With the current US produce safety system seen by many as being “fragmented, reactive, and providing too little support to growers,” the Reagan-Udall Foundation recently released a report with an assessment of what an enhanced produce safety system could look like if provided with public and private alliance and investment.
While it would seem that such a public/private alliance should include involvement and funding from federal agencies, the recommendations were steered toward a structured, stand-alone, professionally supported, sustainably funded stakeholder collaboration (SSC), recommending a private-sector-led collaboration of non-government partners (e.g., industry, academia, associations, non-governmental organizations, etc.).
When seeking to correct the fragmentation and reactive nature of the current produce safety system, sustained support is critical, and one of those streams should come from the fed government. With the lack of sustained federal funds supporting produce safety program implementation and technical assistance – seen most pointedly in the reduction of funds to the Produce Safety Alliance (PSA) and underfunding of university extension for technical assistance in this area – there is a critical need for top-down focus from the federal government to address multiple challenges in produce safety, adjacent land uses and water quality management to name a few. A lack of federal support can contribute to higher produce safety risk; for example a lack of federal support to implement produce safety programs may disproportionately affect small to medium sized firms who must spend a significant amount of their budget relative to profits to implement produce safety programs. Regardless of operation size All programs should have the opportunity and resources to implement programs of equal rigor (based on appropriate risk assessment and mitigation) so that safe, healthy produce is available to all.
Where a private-sector SCC could be of benefit is in advocacy. The report states that an SSC could advocate for more extension funding – as sustainable food safety technical assistance has long been underfunded by universities or has been grant based. Although we see focusing on short-term goals rather than long-term sustainable support as a good use of an alliance, we do believe the longer term extension and outreach funding mentioned in the report is critical, with the most important being the creation of a sustainable funding framework for produce safety outreach that integrates multiple sources. This needs to include consistent federal support for produce safety education and technical assistance, filling research gaps, and making information public.
The report also notes that recent federal funding cuts have forced prior collaborative partnerships with university extension professionals and state departments of agriculture to be severely crippled, as 16 of 24 land grant universities indicated that State Cooperative Agreement Program (CAP) funds to support extension activities related to the produce safety rule had been decreased to zero. Thus, we agree with considering the need for flexible state-level funding supporting extension and outreach without being tied to inspection quotas, allowing resources to be allocated based on industry needs; and a small per-unit fee at the point of sale ensuring all buyers contribute to produce safety outreach (i.e., distributing costs more equitably across the supply chain). We do wonder, though how an SSC would leverage the work of the current produce sector support groups (CPS, western growers, IFPA, etc.), as the report addresses the importance of complementing and not duplicating past work but doesn’t go into specific strategies.
We also agree with the need for a continuous and stable support structure (i.e., technical assistance, funding, and research), along with the need for data standardization and sharing (both research and outbreak-related root cause analysis data). It will be important, however, to ensure data sources are protected from regulatory backlash and to provide incentive for data sharing.
In discussing potential pilots as a starting point, agricultural water was proposed. However, with no consensus reached as to what such an effort would entail, the foundation turned it over to the to-be-developed SSC, stating that deliberation on a path forward should be managed within the SSC.
The report describes four strategic opportunities identified through a produce safety dialogue process, two of which particularly caught our attention:
- Make the case for and develop a strategy to increase public investment in produce safety. TAG’s Take: The public already has a great investment in produce safety; the main challenge for the public is misinformation about produce and food safety in general.
- Increase incentives for growers to implement best practices. TAG’s Take: We strongly agree that this needs focus and resources devoted to it – particularly in making this accessible to growers and increasing incentives to implement food safety practices. More sustainable federal incentives and support should be issued and available to growers.
Additionally, a workgroup on policy and economic opportunities addressed a number of needs, of which TAG sees the most important as being ensuring regulatory requirements do not cause undue burdens to entry across scale or product diversification, and addressing the complex food safety challenges of mixed and complex (animal/plant) farming ecosystems and their wildlife borders – both of which require the involvement of federal agencies.
