing a pre-harvest risk assessment (n=75, 64.7%) and

conducting a water system risk assessment (n=56, 53.3%) not to slightly challenging (Table

4.23). However, for 34% of respondents (n=39) writing a risk assessment on domestic and wild

animal activity was “moderate to very challenging.”

Table 4.23

Challenging Food Safety Standards Related to Risk assessments

Risk assessments Total

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

n % n % n %

Performing a pre-

harvesting risk

assessment

116 75 64.7 21 18.1 20 17.2

Conducting a water

system risk assessment 105 56 53.3 23 21.9 26 24.8

Writing a risk assessment

on domestic and wild

animal activity

114 57 50.0 18 15.8 39 34.2

Other standards. In this section of other standards, growers were asked to rate how

challenging it was for them to keep initial risk assessment records of their farms, routinely

monitoring animal activity on and around their farms, and document policies for subcontractors.

For the majority of the respondents (n=74, 65.5%) keeping records for risk assessments were

“not to slightly challenging” (Table 4.24). However, at least 30% of the respondents indicated

that routinely monitoring of animal activity was “moderate to very challenging” to comply. In

comparison to other food safety standards, a relatively lesser number of growers responded to the

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questions on documentation of policy for subcontractors as for many growers that standard was

not applicable. Moreover, out of 75 respondents, 26 (34.7%) rated complying with that standard

as “moderate to very challenging.”

Table 4.24

Growers’ Rating of the Challenge to Comply with Other Food Safety Standards

Other standards Total

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

n % n % n %

Keeping initial risk

assessment records 113 74 65.5 24 21.2 15 13.3

Routinely monitoring of

animal activity 113 55 48.7 24 21.2 34 30.1

Documentation to assure

that sub-contractors are

complying with food

safety standards

75 29 38.7 20 26.7 26 34.7

Overall Major Challenging Food Safety Standards

Table 4.16 ranks the most challenging GAPs harmonized food safety standards. Ranking

of standards was based on the overall percentage of respondents’ rating of standards as

“moderate to very challenging” to comply with. In total for 13 food safety standards,

approximately 25% or more respondents indicated to comply with them was either moderately or

very challenging (Table 4.25). With 49% writing a food safety plan and keeping records for food

safety plan top the list, most challenging of all standards. The most challenging food safety

standards included writing and implementing a water management plan, writing risk assessments

on the domestic and wild animal, writing a policy on glove uses on farms, and documenting and

carrying out trace back and trace forward exercise. A thorough review of these standards showed

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that the majority of the most challenging food safety standards were related to writing and/or

documentation activities.

Table 4.25

Ranking of Overall Challenging Standards (Criteria ≥ 25% of total Respondents)

Food Safety Standard Total n %

1. Writing a food safety plan 112 55 49.1

2. Keeping records for a food safety plan 116 57 49.1

3. Writing and implementing a water management plan 106 37 34.9

4. Documentation to assure that sub-contractors are complying with

food safety standards 75 26 34.7

5. Writing a risk assessment on domestic and wild animal activity 114 39 34.2

6. Writing and implementing policies and procedures in your plan,

such as whether or not you require gloves when handling

produce

112 38 33.9

7. Documenting and carrying out a trace back and forward exercise 113 38 33.6

8. Routinely monitoring of animal activity 113 34 30.1

9. Documenting corrective actions 113 33 29.2

10. Writing procedures for water testing 106 30 28.3

11. Making sure that employees follow hygienic practices 116 31 26.7

12. Conducting a water system risk assessment 105 26 24.8

13. Writing a policy that identifies potential food safety hazards

during harvesting and how you plan to control them 110 27 24.5

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Variation of Most Challenging Standards Across the States

In order to test if the most challenging standards were significantly varied for different

states, z-score proportional tests were performed. Tables showing results are presented in

Appendix C. As mentioned earlier in the methodology section, the most challenging food safety

standards were the standards for which more than or equal to 25% of the respondents indicated

either moderate or very challenging to comply (Table 4.25). Since the number of respondents

was higher for Pennsylvania, New Jersey, and New York, these three states were included for the

proportional tests.

z-test of proportional difference was performed between proportions of growers from

Pennsylvania and New Jersey who rated the food safety standards as moderate to very

challenging. For all the most challenging food safety standards, except one, the study failed to

reject the hypothesis (H0): There were no significant proportional differences in growers’

responses between the two states. Results showed that the proportional difference between

respondents indicating writing a food safety plan as “moderate to very challenging” was

significant (z=-2.12, p=.034). The negative value of proportional difference indicated that more

produce growers of New Jersey rated writing a food safety plan moderately to very challenging

than respondents of Pennsylvania.

Similar tests were performed between Pennsylvania and New York and between New

York and New Jersey. For none of the food safety standards the proportional differences between

the Pennsylvania and New York were statistically significant. The z-score test statistic results

support the hypothesis that there was no significant difference between the proportions of

growers from Pennsylvania and New York who rated food safety standards as moderate to very

challenging.

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z-test of proportional difference was performed between proportions of growers from

New York and New Jersey who rated the food safety standards moderately to very challenging to

meet the requirements. Among the 13 standards, for 10 the proportional differences were not

statistically different and hence, the test failed to reject the hypothesis (H3). The proportional

differences were statistically different for writing food safety plan (z=-2.26, p= 0.024) and

writing a policy identifying and controlling physical food safety hazards during harvesting (z=-

2.02, p=0.043). The negative z-score values indicated that complying with standards related to

food safety plan and physical hazards were more challenging for produce growers of New Jersey

than New York. Additionally, for a higher proportion of growers from New Jersey ensuring

employees are following hygienic standards were challenging than growers of New York (z= -

1.88, p =.06).

Produce Type and Challenges to Implementing GAPs

In order to test if there were any associations exist between growers’ rating of challenges

to implementing food safety standards and type of produce they grow, Chi-Square test of

association was performed. Consistent with the GAPs harmonization parameter, the study

hypothesized that growers rating of challenges to implementing GAPs on their farm was

independent to the type of produce they grow (i.e., fruits, vegetables, or both). The Chi-Square

tests results indicated almost all the food safety standards were independent of the types of

produce, except for the standards related to transportation.

Chi-square tables were created for the two transportation harmonized standards for which

the association was significant at the level of .05. Table 4.26 displays the Chi-square 3 x 3

contingency table of produce type and the challenge to write procedures for cleanliness and

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proper functioning of shipping units and preventing damage to produce before loading onto

trucks. The Chi-square value of 10.47 (df=4, p<.05) showed a significant association between the

two variables: Produce type and the challenge to comply with cleanliness standards.

Table 4.26

Test of Association for Produce Type and Writing Procedures for Cleanliness and Proper

Functioning of Shipping Units

Produce

Type

Writing Procedures for Cleanliness and Proper Functioning of Shipping Units

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

Fruits 16 (53.3%) 12 (40.0%) 2 (6.7%)

Vegetables 33 (66.0%) 8 (16.0%) 9 (18.0%)

Fruits and

Vegetables 22 (78.6%) 3 (10.7%) 3 (10.7%)

Note. 2 = 10.47*, df = 4. Numbers in parentheses indicate row percentages. *p < .05

The chi-square test also indicated a significant association between produce type and the

growers’ challenge to prepare a checklist to verify the cleanliness of shipping units. However,

since 33% of cells in the contingency table had expected counts less than five, the results were

not included. Table 4.27 shows the chi-square test results for produce type and growers’

challenge to write a policy on how to safely handle trash and kept out of the field. Results

showed a significant association between produce type and growers challenge to write a policy

on trash management as the (2 = 12.64, df = 4, p <.05).

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Table 4.27

Test of Association Between Produce Type and Writing a Policy on On-Farm Trash Handling

Produce Type

Writing a policy for safely handling Trash and kept out of fields

Not to Slightly

Challenging

Somewhat

Challenging

Moderate to Very

Challenging

Fruits 19(57.6%) 13 (39.4%) 1 (3.0%)

Vegetables 34 (68.0%) 8 (16.0%) 8 (16.0%)

Fruits and

Vegetables 22 (81.5%) 2 (7.4%) 3 (11.1%)

Note. 2 = 12.64*, df = 4. Numbers in parentheses indicate row percentages. *p < .05

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Objective 4: Determine the Source of GAP Information, Barriers to Implementing Gaps

and Carry Out Risk Assessments on the Farms

Source of GAP Information

Produce growers were asked to rate the amount of GAP information they receive from

various sources. Table 4.28 shows the list of GAP information sources and the amount of

information that growers of Mid-Atlantic states and New York receive from those sources.

Results showed that Cooperative Extension (n=50, 43.9%), USDA GAPs user guide (n=38,

33.3%), and online (n=31, 27.2%) were the top three GAP sources from where produce growers

received “quite a bit to a great deal of information.” Respondents also indicated that they

received quite a bit or a great amount of GAP information from consultants (n=29, 25.4%) and

other farmers (n=26, 22.8%). Six growers mentioned that they received “quite a bit of to a great

amount of” GAP information from other sources. The other sources included Wegmans (n=2),

other certifying agencies such as Global GAP (n=1), and USDA meetings (n=1).

Table 4.28

Amount of Information from Various Sources (Total=114)

GAP-Information Sources None to a little A fair amount

Quite a bit to a

great deal of

n % n % n %

USDA GAPs user guide 44 38.6 32 28.1 38 33.3

Grower associations 72 63.2 20 17.5 22 19.3

Cooperative Extension 39 34.2 25 21.9 50 43.9

Consultants 70 61.4 15 13.2 29 25.4

Other farmers 67 58.8 21 18.4 26 22.8

Online sources 63 55.3 20 17.5 31 27.2

Agricultural industry

representatives 82 71.9 18 15.8 14 12.3

Other 108 94.7 - - 6 5.3

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Crosstab of the amount of GAP information from various GAP sources and states

provided further insight into the major information source for produce growers in individual

states. Results showed that majority of growers of New Jersey (n=12, 70.6%), New York (n=26,

74.3%), and Maryland (n=4, 80%) received a fair to great amount of GAP information from

USDA users guide. Cooperative extension provided a fair to great amount of information to the

majority of respondents (≥ 50%) of all the Mid-Atlantic states and New York.

Three out of four respondents from Virginia and three out of five respondents from

Maryland received a fair to a great amount of information from consultants and other farmers,

respectively. Online sources provided a fair to a great amount of GAP information to the

majority of the respondents of all the states (≥ 50%), except Pennsylvania. The majority of the

respondents from New Jersey received a fair to great amount of information from agricultural

industry representatives.

Barriers to Implementing GAPs

Produce growers were asked to mention the barriers to implementing GAPs on their

farms. In total 112 produce growers answered the questions. Results showed that the major

barriers to implementing GAPs were time, cost to comply with food safety standards and clarity

in GAP guidelines (Table 4.29). Around 87% (97) of the respondents indicated time was a

barrier for them to adopt GAPs on their farms. Next to time, the other major barrier for GAP

implementation was cost as 53.6% (n=60) of the total respondents identified cost as a barrier.

The majority of growers from all the Mid-Atlantic States and New York identified cost as

a barrier, expect Virginia. None of the respondents from Virginia indicated cost a barrier for

them to adopt GAPs on their farms. Fifty-two respondents (46.4%) mentioned the lack of clarity

in GAP guidelines as a barrier. All the two respondents from Delaware mentioned clarity as a

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barrier. For 20% the total respondents, lack of adequate knowledge on GAPs was a barrier to

implementing GAPs on their farms. Growers mentioned language, training materials, record

keeping, and very importantly having an employee dedicated all the documentation and record

keeping work as other GAP barriers. Indicating time, effort and the need for a trained employee

as major barriers to implementing GAPs on his/her farms, one growers stated that

“it takes a full time person to implement/start the standards/training/plan, so the greatest

barriers is time and the effort and finding the right person to do it.”

Table 4.29

Barriers to Implement GAPs (Total =112)

Barriers n %

Time 97 86.6

Cost 60 53.6

Clarity in GAP guidelines 52 46.4

Resources 25 22.3

Adequate knowledge of GAPs 22 19.6

Other 17 15.2

Association between GAPs Barriers and the Challenge to Comply with Standards

Barriers to implementing GAPs on the farms were independently examined to determine

the association with produce growers’ challenge to comply with each food safety standards.

Pearson Chi-square test of association was performed to examine the association between the

two variables. Since food safety standard challenge was measured on an ordinal scale, the linear-

by-linear association values were also calculated to test the linearity of the associations. In

addition, Cramer’s V values were also calculated to determine the strength of the relationship

between GAP barriers and the degree GAP implementation challenge. Cramer’s V is a non-

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parametric test to measure inter-correlation between two nominal variables. Tables 4.30-4.33

shows the results of Pearson Chi-square test of association with significant chi-square, linear-by-

linear association, and Cramer’s V values.

Time. The results showed that the barrier time was significantly associated with two food

safety standards related to documentation of corrective actions (2 = 10.37, p<.05) and routinely

monitoring of animal activity (2 = 4.95, p<.10) (Tables 4.30). Further analysis shows that only

documentation of corrective action was strongly (Cramer’ V value =.308) and linearly associated

(8.37: p<.05).

Table 4.30

Chi-Square Test of Association Between Time and Challenge to Comply Food Safety Standards

Food Safety Standard Chi-square Cramer’s V p Linear-by-linear

Association p

Documenting corrective actions 10.365 .308 <.05 8.370 <.05

Routinely monitoring of animal

activity 4.946 .213 <.10

Cost. GAP implementation cost was found to be significantly associated with a relatively

large number of food safety standards as indicated in Table 4.31. Among those food safety

standards, writing a policy to identify potential food safety hazards and control plan (2 =13.254,

p<.05) and documentation of corrective actions (2 =13.153, p<.05) were relatively strongly

associated with cost as the Cramer’s V values were .354 and .347, respectively. Significant

linear-by-linear association values further indicated a linear association between those two food

safety standards with cost.

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Table 4.31

Chi-Square Test of Association Between Cost and Challenge to Comply Food Safety Standards

Food Safety Standard Chi-square Cramer’s

V p

Linear-by-linear

Association p

Writing a policy that identifies

potential food safety hazards 13.254 .354 <.05 8.827 <.05

Documenting corrective actions 13.153 .347 <.05 12.147 <.05

Ensuring that employees are

adequately trained in food safety 8.390 .274 <.05

Writing a food safety plan 7.936 .271 <.05

Having a disciplinary policy for any

food safety violations 7.163 .258 <.05 6.150 <.05

Documenting and carrying out a

trace back and forward exercise 6.568 .245 <.05 4.546 <.05

Writing and implementing a water

management plan 6.315 .249 <.05 3.884 <.05

Routinely monitoring of animal

activity 5.196 .218 <.10 5.018 <.05

Writing procedures for cleanliness

and proper functioning of shipping

units 5.021 .217 <.10 3.737 <.10

The other standard that were significantly and linearly associated with cost were having a

disciplinary policy for food safety violations (2 =7.163, p<.05), documenting and carrying out a

trace back and forward exercise (2 =6.568, p<.05), and writing and implementing water

management plan (2 =6.315, p<.05). These three policies related to food safety violations, trace

back and forward exercises and water management plan were moderately related to cost, as the

Cramer’s V values were .258, .245 and .249, respectively.

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In addition, standards related to ensuring employees are adequately trained (2 =8.39,

p<.05) and writing a food safety plan (2 =7.936, p<.05) were significantly associated with cost.

However, such associations were not linear at a significant level of .05. Table 4.31 also shows

that routinely monitoring of animal activities and cleanliness and functioning of shipping units

were also associated with cost (p<.10).

GAP resources. Results showed that GAP resources found to be significantly associated

with relatively highest number of food safety standards. Challenges to routine monitoring of

animal activities (2 =11.381, p<.05) and preparing a checklist to verify the cleanliness of

shipping units (2 =9.297, p<.05) were moderate to strongly associated with GAP resources with

Cramer’s V values .323 and .298, respectively (Table 4.32). Such associations were further

found to be linear at a significant level of .05. Even though, the standard related to proper

cleaning and sanitizing procedures was significantly associated with GAP resources (2 =8.534,

p<.05), the association was not linear.

