The Food Safety Conundrum for Small Growers
Which comes first, food safety or marketability? For many small growers, these two issues are increasingly melding into one big challenge.

By Jodean Robbins

The popular focus on local sourcing has put smaller growers in the spotlight, yet success can be a double-edged sword, as those same growers must now implement effective food safety measures. “We know local, smaller growers, in particular, can find food safety a daunting issue,” says Bob Whitaker, chief science and technology officer for the Produce Marketing Association (PMA) in Newark, DE. “Despite the challenges, it is important for operations of all sizes to have risk- and science-based food safety programs in place.”

While various arguments and exemptions seek to give small growers a pass on food safety, reality attests otherwise. “The Tester Amendment to the Food Safety Modernization Act exempted very small, local operations from federal food safety regulations,” says David E. Gombas, senior vice president for food safety and technology at United Fresh Produce Association in Washington, D.C. “Unfortunately, no one told the pathogens about the exemption. Pathogens don’t know what size operation they are on.”

“Pathogens like Salmonella and E. coli can’t tell the size of a farm,” agrees Scott Horsfall, CEO of the California Leafy Greens Marketing Agreement (LGMA) in Sacramento, CA. The market is the real driver for food safety at all levels. “In the eyes of the marketplace, small and local growers are expected to have effective and verifiable food safety programs,” says Whitaker. “Buyers are looking to support local suppliers, yet these very same suppliers could find themselves at a market disadvantage if they do not have adequate risk- and science-based food safety programs.” “We do not believe food safety should be excluded from one company versus another,” says Maria Brous, director of media and community relations for Publix Super Markets Inc., based in Lakeland, FL. “Food safety is everyone’s responsibility.” Tim York, president of Markon Cooperative, located in Salinas, CA, adds, “Given some small growers’ inability to understand and comply with industry Best Practices, it is incumbent upon buyers to understand the programs in place and measure the risk they are willing to take in providing small local grower products to their customers.”

Food Safety Is Scaleable
An effective food safety program can be adjusted to meet the size of the operation. “Food safety is scalable,” says PMA’s Whitaker. “Everybody needs to have a program, but it will vary depending on size, location, product, etc. Different factors all influence what type of food safety program is developed. Risk management practices and preventive controls can be designed to match the risk and the scale of the operation.”

“It is important for all farmers to use good agricultural practices, to have verification, and to correct any citations,” says Horsfall. “All of these are elements of the LGMA program and our program is scalable for large or small farms, organic or traditional farming practices.”

In most cases, the expenditure of resources should be proportional to the size of the operation. “A small processor with a handful of employees could expect to spend considerably less than a larger operation,” explains Whitaker. “The degree of sophistication employed may be much less and offset the costs.”

A strong collaboration between government and farming communities, the LGMA illustrates a model food safety program reaching beyond an audit score focus. “The program can be easily adapted for a wide range of farming operations and products,” explains Horsfall. “Similar to HACCP, our program revolves around six principal elements: 1. Assess Risks; 2. Apply Science; 3. Verify Compliance; 4. Promote Transparency; 5. Document Practices; and 6. Provide Corrective Actions.”

Get Over The First Hurdle
Often the biggest difficulty small growers face is simply the thought of starting a food safety program. “One challenge we’ve seen with smaller growers is helping them see how food safety fits into their operation, and why it’s important,” says Dave Corsi, vice president produce and floral merchandising for Wegmans Food Markets in Rochester, NY, with 79 stores.

“Resources can present a big barrier,” agrees PMA’s Whitaker. “Some farms are just a guy and his wife or brother. So they have to carve out a piece of their time to look at things through the food safety lense. In many cases, the real hurdle is the anxiety. It’s not understanding exactly what’s being asked or why, or what they can do to put a program together. It’s not that people aren’t willing; they want to do the right thing. It’s more about getting over the hurdle of how to get started.”

“We’ve seen folks struggle with having to write a food safety plan for their operation,” adds Corsi. “We’ve done entire training sessions focused solely on how to write a food safety plan. It’s getting people to take the first steps, and once they’ve done it things seem to go much easier.”

Keep It Simple
Many food safety practices are practical for small and very small businesses to implement. “Once operators understand basic concepts in hazard analysis and management, they begin to find simple practices that are not expensive to implement,” explains Whitaker. “Often these controls are simply good operational or business practices.”

