Source: UNH Cooperative Extension submitted to NRP
ASSISTING MAPLE SYRUP PRODUCERS TO COMPLY WITH THE PREVENTIVE CONTROLS FOR HUMAN FOOD RULE OF FSMA
Sponsoring Institution
National Institute of Food and Agriculture
Project Status
COMPLETE
Funding Source
Reporting Frequency
Annual
Accession No.
1017593
Grant No.
2018-70020-28850
Cumulative Award Amt.
$29,427.00
Proposal No.
2018-05212
Multistate No.
(N/A)
Project Start Date
Sep 1, 2018
Project End Date
Aug 31, 2019
Grant Year
2018
Program Code
[A4182]- Regional FSMA Center
Recipient Organization
UNH Cooperative Extension
RM 212 Nesmith Hall, 131 Main St
DURHAM,NH 03824
Performing Department
Cooperative Extension
Non Technical Summary
The 2012 Census of Agriculture reports there are 518 maple syrup producers in New Hampshire. We anticipate that many of these operations will be eligible for the retail food establishment exemption under the Preventive Controls for Human Food Rule of the Food Safety Modernization Act (FSMA). However, a number of operations, particularly larger and more diversified operations producing an range of value added products will need to comply, and many still do not know where they fall under the rules.The purpose of this project is to create a two day workshop series that will help operations determine whether they must comply with FSMA and provide a relevant and valuable review of state regulations and food safety topics. It is our recommendation to food businesses and farms alike, that even if a food safety plan is not necessary for their business to be compliant, a food safety plan or even a checklist can be a valuable risk management tool. We plan to work with the NH Maple Syrup Producers Association and our associated networks to promote the training and online resources to all producers who will benefit from the information the program will deliver.The proposed program includes a regulatory assessment to verify and clarify our current understanding of the specific steps maple producers will need to take to comply with FSMA, an informational and educational needs assessment of maple businesses in relation to FSMA compliance, and development and delivery of a tailored workshop series and associated educational resources to help these businesses come into compliance.The workshop series will be run twice in different parts of New Hampshire. The workshop series will consist of a one-day in class workshop focusing on the federal and state regulations that may apply to their businesses. The second day will be an on-farm meeting, hosted by a maple producers. This second day will allow the participants to tour a facility where best practices are in place or are being developed. Producers will engage in a group discussion of food safety and FSMA implementation options.Once developed, delivered, evaluated, and refined, the training program for maple producers along with lessons learned will be shared regionally through the NECAFS clearinghouse, an online resource for educators and farm and food businesses. Resources will also be posted on our UNH Cooperative Extensions website for use by maple producers and service providers in state.
Animal Health Component
(N/A)
Research Effort Categories
Basic
(N/A)
Applied
(N/A)
Developmental
(N/A)
Classification