Furthermore, challenges to performing pre-harvest risk assessments, keeping records for

food safety plan, conducting water system risk assessments and documenting corrective actions

were significantly associated with GAP resource barriers. Such associations of GAP resource

barrier with food standards related to pre-harvest risk assessments, keeping records, and water

system risk assessments were linear and relationships were moderately strong. The challenge to

comply with documenting corrective actions was moderately related with GAP resources. The

table also listed three food safety standards related to trace-back and forward exercise, adequate

training of farm employees, and writing and implementation of food safety plan procedures,

which are associated with the barrier of GAP resources (p<.10).

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Table 4.32

Chi-Square Test of Association Between GAP resources and Challenge to Comply Food Safety

Standards

Food Safety Standard Chi-

square

Cramer’s

V p

Linear-by-linear

Association p

Routinely monitoring of animal

activity 11.381 .323 <.05 9.973 <.05

Preparing a checklist to verify

cleanliness of shipping units 9.297 .298 <.05 7.166 <.05

Using proper cleaning and sanitizing

procedures 8.534 .280 <.05 3.326 <.10

Performing a pre-harvesting risk

assessment 8.332 .273 <.05 6.361 <.05

Keeping records for a food safety plan 8.149 .271 <.05 6.155 <.05

Conducting a water system risk

assessment 6.871 .261 <.05 6.214 <.05

Documenting corrective actions 6.328 .241 <.05 6.087 <.05

Documenting and carrying out a trace

back and forward exercise 5.783 .230 <.10

Ensuring that employees are

adequately trained in food safety 5.713 .226 <.10

Writing and implementing policies

and procedures 5.472 .225 <.10

GAP knowledge.

Pearson Chi-square test of association was performed for GAP knowledge barrier and

challenge to implement food safety standards. Table 4.33 shows the food safety standards that

were significantly associated with GAP knowledge. The same table also lists chi-square,

Cramer’s V and linear-by-linear values. The challenges to conduct a water system risk

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assessment (2 =6.871, p<.05), t, writing and implementing food safety plan (2 =6.651, p<.05),

and documenting corrective actions (2 =6.524, p<.05) were significantly and linearly associated

with GAP knowledge. Furthermore, the Cramer’s V values for those three standards related to

water system risk assessment, food safety plan, and corrective actions were moderately related

with GAP knowledge.

The challenge to make sure farm employees were following hygienic practices (2

=9.715, p<.05) and writing a risk assessment on animal activities (2 =6.232, p<.05) were

significantly associated with knowledge barrier. However, the associations were not linear at a

significant level of .05. Additionally, challenges to comply with food safety standards such as

preparing a checklist for cleanliness of shipping unit, finding GLP, and keeping initial risk

assessment records were also associated with knowledge barrier (p<.10).

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Table 4.33

Chi-Square Test of Association Between GAP knowledge and Challenge to Comply Food Safety

Standards

Food Safety Standard Chi-

square

Cramer’s

V p

Linear-by-linear

Association p

Making sure that employees follow

hygienic practices 9.715 .295 <.05 2.758 <.10

Conducting a water system risk

assessment 6.871 .261 <.05 6.214 <.05

Writing and implementing policies and

procedures 6.651 .248 <.05 4.954 <.05

Documenting corrective actions 6.524 .245 <.05 6.162 <.05

Writing a risk assessment on domestic

and wild animal activity 6.232 .238 <.05 3.192 <.10

Preparing a checklist to verify

cleanliness of shipping units 5.052 .219 <.10 4.898 <.05

Finding a water testing laboratory, GLP 4.942 .216 <.10 2.809 <.10

Keeping initial risk assessment records 4.750 .209 <.05 4.269 <.05

Barriers to Carrying Out Risk Assessments

Produce growers were also asked to answer questions related to the barriers to carrying

out risk assessments on their farms. The majority of the growers indicated figuring out what to

include in a risk assessment plan (n=75, 69.4%) and understanding what the auditors would look

for in the plan (n=72, 66.7%) as the barriers for performing risk assessments (Table 4.34). One

grower out of four from Virginia stated writing a risk assessment plan a GAP barrier.

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Table 4.34

Barriers to Carry out Risk Assessment (Total=108)

Barriers n %

Figuring out what to include in a risk assessment plan 75 69.4

Understanding what the auditors would look for in the plan 72 66.7

Writing management procedures for reducing risks 46 42.6

Accessing and understanding the latest scientific information

on produce food safety 41 38.0

Preparing food safety plan verification checklists 26 24.1

Identifying sources of contamination 19 17.6

Other 7 6.5

The majority of respondents from the Mid-Atlantic states and New York stated

understanding of auditors’ specific requirements for the risk assessment plan as a barrier, except

respondents from Maryland. Since only two out of five respondents stated understanding of

“what auditors would look for in the risk assessment plan” as a risk assessment barrier. However,

unlike the respondent from other states, for most of the Maryland respondents (four out of five)

the writing management procedures for reducing risks was a major barrier. Overall 42.6% and

38% of the respondents pointed out writing risk assessment procedures and assessing and

understanding scientific food safety information were barriers to carrying out risk assessments,

respectively.

110

Barriers to Perform Risk Assessments Vs. Challenges to Comply Food Safety Standards

The questionnaire contained three questions relative to risk assessments. In order to

verify if there are any relationship and associate exist between risk assessment tasks and barriers

to performing a risk assessment on the farm. Pearson chi-square tests were performed and linear-

by-linear association and Cramer’s V values and calculated. Tables 4.35-4.37 show the

significant barriers that are significantly related to risk assessments of food safety standards.

Performing a pre-harvest risk assessment. The challenge to perform a pre-harvest risk

assessment was tested for its association with the potential barriers that the growers face in

carrying out risk assessments. Pearson chi-square test of association results showed that the

challenge to perform a pre-harvest risk assessment was significantly and linearly associated with

writing management procedures for reducing risk (2 =18.782, p<.05) and figuring out what to

include in a risk assessment plan (2 =6.05, p<.05) (Table 4.35). Furthermore, growers’

challenge to perform a pre-harvest risk assessment strongly related with writing risk management

procedures were (Cramer’s V=.417) and moderately related to developing risk assessment plan

(Cramer’s V=.237).

In addition to that, the barriers related to the identification of the source of contamination

and preparation of food safety plan verification checklists were also significantly associated with

the challenge to perform a pre-harvest risk assessment. For the 2x3 chi-square contingency tables

for the barriers and pre-harvest standard, in two (33%) cells of each table the expected count was

less than five, the minimum expected count required for a chi-square test of association.

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Table 4.35

Chi-Square Test of Association Between Challenge to perform a Pre-Harvest Risk Assessment

and Barriers to Carry Out Risk Assessments

Barriers Chi-

square

Cramer’s

V p

Linear-by-linear

Association p

Writing management procedures for

reducing risks 18.782 .417 .000 18.341 .000

Figuring out what to include in a risk

assessment plan 6.05 .237 .049 5.966 .015

Identifying sources of contamination 9.845* .302 .007 8.804 .003

Preparing food safety plan verification

checklists 6.965* .254 .031 6.055 .014

Note. *2 cells expected count less than 5; df=2

Conducting a water system risk assessment. Growers’ challenges to comply with food

safety standard related to conducting a water system risk assessment was tested for significant

association with the barriers to carrying out a risk assessment. Risk assessment barrier related to

writing management procedures for reducing risk was significantly and linearly associated with

the challenge to conducting a water system risk assessment (2 =9.679, p<.05) (Table 4.36).

Cramer’s V value of .314 indicated a strong relationship between pre-harvest risk assessment and

management procedures.

As can be seen in (Table 4.36), growers challenge to perform a pre-harvest risk

assessment was also associated with the barriers of preparation of verification checklists (2

=4.813, p<.10) and assessing and understanding the latest scientific information (2 =4.692,

p<.10) at a higher significance level of .10. However, the association was significantly linear for

the checklist preparations.

112

Table 4.36

Chi-Square Test of Association Between Challenge to Conduct a Water System Risk Assessment

and Barriers to Carry Out Risk Assessments

Barriers Chi-

square

Cramer’s

V p

Linear-by-linear

Association p

Writing management procedures for

reducing risks 9.679 .314 .008 9.4 .002

Identifying sources of contamination 8.567* .296 .014 8.476 .004

Preparing food safety plan verification

checklists 4.813 .222 .09a 4.526 .033

Accessing and understanding the latest

scientific information 4.692 .219 .096a 3.295 .069a

Note. *2 cells expected count less than 5; df=2

a p<.10

Writing a risk assessment plan on the domestic and wild animal. Results showed that

the challenge to comply with the food safety standard related to writing a risk assessment plan on

the domestic and wild animal was significantly associated with the barrier of identification of

sources of food contamination (2 =6.708, p <. 05) (Table 4.37). Furthermore, linear-by-linear

association value of 6.596 (p<.05) and Cramer’s V of .250 indicated linear association and

moderate relationship between the two nominal variables, respectively. In addition to that the

challenge to write a risk assessment plan also linearly associated with the barrier of figuring out

what to include in a risk assessment plan (2 =5.214, p<.10).

113

Table 4.37

Chi-Square Test of Association Between Challenge to Write a Risk Assessment Plan on Domestic

and Wild Animal and Risk Assessment Barriers

Barriers Chi-

square

Cramer’s

V p

Linear-by-linear

Association p

Identifying sources of contamination 6.708 .250 .035 6.596 .01

Figuring out what to include in a risk

assessment plan 5.214 .221 .074* 3.812 .051*

Note. * p<.10; df =2

Summary

Objective 1 identified the harmonized GAPs food safety standards for which the

frequency CAN or IAR were relatively higher. In total, 166 audits were analyzed, and

descriptive results were presented for individual states. On nine out of 36, farms in New Jersey

corrective actions or immediate actions required to meet the requirement of standard 2.2.6.

Analysis of the audits from New York revealed 4.1.1 as the standard for which noncompliance

was frequently reported. Whereas in the audits from Delaware, CAN frequency was relatively

higher for standards 2.2.10 and 2.2.11. Noncompliance to the standard 1.8.1 was frequently

reported in Maryland.

Proportional test and risk ratio test results were consistent. For the majority of the

sections, there was no significant difference in reporting of noncompliance between New Jersey

and New York. From the risk ratio tests it was concluded that for a few GAP areas the likelihood

of reporting of noncompliance was higher on the farms of New Jersey than on the farm of New

York and Pennsylvania. More specifically, those GAP areas were related to worker education

and training, their health and hygiene, testing and sampling, and condition of farm equipment

and vehicle than farms of either Pennsylvania and New York.

114

Objective 2 focused on the aspects of GAP noncompliance. Auditors’ comments were

reviewed to determine the various aspects of noncompliance. Documentation, writing corrective

actions, keeping records, and more importantly compliance with the established food policy were

the key areas for where noncompliance was reported.

On the other hand, objectives 3 and 4 presented results from descriptive and correlational

analysis of 116 surveys. Respondents from Pennsylvania constituted almost 47% of the survey

sample. Resellers and direct sales were found to be the two major produce marketing channels

for GAP certified growers of Mid-Atlantic states and New York. Objective 3 also identified the

most challenging food safety standards. Writing a food safety plan, keeping records for a food

safety plan, and writing and implementing water management plans were found to be

comparatively more challenging tasks that other certification requirements. Proportional test

results showed that growers did not differ significantly based on their experience in complying

with the food safety standards. Besides, Growers experience with meeting transportation

standards was significantly associated with the type of produce they grow.

Objective 4 provided results related to GAP information sources, barriers to complying

with GAPs and carry out risk assessments on the farms. Results showed that Cooperative

Extension and USDA GAPs user guide are the primary GAP information sources for certified

growers. Time and cost were identified as the significant barriers to GAP implementation, and

preparing a risk assessment plan and understanding auditors’ expectations were found to be the

key obstacles for carrying out risk assessments.

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Chapter 5

Discussion, Conclusions, and Recommendations

Discussion

The study utilized a mixed-method approach in assessing the implementation of

harmonized Good Agricultural Practices (GAPs) food safety standards on Mid-Atlantic region

farms. Audits were treated as a principal evaluation tool in identifying standards as well as the

criteria for GAP noncompliance. The administered surveys intended to further validate findings

from the audit analysis.

The current study is arguably unique in two aspects. First, of previous studies that

targeted GAP certified growers, none or very few adopted audit analysis as a methodology for

identifying noncompliance. Second, rather than relying on growers’ self-reports of compliance to

standards, the survey asked growers to rate how challenging it was for them to meet standard

requirements. For example, in Hultberg et al. (2012), Rangarajan et al. (2002), Cohen et al.

(2005), and Jackson et al. (2007), growers self-reported their food safety practices. In self-

reporting, growers might be inclined to offer socially favorable answers.

The study objectives primarily focused on four aspects of GAP implementation: (1)

standards for which noncompliance was higher, (2) criteria for noncompliance, (3) standards that

are challenging for growers to meet, and (4) barriers to implementing GAPs and performing risk

assessments.

General questions. Findings from all five states—Pennsylvania (PA), New Jersey (NJ),

Maryland (MD), Delaware (DE), and New York (York)—were consolidated to determine the

most problematic harmonized GAP food safety standards in terms of noncompliance. The

majority of the farms audited for the year 2013–14 met the standard requirements for harmonized

116

audits. However, there were certain standards for which the frequency of noncompliance was the

higher and therefore evaluated as major food safety concerns. Growers largely met the general

requirements of having a food safety plan and documentation for that plan. However, developing

a food safety plan and keeping records it were challenging to almost half of the surveyed

growers. Such findings accorded with Bihn et al. (2013), which reported that the majority of their

surveyed farms had no food safety plan.

Under general questions, the two subsections having to do with growers’ most frequent

failure to comply with requirements were worker education and training, and sampling and

testing. The majority of the noncompliance on worker education and training were reported for

the standard 1.4.3 when farm operations had no food safety policy for sub-contractors. As per

1.4.3, subcontractors are required to hold to the same policy as farm employees. However, a

majority of New Jersey farms had no policy for subcontractors.

With regard to having the same policy for subcontractors same as for farm employees,

more than half of the survey participants rated compliance as somewhat to very challenging. This

standard was one of the more challenging standards for a relatively greater number of produce

growers than any other standards. Findings from the audits and the surveys on subcontractor

policy were consistent with one another. However, the survey appeared to show that not all farm

operations were required to have a subcontractor policy as a requirement to pass the audit.

Audits revealed that documentation for self-audits was not a major noncompliance issue

for a majority of farms; survey findings confirmed that further. Only a few farm operations did

not have corrective action procedures available for review during the audit process, and more

than half of the surveyed growers indicated that documenting corrective actions was somewhat

to very challenging for them. Similarly, results from the audits and survey were inconsistent

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regarding documentation and carrying out a traceback and forward exercise. A very few farm

operators were unable to document and perform a traceability exercise. However, one-third of

survey respondents indicated such practices were “moderate to very challenging” for them.

Additionally, corrective actions were required more frequently to address standard 2.2.9,

which mandates a glove use policy— that is, workers are required to wear gloves if needed

during field production activities. Results appeared to show that growers were more likely not to

be sure about the exact policy requirements. In some occasions, the policies were incomplete—

in other cases, workers were not adhering to company policy. The assumption was that writing

and implementing a glove use policy might be challenging for the farm operations. In support of

the assumption, survey results revealed that having a glove use policy and complying with it was

one of the challenging food safety standards for Mid-Atlantic and New York growers. Therefore,

more clarity is required in developing a glove use policy and conveying the policy requirements

to suppliers as well as the farm workers in particular.

