Understanding The Costs of
On-Farm Food Safety
Martha Sullins
Colorado State University Extension
January 11, 2014
Overview
• What are the key policy and economic
drivers impacting food safety today?
• FSMA update
• Role of Good Agricultural Practices
• Estimated costs of good agricultural
practices
• Managing expenses AND keeping your
produce safe
Balancing public and
individual health
High levels of foodborne illness
in the U.S.
Most recent estimates:
• 48 million cases per year
– One out of every six of us
• 128,000 hospitalizations
• 3,000 deaths
• Not all persons are at equal risk of
contracting a foodborne illness – some have
higher risk
– pregnant women (& fetus), seniors, young
children, compromised immune system
Source: Scallan et al., 2011
The costs of food safety
incidents to consumers and
their communities
Ohio State Researcher: Foodborne Illness
Costs $77.7 Billion a Year
Jan 17, 2012
Cost of food-borne illnesses is deemed much
higher than earlier estimates
A report sponsored by the Produce Safety Project at
Georgetown University puts the health-related price tag at
$152 billion a year. That's more than four times an earlier
USDA estimate.
March 03, 2010|By Andrew Zajac and P.J. Huffstutter
COLUMBUS, Ohio -- The cost of foodborne illness in the United States is now estimated to be
up to $77.7 billion a year, according to an analysis by Ohio State University researcher Robert
Scharff.
The industry says … “Produce is a
target”*
• 24-hr news cycles (TV, Internet & social
media) have changed food safety
forever…
• Reports of lost consumer confidence
abound
 Works against consumption
 Who is the most trusted spokesman?
• Advocacy groups increasing
• Food safety law is growing field
• Brand protection = buyer requirements
• Liability insurance needs impacting
producer/buyer relationships?
*From Produce Marketing Association
Yet, we’re lagging in fruit and
vegetable consumption
• USDA Food Patterns (2010) recommend
consuming 2.5 servings of vegetables and 2
servings of fruit per day.
• CDC (2010) estimated only 26% consumed
vegetables three or more times per day, and
only 33% of adults consumed fruit two or
more times per day.
• CO Child Health Survey (2012) estimated
56% consumed less than 2 servings of
vegetables per day and 50% consumed less
than 2 servings of fruit per day.
A look at federal government
and produce grower responses
to food safety issues
What is FSMA?
Food Safety Modernization Act
• Reform of US food safety laws affecting
domestically grown and imported foods (for
human and animal foods), through 7 major
rules, plus guidance, including:
– Produce Safety (Standards for the Growing, Harvesting,
Packing, and Holding of Produce for Human Consumption)
– Preventive Controls (Current Good Manufacturing Practice
and Hazard Analysis and Risk-Based Preventive Controls for Human
Food)
• FSMA was signed into law on January 4, 2011
List of all FSMA rules and guidance:
http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm253380.htm
For the produce industry, the
proposed Produce Safety rule:
• Means new standards for growing,
harvesting, packing, and holding produce.
• Applies to fruits and vegetables normally
consumed raw (e.g., apples, carrots,
lettuce, onions, tomatoes).
• Does not apply to produce rarely
consumed raw (e.g., kale, potatoes, winter
squash) or grown for personal
consumption.
Proposed Produce Safety rule
establishes standards for:
•
•
•
•
•
Agricultural water,
Soil amendments (manure/compost),
Animals (domesticated & wild),
Workers’ health and hygiene, and
Equipment and food contact surfaces
Addresses the same 5 likely sources and vectors of
fresh produce contamination in the field, during
and post-harvest, as in the 1998 FDA GAPs Guide
and most fresh produce guidance docs.
Who does the Produce Safety rule
apply to?
• At this time, any farm that grows, harvests
and distributes fruits and vegetables into
commerce, with exemptions for:
– Size of business (based on total sales )
– Percentage of direct sales to qualified end users
Food sales include all products grown or raised for human or animal
consumption or to be used as ingredients in any such item (i.e. produce that is a
RAC), processed produce (non-RACs such as fresh-cut produce), animal-derived
products such as milk and meat, aquaculture.
How have the last 12 months
influenced food safety policy?
• FDA developed resources, held meetings
and webinars to respond to industry
concerns
• 7-month comment period
– Produce Safety Rule (18,547 comments rec’d)
– Preventive Controls Rule (7,437 comments
rec’d)
Coalition of state ag directors, NSAC
& United Fresh identified:
• Added regulatory costs could reduce profits
for existing farmers & prevent farm start-ups.
