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Equivalent Curriculum to the PSA Training
26 Plays1 year ago
The FSMA Produce Safety Rule requires that growers take a standardized food safety training recognized as adequate by the Food and Drug Administration (FDA). Sara Runkel, a Local Produce Safety Coordinator with Carolina Farm Stewardship Association, and Steve Warshawer, Enterprise Development Manager with the La Montañita Food Co-op, are part of a team that is developing an equivalent training program to the Produce Safety Alliance (PSA) Grower Training that is accepted by the FDA. In this episode, Phil Tocco, Produce Safety Educator with Michigan State University Extension, talks with Sara and Steve to learn more about the details of this training, how it will compare to the PSA Training, and the key elements that make a produce safety training effective.
Funding for this podcast was made possible in part by the Food and Drug Administration through grant PAR-16-137. The views expressed in the posted materials do not necessarily reflect the official policies of the Department of Health and Human Services, nor does any mention of trade names, commercial practices or organization imply endorsement by the United States Government.
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Transcript
Introduction to Agri-Food Safety Podcast
00:00:00
Speaker
Hello and welcome to the Agri-Food Safety Produce Bytes podcast, where we discuss all things produce safety and dive into the rules and regulations surrounding the Food Safety Modernization Act Produce Safety Rule.
Sarah Runkle on Small Farm Safety
00:00:14
Speaker
I'm Sarah Runkle. I'm a local produce safety coordinator with Carolina Farm Stewardship Association. And I work with small diversified farms across North and South Carolina to help them prepare for food safety audits and provide food safety education. Working on food safety issues since 2010 and participated in one of the first rounds of PSA pilot trainings.
Steve Warshour's Safety Experience
00:00:40
Speaker
And I'm Steve Warshour. I am one of the original participants in the NSAC Food Safety Working Group that worked through FISMA and GAP and a decade of helping farms be ready to survive and thrive in a regulatory environment. And I also am a farmer, founded the first CSA in New Mexico in the mid-90s and worked for a food co-op in
00:01:10
Speaker
Albuquerque and work in New Mexico with a very robust training collaborative group of non-profits, food hubs, extension and other food safety professionals.
Phil Toko's Role at Michigan State
00:01:24
Speaker
And I'm Phil Toko with Michigan State University Extension based in Jackson covering the entire state with respect to on-farm produce safety.
FDA-Approved Training Requirements
00:01:32
Speaker
So currently growers are required to take a training that is recognized by the FDA as being satisfactory to meet a certain provision of the produce safety rule. The one training that is currently acceptable by FDA is the Produce Safety Alliance Grower Training or the PSA training.
00:01:55
Speaker
So it basically is a full day of an eight-hour PowerPoint that one person on the farm who's associated with the farm has to sit through. And they receive a certificate from the Association of Food and Drug Officials for attending. And once they have that, then if the farm is inspected,
00:02:16
Speaker
the inspectors will ask to see the certificate and then that will help have that farm meet that particular provision of the rule.
Developing Practical FDA-Equivalent Training
00:02:27
Speaker
On 12-22, at least one supervisor responsible party for your farm must have successfully completed food safety training at least equivalent to that received under standardized curriculum recognized as adequate by the Food and Drug Administration.
00:02:42
Speaker
the Produce Safety Alliance Grower Training is the FDA approved standardized curriculum. So the FDA never wanted to necessarily say that there was only one training. So within the provision, the FDA states that the training must meet FDA specifications or equivalent
00:03:07
Speaker
And they say we're equivalent in the rule. And so the nice thing about what the folks at Carolina Farm Stewardship and La Montanita and NSAC, the National Sustainable Ag Coalition, are doing is trying to put together a training that would be equivalent to one that's accepted by FDA. And that FDA has reviewed. Correct.
00:03:37
Speaker
FDA's goal in the creation of these alliance-based curriculums, like the Preventive Controls Alliance, their goal was a uniform standardized curriculum.
Challenges of Standardized Curriculum
00:03:49
Speaker
Farms are sadly not so uniform or standardized, so there's a bit of a challenge there. We all knew that. FDA had to do what FDA had to do and the Produce Alliance delivered. Product is there, product is sound, product is encyclopedic in content and accurate.
