Food Safety Culture and the Local Food Movement

The highly regulated food industry has recently reached major milestones in its food safety culture journey. In addition to general acceptance of the key concepts, a unified language and framework has been developed. Food safety culture is no longer a "fuzzy academic concept, lacking in empirical validation."¹ Also, relevant stakeholders including regulatory bodies such as the U.S. Food and Drug Administration (FDA) and the European Union (EU), as well as scheme owners, have incorporated the foundational requirements into their working documents. Examples of such updates include the GFSI position paper,² SQF³ and FSCC⁴ scheme updates, and the Codex Alimentarius^5,6 amendments. Companies can now benchmark and be audited against these standards to determine the maturity of their food safety culture.

Ongoing Challenges

Although food safety culture is now widely accepted in the food industry, many companies still have much work to do to realize the level of maturity stipulated by the benchmark as integrated. Human behavior remains a limiting factor, with reports⁷ indicating that many managers do not trust their employees to train one another in food safety. Additionally, many frontline workers are still not following standard operating procedures (SOPs), despite proper training. Making enough time for education, training, coaching, mentoring, and effectively completing production tasks continues to be a challenge. Investment in food safety culture-related initiatives should reflect the upper management goal to "walk the talk."

The Local Food Movement

The local food movement (LFM) is characterized by short supply chains, typically involving direct sales to consumers. The majority of businesses in this category have a handful of employees and include small-scale farmers and processors, as well as cottage food producers. It is normal to find businesses owned and operated by individuals. Given the nature of the products and relevant state or local laws (where applicable), producers focus on non-potentially hazardous foods that are shelf stable with a water activity < 0.85 and/or a pH < 4.6. The processing of fresh produce before sales is minimal and requires the use of a commercial-grade kitchen. The introduction of the Food Safety Modernization Act (FSMA) Final Rule on Produce Safety⁸ broadened the understanding and scope of Good Agricultural Practices (GAPs). However, small-scale farmers are exempt from requirements in the Produce Safety Rule. Likewise, cottage food producers are exempt from the FSMA Final Rule for Preventive Controls for Human Food.⁹

The foundation of education and training experiences for local producers is based on GAPs and relevant parts of current Good Manufacturing Practices (cGMPs). The concepts of food safety culture are at the infancy stage, gaining traction as the rest of the food industry settles into the new normal of behavior-based food safety practice. This segment of the industry is governed by state-specific oversight, including tax and zoning regulations. There is heavy reliance on university extension services and nonprofit organizations for education, training, and synthesis of relevant scientific information to make business decisions. Investments are based on personal funds, small business loans, and seed grants from state agencies or nongovernmental organizations. Local food systems are also exemplified by significant peer support and shared learning experiences to establish, expand, and sustain the local food movement.

Critical Questions: How Do Food Safety Culture Cornerstones Apply to the LFM?

An important question that must be asked with regard to the place of food safety culture in the LFM is: To what extent do established food safety culture cornerstones² (Table 1) apply to the local foods segment of the food industry?

The five cornerstones of food safety culture, as outlined by GFSI in its position paper, can be applied to the LFM as outlined below:

• Vision and mission: These are established by the business owner. In a situation where the business is a sole proprietorship, all aspects relating to the structure, values, purpose, direction, expectations, leadership, and messaging to consumers is based on the viewpoint of one individual or a handful of people (often a family).
• People: Those involved depend on the number of employees. If the company comprises only one individual, then this person must manage key stakeholders including customers, other producers, and regulators. Communication is highly dependent on the individual's style and may be fragmented in some cases, especially for producers who speak English as a second language. The business owner must determine what information is relevant and how and where to acquire such information. External reward/incentive systems include profitable sales and happy customers. Competition from larger businesses results in a thinner profit margin, but local producers depend on consumers who are determined to pay a premium for locally produced food.
• Consistency: In the local food space, where producers sell directly to consumers and are mostly exempt from federal regulatory requirements, traceability is less complex of an issue than it is with large, corporate businesses. Producers are still advised to keep production records and documentation for lab tests in the case of a foodborne illness report or outbreak. However, small, local food producers are generally not audited, and unless there is a foodborne illness investigation, there is no way to know how thorough these records are, or if they exist at all.
• Adaptability: Local food producers may struggle to keep up with current industry regulations and guidelines. The sheer volume of information can be overwhelming, especially when trying to determine relevant parts of state regulations that apply to their production space. This includes the need for licenses, tax laws, and zoning issues. However, as noted during the COVID-19 crisis,¹⁰ local producers stepped in and filled the gap in many communities when the major supply chains failed. The small company sizes make them agile, and producers can quickly pivot between product types to address consumer needs. For example, a small producer in Minnesota closed his baking business and expanded his fresh produce and flour milling businesses in response to an obvious need in the community between 2020 and 2022.
• Awareness of hazards and risks: Anecdotal and survey¹¹ data indicate that local food producers and their customers generally consider locally produced food to be safe. This belief is reinforced by the fact that few cases of foodborne illness or outbreaks have been associated with this segment of the industry (e.g., only two documented cases in Minnesota related to the cottage food industry). Nevertheless, food safety culture is based on prevention rather than reactive response to illness cases. To this end, it is critical to find effective ways to communicate the risks associated with food handlers,¹² which are relevant regardless of the industry segment. Since these businesses are so small and often have just one or a few individuals, keeping the person(s) engaged in food safety conversations is as challenging as it is pivotal. In the absence of audits or inspections, there is no easy way to verify risk and hazard awareness beyond post-training evaluations and follow-up surveys. This information becomes apparent only by maintaining ongoing conversations with producers and listening to their feedback to determine when further education, demonstration of methods, training, or technical support are warranted.