• Reduced access to fresh local food, and regs
discouraging on-farm value-added processing.
• Diversifying income more difficult since more
revenue would bring more regulation.
• Costly water testing, including requirement
that farmers test water from open sources
every seven days.
Farmer friendly?
“Because of the input we
received from farmers and
the concerns they
expressed about the
impact of these rules on
their lives and livelihood,
we realized that significant
changes must be made,
while ensuring that the
proposed rules remain
consistent with our food
safety goals."
Michael Taylor, FDA
What’s next?
• Environmental impact statement still open
for comment until March 15, 2014
• FDA is revising language on both rules, will
open them for comment in early summer
2014
• In particular, FDA is revising:
– water quality standards and water testing
– standards for using raw manure and compost
• Final rules must be published in the Federal
Register by June 30, 2015
Final implementation
• Two year implementation (2016 likely first
year of enforcement)
• Dates to be staggered for small (3 years)
and very small (4 years) operations
• Plus 2 years for some water requirements
Science-based food safety
practices
What are GAPS?
Good Agricultural Practices
During
Harvest
During
Production
Before
Planting
PostHarvest
GAPs
• Practices used during crop production, harvesting,
and packing to minimize the contamination of fruits
and vegetables from human pathogens.
• Focus on the fundamentals of:
‒ Safe Soil
‒ Clean Water
‒ Clean Surfaces
‒ Clean Hands
How much do fruit and
vegetable producers invest in
food safety?
In this study, CSU wanted to
understand…
• The costs of GAPs for worker training,
recordkeeping, monitoring, testing,
cleaning and sanitizing activities to
produce and sell produce with the lowest
risk of microbial contamination
Collecting data to understand current
costs that growers face
This will allow us to:
1. Help growers better incorporate food
safety into their financial planning
2. Provide feedback to FDA on the impact
of FSMA in Colorado, to different sizes
of fruit and vegetable operations
3. Project increased costs under FSMA
Wide range of on-farm food safety
costs
• Labor force:
– New hires to manage food safety program or
practices?
– New tasks for existing workers?
• Worker hygiene:
– Training
– Sanitation supplies
• Facility improvements & upkeep
– Restrooms, hand-washing stations
– Drinking water stations
Costs of ensuring safe inputs
Testing:
– Production and post-harvest water
– Soil & soil amendments
Monitoring:
– Supplies for temperature control
Management:
– Sanitizing post-harvest water
– Fencing, deterring wildlife & pets, berms,
irrigation system modifications
Expenses related to facilities, tools
& equipment
•
•
•
•
Rodent control
Cleaning supplies
New tools, equipment & packaging
New or improved facilities:
– Construction of new wash stations, coolers,
storage areas
– Upkeep on buildings, equipment
Recordkeeping, marketing
communication, other costs
•
•
•
•
•
Signage, labeling, packaging
Traceabililty
Web site improvements, software
Audits
Insurance
So far, growers from 13 counties
have responded
• Most are growing diverse crops that will fall
under FSMA
• By size of farm:
>100 acres
30%
(9 farms)
10-100 acres
13%
(4 farms)
<10 acres
57%
(17 farms)
Farm profile
• By annual sales:
>$500,000
(17%)
$250,000$500,000
(40%)
Under
$25,000
(30%)
$25,000$249,999
(13%)
• 40% have livestock operations also
• 67% are open to the public
Most report having a food safety
plan
Working on
it now
(33%)
No plan
(3%)
Yes
(60%)
Most growers use GAPs, as well as
other food safety practices
80%
70%
60%
50%
40%
30%
20%
10%
0%
More than half have conducted an audit
themselves, but have not used outside
auditor
• Self-audit in 2013=60%
• Third-party audits: 53% have not
conducted one, but other growers have:
25%
20%
15%
10%
5%
0%
Labor impacts of food safety
• A few growers hired new staff (20%)
2012
2013
Managers
20%
10%
Paid labor
7%
3%
Volunteers, interns
0%
0%
But many conducted annual
worker training in 2013
• 80% trained managers at $388 per manager
• 57% conducted worker/field labor training
at $31 per worker
• 20% trained volunteers at value of $40 per
volunteer
Training costs depend on scale of
operation and practices
Average number trained
Managers
Field workers
>100 acres
5
162
10 - 100 acres
2
31
<10 acres
1
5
Hidden or unanticipated costs: labor
1. Labor costs
(management)
2. Labor costs
(nonmanagement)
• Employee training
(delivery & participation)
• Recordkeeping
• Hygiene
• Post-harvest food safety
• Cleaning food contact
surfaces
• Vehicle inspection and
cleaning
• Mock audit
What do growers report as their
yearly costs of GAPs?