Corrective actions also were more frequently required to address standards related to

testing and sampling. Furthermore, in both cases, whether it was workers training or testing

procedures, the majority of farm operations were in New Jersey. In addition to policy on

subcontractors and testing and sampling, documentation on corrective procedures was another

area in which growers were required to take corrective actions, mostly because documentation

was either incomplete or not being followed.

Field production. Twenty-one questions on the audit checklist ensure that farm

operations are taking adequate precautions to address worker health and hygiene and provide

toilet and handwashing facilities. The policy requires farm operations to have an appropriate

number of well-maintained toilet and handwashing facilities for and accessible to the farm

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workers. The workers’ health and hygiene category not only contained a higher number of

sections/questions but also reported a higher number of corrective actions for that category.

The survey questions focused on three key areas of employee training, such as adequate

training for farm workers, keeping records as proof of employees receiving food safety training

regularly, and making sure workers are following hygienic practices in the field. The unhygienic

behavior of field workers in produce-growing areas was one of the major reasons for produce

contamination with human pathogens. Although farm operations had policies for hygienic

practices, auditors observed unhygienic behaviors, such as smoking, eating, or spitting on the

field. Such unhygienic behavior of food handlers increase the chances of produce contamination

and led to the automatic failure of the audit as observed in a few cases. Those failures included

cases in which workers did not wash their hands before returning to work.

Survey results indicated that convincing workers to follow hygienic practices on the field

was often a challenging task for growers. Although only one-fourth of study respondents

confirmed that ensuring workers follow hygienic practices was challenging, it remains an on-

farm food safety concern. In addition, worker education and training, and documentation

emerged from the audit analysis as food safety concerns. Hamilton et al. (2015) also found a lack

of proper documentation in the audit process for Minnesota farm operations.

Furthermore, when produce growers were asked about compliance with worker-training

related standards, the majority stated that ensuring their farm employees were receiving adequate

training and documentation was either not or a slightly challenging task for them. Adequate

training of employees may not guarantee incorporation through behavioral change. Thus, an

effective monitoring procedure should be in place to ensure employees are following the

company’s food safety policies. Such situations call for a better and more efficient method of

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communication between growers and farm workers to promote Good Hygienic Practices (GHP)

and a food safety culture within the operation.

Cohen et al. (2005) provided an indication that New England growers were unaware of

the need to test irrigation water for coliform. On the contrary, from the results, it appears that

audited growers in Mid-Atlantic states and New York were in compliance with water-testing

policies. Growers using municipal water are not required to test it for pathogen levels. If testing

is required, all tests should be performed at “Good Laboratory Practices” certified labs. Finding

such labs is not a challenge for growers. However, writing procedures for water testing, a water

management plan, and developing a procedure for implementing that plan were challenging for

more than one-fourth of survey respondents. Furthermore, there were cases in which farm

operations had no water management plan, or lacked a written policy regarding cleaning water

tanks at a sufficient frequency.

Harvesting. Harvesting policies also focus on pre-harvesting risk assessments, use of

water and ice, containers, bins and packing materials, field packing and handling, and post-

harvest handling and storage. Corrective actions were less frequently required for harvesting

standards than field production. In other words, correctives actions were needed to meet

harvesting harmonized policies in fewer farms compared to field production standards.

Food safety standards require growers to keep farm equipment and other tools that come

in contact with produce in good repair condition. Hultberg et al. (2012) identified deficiencies in

growers’ compliance with cleaning of harvesting tools and water treatment for washing and

cleaning. Confirming Hultberg et al. (2012), the results from audits showed noncompliance in

keeping records that verify proper and regular equipment maintenance activities— another major

area of food safety concern. On the contrary, survey results showed that complying with food

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safety standards related to cleaning and sanitizing procedures was not challenging to most of

produce growers in the Mid-Atlantic states and New York. Similarly, only one out of five

produce growers noted that having a disciplinary policy for food safety violations was a

challenging task.

Field packing and handling requirements were identified as a major noncompliance issue

on the audited farms. For example, no written policy indicated that damaged or decayed produce

should not be harvested or should be culled. Analysis of audits concluded that growers

frequently failed to meet policy requirements on containers, bins, and packaging materials, and

field packaging and handling. Furthermore, in few audits there were no written policies

regarding storage of harvest containers; and in some cases, even though the policy was in place,

auditors witnessed non-adherence to it. Meeting the requirement of food safety standards related

to the cleanliness of harvesting containers and the policy on non-root crops was not challenging

for the majority of survey respondents. On the other hand, writing a policy on hazard

identification and control was a challenging area for growers.

Transportation. Growers were largely in compliance with transportation harmonized

standards. Keeping records and maintaining a verification checklist were areas in which growers

more frequently failed to comply with requirements—growers in New York and New Jersey

appeared especially less likely to meet these requirements. On the other hand, one out of ten

respondents mentioned that preparing a checklist to verify the cleanliness of shipping units was a

challenging practice.

Risk assessments. Assessment of risk associated with preharvest activities, water system

and wild and domestic animal activities on the field are the three top tasks under risk

assessments. Among these three activities, risk assessment of animal activities was the most

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challenging task for the grower to perform. Audits also confirmed these results— auditors found

that documentation related to assessing animal activities in and around the field was incomplete

in some audited farms. Furthermore, one out of four producers indicated that conducting water

system risk assessment was a challenging standard for them.

Growers rated compliance with routine monitoring of animal activity in and around the

field as a difficult task. This finding was supported by Hultberg et al. (2012) and Hamilton et al.

(2015). These studies reported growers’ noncompliance with keeping animals out from the field,

packing or storage areas. On the other hand, the majority of participants in Lichtenberg and Page

(2016) reportedly inspected and monitored their field for wildlife activities. The major barrier in

performing a risk assessment was preparing a risk assessment plan.

Other survey findings. The study considered the state as a variable and tested whether

growers significantly varied based on their experience with GAP implementation. Hypotheses

were developed to test whether the challenge to implement harmonized standards varied among

New York, New Jersey, and Pennsylvania. Findings from the proportional tests accepted the test

hypothesis of no significant difference in produce growers experiences with implementing

harmonized GAPs. Regardless of the states to which produce growers belonged, their experience

with GAPs remained the same, except for a few standards that included:

Writing a food safety plan and hazard identification and writing control procedures were

challenging to significantly more produce growers in New Jersey than in New York;

When compared to growers in Pennsylvania, the growers in New Jersey were more likely

to find writing a food safety plan a challenging task;

For overall challenging standards, the study did not find any significant difference in the

proportions of growers in Pennsylvania and New York; and

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For the majority of challenging standards, growers’ experience remained the same. In

other words, standards were equally challenging for growers in New York, Pennsylvania,

and New Jersey.

Except for standards related to transportation, study findings suggested that grower on-

farm food safety implementation experience was independent of the type of produce they grew.

Produce growers in Mid-Atlantic states and New York obtained GAP information from various

sources. However, the amount of information they received from those sources varied.

Cooperative Extension was among the top sources of GAP information. The majority of the

USDA-audited growers received a fair to significant amount of information from Extension.

Moreover, these study findings suggest that produce growers in the six states depend on

Cooperative Extension services and a USDA user’s guide for GAP information.

The study focused on the barriers to implementing GAPs. Time and cost were found to be

the major barriers to GAP implementation. Becot et al. (2012) and Korslund (2014) found

similar results and reported time and cost to be major GAP barriers. Hardesty and Kusunose

(2009) reported an overall increase in cost of due to LGMA compliance. In addition, other

studies such as Karaman et al. (2012) identified cost and knowledge as barriers in implementing

HACCP in the dairy industry; and Jackson et al. (2007) identified cost and GAP resources as

barriers to GAP implementation. The study revealed that the clarity in GAP guidelines could also

be an adoption barrier to many produce growers.

The other major concern was the burden of documentation or the amount of paperwork

that needed to be completed to meet standard requirements. Growers indicated a need for a

permanent employee for all documentation work; at the same time, small growers could not

afford an additional employee dedicated only to documentation work (Korslund, 2011). On the

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other hand, growers also indicated that implementation of a GAP program was challenging only

in the beginning year. Once a food safety plan is written and growers go through the

documentation process to establish a GAP program at the beginning, the next year it becomes

easier to repeat the activities for certification. The survey showed that for some producers,

implementing the food safety plan is a more challenging task than documentation.

GAP barriers were tested for their association with the challenges to meet harmonized

food safety standards. Time also was an obstacle for more than 80% of respondents, was

independent of most of the food safety standards. On the other hand, the cost was significantly

associated with growers’ rating of how challenging it was for them to meet standard

requirements.

From the significant linear-by-linear association between cost and the challenge in

complying with standards, it appeared that: (1) many standards did not require direct costs, and

(2) the indirect cost associated with the activities might be the reason for the significant

association. The indirect cost might be employing a full-time person to take care of writing,

documenting and monitoring activities in compliance with a food safety plan, such as writing a

water management plan and policy for possible hazard identification or documentation on

corrective actions and a trace back and forward exercise.

Only 22% of the growers mentioned that a lack of resources was a barrier for them. On

the other hand, the test of association showed that GAP resources needed to comply with the

standard were significantly as well as linearly associated with a relative higher number of

standard requirements. For example, the challenge to routine monitoring of animal activities, use

of proper cleaning and sanitizing procedures, preparing a checklist to verify the cleanliness of

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shipping units, performing a pre-harvest and water system risk assessment, and documenting

corrective actions were associated with resources.

Although GAP knowledge was reportedly a barrier to only 20% of survey respondents, it

was significantly associated with standards related to employees’ hygienic practices, writing

corrective actions, writing risk assessment on domestic and wild animal activities, and

conducting water system risk assessments. Clarity in GAP guidelines was identified as a major

GAP barrier that was, however, not associated to any of the harmonized standards.

Almost 70% of the surveyed producers indicated that identifying what to include in a risk

assessment plan was an obstacle in performing risk assessments. Such findings shed light on the

disconnect in communication between growers and auditors regarding a comprehensive risk

assessment plan. Thus, to ensure better implementation of a GAP certification program, there

needs to be effective and clear risk communication between the auditing agencies/auditors and

the producers. Future studies focusing on risk communication may consider adopting mental

models to determine how growers and auditors perceive risk associated with various on-farm

practices (Eggers et al., 2010).

The study showed that identification of potential sources of contamination was not a

major barrier for produce growers. However, writing a risk-mitigating plan was a challenging

task for four out of ten produce growers. Another major challenge for growers was accessing and

understanding the latest scientific information on produce safety. Effective implementation of a

GAP program requires growers not only to keep up-to-date on emerging food safety issues but

also to take measures to mitigate those risks. Therefore, it also becomes a responsibility of

outreach agencies to inform growers regarding recent developments in produce safety as well as

science-based methods of controlling emerging issues in a manner that enables growers to easily

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access and understand them. USDA GAP-certified growers were able to identify the potential

source of contaminations on the farms and did not consider them a barrier in performing risk

assessments, according to study results.

The potential barriers to performing risk assessments on the farms were tested to examine

their associations and relationships with performing post-harvest, water system, and animal

activity risk assessments. Although identification of the source of contamination was not

assessed as a barrier by the majority of produce growers, results showed significant association

and positive relationships with carrying out pre-harvest, water system and animal activity risk

assessments. In other words, growers who rated complying with all three risk assessment

standards as challenging were also likely to find the identification of the source of contamination

to be a barrier.

Growers who reported pre-harvest and water system risk assessments to be challenging

compliance task were likely to find writing management procedures to reduce risks and prepare

food safety plan verification checklists to be risk assessment barriers. The barrier in preparing a

risk assessment plan was significantly and positively related to the challenge in performing a pre-

harvest risk assessment.

Conclusions

Conclusions are based on across-methodology validation through confirmation and

contradictions in the findings. The preconceived notion is that suppliers who decide to go

through the GAP auditing process and receive certifications do make the necessary modifications

in accordance with the guidelines. Growers stated that the first year of GAP implementation for

the audit was difficult compared to subsequent years. In other words, preparation for certification

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is more challenging than subsequent years, when the growers know which modifications they

need to make to become certified, and all of the documentation is in place.

The study revealed that audited farm operations were largely in compliance with food

safety standards, except for a few with higher noncompliance rates. Examples include glove use

policy, worker education and training, policies about sub-contractors, and maintenance of

vehicles and equipment. Furthermore, noncompliance with standards varies from state to state.

The absence of written policy, incomplete documentation, absence of or incomplete records, and

workers’ nonadherence with company policies were the criteria in most cases requiring

corrective actions. The failure of a few farm operations to pass audits and obtain GAP

certifications highlighted their lack of preparation for complying with GAP standards.

Meeting the requirements of the harmonized standards about passing audits does not

necessarily reflect the fact that the standards may not be challenging due to numerous on-farm

constraints. Although growers are largely in compliance with general food standards, survey

findings showed that writing a food safety plan and keeping records on the plan were challenging

tasks for most produce growers. Writing a risk assessment plan and monitoring of domestic and

wild animal activities were also found to be challenging tasks.

The study indicated no significant differences in PA, NY, and NJ growers’ experiences in

implementing GAPs. Similarly, except for a couple of standards related to transportation, there

was no significant association or relationships between the type of produce grown by producers

and their challenge in meeting food safety standards. Therefore, the study may conclude that

growers’ experiences with incorporating the harmonized food safety standards were similar

irrespective of their farm location and the types of produce they grew.

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The study, aligned with findings from other similar studies, revealed time and cost to be

the major barriers to GAP adoption. GAP knowledge and resources were also barriers for many

produce growers in this study. Survey results also showed that excessive documentation and

paperwork needed to be completed to pass an audit, necessitating an additional burden of

employing a worker for that purpose. Additionally, the lack of understanding of what to include

in a risk assessment plan and what the auditors would look for in a risk assessment plan was a

major obstacle for produce growers in carrying out risk assessments.

Produce growers in five Mid-Atlantic states and New York obtained GAP information

from various sources. This study identified Cooperative Extension as a major GAP information

provider along with a USDA GAP user guide for GAP-certified growers. Eggers et al. (2010)

also reported growers’ preference for GAP information and support from agricultural extension

agents and university experts. Certified growers in those states mostly sold their produce directly

to restaurants, supermarkets, consumers and resellers such as wholesaler distributors. The study

also concluded that certified growers complying with harmonized GAPs food safety standards

were more likely to stay in the harmonized program and renew their certification annually.

Implications for Extension. The Cooperative Extension Service has a mandate to serve

the farming community through non-formal education and assistance. Extension has been

offering workshops and training programs to produce growers to implement food safety practices

and prepare for GAP audits (Mahmoud, Stafne, Coker, Bachman, & Bell, 2016). These GAP

workshops were found to be effective in increasing growers’ knowledge and attitude changes on

the adoption of GAPs (Nayak, Tobin, Thomson, Radhakrishna, & LaBorde, 2015; Shaw,

Strohbehn, Naeve, Domoto, & Wilson, 2015).

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One of the purposes of the study was to assist Cooperative Extension in developing and

improving on-farm food safety programming through the provision of valid evidence that better

serves and prepares growers. The study identified areas of GAP harmonized audits in which

growers are more likely to fail to meet requirements and standards found to be a compliance

challenge. Identification of these specific standards would be valuable to Extension as it seeks to

improve current programs, prioritize objectives, and design new programming interventions.