Knowledge Area (KA)Subject of Investigation (SOI)Field of Science (FOS)Percent
71220993100100%
Goals / Objectives
Conduct a regulatory assessment to verify and clarify our understanding of the steps New Hampshire maple producers will need to take to comply with FSMA.Conduct an informational and educational needs assessment of New Hampshire maple producers.Create, deliver and evaluate a training program tailored to New Hampshire's maple producers that will help them come into compliance with FSMA.Evaluate the effectiveness of our training program and resulting producer business and practice changes implemented to achieve compliance and improve food safety.Share our findings with regional partners through NECAFS' recently completed clearinghouse and through other regional centers.
Project Methods
Regulatory Assessment (October and November, 2018)Our first step will be to seek verification as necessary from the FDA through questions submitted to the FDA's Technical Assistance Network (TAN) and discussions with state regulators, as to the specific steps maple producers will need to take to come into compliance. It is our current understanding that most New Hampshire maple producers who are not retail food establishments will be considered very small businesses conducting only low risk activities as defined by the Preventive Controls Rule for Human Food of FSMA. As such, they are required to register as a food facility and follow CGMPs. With the verified information obtained, we will create a factsheet for maple producers that will be incorporated into the training program. Realistically, we have already done much of this work, and will continue this effort, including creation of the factsheet, prior to the beginning of the project.Producer Needs Assessment (October and November, 2018)We will assess current production methods and will identify information and education needs of maple producers using an on-line survey distributed to producers through the mailing lists of the New Hampshire Maple Producers Association and UNHCE. The survey will focus on production practices, producers' food safety questions, an assessment of the current level of knowledge of FSMA, and the tools and information the maple syrup producers feel they will need in order to come into compliance. The survey will also serve as a "Save the Date" notification for the in-person workshops we will conduct in the winter of 2018-19.Training Curriculum and Educational Tools Development (November, 2018)Based on the information obtained and verified during the regulatory and producer needs assessments, we will develop the training program and the necessary tools identified.Workshop Series - in-class workshop (December and January - timed to the maple syrup producers' slow season)Using the information gained in the regulatory and producer needs assessments, we will create a training program that will start with two one-day in-person workshops. This will take the form of creating one workshop curriculum and delivering it in two different locations to make it more geographically accessible to participants.Speakers at the workshops will include UNHCE staff and a staff member(s) from the NH Department of Agriculture Markets and Food (DAMF) which regulates the sale of maple syrup in the state. DAMF also runs a voluntary marketing program called the Seal of Quality which requires an annual inspection for maple producers who choose to participate.The information presented in the workshops will help producers come into compliance with FSMA by informing them about the process of registering as a facility, implementing and documenting updated CGMPs, and/or creating and implementing a food safety plan. The workshop will include a best practice recommendation that operations create a food safety plan even though such a plan will not be required for some maple operations under FSMA. Any businesses that do need a Preventive Controls plan will be directed to appropriate educational opportunities available to them, including scheduled Food Safety Preventive Controls Alliance (FSPCA) Preventive Controls for Human Food courses offered in New Hampshire and in neighboring states.Workshop Series - on-farm workshop (December and January - timed to just before the maple syrup producers season gets busy but after they have gotten the equipment set up and ready)In December and January, we will hold two on-farm meetings, hosted by maple producers, which will allow the participants to tour a facility where best practices are in place or are being developed. Producers will engage in a group discussion of food safety and FSMA implementation options. The date for the meeting will be set prior to the in-person workshop so that the producers can hold the date in their calendars.Evaluate Business Changes and Additional Needs (June 2019 - timed to the end of the maple producers' busy season)In addition to end of session evaluations, an online survey will be conducted with the participants 5 to 6 months after the trainings. At this time we will perform a gap analysis to identify unaddressed challenges or those needing more development and attention.Refine Program Curriculum: (July and August, 2019)Based on evaluation and survey results, and based on our self-evaluation of the program, we will refine the curriculum and associated resources as needed to meet producer needs as identified.Reporting and Sharing of Results: (August and September, 2019)Once developed, delivered, evaluated, and refined, the training program for maple producers along with lessons learned will be shared regionally through the NECAFS clearinghouse. We have been in contact with NECAFS regarding this project and about collaborative plans to make training materials and producer tools available regionally through the network and specifically through the clearinghouse. We will similarly reach out to other regional centers and the Lead National Center, as developed, to share the program through their outreach channels. We will share program agendas, presentations, factsheets, resources developed, numbers of participants and trainers, amount of follow up one-on-one work with participants conducted, outcomes, and participant feedback so that service providers in other maple-producing states may use and adapt the program to meet their state's specific needs.A final report will be developed and provided to the regional center and to USDA-NIFA in REEport. The final report will include program agendas, resources developed, participant demographics, pre and post session survey data showing current and gained knowledge, reported changes or intent to change production or business practices, and impact statements documenting the program's impact on participants.The PD of this project will attend an annual meeting with NIFA and FDA staff where she will report on the progress of the project, share updates on training materials and curricula developed, and report program outcomes to date.UNHCE has developed a website for FSMA resources (https://extension.unh.edu/programs/food-safety-modernization-act-fsma ) and an on-line Farm Food Safety Toolbox (https://nefoodproducers.org/farm-food-safety-toolbox ). The educational and information materials developed as part of this project will be posted on each of these sites for access by maple producers inside and outside of New Hampshire.Program announcements and impacts will be shared with stakeholders and the public through articles posted in UNHCE's Maple Sugaring newsletter, and newsletters of partner organizations such as the New Hampshire Department of Agriculture, Markets, and Food's Weekly Market Bulletin.The PD of this project will ensure that USDA-NIFA funding support is appropriately acknowledged in all publications, announcements, and other related communications.We have thus far identified one pitfall this program may encounter. The cost of compliance with the regulations may make maple syrup an economically non-viable enterprise for some producers, particularly those where maple is one enterprise within a larger diversified operation.A limitation to our proposed program plan, is that the majority of maple producers in New Hampshire are small part time operations and may be unable or unwilling to take the time out of their schedules to attend the training sessions. We hope that the educational resources we post to our website will help those operators and will serve as resources that Extension Field Specialists can use in one-on-one education with individual businesses as needed.

