You Say Tomato, I Say Raw Agricultural Commodity: Effectively Communicating Regulatory Requirements to Produce Farmers

Introduction: There are approximately 121,000 fruit and vegetable farmers in the United States. Considering exclusions and exemptions in the Food Safety Modernization Act Produce Safety Rule, about 35,000 of these farmers may require produce safety training and the rest may need training to meet market demand for food safety practices. The Produce Safety Alliance standardized training includes both best practices and regulatory requirements to reduce produce safety risks, however, the balance between regulatory language and understandable terms was difficult to strike.

Purpose: This narrative case study provides insights and mechanisms used to balance the need to retain the value of the curriculum to enhance produce safety training while meeting regulatory requirements.

Methods: Seven training modules were developed over five years, with input from hundreds of subject matter experts including farmer focus groups. Upon incorporation of the final Produce Safety Rule language, the modules were submitted to FDA for review.  Comments from the first round of the final FDA review were summarized according to type.

Results: One challenging training module, agricultural water, received 380 comments during the review.  In all, 50% (209 of 421) of the statements in the training module received comments.  Approximately 8% questioned the accuracy of the regulatory information and 9% represented requests to convert grower-friendly language to regulatory language.  The majority of comments (74%) addressed training material that was not intended to represent the regulatory language but may have been interpreted as regulatory content. 

Significance: The educational value of the module was retained by arranging the slides into two types:  those dealing with plain language Good Agricultural Practices, and the other dealing with regulatory requirements that included the addition of the provision symbol in the corner of the slide.  This strategy resulted in a well-balanced module and is presented as a practical model for other food safety education professionals facing similar challenges.