Figure 5.1 presents the overall findings of the audit and survey analyses. The figure

displays food safety standards that frequently lack compliance as well as challenging food safety

standards. Extension food safety programming should focus on these standards and prioritize

them in their curricula recognizing the barriers growers face in implementing GAPs and carrying

out risk assessments on their farms. Findings from this study have implications for Extension as

it works to improve current and tailor new programs to educate, train, assist, and prepare produce

growers to successfully incorporate GAP programs on farms and obtain GAP certification. The

study makes the following recommendations should be considered by Extension:

1. Training growers on writing a food safety plan for the operation and effective

communication of those policies to farm employees. More specifically, this would

include policies related to the use of gloves in the field by the workers and policies for

subcontractors., if applicable to the farm;

2. Educating growers about ways to efficiently identify and evaluate all potential food

safety hazards during field production and harvesting practices and writing an effective

hazard control plan (Bihn & Gravani, 2006);

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3. Writing procedures for (1) testing and sampling, (2) corrective actions, (3) field

packaging and harvest containers, (4) non-root crop management practices, and (5)

handling and storage of harvest containers;

4. Training farm workers to adopt good hygienic practices;

5. Offer commodity-specific training to growers and more importantly educating growers

about past cases of outbreaks linked to particular fruits and vegetables and the traced

sources of contaminations (Rangarajan et al., 2002);

6. Working closely with stakeholders to establish an effective communication link between

auditing agencies and growers;

7. Offering training programs not only to growers who are newly establishing GAP

programs for their farms, but also producers who have been through the auditing process

already in past years; and

8. The promotion of food safety culture in farm operations.

Food safety culture. Powell, Jacob, and Chapman (2010) advocated the adoption of food

safety culture in food manufacturing, processing and service facilities to reduce the rate of

foodborne illness. Their main argument was that organizational culture change could more

effectively lead to practice change than only by educational training. Educational training models

that solely focus on knowledge dissemination in order to bring about change in practice are often

criticized for linearity in assumptions. Extension services can simultaneously promote and assist

growers and farm workers to adopt a food safety culture on their farms.

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PA NY VA MD DE NJ

Figure 5.1. Overall result chart showing implications for Extension©

)

Target States

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Yiannas (2009) strongly supported creating a behavior-based food safety management

system in which the food safety system is an integral part of organizational culture. According to

Griffith, Livesey, and Clayton (2010) “food safety culture can be viewed as the shared attitudes,

values and beliefs towards the food safety behaviors that are routinely demonstrated in food

handling organizations” (p. 434). Figure 5.2 characterizes the worker’s ability and responsibility

in an ideal food safety cultural setting as presented in Powell et al. (2011). In a food safety

cultural setting, the farm employees (1) are able to effectively evaluate and manage risks linked

to foods they handle, (2) stay informed of emerging food safety issues, (3) promote a value

system that discourages illnesses, (4) communicate effectively risk-reduction messages and also

empower others to adopt the practices, (5) endorse an effective food system in the operation, and

(6) do not blame customers or take responsibility when reported illness is linked to products

from their farm operations.

Food Safety Modernization Act. The passage of FSMA was a major step towards

revamping food safety law in the U.S (Yang & Swinburne, 2016). FSMA makes food production

facilities, suppliers, processors, and packer liable for implementing science-based preventive

measures. With the introduction of produce safety rules under the FSMA, produce safety is

moving from a more voluntary regulatory environment into a mandatory one. The produce rule

applies to all farms that grow produce likely eaten raw with average annual produce sales over

$25,000 with certain criteria of exemptions. The application of the produce rule varies according

to the category of produce, production method, market coverage, and sales of the operation.

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Figure 5.2. Aspects of food safety culture (from Powell, Jacob, & Chapman, 2011)

Adherence to the requirements FSMA incurs additional costs for farm businesses.

Discussing the implications of FSMA for growers, Calvin (2013) stated that “those who were

proactive in adopting food safety practices may not face many additional requirements with

FSMA; others may face substantial new requirements” (p. 2). Concerns have been raised

regarding the performance and compliance of small farmers in this regulatory environment with

the additional burden of conformity. Large farms with established food safety programs are in

better position to meet the requirements relative to the small farms. Boys, Ollinger, and Geyer

(2015) studied the implications of the FSMA for small-scale farms in the U.S. However, through

the Tester-Hagan Amendment, small farms may be exempted from some of the provisions of

FSMA.

Food Safety Culture

Knowledge of Risk &

Management

No Blaming to Customers

Up-to-date with

Emerging Issues

Promote a Value System

Effective Communicati

on System

Effective Food Safety

System

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At this point, the extent to which various criteria for exemptions would affect small farm

businesses is unclear. However, those buying produce from small farms may demand that

suppliers comply with their FSMA-like food safety requirements (Boys, Ollinger, & Geyer 2015;

Lichtenberg & Page, 2016). In other words, foodservice and retailers may still require their

suppliers to obtain GAP audits from various programs, even though they are exempt under the

FSMA. Gorny (n.d.) pointed out that produce GAPs Harmonized Food Safety Standards will

more likely incorporate the FSMA produce rules. In a regulatory setting, producers wanted to

utilize food safety audits as a tool for market access. However, after the passage of FSMA,

producers may want to use GAPs harmonized certification to show compliance with FSMA

requirements. Roland (2015) analyzed the effects of produce rules and the exemption criteria on

the farmers and argued that the regulations will ultimately impact the customers. With the

exemption of a large number of farms from FSMA, the exact impact of FSMA on controlling

foodborne illnesses cannot be assessed (Roland, 2015).

Recommendations for Future Studies

This study focused on USDA-audited farm operations for field operations and harvesting

harmonized standards in the Mid-Atlantic region of the U.S. Similar studies should be conducted

in other regions to assess growers compliance with food safety standards and to determine

whether variation in location has any effect on GAP compliance. The current study intended to

collect responses from all accessible USDA harmonized GAP-certified growers. Studies that

focus on a larger population and wider geographic region may consider using stratified random

sampling methods when selecting representative samples.

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Future studies also may include farms that are being audited by other certifying agencies

such as GLOBAL G.A.P. and SCS Global Services. In this study, the sample size from

Maryland, Delaware, and Virginia was proportionally low in comparison with that from

Pennsylvania, New York, and New Jersey, and therefore, restricted the generalizability of study

findings. The addition of farm operations audited by other certifying agencies to the sample

frame will not only increase sample size but also increase the generalizability of findings.

Researchers also may find this an opportunity to assess the similarities and variations in

challenging food safety requirements, GAP information sources, and the amount of information

growers receive from those resources across different states and auditing agencies.

A typical produce harmonized GAPs audit checklist contains additional information

related to farm size, address, audit duration, and more importantly, commodity type. Since

information in the accessed audits on commodity type was redacted, no direct relationship

between products and food safety practices was examined. Information on product type in

assessing growers’ compliance with food safety standards might be useful to outreach agencies

seeking to better serve growers who wish to meet producers’ commodity-specific GAP

requirements. Thus, future studies should use audit analysis as a methodological approach when

considering commodity type as a variable and determining its relationship with farm practices.

Assessment studies that intend to understand the overall aspects of the adoption of

preventive measures on farms and barriers to their implementation may need to expand the study

questionnaire with additional questions. On the other hand, analysis of the effect of time, cost,

and resources and the relationship of produce marketing channels and farm size with GAP

adoption would be beneficial to outreach agencies seeking to tailor effective on-farm food safety

programs for produce growers. For example, a cost-benefit analysis would be useful in

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determining the burden of cost on growers in modifying practices to incorporate food safety

programs and the return incentive for such changes. With regard to risk assessments on farms,

the study recognizes the significance of consistencies in growers’, experts,’ and auditors’

perceptions of food safety risks associated with various potential hazards. Therefore, further

research is necessary to determine areas of inconsistency in perceiving risks in establishing an

effective communication model for all major players.

Follow-up in-depth interviews with produce growers and auditors would be beneficial to

improving understanding of growers’ experience with GAP programs and commodity-specific

GAP needs. To enhance the rigor of the study design and collect more evidence on GAP

implementation, further research should be conducted that takes auditors’ perspectives into

account. Additional information provided by auditors would not only further validate findings

but also introduce auditors’ perspectives on on-farm implementation of GAPs. The inclusion of

auditors to the research design might help in establishing effective communication between the

growers’ and auditors’ expectations. Studies should also be conducted with packers and

distributors on their compliance with food safety standards to assess the adoption of post-harvest

harmonized standards. In addition to harmonized GAP audit programs, evaluation studies may

also focus on other produce GAP auditing programs to understand producers’ GAP experiences.

The study did not find any significant difference in growers’ experiences with complying

with challenging food safety standards. The study concluded that in general, the audited produce

growers in Delaware, Maryland, New Jersey, New York, Pennsylvania, and Virginia were in

compliance with the harmonized GAP standards except for a few farms that failed to obtain

certification. Produce growers in these states profoundly rely on Cooperative Extension for GAP

information. Therefore, findings have implications for Extension as it seeks to improve on-farm

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farm food safety programming and assist growers in obtaining certifications. The study urges

Extension to promote food safety culture through educational and training programs.

Study conclusions were based on certain critical assumptions—e.g., auditors are equally

trained and there are no variations in their competency to assess of GAP compliance.

Assumptions were also made that supported no variations in auditors’ interpretations of food

safety standard requirements and perception of risks. The USDA (2011) user’s guide claims that

auditors undergo rigorous training before officially being licensed to conduct farm audits in

order to provide impartial assessments. Auditors receive formal classroom and job training, and

are evaluated by program management before they receive their license to audit. Auditors are

evaluated yearly and take yearly ethics and professional development training. The guide also

states that “USDA licensed auditors provide impartial, prompt third party services to the fruit

and vegetable industry and have no financial interest in the products and services they are

auditing” (USDA, 2011, p. 2). All USDA audit program auditors meet strict training and

evaluation criteria following AMS Auditor criteria (Petersen, 2015).

Even in the presence of claims made by the USDA, the possibility of variations among

auditors in interpreting and evaluating compliance with individual standard requirements cannot

be discarded. Gorny (n.d.) and Petersen (2015) stated that that produce GAPs harmonized food

safety standards purposely did not address auditor competence. The revelation that relatively

higher proportions of produce farms in New Jersey were not compliant with food safety

standards definitely opens a discourse in this regard. Relevant questions may include following:

are the New Jersey auditors more stringent than their counterparts in Delaware, Maryland, New

York, Pennsylvania, and Virginia? Do their personal traits and perceptions affect audit

outcomes? Is there any difference in audit outcomes when the audit process is carried out by an

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individual auditor or by a group of auditors? Each of these questions seems relevant. Ho (2016)

used variation in code violations among food inspectors to study the effect of peer review. The

study found significant differences in reported code violations between restaurant inspectors

when inspected identical conditions. This likely applies to farm food safety auditors. The

different perceptions of the significance of farm food safety risks among auditors could be a

reason for variability between states and within states.

While engaging in discourses on auditors may likely shift the focus from variations in the

implementation of GAPs by produce growers to the legitimacy of the auditing process, it is

necessary to evaluate the food safety regulatory and enforcement system. Studies that focus on

deficiencies in GAP compliance should take both aspects of GAP implementation by growers

and certification process for auditors into consideration. This may be one of the limitations of the

study— not to including auditors as one of the mediating variables in assessing GAP

implementation on farms.

Summary

The analysis of audits helped in identifying standards as well as criteria for GAP

noncompliance. The mail surveys further validated findings from the audit analysis. Frequent

noncompliance was reported for standards related to having a food safety policy for

subcontractors and policy on glove use by the farm workers. Writing a food safety plan and

keeping records on it were found to be challenging tasks for growers.

Testing and sampling and hygienic practices by farm workers emerged as major food

safety concerns on farms in the Mid-Atlantic states and New York. Convincing workers to

follow hygienic practices in the field was challenging for growers. Furthermore, writing

procedures for water testing and water management plans, and implementing these plans are

138

areas in which where growers may need assistance in order to comply with audit requirements.

Time and cost were identified as major barriers to GAP implementation. On the other hand, lack

of knowledge on the content of risk assessment plans and deficiencies in communications with

auditors were found to be major barriers to carrying out risk assessments on farms.

139

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Appendix A

Field Operations and Harvesting Harmonized Standards

Standard Requirement

1.1.1. A food safety policy shall be in place.

1.1.2. Management has designated individual(s) with roles, responsibilities, and resources for food

safety functions.

1.1.3. There is a disciplinary policy for food safety violations.

1.2.1. There shall be a written food safety plan that covers the operation.

1.2.2. The food safety plan shall be reviewed at least annually.

1.3.1. Documentation shall be kept that demonstrates the food safety plan is being followed.

1.3.2. Documentation shall be retained for a minimum period of two years, or as required by

prevailing regulations.

1.3.3. Documentation shall be retained for a minimum period of two years, or as required by

prevailing regulation.

1.4.1. All personnel shall receive food safety training.

1.4.2. Personnel with food safety responsibilities shall receive training sufficient to their

responsibilities.

1.4.3. Subcontractors are held to the relevant food safety standards as they would be as employees.

1.5.1. Where laboratory analysis is required in the Food Safety Plan, testing shall be performed by

a GLP laboratory using validated methods.

1.5.2. Where microbiological analysis is required in the food safety plan, samples shall be drawn in

accordance with an established sampling procedure.

1.5.3. Tests, their results and actions taken must be documented.

1.5.4. All required testing shall include test procedures and actions to be taken based on the results.

1.6.1. A documented traceability program shall be established

1.6.2. A trace back and trace forward exercise shall be performed at least annually.

1.7.1. A documented recall program, including written procedures, shall be established.

1.8.1. The operation shall have documented corrective action procedures.

1.9.1. The operation shall have documented self-audit procedures.

2.1.1.

The food safety plan shall, initially and at least annually thereafter, evaluate and document

the risks associated with land use history and adjacent land use including equipment and

structures.

2.1.2. For indoor growing and field storage facilities, facility shall be designed, constructed and

maintained in a manner that prevents contamination of produce.

2.2.1. Operation shall have a policy for toilet, hygiene, and health.

155

2.2.2. Employees and visitors shall follow all personal hygiene practices as designated by the

operation.

2.2.3.

Toilet facilities shall be designed, constructed, and located in a manner

that minimizes the potential risk for product contamination and are directly

accessible for servicing.

2.2.4. Toilet facilities shall be of adequate number, easily accessible to employees and in

compliance with applicable regulation.

2.2.5. Toilet and wash stations shall be maintained in a clean and sanitary condition.

2.2.6. Personnel shall wash their hands at any time when their hands may be a source of

contamination.

2.2.7. Signage requiring handwashing is posted.

2.2.8. Clothing, including footwear, shall be effectively maintained and worn so as to protect

product from risk of contamination.

2.2.9. If gloves are used, the operation shall have a glove use policy.

2.2.10. Protective clothing, when required, shall be maintained, stored, laundered and worn so as to

protect product from risk of contamination.

2.2.11. When appropriate, racks and/or storage containers or designated storage area for protective

clothing and tools used by field employees shall be provided.

2.2.12. The wearing of jewelry, body piercings and other loose objects (e.g. false nails) shall be in

compliance to company policy and applicable regulation.

2.2.13. The use of hair coverings shall be in compliance to company policy and applicable

regulation.

2.2.14. Employees' personal belongings shall be stored in designated areas.

2.2.15. Smoking, chewing, eating, drinking (other than water), urinating, defecating or spitting is not

permitted in any growing areas.

2.2.16. Operation shall have a written policy that break areas are located so as to not be a source of

product contamination.

2.2.17. Drinking water shall be available to all field employees.

2.2.18. Workers and field personnel who show signs of illness shall be restricted from direct contact

with produce or food-contact surfaces.

2.2.19. Personnel with exposed cuts, sores or lesions shall not be engaged in handling product.

2.2.20. Operation shall have a blood and bodily fluids policy.

2.2.21. First Aid Kits shall be accessible to all personnel.

2.3.1. Use of agricultural chemicals shall comply with label directions and prevailing regulation.

2.3.2. If product is intended for export, agricultural chemical use, including postharvest chemicals,

shall consider requirements in the intended country of destination.

2.3.3. Agricultural chemicals shall be applied by trained, licensed or certified application

personnel, as required by prevailing regulation.

156

2.3.4. Water used with agricultural chemicals shall not be a source of product or field

contamination.

2.3.5. Agricultural chemical disposal shall not be a source of product or field contamination.

2.4.1.1. A water system description shall be available for review.

2.4.1.2. The water source shall be in compliance with prevailing regulations.

2.4.1.3. Agricultural water systems shall not be cross-connected with human or animal waste

systems.

2.4.2.1.