00:04:06
Speaker
The equivalent part is how do you meet that aspect, encyclopedic in content and accurate, while also going and doing other things perhaps as well. How do you differentiate now? Remember the original Cornell self-assessment gap guide? It was a three-ring binder about an inch and a half thick. It was basically written to the 1998 FDA guidance
00:04:36
Speaker
But what it did was it allowed a farmer to go through on their own time and self-assess. Okay. Okay. I think what we're aiming towards is something that has a balance between that kind of self-assessment risk level usefulness and darn good content.
Interactive Training Design
00:05:00
Speaker
It's designed to be delivered in person. I feel on farm.
00:05:05
Speaker
There's no presentation slideshow. We have discussed developing a teaching toolkit that includes flip chart material and other visual aids to go along with the workbook that all of the participants will have. And we're not going to like read the whole workbook in the training, but there's highlighted text in the workbook that as part of meeting the equivalency with FDA,
00:05:34
Speaker
We have to designate to them what material is going to be presented verbally, just like in the PSA training. It's like what's on the slide versus what's in the notes. And then there are activities integrated into each chapter. So some discussion based, some actual hands-on activities. And some are done in breakouts to small groups and some are done in large groups.
00:06:01
Speaker
And in terms of how long the training is going to take, that's something that we're going to sort out during the first couple of pilots. So we're scheduling the initial pilots. Our plan is to schedule them for a day and a half so that we have time to make sure we get through all of the material and get feedback from the participants. But the goal, I think, is to have it as a one-day training because we recognize that it's
00:06:30
Speaker
a burden for folks to travel and have to stay overnight somewhere to receive the training or attend the training. I think though a lot of that can depend on time of year and location.
Piloting and Regional Considerations
00:06:42
Speaker
Like in Albuquerque, where we have the Rio Grande running through the middle of the city and a real resurgence of little bits of irrigated farming and almost year round, we could do a module a week and have dozens of people and move from farm to farm.
00:06:59
Speaker
the versatility, what we have to start with some degree of assessment of how effective can we be in a day. And that assessment will tell us how important these other ways of presenting are. And we spend a fair amount of time discussing farmers don't want this, farmers don't want that. Well, we haven't asked enough farmers yet and farmers are different in different locales and at different times of year.
00:07:28
Speaker
Detroit's going to do stuff differently than Southwest Michigan is going to do stuff, let alone the UP, eh? Yeah. We've come up with a workbook design that I think is really informative and farmer friendly. How to PowerPoint could be our main selling point. Food safety training without PowerPoint, sign up here.
00:07:55
Speaker
Okay. So let's, let's back up. What are some hallmarks of a good produce safety training?
Key Elements of Effective Training
00:08:00
Speaker
I think we all would agree that it teaches risk assessment and it provides accurate information on the current public health state of play. And it provides hints as to the evolving nature of that state of play. And it focuses on the human being in the right ways that are implementable and then documentable.
00:08:24
Speaker
We could start making general statements and then we zero in from those general statements to if you're PSR covered, there are record requirements. If you're harmonized gap, there are record requirements. If you're good old gap, there are record requirements.
00:08:40
Speaker
Now we're getting to the gap, the gap little GAP between if it isn't documented, it didn't happen. And the reality, which is any good inspector or auditor is doing an awful lot of interviewing no matter what the records show. Would you agree with that Sarah? Yeah. And I think, you know, in terms of training delivery, it is really hard with this subject area to
00:09:08
Speaker
provide all of this content in a way that's digestible for a broad spectrum of people, right? It's just like a ton of information. And so I think, you know, we have done a good job of using like small diversified farm scale examples in the training and building in time for participants to
00:09:37
Speaker
Think about how risk assessments and other risk management practices might apply to their particular situation.
Using Real-World Farm Examples
00:09:48
Speaker
So it's not as broad. And then being able to have it on a farm and utilize the farm as a real world example too, I think helps to reinforce the content.
00:10:01
Speaker
So I can tell a good training or an effective training, a solid produce safety training should contain both risk assessment. How do I fit into the overall sort of continuum of produce safety for particular things that are pertinent to the rule? And then where are the points that are likely going to change and evolve over time?
Identifying Ineffective Training
00:10:28
Speaker
Are those the three things that you think any and every
00:10:30
Speaker
or do safety training should have in it? I think so because, and it might not be only those three, but that's a starting point.
00:10:38
Speaker
So I'm going to flip the script a little bit and we've talked about what makes for a good food safety training. What should growers look out for to know when they're getting a bad grocery safety training? The problem is you don't know you've had a bad training till you try and go back to the farm and use it. And it might be bad because of not because of the content, but simply because of the trainer or even a fantastic trainer had a bad day. I got a car accident on my way to a training one time.