Progress 09/01/18 to 08/31/19

Outputs
Target Audience:The audience our project reached were maple syrup producers. Most were either retail food establishments or farm mixed-type facilities, as defined in the Preventive Controls for Human Food Rule of FSMA. Prior to applying for this grant we had solicited feedback from producers who attended two introductory presentations. Based on their feedback as well as feedback solicited from individual maple producers in the community, we knew the audience had limited familiarity with FSMA and were not clear if and how the rule would impact them. Changes/Problems: Nothing Reported What opportunities for training and professional development has the project provided?Two, eight-hour trainings were held for maple producers. Of the eight hours, six hours was an in-class session which was designed with some interactive presentations, and two hours was a tour of a maple operation to discuss specific food safety and regulatory preparation undertaken by the hosts. How have the results been disseminated to communities of interest?We have posted the flow chart and online tool to our website and the NECAFS Clearinghouse for use by maple syrup producers. At our request, the NH Maple Producers Association sent the link to the online tool to their 400+ membership email list. As of November 22, 2019, it had been used 484 times. We also posted the portions of the curriculum that relate to food safety and FSMA compliance to the NECAFS Clearinghouse for use by educators in other states. We did not include the portions of the curriculum that related to state regulatory compliance in NH as that part is state specific. What do you plan to do during the next reporting period to accomplish the goals? Nothing Reported

Impacts
What was accomplished under these goals? Objective 1: As part of Objective 2's needs assessment, we collected information on maple products currently on the market. The major area that emerged from that was the question of whether specific products were low risk activity/food combinations. For the regulatory assessment, we used the full text of the rules and the TAN to help us answer those questions. We also created a flow chart to help producers determine where they fall under the rules, and an online tool that asks the user a series of questions. Based on the answers, the tool tells them where they most likely fall under the rules. As of November 22, 2019, it had been used 484 times. Objective 2: We developed a needs assessment survey and asked our contacts at the NH Maple Producers Association to disseminate it for us using their 400+ membership email list. The results of that assessment showed that only 15 out of 71 respondents (15%) knew where their business fell under FSMA. The rest either didn't know (44%), weren't sure (34%) or chose not to answer (1%). The survey also gave us a much more in-depth understanding of the range of maple products on the market. Objective 3: Using brainstorming and a logic model design we created a two-day training curriculum that covered determining FSMA compliance requirements for a business, determining if a product was a low risk activity/food combination, facilities registration, understanding Current Good Manufacturing Practices (CGMPs) and other food safety topics relevant to maple syrup, and understanding state regulations related to maple syrup. We conducted the two-day training in two locations. In total 31 people participated representing 23 operations. Objective 4: We used an end of session survey. 17 people completed it, and 69% of them rated the workshops "very useful" or "will use immediately". Six months after the end of the program we called all the participants to ask them a series of evaluation questions to help us gauge the impact of the training and identify any challenges these participants were still dealing with. We completed interviews with 15 participants representing 15 operations. Nine participants (60%) reported making changes in their operations based on things they learned in the course. Example changes were improving cleaning practices including one who reported creating SOPs, reorganizing production space for easier cleaning or safer storage, changing pest management practices, registering as facilities, and improving recordkeeping. The six participants (40%) who reported making no changes said either the course reinforced their understanding that they were already in compliance and producing a safe product or that they are planning retirement. Nine participants (60%) reported they are planning changes in the future based on what they learned. Specifically, three of the nine reported incorporating the information from the class into future expansion plans for their operations. All 15 respondents (100%) said that after the class they are confident they know where they fall under FSMA and what they need to do to comply. Operations required to register as facilities are required to follow CGMPs, a set of food safety best practices that were covered in the class. When asked what remaining challenges they felt they had with CGMPs, two operations cited challenges with creating an acceptable and effective rodent control program and one reported not yet being certain they have the paperwork in order. One operation had specific questions that we were able to help her research and answer. Objective 5: We posted our flow chart, online tool, and curriculum to the NECAFS Clearinghouse. The flow chart and online tool are also available on the UNH Cooperative Extension website for use by maple producers. Additionally, prior to the workshop series we tested our online tool in an interactive presentation at the North American Maple Syrup Council's International Maple Syrup Institute held in Concord, NH on October 28th, 2018. Attendees of this Institute were maple syrup producers, educators, and companies that market good and services to maple producers. We presented a summary of our evaluation results at the FDA Northeast Food Protection Seminar in September 2019 and will be presenting a brief summary of our project results during the National FSOP Roundtable Webinar to be held on December 16, 2019.

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