An initial risk assessment shall be performed and documented that takes into consideration

the historical testing results of the water source, the characteristics of the crop, the stage of

the crop, and the method of application.

2.4.3.1. There shall be a water management plan to mitigate risks associated with the water system

on an ongoing basis.

2.4.3.2.

Water testing shall be part of the water management plan, as directed by the water risk

assessment and current industry standards or prevailing regulations for the commodities

being grown.

2.4.3.3. The testing program shall be implemented consistent with the water management plan.

2.5.1. The operation has a written risk assessment on animal activity in and around the production

area.

2.5.2. The operation routinely monitors for animal activity in and around the growing area during

the growing season.

2.5.3. Based on the risk assessment, there shall be measures to prevent or minimize the potential

for contamination from animals, including domestic animals used in farming operations.

2.6.1. The food safety plan shall address soil amendment risk, preparation, use, and storage.

2.6.2. If a soil amendment containing raw or incompletely treated manure is used, it shall be used

in a manner so as not to serve as a source of contamination of produce.

2.7.1. Equipment, vehicles, tools utensils and other items or materials used in farming operations

that may contact produce are identified.

2.7.2. Equipment, vehicles, tools and utensils used in farming operations which come into contact

with product are in good repair, and are not a source of contamination of produce.

2.7.3. Vehicles, equipment, tools and utensils shall be controlled so as not to be a source of

chemical hazards.

2.7.4. Vehicles, equipment, tools and utensils shall be controlled so as not to be a source of

physical hazards.

2.7.5. Cleaning and sanitizing procedures do not pose a risk of product contamination.

2.7.6. Water tanks are cleaned at a sufficient frequency so as not to be a source of contamination.

3.1.1. A pre-harvest risk assessment shall be performed.

3.2.1. Operation has procedures for water used in contact with product or food contact surfaces.

3.2.2. Water use SOPs address the microbial quality of water or ice that directly contacts the

harvested crop or is used on food-contact surfaces.

157

3.2.3. Water use SOPs address treatment of re-circulated water, if used.

3.2.4. Water use SOPs address condition and maintenance of water-delivery system.

3.2.5. If applicable to the specific commodity, water use SOPs address control of wash water

temperature.

3.3.1. Operation has written policy regarding storage of harvesting containers.

3.3.2. Operation has written policy regarding inspection of food contact containers prior to use.

3.3.3. Operation has written policy regarding acceptable harvesting containers.

3.3.4. Operation has written policy prohibiting use of harvest containers for non-harvest purposes.

3.4.1. Operation shall have a written policy that damaged or decayed produce is not harvested, or is

culled.

3.4.2. Product that contacts the ground shall not be harvested unless the product normally grows in

contact with the ground.

3.4.3. Harvest procedures shall include measures to inspect for and remove physical hazards.

3.4.4. Cloths, towels, or other cleaning materials that pose a risk of cross-contamination shall not

be used to wipe produce.

3.4.5. Packaging materials shall be appropriate for their intended use.

3.4.6. Packaging shall be stored in a manner that prevents contamination.

3.4.7. Operation has written policy regarding whether packing materials are permitted in direct

contact with the soil.

3.5.1. Harvested produce is handled in a manner such that it is not likely to become contaminated.

3.5.2. Materials that come in contact with the produce shall be clean and in good repair.

3.5.3. Harvested produce shall be stored separately from chemicals which may pose a food safety

hazard.

4.1.1. The operation shall have a policy, written procedures, and a checklist to verify cleanliness

and functionality of shipping units (e.g., trailer).

4.1.2. Loading/unloading procedures and equipment shall minimize damage to and prevent

contamination of produce.

4.1.3. Trash shall not come in contact with produce.

158

Appendix B

Overall Count Tables for PA, DE, MD, NJ and NY

State 1.1.1. 1.1.2. 1.1.3. 1.2.1. 1.2.2. 1.3.1 1.3.2. 1.4.1. 1.4.2. 1.4.3. 1.5.1. 1.5.2. 1.5.4. 1.6.1. 1.6.2. 1.7.1. 1.8.1. 1.9.1.

PA 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 1 2

DE 1 1 0 1 0 1 1 1 1 2 0 2 2 0 0 0 0 0

MD 0 0 0 0 1 0 0 0 0 0 0 0 0 0 1 0 3 0

NJ 0 0 0 0 0 1 0 2 1 24 1 2 6 2 2 2 2 2

NY 0 0 2 0 1 0 0 3 0 4 0 1 0 0 0 0 1 1

Total 1 1 2 1 2 2 1 6 2 31 1 5 8 2 3 2 7 5

State 2.1.1. 2.2.2 2.2.4 2.2.5 2.2.6 2.2.7 2.2.8 2.2.9 2.2.10 2.2.11 2.2.12 2.2.13 2.2.14 2.2.15 2.2.16 2.2.17 2.2.21

PA 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 1

DE 0 2 0 0 2 0 0 2 3 3 1 0 2 2 1 0 1

MD 0 0 1 0 0 0 0 0 0 0 0 0 0 1 0 0 1

NJ 2 1 0 1 1 1 1 9 0 1 2 0 3 1 1 1 2

NY 0 0 0 3 0 2 0 1 0 0 1 3 0 0 0 1 0

Total 2 3 1 4 3 3 1 12 3 4 4 3 5 5 2 2 5

State 2.3.3 2.3.4 2.3.5 2.4.1.1 2.4.1.2 2.4.1.3 2.4.2.1 2.4.3.1 2.4.3.2 2.4.3.3 2.5.1 2.5.2 2.6.1 2.6.2 2.7.1 2.7.2 2.7.3 2.7.4 2.7.5 2.7.6

PA 1 0 0 2 0 1 0 1 0 0 0 0 0 0 0 3 0 0 0 0

DE 0 0 1 0 0 0 1 1 1 1 1 2 1 1 2 1 1 2 0 2

MD 0 0 0 0 0 0 0 0 2 0 0 0 0 0 0 1 0 2 0 0

NJ 0 1 0 0 0 0 2 1 2 3 0 2 0 0 4 4 3 1 3 2

NY 0 2 0 1 1 0 1 0 1 1 0 1 0 1 3 2 0 0 0 2

Total 1 3 1 3 1 1 4 3 6 5 1 5 1 2 9 11 4 5 3 6

State 3.1.1. 3.2.5. 3.3.1. 3.3.3. 3.3.4. 3.4.1. 3.4.2. 3.4.3. 3.4.4. 3.4.6. 3.4.7. 3.5.1. 3.5.2. 4.1.1. 4.1.3.

PA 0 1 0 0 1 0 0 0 0 0 0 0 0 1 0

DE 0 0 1 0 0 0 0 0 1 1 1 0 0 1 1

MD 0 0 0 0 0 1 1 1 0 0 0 0 0 1 0

NJ 0 0 3 1 0 1 1 0 1 0 1 2 1 5 2

NY 1 0 2 1 0 2 0 0 2 0 2 1 0 5 0

Total 1 1 6 2 1 4 2 1 4 1 4 3 1 13 3

159

Appendix C

H0: There were no statistical differences in proportions of growers in Pennsylvania and New Jersey who rated

food safety standards as moderately to very challenging.

Table 4.21

Proportional Differences for Most Challenging Food Safety Standards for Growers of PA and NJ

Most Challenging Standards Pennsylvania

New

Jersey

Prop.

Difference z Score p

Value n1𝜋1 n1 n2𝜋2 n2 𝜋1- 𝜋2

Writing a food safety plan 20 49 12 17 -0.298 -2.12* 0.034

Keeping records for a food safety

plan 23 53 10 17 -0.154 -1.11 0.267

Writing and implementing a

water management plan 19 48 7 16 -0.042 -0.29 0.772

Documentation to assure that

sub-contractors’ compliance 11 27 6 16 0.032 0.21 0.834

Writing a risk assessment on

domestic and wild animal activity 22 52 5 17 0.129 0.95 0.342

Writing and implementing

policies and procedures in plan,

such as use of gloves

16 49 6 17 -0.085 -0.64 0.522

Documenting and carrying out a

trace back and forward exercise 20 51 4a 16 0.142 1.03 0.303

Routinely monitoring of animal

activity 17 52 3a 16 0.139 1.07 0.285

Documenting corrective actions 18 51 4a 16 0.103 0.77 0.447

Writing procedures for water

testing 15 50 5 16 -0.012 -0.10 0.928

Making sure that employees

follow hygienic practices 12 53 7 17 -0.186 -1.50 0.134

Conducting a water system risk

assessment 14 49 5 16 -0.026 -0.20 0.841

Writing a policy identifying and

controlling potential food safety

hazards during harvesting 11 48 7 16 -0.209 -1.61 0.107

Note. *p<.05;

𝑛𝜋 = The number participants indicated the standard is moderately or very challenging; a𝑛𝜋<5

160

H0: There were no statistical differences in proportions of growers in Pennsylvania and New York who rated

food safety standards as moderately to very challenging.

Table 4.22

Proportional Differences for Most Challenging Food Safety Standards for Growers of PA and NY

Most Challenging Standards Pennsylvania New York

Proportional

Difference z Score p

Value

n1𝜋1 n1 n2 𝜋2 n2 𝜋1- 𝜋2

Writing a food safety plan 20 49 13 35 0.037 0.34 0.728

Keeping records for a food safety

plan 23 53 16 35 -0.023 -0.21 0.834

Writing and implementing a water

management plan 19 48 8 31 0.138 1.26 0.208

Documentation to assure that sub-

contractors’ compliance 11 27 5 23 0.19 1.44 0.150

Writing a risk assessment on

domestic and wild animal activity 22 52 9 34 0.158 1.49 0.134

Writing and implementing policies

and procedures in plan, such as

use of gloves

16 49 11 35 0.013 0.12 0.905

Documenting and carrying out a

trace back and forward exercise 20 51 9 35 0.135 1.30 0.194

Routinely monitoring of animal

activity 17 52 10 34 0.033 0.32 0.749

Documenting corrective actions 18 51 7 35 0.153 1.54 0.126

Writing procedures for water

testing 15 50 8 29 0.024 0.23 0.818

Making sure that employees

follow hygienic practices 12 53 6 35 0.055 0.63 0.529

Conducting a water system risk

assessment 14 49 5 29 0.114 1.13 0.259

Writing a policy identifying and

controlling potential food safety

hazards during harvesting 11 48 6 35 0.058 0.64 0.522

𝑛𝜋 = the number participants indicated the standard is moderately or very challenging

161

H3: There were no statistical differences in proportions of growers in New York and New Jersey who rated food

safety standards as moderately to very challenging.

Table 4.23

Proportional Differences for Most Challenging Food Safety Standards for Growers of NY and NJ

Most Challenging Standards New York New Jersey

Proportional

Difference z Score p

Value n1𝜋1 n1 n2𝜋2 n2 𝜋1- 𝜋2

Writing a food safety plan 13 35 12 17 -0.335 -2.26* 0.024

Keeping records for a food safety

plan 16 35 10 17 -0.131 -0.89 0.374

Writing and implementing a

water management plan 8 31 7 16 -0.18 -1.25 0.211

Documentation to assure that sub-contractors’ compliance

5 23 6 16 -0.158 -1.08 0.280

Writing a risk assessment on

domestic and wild animal activity 9 34 5 17 -0.029 -0.22 0.826

Writing and implementing

policies and procedures in plan,

such as use of gloves

11 35 6 17 -0.039 -0.28 0.779

Documenting and carrying out a

trace back and forward exercise 9 35 4a 16 0.007 0.05 0.960

Routinely monitoring of animal

activity 10 34 3a 16 0.106 0.80 0.424

Documenting corrective actions 7 35 4a 16 -0.05 -0.40 0.689

Writing procedures for water

testing 8 29 5 16 -0.036 -0.26 0.795

Making sure that employees

follow hygienic practices 6 35 7 17 -0.241 -1.88** 0.060

Conducting a water system risk

assessment 5 29 5 16 -0.14 -1.08 0.280

Writing a policy identifying and

controlling potential food safety

hazards during harvesting 6 35 7 16 -0.267 -2.02* 0.043

𝑛𝜋 = the number participants indicated the standard is moderately or very challenging

*p<.05, **p<.10

162

Appendix D

1. Please rate () how challenging it is to comply with the following USDA GAPs Harmonized Food Safety Standards. Indicate “NA” if it is not applicable to your farm.

GAPs Harmonized Standards

Food safety plan

Not

Challenging

Slightly

Challenging

Somewhat Challenging

Moderately Challenging

Very

Challenging NA

Writing a food safety plan

Keeping records for a food safety plan

Writing and implementing policies and procedures in your plan, such as whether or not you require gloves when handling produce

Documentation

Not

Challenging

Slightly

Challenging

Somewhat Challenging

Moderately Challenging

Very

Challenging NA

Documenting corrective actions

Documenting self-audit procedures

Documenting and carrying out a trace back and forward exercise

Employees’ training

Not

Challenging

Slightly

Challenging

Somewhat Challenging

Moderately Challenging

Very

Challenging NA

Ensuring that employees are adequately trained in food safety

Making sure that employees follow hygienic practices

Keeping records that document employees received food safety training

Water management

Not

Challenging

Slightly

Challenging

Somewhat Challenging

Moderately Challenging

Very

Challenging NA

Writing and implementing a water management plan

Writing procedures for water testing, such as frequency of testing, how the sample is collected, and type of test

Finding a water testing laboratory that is certified to be following “Good Laboratory Practices”

Go to Page 2

163

2. Please rate () how challenging it is to comply with the following USDA GAPs Harmonized Food Safety Standards. Indicate “NA” if it is not applicable to your farm.

GAPs Harmonized Standards

Cleaning procedures

Not

Challenging

Slightly

Challenging

Somewhat Challenging

Moderately Challenging

Very

Challenging NA

Keeping equipment, vehicle, tools and utensils in good repair

Using proper cleaning and sanitizing procedures

Having a disciplinary policy for any food safety violations

Harvesting policy

Not

Challenging

Slightly

Challenging

Somewhat Challenging

Moderately Challenging

Very

Challenging NA

Writing and implementing a policy regarding cleanliness of harvesting containers

Writing a policy regarding preventing non-root crop produce from contacting the ground after harvest

Writing a policy that identifies potential food safety hazards during harvesting and how you plan to control them

Transportation

Not

Challenging

Slightly

Challenging

Somewhat Challenging

Moderately Challenging

Very

Challenging NA

Writing procedures for cleanliness and proper functioning of shipping units and preventing damage to produce before loading onto truck

Preparing a checklist to verify cleanliness of shipping units, such as a trailer

Writing a policy for how trash should be safely handled and kept out of fields

3. Out of the following items, which is/are the major barrier/s to implement GAPs on your farm? (Check all that apply)

Time

Cost

Resources

Adequate knowledge of GAPs

Clarity in GAP guidelines

Other, please specify__________________________________________________

Not Applicable

Go to Page 3

164

4. Please rate () how challenging it is to comply with the following USDA GAPs Harmonized Food Safety Standards. Indicate “NA” if it is not applicable to your farm.

GAPs Harmonized Standards

Risk assessments

Not

Challenging

Slightly

Challenging

Somewhat Challenging

Moderately Challenging

Very

Challenging NA

Performing a pre-harvesting risk assessment

Conducting a water system risk assessment

Writing a risk assessment on domestic and wild animal activity

Other standards

Not

Challenging

Slightly

Challenging

Somewhat Challenging

Moderately Challenging

Very

Challenging NA

Keeping initial risk assessment records

Routinely monitoring of animal activity

Documentation to assure that sub-contractors are complying with food safety standards

5. Out of the following activities, indicate the major barrier/s you faced when writing or carrying out risk assessments on your farm? (Check all that apply)

Figuring out what to include in a risk assessment plan

Identifying sources of contamination

Writing management procedures for reducing risks

Understanding what the auditors would look for in the plan

Preparing food safety plan verification checklists

Accessing and understanding the latest scientific information on produce food safety

Other, please specify__________________________________________________

Not Applicable

If there are any other concerns regarding risk assessments that you wish to share with us, please write them below.