To capture input from the diversified nature of individuals involved in the fresh produce industry, the report included a public questionnaire on produce safety was developed and launched in October 2024. A total of 100 responses were submitted with the following general responses to key theme questions (full detail in Appendix C of the Report):
- What Is Working Well for Produce Safety Programs?
The most frequently mentioned efforts were education and outreach, including Produce Safety Alliance (PSA) trainings; state-led inspection programs; collaboration across state, federal, and industry; On-Farm Readiness Reviews (OFRRs); research support (especially CPS-funded research projects); improved awareness and communication; flexibility in regulations (educate while regulate); traceability initiatives and Good Agricultural Practices (GAP) audits; improved sanitation and environmental monitoring focus; remote training.
- What Can Help Improve Produce Safety?
Key responses were increased resources and funding for small farms, research, and training programs with resources designed to address the specific needs of small-scale growers and regional operations; collaboration among growers, regulators, and retailers with equitable distribution of costs and a multidisciplinary approach; improved education and outreach with hands-on, scenario-based training for growers, especially underserved groups, and transparent communication and clear guidance from regulatory agencies; standardization and policy improvements to include harmonizing audit schemes, clear phased regulations with practical examples and addressing of policy gaps; research into contamination pathways and mitigation strategies with targeted interventions and advanced tools for a proactive focus on risk management; and consumer and retail engagement and education.
- What do you believe is a major obstacle to produce safety progress?
Respondents cited resource and funding limitations, regulatory challenges, communication and education gaps; industry and stakeholder engagement; systemic inefficiencies; economic pressures and market dynamics; political and bureaucratic challenges; and overarching cultural and knowledge barriers. Those which resonated most strongly with TAG were
- Systemic inefficiencies, for which respondents noted that there is a “check-the-box” approach to food safety audits, with the lack of tailored food safety systems for different types of production systems or crops resulting in ineffective practices. Adding the lack of adequate research prevents the development of practical tools for real-world applications.
- Economic pressures and market dynamics with profit-driven motives and lobbying power often overshadow food safety concerns, with smaller farms disproportionately affected by the cost of implementing safety measures and larger corporations sometimes imposing requirements without fully understanding their impact on the supply chain. We also see the lack of adequate knowledge of inspectors being an issue and a symptom of reduced regulatory support overall in this public health sector. Once this is corrected with identification of and alignment around best practices, whether across the board or specific to commodities, we agree that audits should be streamlined to focus on priority areas agreed upon by the produce community.
Respondents were also asked what they saw as major policy changes that could improve produce safety. While we agree with most of the recommendations (many of which are mentioned elsewhere in this article), we do not agree with a simplification of regulations. Although it is true that the current regulatory framework is seen as complex and difficult to navigate, the education of and outreach to producers would provide a better solution then implementing a more streamlined approach which would not necessarily address the diversity of challenges among produce growers.
Two final areas we’d like to address are research and outbreak lessons learned:
- Research: TAG agrees that research is currently fragmented. A lot of groups are doing great work, but there’s no ability to pull together data from all the different work to come up with meaningful metrics or evidence-based risk reduction practices. This is due in part to the variability of the U.S. produce risk landscape (i.e., different agricultural environments have different hazards). Even when research has addressed specific situations, the methods aren’t standardized. Thus, an SSC should have a research support function for recommending standard methods to researchers and having a data repository to help define safer practices. We see this as also helping to incentivize produce industry partners to participate in research.
- Outbreaks: The report notes that a thorough understanding of food safety failures may provide the best evidence for identifying critical practices, so it is important to learn from outbreaks and “near misses.” This is not only about information being gleaned, but also how that information might be used. While the report does mention the formation of rapid response teams (“Go Teams”) and notes that continuing collaboration can help to develop mechanisms to mobilize such teams for quickly gathering insights, we have to wonder how this would work legally, and how the actual steps to close the gaps would be taken. Perhaps the information could be de-identified and released after a designated period?
The report included a great deal of information focused on a myriad of food safety efforts, both current and recommended, but it also brought to mind a number of questions – not the least of which is where the funding would come from. Regan Udall pretty much left that to the SSC, with the report’s overarching recommendation for the establishment of an SSC to deal such questions, seek private-sector investment, and take the next steps.