What Defines the Local Food Movement Culture?

Another important question when it comes to looking at culture in the LFM is: What defines food safety culture in the LFM?

Producers may use their uninspected home kitchens or commercial-grade kitchens for production, depending on the state, product type, and whether or not the consumer is an end user. Trust is key, and consumers are willing to pay a premium to purchase locally produced food and to "know" the producer. There is an inherent belief among consumers that local food is unique (as opposed to mass-produced), safe, organic, produced sustainably, and contributes positively to the climate change narrative. It is important to mention that this is not always the case, although consumers assume it is; and that belief drives the movement among locavores.¹³ Producers have a strong sense of pride and a merged identity with the successes and failures of the business. This is an incentive to do better each time.

The organized corporate structure and resulting pressure from upper management are missing in the LFM. As such, the pressure comes from consumers, other competing producers, and customers such as retailers and wholesalers (where applicable) that might require audits and food safety training certificates to buy from the producer. Trends are significant, especially in the cottage food industry, which is regulated at the state level. Events happening in one state inform producers in other states what goals are within reach. For example, Wyoming established Food Freedom Laws,¹⁴ which set a very high bar for other states. This flexibility is and continues to be a driving force behind bills proposed in dozens of states, some of which have strict laws pertaining to home-based food businesses. In a state like Minnesota, the Product of the Farm¹⁵ exemption to licensure allows any farmer to sell any product personally produced without a license, provided that that no off-farm ingredients are added. Neighboring states struggle with this exemption when Minnesota farmers living near the border sell produce at farmers markets across state lines.

Producers are the primary drivers of many changes in regulatory oversight. As of 2023, all 50 states¹⁶ allow some form of homemade food to be sold directly to consumers. The privileges, however, differ to the extent that every state varies in terms of sales caps, points of sale, food safety training requirements, and other parameters. The producers take a lead in evaluating what is happening in other states and use this information as evidence in proposing amendments to related laws in their specific state. For example, in 2021, cottage food producers in Minnesota proposed amendments to the state Cottage Food Law,¹⁷ which raised the sales cap from $18,000/year to $78,000/year per individual, allowed the sale of non-potentially hazardous pet treats, and also allowed the organization of such businesses as LLCs.

How Can the LFM be Effectively Educated to Achieve a Positive Culture?

A third essential question for food safety culture and the LFM involves education: How can local food producers be effectively educated to achieve a widespread, positive food safety culture?

The LFM can benefit significantly from training and the principles of adult learning,¹⁸ in which Knowles highlights several important points, as explained below.

Adults have a self-concept, meaning they are autonomous, independent, and self-directed. Affording them a sense of respect and ownership of the learning process is crucial to ongoing engagement. Learners that feel disrespected will mentally disengage or leave the room altogether. This includes a respect for native knowledge or lived experiences, whether in the U.S. or abroad. While food safety culture concepts are based on current understanding of science, many of the food preparation and preservation techniques have origins in traditional methods. By acknowledging that every producer has an established process and focusing on science as a unifying space rather than a place where producers lose their identities, trainers can alleviate the pain of learning, unlearning, and relearning that might need to happen during and after the lesson.

Adults also learn from previous experiences, so trainers should introduce food safety principles as new tools in an existing toolbox, rather than trying to overhaul an existing food safety management system, no matter how rudimentary it may seem. Instead, following the technique of scaffolding—connecting new knowledge to existing skills—is a better approach than treating the learners as novices who do not understand basic information. Pre-session evaluations may offer a reasonable baseline from which to start, to ensure that learners are not offended by overly simplified information.

Adults tend to focus on learning about what has personal value. This means that the first few minutes of training or methods demonstration must have a "hook" that clearly stipulates the value of this information to the learner, beyond regulatory requirements. The proposed hook should start by acknowledging the producer's interest in contributing to the food supply in their community in a manner that is safe and sustainable. The trainer then connects this fundamental, personal goal to the science-based practices that help the producer achieve these goals most effectively. Once the producer internalizes and personalizes the lesson ahead of them, the remainder of the learning process is bound to be engaging and, if necessary, behavior-changing.