__________________________________________________________________________________________________

__________________________________________________________________________________________________

__________________________________________________________________________________________________

Go to Page 4

165

6. What produce do you grow? (Check all that apply)

Fruits (Tree fruits or Berries) only

Vegetables only

Both Fruits AND Vegetables

Other, please identify______________________________________

7. How do you sell your fruits and vegetables? (Check all that apply)

Direct sales (such as supermarkets, restaurants, consumers at farm stands, farmers markets)

Sales at produce auctions

Sales through cooperatives to which you belong

Sales to resellers (such as wholesaler distributors)

Other, please specify_______________________________________

8. Please indicate () the amount of information you obtain from the following sources.

GAP Information Sources None A little A fair

amount Quite a bit

A great deal of

USDA GAPs user guide Grower associations Cooperative Extension Consultants Other farmers Online sources (websites, emails etc.) Agricultural industry representatives Other Please tell us__________________________

9. Do you intend to renew your GAPs Harmonized audit certificate annually?

Yes

No

Not sure

Additional Feedback

Please share any additional comments.

Thank you for taking the time to fill out our survey. Please mail it back to me in the enclosed postage-paid envelope.

166

Appendix E

Growers’ Comments on GAP Barriers

A. Cost cost cost

B. Finding employees to document + record keep

C. Interpretation for aeroponic system

D. It takes a full-time person to implement/start the standards/training/plan, so the greatest

barrier is time and effort and finding the right person to do it.

E. Language barriers

F. Making record keeping an un-cumbersome routine so that it gets done consistently also

having potable water for hand washing & post-harvest wash

G. Need better training material for farm

H. Paper work - Typical Gov.

I. Reuse of flume water. We treat the water with chlorine but we are being told that FSMA

wasn't allow the reuse of the water. After the flume our potatoes go through a chlorinated

wash with potable well water.

J. Smaller producers cannot devote the time required and still manage their business.

K. Some rules are stupid. Employees recognize this and do not respect them. Best example is

"no drinking anything except water." If it’s okay to drink water, what's the difference if

you're drinking coffee? For example

L. Still a lot of "grey areas" without difficult numerical values to follow ie - sanitizer rate-

no approved GAPs cleaning/chemical list

M. Time

N. Time is the biggest challenge we can do all this and cost is not that bad. But the time

involved is more than small operators can bear

O. Time to document everything

P. Trained and knowledgeable personnel that have the time to ensure that all the protocol

and records are completed

Q. Very expensive for small farms

R. Water testing is the biggest cost. 40 Wells x $70=$2800; 40 wells x $120=$4800. 2) Not

all guidelines are straight forward and can be interpreted multiple ways. I have had

167

many disagreements with auditors and have challenged them. Often I have won once they

researched it.

S. We have no employees so many items (checklists) don't apply but have to be included.

Growers’ Comments on Risk Assessment Barriers

A. Excessive management time (No attempt to streamline)

B. Finding time away from farming and managing business

C. Grow indoors - what to do about what does not apply

D. Requirements are still not finalized

E. Writing easy to understand + follow SOPs

F. Writing it all down

G. You really don't know everything you need until you go through an audit

Comments on Risk Assessment

A. Food safety is basically using common sense.

B. Many times we have to guess on what companies look for. It is apparent that the main

concern is liability on food retailers - We are approaching this in a backwards manner.

C. Once in place, I feel complying with GAPs food safety standards is easy. Training all

employees would be the most challenging aspect in my opinion.

D. Pretty straight forward only you know what your

E. Prior building impacts; determining what employee hygiene wear is best suited to cooler

and other areas

F. So far no one has gotten sick from fresh apples due to on-farm practices. So we've

minimize risks that may not exist

G. Some risks are sill. Takes too much time. Manager/operators do not have extra time to

perform these added tasks

H. There are numerous risks involving in a farm operation especially tree fruit so that # of

employees + Machines operator in packing house and orchards complicate f

I. Time +Personnel=cost

J. We as a family farm operation are dedicated to raising food that is safe to eat for ourself

and others regardless of GAP. Thank you.

K. We have encountered varied opinions among auditors as to what consists sufficient

measures to address risk (specifically to irrigation water).

168

Appendix F

Manuscript Prepared in Partial Fulfilment

of the Requirements

for INTAD

169

1

Assessment of Farm Science Centre’s Involvement in Offering Food Safety 2

Training to Farmers of India 3

Roshan Nayak 4

rkn112@psu.edu 5

John Ewing 6

jce122@psu.edu 7

Edgar Yoder 8

epy@psu.edu 9

Luke LaBorde 10

lfl5@psu.edu 11

The Pennsylvania State University 12

University Park, PA 16801 13

The United States of America 14

15

16

17

18

19

170

Assessment of Farm Science Centre’s Involvement in Offering Food Safety 1

Training to Farmers of India 2

Abstract 3

Foodborne illness due to consumption of contaminated food and water is a public health 4

concern in India. This study is primarily intended to contribute to the discourse on engaging 5

Krishi Vigyan Kendras-KVKs (Farm Science Centre) in training farmers to adopt food safety 6

practices on their farms. The study objectives focused on current involvement of KVK in food 7

safety training, Programme Coordinators (PCs) of the KVKs provided information regarding 8

food safety training and programming needs. An online questionnaire was developed, validated, 9

and administered to PCs to collect data. The results showed that excessive use of pesticides, lack 10

of hygienic practices in food processing, and improper washing of vegetables were the major 11

food safety concerns. PCs were familiar with Good Agricultural Practices (GAPs) and valued the 12

importance of food safety training for farmers. KVKs with food safety subject matter specialist 13

(SMS) were more likely to offer food safety training to farmers than KVKs without food safety 14

SMSs. PCs expressed the need for having a food safety (SMS) to provide food safety training. 15

KVKs need to find ways to accommodate and prioritize on-farm food safety awareness programs 16

in their annual action plans. As one of the major component of public Extension system and with 17

its wide presence in India, KVKs should take a lead role in training Extension professionals and 18

farmers regarding on-farm food safety practices. 19

20

21

Keywords: Farm Science Centre, Krishi Vigyan Kendra, Food Safety, Extension, Assessment 22

23

171

Introduction 1

Public Health and Food Safety 2

Foodborne diseases attributed to contaminated food and water affect millions of people 3

worldwide. The World Health Organization (WHO) report documents that each year about 2.2 4

million people die due to illness caused by microbial food and water contamination (WHO, 5

2014). For example, diarrhea is one the top five causes of death in India (WHO, 2012b). The 6

impact of foodborne diseases on society can be estimated in terms of economic and social costs. 7

The economic cost includes the cost of treatment, investigation, and businesses losses; whereas, 8

the social cost includes the reduction in human productivity, pain, grief, and disability (Griffith, 9

Mullan, & Price, 1995). Foodborne diseases in India further worsen the state of poverty for 10

families as diseases affect their ability to work and add extra health costs. 11

Lack of food safety awareness coupled with untrained food handlers across the food 12

supply chain, inadequate laboratory testing facilities (Chakrabarti, 2013), and poor enforcement 13

of food safety regulations (Umali-Deininger & Sur, 2007) have contributed to an inefficient food 14

control system in India. In this fragmented system food in the supply chain is exposed to a 15

multitude of food handlers as well as the risk of exposing food to an unhygienic environment and 16

food safety hazards. In 2003, the Food and Agriculture Organization (FAO) and WHO jointly 17

published guidelines for strengthening national food control systems. This document emphasized 18

potential food safety hazards along with factors that contribute to these hazards. Potential major 19

food safety hazards include microbiological and chemical contaminants, pesticide residues, and 20

allergens (FAO & WHO, 2003). Food at the farm level when exposed to disease-causing 21

pathogens when supplied to local markets immediately impact consumers’ health. “Improper 22

agricultural practices; poor hygiene at all stages of the food chain; lack of preventive controls in 23

172

food processing and preparation operations; misuse of chemicals; contaminated raw materials, 1

ingredients and water; and inadequate or improper storage” (FAO and WHO, 2003, p. 3) promote 2

food contamination. 3

Despite the increasing concern over foodborne illness, addressing on-farm food safety 4

issues has either been neglected or marginalized in the political and academic discourses in India. 5

The Indian focus on food quality and safety standards has been largely confined to standards and 6

regulations for the export market rather than the domestic food supply (Chakrabarti, 2013). 7

Jairath and Purohit (2013) emphasized the need for food safety awareness programs to educate 8

and train farmers regarding hygiene practices. This study urges that aware and motivated farmers 9

for improving their food safety practices and the subsequent impact on consumers’ health will 10

result in farmers being likely to adopt food safety practices. Educational programs to promote 11

food safety and motivate farmers to adopt Good Agricultural Practices (GAPs) are vital in 12

addressing on-farm food safety concerns and building consumer confidence in the domestic food 13

supply. 14

GAPs represent a set of on-farm preventive measures that address microbial water 15

quality, cleaning and sanitation, worker health and hygiene, animal and pest management, and 16

manure and composting (Bihn & Gravani, 2006). Therefore, GAPs are effective preventive 17

control measures for controlling food contamination by disease-causing hazards (FAO, 2003), 18

including mycotoxins (Bhat & Vasanthi, 2003). Kaferstein (2003) in assessing the implications 19

of food safety practices on public health in developing countries, described the principles of 20

GAPs as the first line of defense to prevent contamination of food. The Quality Council of India 21

(QCI), which promotes the implementation of on-farm food safety practices, has also stated that 22

adoption of GAPs not only ensure the safety of food products but also promote sustainable 23

173

farming practices (QCI, 2014). The QCI calls for “cooperation and active partnerships with all 1

stakeholders that include farmers, industry, and consumers" to create an efficient food control 2

system (QCI, 2014, p. 4). 3

Extension and Food Safety Education 4

The study positioned public Extension as a potential stakeholder in strengthening the 5

food control system in India. The Extension service is mandated to work for welfare of farming 6

community and the society and is primarily focused on production agriculture. Farm Science 7

Centre (Krishi Vigyan Kendra-KVK) along with the State Department of Agriculture, 8

Agricultural Technology Management Agency, State Agricultural Universities are the major 9

components of the public Extension system in India (Glendenning, Babu, & Asenso-Okyere, 10

2010). First established in 1974, the primary purpose of KVK was to provide vocational training 11

to the farmers, school dropout youth, and Extension field workers. 12

At present, KVKs are functioning in 642 locations in eight zones (Zone I-VIII) of India 13

(ICAR, 2016). KVKs receive funding and technical supervision from the Indian Council of 14

Agricultural Research (ICAR) and are administered by ICAR institutes, State Agricultural 15

Universities (SAUs), Central Agricultural University (CAU), Non-Governmental Organizations 16

(NGOs) or State Agriculture Departments (Glendenning et al., 2010; ICAR, 2016). KVKs 17

prepare their yearly action plans in coordination with other stakeholders such as government 18

personnel, progressive farmers and the zonal coordinators (Glendenning et al., 2010). 19

Programme Coordinators (PCs) are the head of the KVKs, and their multifold 20

responsibilities include decision making and planning, implementing, supervising, assessment of 21

new technologies and establishing links with clientele (Chauhan, 2011). KVK functions on the 22

mandates of on-farm demonstration and evaluation of production technologies, capacity 23

174

development of farmers and extension personnel, work as a knowledge and resource center for 1

agricultural technology, and offer farm advisories to clientele on varied topics of interest (ICAR, 2

2016). Subject Matter Specialists (SMS) are multi-disciplinary extension professionals; and they 3

work with the PC in achieving the mandate of KVK (Patil & Kokate, 2011). Gowda (2012) 4

stated that “KVKs have significantly contributed in educating farmers in improved practices and 5

enhancing productivity levels” (p. 6). With a presence in almost all districts of India and 6

considering the KVK expertise and clientele base, KVK is well-positioned to take a leading role 7

in training farmers and Extension professionals regarding on-farm food safety practices. 8

Theoretical Framework 9

The study utilized an integrated approach that supports Extension’s intervention in 10

emerging areas and development of programs based on Tone’s Health Action Model (THAM) for 11

food hygienic education (Rennie (1995). Lindner and Dolly (2012) proposed a conceptual 12

framework consisting of ten areas on which Extension must focus on outreach programs. One of 13

the ten focus areas states that Extension must “address important and contemporary 14

issues/problems.” Adopting the same focus area for effective outreach, Roberts, Ganpat, Narine, 15

Heinert, and Rodriguez (2015) assessed the training needs of Trinidad food producers. 16

Extension programs with a goal of translating farmer’s knowledge gained as a result of 17

food safety training into sustained behavior change may employ knowledge deficit models such 18

as KAP models focusing knowledge, aspirations, and practice change. However, the assumption 19

of linearity of behavior change process in knowledge deficit models is often questionable, since 20

behavior change as a result of food safety training may be subject to the influence of other 21

factors such as social and environmental factors. The present study supports Extension efforts to 22

develop and offer food safety training in the context of THAM as applied to food hygienic 23

175

education by Rennie (1995). Nieto-Montenegro, Brown, and LaBorde (2006) developed food 1

safety education materials using THAM. Tone’s model incorporates Health Belief Model (HBM) 2

and Theory of Reasoned Action and also emphasizes social and environmental factors (Rennie, 3

1995). Extension programming on food safety should not only disseminate food safety 4

knowledge among farmers but also motivate them to bring changes in their farm practices. 5

Knowledge gain and motivations are key constructs of THAM, and therefore, this study assessed 6

it’s use as an appropriate model for food safety educational program development. 7

Purpose and Objectives 8

The study purpose was to determine KVKs’ involvement in offering food safety training 9

to farmers. The four objectives were to: 10

1. Identify major food safety concerns related to farming practices in KVK districts; 11

2. Determine Programme Coordinators’ (PCs) attitudes towards public health issues, food 12

safety training and familiarity with GAPs; 13

3. Assess the current status of food safety programming and the perceived need for food 14

safety subject matter specialists (SMS); and 15

4. Determine PCs’ area of specializations, affiliations, experience, and responsibility 16

including the characteristics of KVKs’ clientele. 17

Methodology 18

The study used descriptive survey research methodology to answer study objectives. An 19

assessment questionnaire was developed at the [State] University. Survey questions measured 20

PCs’ attitudes toward public health issues and food safety training, their familiarity with GAPs, 21

the status of current food safety programs, the need for food safety SMS and the level of food 22

safety concerns related to on-farm food production practices. The survey also collected PCs’ as 23

176

well as farmers’ interest in participating in food safety programs and information about the 1

involvement of other organizations in providing food safety education. A final section included 2

questions related to PCs’ areas of specialization, work experience, job responsibilities and 3

affiliation, KVK zones, and characteristics of clientele. In an open-ended question, PCs were 4

asked to identify topics and concerns related to food safety programming in their districts. 5

An expert panel assessed content validity, and feedback from PCs and experts in India 6

were incorporated to improve the quality and readability of the survey questions. The 7

Institutional Review Board (IRB) at the [State] University approved the study protocol. 8

Electronic mailing addresses of 629 PCs (from each of the eight zones) were accessed from the 9

ICAR’s 2016 KVK directory (ICAR, 2016). Email messages consisting of a description of study 10

purpose and a web link to the survey were sent in January 2016 to all 629 PCs. 11