(Average expenses per acre, all farms)
Additional time spent on food safety
practices
$ 1,292
Employee training
$ 248
Improvements (coolers, restrooms,
fencing)
$ 614
Supplies (paper towels, gloves, sanitizers)
$
Audits, packaging, consumer info. at
market
$ 267
Annual expenses for improvements
$ 202
Water & soil testing
$
Average total expenses on food safety
$ 2,942
296
24
Average annual per acre costs for
supplies ($296)
Containers, packaging
$
167
Handwashing & hygiene supplies
$
39
Office supplies for traceability,
documentation
$
34
Rodent control supplies
$
24
Sanitizers for post harvest water
$
12
Cleaning supplies & sanitizers for tools, etc.
$
10
Temperature control supplies
$
9
One-time investments, average annual
per acre costs ($614)
Fencing, wildlife deterrents
$ 331
Coolers, insulation
Post-harvest handling (wash stations,
sanitation equip)
Production water-source, delivery, drainage
changes
Hygiene improvements (restrooms, handwashing)
$ 96
Processing & packing costs
$ 27
Harvest tools & equipment
$ 26
Signage on safety, visitor & worker policies
<$ 1
$ 48
$ 42
$ 33
Examples of unanticipated or
overlooked costs
• First aid kits, drinking water stations in the
field
• New electrical wiring to support walk-in
cooler or other refrigeration
• Software to track employee training,
payroll
• All new packaging required by produce
buyer
Keeping your costs under control
1. Assess your food safety risks, based on
your production inputs, managerial
capability, workforce, adjacent land uses
& activities, water sources
2. Use estimated costs as a budgeting
guideline
3. Follow critical practices
Critical practices that will help avoid
or reduce additional costs
• Document, document, document
– Keep track of your practices
– Keep track of your costs
• Test water regularly
• Keep work areas clean
• Train workers regularly on hygiene &
sanitation practices
• Check cooler temperatures daily
• Sanitize all tools and harvest containers often
• Use well-composted manure
• Keep animals out of crop production areas
Save the Date!
Tools for Improving Food Safety on Your
Farm
March 12, 2014
Montrose County Fairgrounds
Topics covered:
• Assessing worker practices & developing a training program
for your workforce
• How and when to take water samples, how to read water test
results, & developing a management plan based on test results
• Developing and implementing cleaning and sanitizing
procedures for tools and equipment
• Developing a product traceability, recall and communication
plan for diverse supply chains
Resources - Basics of GAPs
Good Agricultural Practices webinars
• Part 1: Food Safety Basics, Regulatory Landscape, 3rd
Party Audits, Worker Hygiene
Available from:
https://connect.extension.iastate.edu/p97225744/Webi
nar 1 Slides
• Part 2: Minimizing Risks During Production: Irrigation
Water and Manure Management
Available from:
https://connect.extension.iastate.edu/p26083829/
Webinar 2 Slides
• Part 3: Minimizing Risks During Harvest & Post-Harvest:
Washing & Packing, Cooling & Storage, Transportation &
Traceback
Available from: Webinar 3 Slides
Resources - Creating a Plan
• Fundamentals of Creating a Colorado Farm
Food Safety Plan Webinar: Webinar:
https://connect.extension.iastate.edu/p4b9anz
5nu9/
• Colorado Farm Plan Guide:
http://www.farmtotable.colostate.edu/growfiles/ColoradoFoodSafetyPlanGuide.pdf
• Colorado Farm Plan Template:
http://www.farmtotable.colostate.edu/growfiles/2012-ColoradoFarmPlanFillableForm.pdf
More Resources
• Global GAP: http://www.globalgap.org/uk_en/forproducers/crops/
• Harmonized GAP:
http://www.ams.usda.gov/AMSv1.0/HarmonizedGAP
• CSU Extension food safety web site:
www.farmtotable.colostate.edu
• Food safety & direct marketing regs:
www.cofarmtomarket.com
• http://www.foodsafetynews.com/
• http://www.fda.gov/Food/FoodSafety/FSMA/default.htm
• FSMA Updates to subscribe to email updates from FDA
Questions or for more information,
Martha Sullins
Colorado State University Extension
martha.sullins@colostate.edu
970-498-6006