00:11:06
Speaker
I don't think I did a very good job that day. This is the reality. This is part of what we're talking about. Who do you trust? Why do you trust them? That's also important. So these are the things that I think come together in adult education and when we're doing adult education for the purpose of public health and business development.
00:11:30
Speaker
So unfortunately, I'm evading your question. We can probably do better than that, but I do think that's an important consideration that you may not really know till you get home and try to use it. So this is my question. What should you do if you realize the food safety training you just took didn't get you where you wanted to be? What should you do? Do you just check the box and say, well, at least I'm covered?
00:11:55
Speaker
And frankly, if you're, if you're good enough to know, if as a farmer, you're able to go home and recognize that the training you just got didn't help you much, that's a success.
Integrating Safety into Farm Activities
00:12:07
Speaker
Because you know, you're starting to feel like you're in that culture of food safety genre, finally. So you will then start looking for what you missed. Right, which is a good opportunity to have an OFRR or
00:12:23
Speaker
have someone come out and help you with, you know, if you're going for a gap audit. I do think though, that with this training, because it is targeted more to small, diversified, and that's where we see a lot of beginning farmers, that providing a training that
00:12:49
Speaker
reinforces the idea that food safety is integral to all aspects of farm activities, that it's not an afterthought, which is sometimes where people come in to food safety training, right? Is that they're like, oh, I got to check this box. I've like been working on all these other production areas and now I've got to do this food safety stuff. But really, I mean, I like to remind folks that they should be looking at their farm through a food safety lens at all times, right?
00:13:19
Speaker
being able to reinforce that through a scale appropriate training, I think is really helpful. I would say we will believe that what we're providing sends people home with more actionable doable steps than a typical training.
00:13:38
Speaker
I think that's what we're going to hang our hat on. We send you home ready to get to work and not in a way that undermines what you're already doing well. It's quite the opposite, in a way that builds on your strengths and addresses your weaknesses.
Training for Different Farm Types
00:13:50
Speaker
And that's scale appropriate. That's matching.
00:13:53
Speaker
And I think the thing we were on the lookout for, and a lot of us were concerned about in early FSMA days, even with harmonized gap as well, are we segmenting farming into a point where we're going to have animal farms? Are we going to have diverse farms? Because we tend to think in the sustainable ag world and regenerative ag world that sustainable farms are more diverse. They're not only blueberries.
00:14:22
Speaker
Or only plants. Or only plants. There you go. So what's your vision for your farm? If you are a specialized produce farmer, you may need a different kind of training. If you're a blueberry operation and then you shut down and seasonal and that's all you do, you may need a different kind of training. It may be totally appropriate than what we've developed. Gotcha. Gotcha.
00:14:49
Speaker
Okay. So when do you think the equivalent training will become available to the general public?
Rolling Out Training and Train-the-Trainer
00:14:55
Speaker
I think we'll be piloting it this winter, don't you? Yeah. So we're going to hopefully have the review process done with FDA by the end of September. And then we're going to do, okay. And then we're going to do three pilots. So you're looking to pilot, pilot fall of 2023.
00:15:19
Speaker
fall and winter, fall and winter of 2023. And then roll out the end of 2024. Part of our original deliverables were, was to develop train the trainer process. So depending on how the pilots go, you know, the ultimate goal is to come out of this grant cycle, at least with at least a handful of trainers on the curriculum around the country.
00:15:48
Speaker
where it goes from there is somewhat dependent on further funding. Okay. The thing I'm excited about is inspectional readiness.
Traceability and Recall Focus
00:16:00
Speaker
What we'd like to know from farmers at the end is if you got a call from your Department of Ag saying we're scheduling a FSMA inspection. And so I think the thing we're leaning into is traceability and recall.
00:16:18
Speaker
as being kind of the bridge between PSR and commerce. And that ultimately you don't want your first experience with a regulator to be on a incident follow-up. So we're wanting to start those conversations where people understand that being all too often
00:16:44
Speaker
that farms were tied to outbreaks, that we have responsibilities, and that if we're ready for them, our businesses come through in good shape. And so what we would like folks to, we'd like to never hear again, food safety put me out of business. Because if you listen to your training and you do your job and you do, food safety is actually making you better. It's not putting you out of business. We want to see that narrative flip.