Online surveys were designed in such a way that participants would read the informed 12

consent letter before responding to the survey. To increase the response rate reminder emails 13

were sent to non-respondents requesting them to complete the questionnaire. The survey was 14

open for participants from January through June 2016. In total, 117 PCs responded to the online 15

survey for a response rate of 18.6%. States and corresponding zones of were identified for 105 16

survey respondents. Table 1 displays the number of surveys completed from different zones 17

along with the list of states and union territories under each zone. The highest number of 18

respondents (N=20, 19.05%) were located in zone V. 19

20

21

22

177

Table 1 1

Respondents by Zone and State (Cases=105) 2

Zone State N % of Zone PCs

Zone I Delhi, Haryana, Himachal Pradesh, Punjab, Jammu and

Kashmir 11 10.48

Zone II Andaman & Nicobar Islands, Bihar, Jharkhand, West

Bengal 11 10.48

Zone III Asom, Arunachal Pradesh, Manipur, Tripura,

Meghalaya, Mizoram, Nagaland, Sikkim 16 15.24

Zone IV Uttar Pradesh, Uttarakhand 15 14.29

Zone V Andhra Pradesh, Telangana, Maharashtra 20 19.05

Zone VI Rajasthan, Gujarat 10 9.52

Zone VII Chhattisgarh, Madhya Pradesh, Odisha 11 10.48

Zone VIII Karnataka, Tamil Nadu, Kerala, Goa, Pondicherry,

Lakshadweep 11 10.48

PC’s familiarity with GAPs, the level of food safety concern on the farms, importance of 3

food safety training for farmers, KVKs offering of training, the need for SMS, and organization 4

involved in on-farm food safety education were measured on five-point Likert scales. 5

Descriptive statistical analyses were utilized including calculation of the average rank scores, 6

frequencies, and percentages. Cross-tabulations were used to determine the distribution of 7

variables. In addition, non-parametric tests were performed to examine the correlations 8

coefficient between variables. 9

Kendall’s tau-b values were calculated to determine relationships among variables: the 10

level of food safety concerns and concerns related to specific farm practices; the need for a food 11

safety SMS and level of food safety concern; and current offering of food safety training and 12

SMS status. The assumptions made in performing Kendall’s tau-b correlation were that 1) the 13

178

variables were measured on ordinal scales and 2) there was a monotonic relationship between the 1

variables. Pearson chi-square test of association was performed between KVK offering of food 2

safety training and SMS status with Cramer’s V calculated to assess the strength of association. 3

Results 4

PC Attitudes Toward Public Health Issues, Food Safety Training, and Knowledge of GAPs 5

In order to determine PCs’ attitudes toward issues affecting public health in India, they 6

were asked to rank seven issues. as per the importance to public health. Results Revealed that 7

showed that PCs ranked food security and climate change as the top two major issues affecting 8

public health in India (Figure 1). PCs further ranked public health issues related to excessive use 9

of chemicals (ranked 3), food adulteration on farms (ranked 4) and health awareness about 10

infection (ranked 5). 11

12

Figure 1. Mean rank value of issues related to public health (N=112) 13

2.49

3.87

4.43

4.46

4.72

4.79

5.51

1 2 3 4 5 6 7

Genetically modified food

Food contamination on farms

Health awareness about infection

Food adulteration

Excessive chemical use on farms

Climate change

Food security

Mean rank valueHighest

Importance Lowest

Importance

179

PCs familiarity with GAPs was assessed utilizing a five-point, Likert scale ranging from 1

“not heard of” to “very familiar”. The results showed that of 96 respondents, 80 (83.43%) 2

indicated they were either moderately familiar or very much familiar with GAPs. Eight 3

respondents (8.33%) were not or slightly familiar with GAPs. PCs’ opinions regarding the 4

importance of food safety training for farmers was also measured on a five-point, Likert scale 5

ranging from “not at all important” to “very important.” Of 97 respondents, 66 (68%) 6

respondents rated food safety training as “very important” for farmers. None of the respondents 7

rated training as “not at all important” (Figure 2). 8

9

Figure 2. Importance of food safety training for farmers (N=97) 10

Results also showed that an overwhelming percentage of the respondents (N=83, 92.2%) 11

expressed personal interest in attending GAPs workshops if offered for the KVK staff. 12

Respondents had a similar opinion about farmers when asked whether farmers would attend food 13

safety training if provided through KVKs. A large majority of the respondents (N=76, 84.4%) 14

indicated that farmers would attend food safety programs if provided through KVKs. 15

03

7

21

66

0

20

40

60

80

Not at All

Important

Less Important Slightly Important Moderately

Important

Very Important

21.6%

7.2%3.1%

0.0%

68.0%

180

On-Farm Food Safety Concerns 1

PCs were asked to indicate their level of food safety concern on the farms in their 2

districts by responding to a five-point, Likert-scale. The scale ranged from “not at all a concern” 3

to “very much a concern.” A slight majority of PCs (N=58, 59.8%) rated food safety on the farms 4

of their districts as a moderate to very much of a concern. Eighteen respondents (18.6%) rated 5

on-farm food safety as “not at all a concern” or “slightly a concern.” Additional questions were 6

asked for further insight into food safety concerns linked with farmers’ on-farm practices and 7

other factors. Respondents rated these practices and factors on a similar five-point, Likert-scale 8

ranging from “not at all a concern” to “very much a concern.” 9

Results showed a slight majority of respondents indicated excessive use of pesticide on 10

the farms (N=53, 58.9%), improper washing of vegetables (N=49, 54.4%), and lack of hygiene in 11

food processing (N=45, 50.6%) were moderate to very much a food safety concern on the farms 12

(Table 2). On the other hand, 27% of the respondents indicated that crop irrigation with 13

contaminated water was moderate to slightly a food safety concern. Additionally, the 14

respondents rated lack of awareness (81%) and high cost of implementing food safety practices 15

(75%) as somewhat to very much of a concern, respectively. 16

17

18

19

20

21

22

23

24

25

26

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Table 2 1

Level of food safety concern associated with farm practices, awareness, or cost. 2

Practice or factor Cases

Not at all to

slightly a

Concerna

Somewhat

a Concern

Moderately to

Very much a

concernb

N % N % N %

Excessive pesticide use 90 22 24.44 15 16.67 53 58.89

Improper washing for vegetables 90 26 28.89 15 16.67 49 54.44

Lack of hygiene in food processing 89 22 24.72 22 24.72 45 50.56

High cost to implement food safety

practices 89 22 24.72 24 26.97 43 48.31

Limited or no water and soil testing

labs 88 28 31.82 18 20.45 42 47.73

Lack of food safety awareness 88 17 19.32 30 34.09 41 46.59

Wild animal roaming in agricultural

field 90 33 36.67 17 18.89 40 44.45

Cleanliness of agricultural equipment 89 29 32.59 26 29.21 34 38.20

Contaminated manure application 88 37 42.04 21 23.86 30 34.09

Contaminated water used for

irrigation 89 48 53.94 17 19.10 24 26.97

Note. a Responses as “not at all a concern” or “slightly a concern” were combined to create a 3

category “not at all to slightly concern” 4 b Responses as “moderately a concern” and “very much a concern” combined to create a 5

category “moderately to very much a concern.” 6

Kendall's Tau-b (τb) was used to determine the relationships between PCs’ rating of the 7

level of food safety concerns on the farms and the level of food safety concern associated with 8

specific farm practices and factors. Table 3 displays the variables and corresponding correlation 9

coefficients (τb) that were found to be significant (p <.01). Lack of awareness (τb =.381, p <.01), 10

high cost (τb =.335, p <.01), and improper washing of vegetables on the farms (τb =.311, p <.01) 11

were moderately related to overall food safety concern. 12

182

Table 3 1

Relationships between level of overall expressed level of food safety concern on the farm and 2

individual practice and factor 3

Practice or factor (V1) Food safety a concern on the farms (V2)

N Kendall’s Tau-ba

Lack of food safety awareness 88 .381

High cost to implement food safety practices 89 .335

Improper washing of vegetables 90 .311

Cleanliness of agricultural equipment 89 .293

Limited or no water and soil testing labs 88 .271

Lack of hygiene in food processing 89 .261

Excessive pesticide use 90 .260

Contaminated water used for irrigation 89 .242

Contaminated manure application 88 .234

Note. Both the variables, V1 and V2, were measured on a five-point Likert scale ranging from 4

“not at a concern” to “very much a concern” 5 a p <.01 6

Current Food Safety Programming Status and the Need for Food Safety SMS 7

A series of questions were asked to assess the current food safety programming status and 8

needs. The first step of the assessment determined the programming status in the KVK’s current 9

action plan. In response to the question about ICAR food safety programming, 75 (78.1%) of 96 10

respondents indicated that ICAR, through various schemes, has prioritized food safety education 11

for farmers. The majority of the respondents (N=70, 72.9%) indicated KVKs are currently 12

involved in proving food safety training. Of the remaining 26 respondents, 24 (92.3%) indicated 13

that KVKs should provide farmers with food safety programs. Additionally, 22 (84.6%) out of 14

the 26 PCs further mentioned that their KVKs would likely to offer food safety training to 15

farmers in the future. 16

183

PCs were asked if any other organizations are currently involved in offering food safety 1

educational programs to farmers in their districts. Of 90 respondents, 16 (17.8%) indicated other 2

organizations in their districts offering food safety programs, and 59% of the participants 3

indicated having no other organization(s) in their district that offered food safety educational 4

programs. Five PCs indicated government organizations and universities, and three PCs 5

indicated NGOs as the organizations other than KVK currently offering food safety education for 6

farmers. None of the respondents indicated the involvement of private corporations or Farmers 7

Cooperatives in such food safety program efforts. 8

Twenty-two PCs (22.7%) out of 97, indicated currently having a food safety SMS at their 9

KVK. The 74 KVKs that mentioned either not having a food safety SMS or did not answer the 10

question on SMS status were further asked to rate the need for a food safety SMS at their KVK. 11

Out of those 74 KVKs, the majority of KVKs (N=49, 66.2%) expressed the need of a food safety 12

SMS as moderate to high. A Kendall’s tau-b correlation was used to determine the relationship 13

between the level of food safety concerns on the farms and the need for a food safety SMS. 14

There was a significant, positive (although low) relationship between the level of food safety 15

concerns in KVK districts and the need for an SMS (τb =.199, p <.05). 16

Pearson chi-square test of association was performed to examine the association between 17

KVKs currently offering a food safety education program and currently having a food safety 18

SMS at the KVK (Table 4). There was a significant association between the current offering of 19

training and having an SMS at the KVK (2 = 5.16, df=1). The Cramer’s V correlation 20

coefficient of .244 (p <.05) indicated a moderate relationship between the two variables. The 21

correlation analysis showed that KVKs with a food safety SMS are more likely to currently 22

offering food safety training programs. 23

184

Table 4 1

Descriptive Statistics and Chi-square Test for food safety SMS status by the current status of food 2

safety training (Total=87). 3

Current status of food safety

training

SMS Status at KVK

Yes No

Yes 21 (95.5%) 47 (72.3%)

No 1 (4.5%) 18 (27.7%)

Note. 2 = 5.16, df = 1. Numbers in parentheses indicate column percentages. 4 *p < .05 5

Characteristics of KVK Clientele and Respondents 6

KVKs work with farmers of varied land sizes, including landless farmers to large-scale 7

farmers having more than four hectares of land. Almost 75% of the respondents (N=59) 8

identified small-scale farmers, having less than two hectares of land as their primary clientele. 9

Indian farmers grow various types of crops including cereals, legumes, fruits and vegetables, 10

aromatic and medicinal plants, and commercial crops. Around 86% of the respondents (N=69) 11

reported that the majority of the farmers in their district grow cereals. At the same time, 50% of 12

the respondents also indicated that the majority of the farmers of their areas grow produce. 13

Respondents indicated having specialization in either one or multiple areas of agriculture 14

and allied subjects. Results showed that 46% (N=37) of the respondents specialized in 15

horticulture and 43% (N=34) in agronomy. In addition, a relatively high number of respondents 16

specialized in animal husbandry, home science, crop production, plant pathology, and soil 17

science as compared to specializing in agricultural economics, engineering, fishery, and plant 18

breeding. Twenty-one (26.2%) respondents had a specialization in agricultural extension with or 19

without combined specialization in any other areas. 20

185

Regarding work responsibility, PCs can have a single job responsibility or combined 1

responsibilities across multiple work areas. More than 80% of the respondents indicated that 2

their main job responsibility was to train farmers. Linkage with line departments, training of field 3

workers, and administrative tasks were found to be the other major areas of job responsibility. A 4

rather lower number of respondents indicated research (N=36, 45.6%) and training of 5

government employees (N=37, 46.8) as their job responsibilities. 6

Respondents were affiliated with either one or more than one organization which 7

included KVK, Agricultural Technology Mobilizing Agency (ATMA), ICAR, SAU, Central 8

Agricultural Universities, and other agencies. The majority of the PCs indicated their affiliation 9

with KVK itself (N=56, 70%). The other two major organizations to which more than 50% of the 10

total respondents were affiliated with were ICAR (N=47, 58.8%) and SAUs (N=51, 63.8%). 11

Twenty-eight respondents (35%) were affiliated with ATMA and four percent with Central 12

Agricultural Universities. Out of the 80 PCs who responded to question related to their 13

experience at KVK, 37 (46.3%) were associated with KVK for more than ten years and 22 14

respondents (27.5%) for five to ten years. Twenty-one (26.3%) survey participants worked in 15

KVK for five years or less. 16

Conclusions and Recommendations 17

The study assessed the food safety concerns related to various farm practices by the 18

farmers in KVK districts. Not only PCs acknowledged the importance of food safety training, but 19

also mentioned that ICAR schemes prioritize food safety training for farmers. PCs recognized 20

on-farm food safety as a concern in the majority of districts, especially regarding contamination 21

from toxic agrochemicals. In addition, lack of hygienic practices during food processing and 22

improper washing of vegetables were also found to be major food safety concerns; whereas, 23

186

application of contaminated manure or water used for irrigation were of a relatively lower level 1

of concern. Based on the findings, on-farm food safety training programs should prioritize 2

hygienic practices including proper washing of vegetables and cleaning of agricultural 3

equipment. 4

The majority of the PCs indicated that their KVKs offered some food safety training to 5

farmers. Analysis of respondents’ comments to an open-ended question revealed a multitude of 6

food safety concerns, particularly excessive use of agrochemicals on the farms and the need for 7

awareness programs for hygienic practices. Furthermore, KVKs that currently are not offering 8

any food safety training acknowledged that they should train farmers and also indicated a greater 9

likelihood to provide such programs in the future. 10

The majority of KVKs have no SMS specialized in food safety. However, they are 11

offering some types of food safety programs. The study results indicated that KVKs with a food 12

safety SMS were more likely to provide food safety programs. SMS with a specialization in 13

home science appeared to be involved in training farm and rural women about hygienic 14

practices. For KVKs without a specialized food safety SMS, the majority expressed the need for 15

an SMS. The findings indicated the need for recruiting a greater number of field workers and 16

SMS. 17

This study concludes that PCs value the importance of food safety education for farmers 18

and Extension workers. The value of food safety education by the PCs was further supported by 19

the findings that more than the overwhelming majority of the respondents indicated their interest 20

in attending workshops on GAPs. PCs also indicated the farmers of their districts would attend 21

food safety workshops if the KVKs offer such training. A robust public health system calls for a 22

greater food safety awareness among food handlers at the farms, processing industry, food 23

187

preparer level and consumers. In the absence of other organizations’ involvement in food safety 1

training to farmers, it becomes necessary for an outreach organization like KVK to play a lead 2

role. In a recent news article published in a leading newspaper, the Food Safety Standards 3

Authority of India (FSSAI) expressed their intentions to spread food safety awareness in 4

coordination with universities, colleges, government and non-government agencies (Anand, 5

2016). 6

The public extension system in India has been traditionally involved in production 7

agriculture by addressing the challenge of food security and improvement in the livelihood of 8

farming community. Programs focusing on technology transfer and farmers training on 9

production agriculture will continue to find it a place in KVK action plans. However, public 10

Extension needs to redefine its current programming priority areas to accommodate food safety 11

awareness programs in its action plan. The study shows that public Extension, with its presence 12

almost in all districts and its connections to the farming communities, can be utilized as an 13

effective medium to promote safe handling of food and hygienic practices. This study is an 14

attempt to engage Extension in strengthening food control system by creating awareness among 15

their clientele and motivating them to produce safety food. 16

To the authors’ knowledge, there are limited or no studies available that focused on 17