Post-training evaluations and long-term follow-up studies¹⁹ are helpful for continuous improvement of education programs, but they do not hold much value for learners unless the trainer reports back the information gained in a meaningful way. This can be done by sharing ongoing newsletter updates, short videos emphasizing specific topics of interest, or collaborating on research projects to further address problems that matter to producers.

Another aspect of adult learning that must be taken into consideration is that adults are busy and prefer to learn information to address an immediate need. Designing a learning experience that is task-oriented, life-focused, and problem-centric increases the chance that the learners will pay attention and apply the lessons learned. The traditional hour-long slide presentation is less appealing, and should be augmented with case studies, hands-on team projects, and an obvious connection between the lesson and the purpose for which the producer is taking the training. At the end of the training, the learner should be equipped with tangible next steps to take toward improving or developing a positive food safety culture. Examples can be a farmer constructing an affordable handwashing station²⁰ at the farm or a cottage food producer reviewing and selecting lab-tested recipes²¹ from the Center for Food Preservation. It also helps to have information that may be relevant, but not directly related to food safety, such as who to contact for questions about zoning and tax laws.

Adults are internally motivated; therefore, scare tactics rarely work (and usually only temporarily, if they do). Data on the incidents of foodborne illness²² and the devastating consequences²³ are important and must be shared. However, local food producers consider their products inherently safe and seem less concerned about microbial contamination²⁴ on their farms, for example. It is best to engage their sense of responsibility and motivation for contributing to the local food system. For local foods, the owner's identity and financial wellbeing is often directly tied to the fate of the business, so appealing to their sense of pride and vested interest in success makes a big difference.

Adult learners give significant weight to the why behind what they need to learn. It is not enough to talk about general food safety as an industry concept, or to mention statistics about foodborne illness. The average adult is aware of the fact that poorly handled food can make people sick. The uphill task for the trainer is helping the producer connect a specific product type and the process of making it, to real-time food safety hazards and risks. Furthermore, the trainer must help the producer see how a shortcoming in the process, including tasks as simple as handwashing, can create a loophole resulting in foodborne illness. Once this connection is made clear, it is easier to help the producer understand why hygienic practices and an overall positive outlook on food safety is invaluable to their business.

Until this personal connection happens, the information provided by the trainer is just data. It remains aloof. This is the most challenging component of food safety education. Sometimes learners struggle to see how their well-thought-out process, which has worked for years and never made anyone sick, could possibly cause a problem. A great learning example for trainers to use is allergen cross-contact, which may not be an issue for the producer and their family but could be fatal to a consumer.

Conclusion

Food safety culture is about creating a way of life as a food producer that minimizes the risk of food contamination and allergen cross-contact to protect consumer health. This goal is relevant to all producers, regardless of the company size or product type. Practitioners must find innovative ways to adapt and funnel food safety culture concepts established by industry toward local food production. Incorporating accepted food safety culture terminology into all types of food safety education experiences will help familiarize local producers with this new set of tools to add to their existing toolboxes. These actions will be especially important as the local food movement grows and some producers graduate into more closely regulated spaces, such as retail or wholesale businesses.

Local foods are part of the supply chain and should, therefore, progress with the rest of the industry in this critical area of changing food safety and quality practices for the better.

References

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9. FDA. FSMA Final Rule for Preventive Controls for Human Food. Current as of July 13, 2023. https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-final-rule-preventive-controls-human-food.
10. Ewing-Chow, D. "COVID-19 Has Given Consumers Five New Reasons To Eat Local." July 30, 2020. Forbes. https://www.forbes.com/sites/daphneewingchow/2020/07/30/covid-19-has-given-consumers-five-new-reasons-to-eat-local/?sh=57447eee3ccc.
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Morrine Omolo, Ph.D., is a Compliance Specialist with the Quality Assurance Team at JonnyPops LLC. Prior to this position, she worked as a Food Safety Extension Specialist in the Department of Food Science and Nutrition at the University of Minnesota. She obtained her Ph.D. in Food Science from the same department in 2020. Dr. Omolo's doctoral research focused on characterizing small-scale food producers in Minnesota, to better understand the private and public value of extension food safety education. She focused on food safety regulations applicable to cottage food producers, food protection managers, and fresh produce farmers. She earned her B.S. degree in Biochemistry from Fairleigh Dickinson University in 2012 and her M.S. degree in Food Science from the University of Minnesota in 2015. Dr. Omolo is passionate about bridging the gap between science and practice, and values active learning as an approach to increasing awareness of foodborne illness. She consistently strives to find a balance between the application of scientific knowledge and the natural predispositions in human behavior. Dr. Omolo hopes to continue contributing to the field of food safety science by finding creative ways to align regulatory requirements for food safety with the realities of food production and consumption.