FSMA Training Certification Changes
00:17:14
Speaker
Produce food safety, we're always learning. It is not a static world. So much so that even in preparing this podcast on training, how and what our focus is in training is also evolving. So just to show you all how dynamic food safety is, let's follow up with an addendum to the podcast that came about during the two months we were preparing to present this to you. We've been having ongoing
00:17:44
Speaker
Mainly Steve and Roland and Connor, or have been speaking with additional folks at FDA about the review and how this will be described to folks in terms of meeting equivalency.
00:18:00
Speaker
You know, this alternative versus equivalent and the 2019 draft final guidance, that's their new Bible. Okay. So if our audience is trainers and organizations who are invested in small farmer success, they're going to want to know that alternatives out equivalent is in the, the, this is the link to the document that tells you the rules for equivalency. Okay.
00:18:30
Speaker
if you want to talk about that. The other thing that's news is PSR inspectors are making less emphasis on the training itself unless they find farms with significant problems. Then the training comes into question more, which is absurd. It's backwards. And I feel like the folks we train, we want them to
00:18:54
Speaker
Embrace food safety as a long-term commitment, not as a check the box, get your certificate, go back to your day job and make somebody sick. And so we're pressing really hard to find out whether 50 different states and 30 tribes with 80 fismas
00:19:14
Speaker
Are messing people up or are they all living by that? Unless your farm's a mess, we don't care what your training was. So what's happening is the training is being rendered irrelevant. They are not asking for certificates. Some might ask, but it's not required. It's not required. The inspector may or may not ask for a certificate. Right.
00:19:37
Speaker
Correct. So we were hung up on our certificate. There is a de-emphasis or a change of focus around certification, around training. I think that's a good message. The role of training in a successful farm has changed since FISMA was written.
00:20:00
Speaker
One could say, based on the feedback that we're getting, not only in our OFRRs, but in inspections, that one of the key deficiencies has been worker training. Now worker training records, but worker training. So that's not the sort of approved curriculum
00:20:23
Speaker
deficiency, that is once the person who takes the bite of the big training and takes it back to the farm, that information isn't getting relayed, isn't getting pushed into the farm workers.
00:20:40
Speaker
Which I would see that as like information that can improve our training in potentially the form of an additional activity or like some supplemental information that focuses on how to effectively deliver food safety training to your workers.
Cultural Shifts in Food Safety Training
00:21:00
Speaker
I think an activity based focus on worker training could be really helpful.
00:21:06
Speaker
And I think, and Steve correct me if I'm wrong, but I think where you were going with that follow up information, knowing from farmers, if they are having issues when it when inspections happen.
00:21:18
Speaker
that are attributed to training, not worker training, but like their supervisory level training, right? That would be great for us to know as curriculum designers trying to improve food safety adoption through this training, right? Where are they seeing issues with their training? When we started doing PSR and developing the standardized curriculum, we weren't hardly even using the word culture of food safety yet.
00:21:48
Speaker
So we're now a decade behind the integrated food world. FDA had a vision of something it called the National Integrated Food Safety Strategy. This thing was written in like 96. Right. We are not incorporating produce training into that National Integrated Food Safety Strategy vision. We're just checking the box. And
00:22:13
Speaker
The place where we learn the most about how far off we are is in food defense and homeland security type of focuses on food. The kind of training we want our farmers to embrace gets all the way to the farm worker with the if you see something, say something type of thinking. But if you see something, say something, you've got to know what you're looking for. You've got to be empowered to talk about it and safe to do so.
00:22:43
Speaker
You've got to not be sent home for the day and lose a day's pay. You've got a bunch of culture shifts that have to happen. This is not a static topic and no level is it static and training itself isn't static.
Acknowledging Collaborators
00:22:58
Speaker
So this project has been going on since 2018 and over the years there have been a number of collaborators working on
00:23:08
Speaker
developing the curriculum, and we just want to make sure we acknowledge all of the different project partners and folks who have contributed to the curriculum. Those project partners include Carolina Farm Stewardship Association, Community Alliance Family Farmers, the Wallace Center, National Farmers Union Local Food Safety Collaborative, the New Mexico Farmers Marketing Association, and the National Sustainable Agriculture Coalition.
00:23:38
Speaker
Links to anything referenced in this episode are provided in our show notes, which can be accessed on the website at c-a-n-r dot m-s-u dot e-d-u slash agri-food underscore safety. Thank you to everyone for listening and don't forget to tune in next month for another episode of our Produce Bites podcast.