“It doesn’t have to be fancy or complicated, but it does need to look at known food safety issues and address how those things are monitored and controlled on that particular operation,” says Corsi. “At the very least, Good Agricultural Practices should be applied across the board. If you are growing produce intended to be consumed by humans, there are basic things you should be doing. Water quality, manure control and personal hygiene practices are important no matter how big or small the operation is.”

“Basic measures such as providing training for worker hygiene, wash water sanitation, facility and equipment sanitation and supplier qualification apply to all operations and can help assure food safety,” adds Whitaker.

Tools like audits and testing can also be scaled to the operation. “Many testing methods available to small companies and growers do not need a full chemist or microbiologist to run,” says Wil Sumner, director of testing services, food and agriculture division for SCS Certified in Emeryville, CA. “For example, in the sprouts industry, some growers have learned to implement the testing of their irrigation water with Elisa-style test kits on a lot-by-lot basis. If they can afford to do this, so can other small businesses. Another possibility is to send out samples on a random basis to an outside lab for verification. Also, implementing an internal audit process on a daily basis can prevent many problems. Have your personnel learn how to implement these practices.”

The Cost Question
The cost of a food safety program should not be an excuse for not having one. “I have heard a lot of wild stories about the expense and unavailability of audits for small and organic growers,” says Devon Zagory, principal with Devon Zagory & Associates LLC, in Davis, CA. “The fact is, audits ought to be the same for them as for anybody else. An annual farm audit can be had for about $500. If you can’t afford $500 a year, then you should probably be in some other business. If you can’t afford to assure the safety of your food products, you have no right to sell them. Food safety costs money, but it is money that everybody does, or should, spend.”

There are ways to leverage costs and knowledge among small growers. “Cooperatives, marketing associations, trade associations and other groups can pool resources to obtain food safety training, consulting and audits,” suggests Zagory. “My previous company, Davis Fresh Technologies, and its successor, NSF Agriculture, have developed many programs for groups of small growers in Latin America and the United States. These approaches take organization and cooperation, but can significantly limit expenses for individual operators.”

PMA’s Whitaker continues, “A lot of the programs we’ve done with our foodservice and retail partners have dealt with those issues. Identifying resources, answering basic questions,and steering growers toward resources at local universities, commodity groups, associations and third parties can help them do things cost effectively and efficiently.”

Help Is Available
There is plenty of help available to get growers over the first hurdle and keep them updated on the latest knowledge. Universities, local ag organizations and cooperative extensions are good places to start. “I recommend small local growers start with their local Cooperative Extension office and ask about GAPs information,” advises Wegmans’ Corsi. “The National GAPS Program website lists a multitude of resources available and shows the GAPs contributors in various states around the country. Penn State, Rutgers and the University of Minnesota all have a tremendous amount of information available to small growers. UC-Davis in California is an established resource for food safety information for growers and is very active with growers on the West Coast.”

“Over the last few years in Florida, efforts have been made to address food safety issues with small farms,” reports Publix’s Brous. “The Florida Food Safety and Food Defense advisory council prepared a white paper titled ‘Small Farms: Recommendations to Minimize Costs While Ensuring Food Safety,’ which is available online. Also, the University of Florida puts on an annual small farms conference, and they also have a wealth of information available on their website.”

Industry associations and private companies are also working with small grower programs. “PMA has had a local grower/small grower food safety training program for about 16 months,” says Whitaker. “We’ve done over 10 sessions across the country. We meet with the growers, provide the training, and take away the anxiety by putting it in language everybody can understand. The PMA-founded Center for Produce Safety is another tremendous source of ongoing food safety research and information.”

“Familyfarmed.org is completing a multi-year effort to develop an online tool for small growers to develop their own food safety programs and recordkeeping,” reports United’s Gombas. “Led by Familyfarmed’s Jim Slama and Earthbound Farm’s Will Daniels, along with a host of capable and concerned stakeholders, this group has worked to bridge the worlds of the overall produce industry’s food safety programs and small companies’ needs and limitations. The group has been piloting and fine tuning their online tool and is expected to launch this year.”

Concerned retailers are also providing leadership on this issue with Wegmans at the forefront. “We’ve partnered with the National GAPs program at Cornell, Rutgers University, Penn State University, the USDA and state departments of agriculture to provide training materials and resources to help local growers implement GAPs on their farms,” says Corsi.

“Retailers like Wegmans have been working with their small growers to encourage adoption of food safety programs,” says Gombas. “They recognize how ‘demand and expect’ isn’t likely to succeed without some support,”

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