Extension’s involvement in food safety training in India. Therefore, similar studies should be 18

conducted to assess Extension’s participation and role to educate and enhance the development 19

of on-farm food safety practices. The study results provide a clear indication that food safety 20

education is vital for future programming. Since the majority of KVK clientele are small farm 21

holders with limited financial resources, KVKs needs to provide farmers the appropriate 22

resources to adopt food safety practices efficiently and technical assistance to support them in 23

188

each step of GAP adoption. Moreover, tailoring of such training programs should prioritize 1

district or regional food safety concerns as well as crop-specific practice requirements. KVK 2

may consider integrating food safety educational programs with vocational and technical training 3

programs for farmers and youth. 4

FAO (2008) suggests that “the concept of GAPs may serve a reference tool” for 5

“sustainable and socially acceptable” practices and outcomes. Safer and higher quality food 6

products, better worker’ health and working conditions and new market opportunities are some 7

of the underlying objectives of GAP adoption. Extension should develop and adopt GAP-8

curriculum for promoting microbial preventive measures on the farms. The WHO’s manual titled 9

“Five keys to growing safer fruits and vegetables: promoting health by decreasing microbial 10

contamination” can be used as a guiding template for developing training programs specifically 11

for small-scale farmers and grass root field workers (WHO, 2012a). The WHO manual also 12

claims that the growing implementation of hygienic food handling practices will contribute to 13

better community health. 14

Studies are available showing participants’ increase in knowledge after attending KVK 15

training offered by KVKs (Shankar, Mamatha, Reddy, & Desai, 2014; Singh, Peshin, & Saini, 16

2010). Programming frameworks like THAM are useful for programs that address social and 17

economic factors. Extension can adopt THAM into their programs to impart knowledge as well 18

motivate farmers in adopting hygienic practices while handling, storing, processing, and packing 19

produce. Smaller steps towards educating farmers about the safety of food will have a greater 20

and positive impact on the public health. Similar studies should be conducted with other 21

Extension systems of India to assess their involvement in food safety educations. 22

189

It is recommended that international food safety certification agencies such as Global 1

G.A.P should be involved with KVK personnel on their programs and train them on international 2

food safety standards and regulations. In the absence of strict food safety regulations and 3

enforcement, food safety has emerged as one of the major public health concern that needs to be 4

dealt with effectively. To strengthen the public health system, Extension can contribute by 5

educating and motivating farmers to adopt food safety practice as a social responsibility. Such 6

intervention not only helps farmers but also build confidence among consumers that farmers are 7

increasing adopting food safety practices to provide them safer food. Food safety is a shared 8

responsibility of all the stakeholders of food supply chain. Therefore, a consensus among the key 9

stakeholders is crucial to engage and bring all the major Extension systems together to address 10

public health issues. 11

12

13

14

15

16

17

18

19

20

21

22

23

24

190

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behavioural scientists. British Food Journal, 97(8), 23-28. 12

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Telephone-Directory.pdf 15

Jairath, M. S., & Purohit, P. (2013). Food safety regulatory compliance in India: A challenge to 16

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Kaferstein, F. (2003): Food safety as a public health issue for developing countries. In L. J. 19

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Nieto-Montenegro, S., Brown, J. L., & LaBorde, L. F. (2006). Using the Health Action Model to 4

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Patil, S. S., & Kokate, K. D. (2016). Training need assessment of subject matter specialists of 7

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Shankara, M., Mamatha, H., Reddy, K. S., & Desai, N. (2014). An evaluation of training 19

programmes conducted by Krishi Vigyan Kendra, Tumkur, Karnataka. International 20

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194

Appendix G

Survey Questionnaire for INTAD Study

Title of Project: Role of Krishi Vigyan Kendra to Promote On-Farm Food Safety Practices in India

Principal Investigator: Roshan Kumar Nayak, Ferguson Building, Penn State University, University Park, PA 16802 United States of America Telephone: +1 (814) 777-7650

Purpose of the Study:This study assesses the significance of food safety educational programming in the current KVK’saction plans including the scope and obstacles to offer food safety programs.

Procedures to be followed:You will be asked to answer a series of questions related to the role that your KVK can play inpromoting food safety practices such as Good Agricultural Practices among farmers, food safetyprogramming needs and challenges in your districts. Discomforts and Risks:There are no risks to participating in this research beyond those experienced in everyday life. Some of the questions may appear personal but answers will be held in strict confidentiality.

Benefits:By participating in this study, you will be providing information that will help in assessing thesignificance of food safety educational programming scopes and challenges, which will benefitKVKs to design and implement effective food safety programs for farmers.

Duration: Survey will take about 12-15 minutes.

Statement of Confidentiality:Only the person in charge (Roshan Nayak) and members of his immediate research team will knowyour identity. You may be assured of complete confidentiality. Your name will never be associatedwith your answers or any of your statements. Only the overall results of the survey will be reported.If this research is published, no information that would identify you will be written. Yourconfidentiality will be kept to the degree permitted by the technology used. No guarantees can bemade regarding the interception of data sent via the Internet by any third parties. The PennsylvaniaState University’s Office for Research Protections and Institutional Review Board, and the Office forHuman Research Protections in the Department of Health and Human Services may review recordsrelated to this project.

1. INFORMED CONSENT

KVK's Role on Food Safety Programming

1

Security of Data: The project investigator (Roshan Nayak) and members of his immediate research team will be theonly persons who will have access to the survey data. These materials will be secured in lockedoffices and computers, when not being analyzed. All materials will be destroyed upon completion ofthe project. Right to Ask Questions:You can ask questions about the research. The person in charge will answer your questions. Please contact Dr. John Ewing at +1 (814) 863-7463 or via email at jce122@psu.edu with questionswith questions, complaints or concerns about this research. If you have any questions, concerns,problems about your rights as a research participant or would like to offer input, please contact ThePennsylvania State University’s Office for Research Protections (ORP) at +1 (814) 865-1775. TheORP cannot answer questions about research procedures. Questions about research procedurescan be answered by the research team.

Voluntary Participation:You do not have to participate in this research. You can end your participation at any time by tellingthe person in charge. You do not have to answer any questions you do not want to answer.Refusing to participate or withdrawing early from the study will involve no penalty or loss ofbenefits you would be entitled to otherwise.

Please Click Next to Start the Survey

2. Opinion on Public Health

KVK's Role on Food Safety Programming

2

1. Please rank the following six issues with respect to their importance to public health in India, where rank1= Most important and 6 = Less important.

Climate change

Food security

Food adulteration

Food contamination in farms

Health awareness about infection

Excessive chemical use on farms

Genetically Modified Food

Good Agricultural Practices (GAPs) are "practices that address environmental, economic and socialsustainability for on-farm processes, and result in safe and quality food and non-food agriculturalproducts" (FAO Definition). GAPs are ways that farmers can prevent contamination of fruits andvegetables on their farm.

3. On-Farm Food Safety

KVK's Role on Food Safety Programming

Never heard of Slightly familiar Somewhat familiar Moderately familiar Very much familiar

2. Please rate how familiar you are with Good Agricultural Practices (GAPs). By familiarity, we mean howwell you know about GAPs.

Not at all a concern Slightly a concern Somewhat a concern A moderate concern Very much a concern

3. In your view, how much is food safety a concern in the farms of your district?

Not at all important Low important Slightly important Moderately important Very Important

4. In your opinion, how important is food safety training for farmers of your KVK district?

3

5. Do you feel ICAR schemes/mandates prioritize food safety education for farmers?

Yes

No

Can not say

6. Is your KVK offering any farm food safety training to farmers of your district?

Yes

No

Can not say

4. KVK Programming Areas

KVK's Role on Food Safety Programming

7. Do you think KVKs should train farmers on food safety practices?

Yes

No

Can not say

Verymuch unlikely Unlikely Neutral Likely Verymuch likely

8. What is your perception that KVK will offer food safety training to farmers in future?

9. Do you have a food safety subject matter specialist at your KVK?

Yes

No

Can not say

5. Food Safety SMS

KVK's Role on Food Safety Programming

4

Not at all needed Somewhat needed Neutral Moderately needed Highly needed

10. Please rate the need for a food safety Subject Matter Specialist (SMS) at your KVK.

6. Farm Level Food Safety Concerns

KVK's Role on Food Safety Programming

5

1=Not at all a

concern 2=Slightly a concern3=Somewhat a

concern4=Moderately a

concern5=Very much

a concern

Improper washing forvegetables

Wild animal roaming inagricultural field

Excessive pesticide use

Cleanliness ofagricultural equipment

Lack of hygiene in foodprocessing

Contaminated manureapplication

Contaminated waterused for irrigation

Lack of food safetyawareness

Lack of awarenessamong consumers

High cost to implementfood safety practices

Limited or no water andsoil testing labs

Other

Other (please specify)

11. On a scale of 1 - 5, where 1= Not at all a concern and 5= Extremely a concern, please rate thelevel of food safety concern associated with the following farming practices on farms of yourdistrict.

7. Food Safety Training

KVK's Role on Food Safety Programming

6

12. In your opinion, do you think, farmers in your district will attend food safety training if it is offered byyour KVK?

Yes

No

Can not say

13. If workshops on GAPs are to be offered for KVK staffs, would you be interested in attending?

Yes

No

Can not say

14. Are there any other organization/s that currently offer food safety education to farmers of your district?

Yes

No

Can not say

8. Other Organizations

KVK's Role on Food Safety Programming

15. Please indicate the organization/s that currently offering food safety educations to farmers of yourdistricts. (Check all that apply).

NGO

Private Corporation

Farmers’ Cooperative

ATMA

University

Government

Any other organization (please specify)

7

On a scale of 1 - 5, where 1= Not a barrier to 5= Extremely a barrier, please rate the followingstructural and cultural barriers in offering food safety educational programs for farmers of yourdistrict.

9. Barriers to offer food safety programs

KVK's Role on Food Safety Programming

1=Not a barrier 2=Slightly a barrier3=Somewhat a

barrier4=Moderately a

barrier5=Extremely a

barrier

Absence of a clearmandate on food safetyeducation

Lack of financial supportfrom ICAR

Limited financialresources of farmers

Insufficient field workers

Lack ofworkers’ knowledge

No subject matterspecialists

Lack of adequatetraining for Extensionstaffs

Other

Other (please specify)

16. Rate the following structural barriers:

8

1=Not a barrier 2=Slightly a barrier3=Somewhat a

barrier4=Moderately a

barrier 5=Extremely barrier

Farmers’ lack ofawareness

Farmers are unwilling toparticipate

Lack of interest amongfarmers

Food safety not a priorityby farmers

Lack of socialaccountability on thepart of food growers

Consumers are lessconcerned

Lack of socialaccountability on thepart food marketingpersonnel

Other

Other (please specify)

17. Rate the following cultural barriers:

On a scale of 1 - 5, where 1= Not a barrier to 5= Extremely a barrier, please rate the following policyrelated and technical barriers in offering food safety educational programs for farmers of yourdistrict.

10. Barriers to offer food safety programs

KVK's Role on Food Safety Programming

9

1=Not a barrier 2=Slightly a barrier3=Somewhat a

barrier4=Moderately a

barrier5=Extremely a

barrier

Food safety not a priorityon KVK's action plan

No clear policy fromICAR on food safety

Lack of adequateconcern on the part ofICAR

No strict food safetyregulations

Lack of awarenessamong farmers

Other

Other (please specify)

18. Rate the following policy related barriers:

1=Not a barrier 2=Slightly a barrier3=Somewhat a

barrier4=Moderately a

barrier5=Extremely a

barrier

Lack of infrastructure totrain farmers

Limited funds to supporttraining

Limited staff members

Inadequate recruitmentof womenscientists/officers atgrass-root level

Inadequate in-servicetraining

Inadequate involvementof women farmerstraining programmes

Other

Other (please specify)

19. Rate the following technical barriers:

10

11. Effectiveness of program delivery methods

KVK's Role on Food Safety Programming

1=Not effective2=Somewhat

effective 3=Neutral4=Moderately

effective 5=Highly effective

Workshops

Demonstrations

Personal Contact

Farm Visit

Farm Field School

Farmers’ Co-operativesat village level

Other

Other (please specify)

20. On a scale of 1 - 5, where 1= Not effective to 5= Highly effective, if food safety training is to beoffered by KVK for farmers, please rate how effective would each of the following training methodsbe:

12. Farmers' Characteristics

KVK's Role on Food Safety Programming

11

21. Majority of the farmers you primarily work with are (Check all that apply)

Small (less than 2ha)

Medium (medium (2-4ha)

Large (more than 4ha)

Landless (no land)

Other (please specify)

22. Indicate the crops that the majority of farmers in your district grow? (Check all that apply)

Cereals

Legumes

Vegetables mostly eaten raw (example Cucumbers, Tomatoes etc.)

Vegetables mostly cooked (example potatoes, Brinjal, Cabbage etc.)

Fruits

Aromatic and Medicinal plants

Other (please specify)

13. Demographic Information

KVK's Role on Food Safety Programming

12

23. Indicate your areas of specialization. (Check all that apply)

Agronomy

Animal Husbandry

Agricultural Economics

Agricultural Engineering

Crop Production

Fisheries

Horticulture

Home Science

Soil Science

Plant Breeding

Plant Pathology

Other (please specify)

24. How long have you been associated with KVK?

25. Indicate your KVK zone

26. Which of the following categories best describes your job responsibility at KVK? (Check all that apply)

Research

Farmers Training

Training Field Workers

Administrative Work

Training of Govt. officers

Linkage with Line Department Officials

Other (please specify)

13

27. Are you affiliated with? (Check all that apply)

KVKs

ATMA

ICAR

State Agricultural University

Central Agricultural University

Central Institutions

Other (please specify)

28. Please write down any other topic that you would like to share with us related to food safety trainingprogramming in you district.

14

VITA

Roshan Nayak

Education

The Pennsylvania State University

Ph.D. Agricultural and Extension Education

Dual Title in International Agriculture and Development

University Park, PA

December 2016

Tarleton State University

M.S. Agriculture and Consumer Resources

Stephenville, TX

August 2012

Banaras Hindu University

B.Sc. Agricultural Science

National Talent Scholarship

Varanasi, India

May 2009

Selected Awards and Recognitions

2nd Place Award at 29th Penn State Graduate Exhibition in Social and Behavioral

Science Category

2016

Graduate Research Grant of $1000 from the Office of the International Programs 2015

2nd Place Award at 27th Penn State Graduate Exhibition in Social and Behavioral

Science Category

2014

International Travel Award from the Office of the International Programs 2013

2nd Place Award at Gamma Sigma Delta Research Expo, Penn State University 2013

Davidson Presidential Scholarship, Tarleton State University 2011-12

Dr. Dennis P. McCabe Student Endowment award, Tarleton State University 2011-12

Selected Publications and Conference Papers

Nayak, R., Tobin, D., Radhakrishna, R., Thomson, J.S., Laborde, L. (2015). Evaluation of on-farm

food safety programming in Pennsylvania: Implications for Extension. Journal of

Extension [On-line], 53(1). Article 1FEA9. Available at

http://www.joe.org/joe/2015february/a9.php

Nayak, R.K., Radhakrishna, R., Foley, C., Thompson, G., & Hawthorne, A. (2015, May). The

Relationship of Graduate Program Satisfaction with Student Learning Ability, Department

Collegiality, and Adequacy of Student Support. Paper Presented at AAAE Conference, San

Antonio, TX.

Radhakrishna, R., Nayak, R. K., Chaudhary, A. K., Gill, T., & Paudel, S. (2014, November). Pre-

needs Assessment Tool for Program Design, Delivery, and Evaluation. Paper presented at

American Evaluation Association, Denver, CO.

Nayak, R. K., Tobin, D., Thomson, J., Radhakrishna, R., & Laborde, L., (2013, December).

Produce Growers’ Challenges in Implementing Good Agricultural Practices. Paper

presented at INSEE Conference, Bangalore.