Source: UNIV OF MASSACHUSETTS submitted to NRP
ENGAGING QUALIFIED-EXEMPT SMPS TO COMPLY WITH FSMA PREVENTIVE CONTROLS FOR HUMAN FOOD
Sponsoring Institution
National Institute of Food and Agriculture
Project Status
ACTIVE
Funding Source
Reporting Frequency
Annual
Accession No.
1028671
Grant No.
2022-70020-37562
Cumulative Award Amt.
$400,000.00
Proposal No.
2022-01740
Multistate No.
(N/A)
Project Start Date
Sep 1, 2022
Project End Date
Aug 31, 2026
Grant Year
2022
Program Code
[A4182]- Regional FSMA Center
Recipient Organization
UNIV OF MASSACHUSETTS
(N/A)
AMHERST,MA 01003
Performing Department
Dept: Resource Economics
Non Technical Summary
Despite significant efforts among extension and food safety providers to engage small andmedium processors (SMPs) in pursing compliance with FSMA's Preventive Controls (PC) forHuman Food requirements, the FDA has expressed surprise with how few attestations have beenfiled to-date, compared with FDA's anticipations based on eligibility. To date fewer than 600Qualified Exempt SMPs in the Northeast have filed attestations, suggesting that SMPs are eithernot aware of the Preventive Controls regulations, or that they are aware, but choose not to file.This lack of participation in fulfilling regulatory obligations has important implications both forthe SMPs that are out of compliance, and for the government's ability to maintain a safe foodsupply. Outreach and engagement models that Food Safety Communicators have used in the pastto reach their target audience do not appear to be reaching SMPs. In this proposal, we propose aseries of innovative methods and activities to shift the paradigm of outreach and engagement toengage this particularly difficult-to-reach target audience of SMPs.Processors that are not aware of the PC Rule will not comply with the Rule; The critical missingstep towards increased SMP compliance is engaging SMPs to learn about the PC Rule and accessPC Resources, such as online materials, technical support tools, trainings, educators, andconsultants. We expand traditional outreach strategies to engage SMPs to take that first criticalstep to learn about the PC Rule and access PC Resources. We leverage existing resources andefforts within Northeast Center to Advance Food Safety (NECAFS) and use behavioral sciencestrategies tools to identify novel outreach content and marketing to engage this difficult-to-reachtarget audience of SMPs in the Northeast. The long-term goal of this project is to increase SMPcompliance with PC by enacting a paradigm shift in Food Safety Communicators' outreachstrategy. To achieve this, we pursue three Objectives:Obj. 1: Work with the food safety community in the Northeast to identify and systematicallyanalyze outreach and extension barriers and opportunities to engaging and supporting SMPs toComply with PC.Obj. 2: Use behavioral science methods to ask SMPs to identify the most promising outreachmethods that would encourage SMP uptake of PC Compliance Extension materials.Obj. 3: Use results from Objective 2 to develop a wrap-around PC Outreach and Awarenesscampaign and increase the number of Qualified Exempt SMPs in the Northeast that use PCResources.This Collaborative Engagement project (A4182) will provide rigorous new outreach andengagement models to increase SMP use of PC Resources, leading to increased PC Complianceand a safe food supply.
Animal Health Component
100%
Research Effort Categories
Basic
(N/A)
Applied
100%
Developmental
(N/A)
Classification

Knowledge Area (KA)Subject of Investigation (SOI)Field of Science (FOS)Percent
5035010104050%
6046220301050%
Goals / Objectives
The long-term goal of this project is to increase SMP compliance with PC by enacting a paradigm shift in Food Safety Communicators' outreach strategy. To achieve this, we pursue three Objectives:Objective 1: Work with the food safety community in the Northeast to identify and systematically analyze outreach and extension barriers and opportunities to engaging and supporting SMPs to Comply with PC. Objective 2: Use behavioral science methods to ask SMPs to identify the most promising outreach methods that would encourage SMP uptake of PC Compliance Extension materials. Objective 3: Use results from Objective 2 to develop a wrap-around PC Outreach and Awareness campaign and increase the number of Qualified Exempt SMPs in the Northeast that use PC Resources.
Project Methods
To achieve the end goal of increasing SMP use of PC content housed on the Roadmap to Resources by engaging SMPs through social media and at four large trade events, the project team will first leverage the experiences and knowledge of the FSC community to identify the factors that support or prevent SMPs from engaging PC resources (Obj. 1.). The project team will use this information to validate or revise our proposed behavioral choice experiment design to develop tools to identify what motivates SMPs (Obj. 2.), and then use this information to develop wrap-around campaign to reach SMPs to raise awareness about PC and increase traffic to the available resources presented in the Roadmap to Resources website (Obj. 3.). The wrap-around campaign will use marketing tools, including in-person outreach at trade events and a social media campaign to deliver existing content through the Roadmap.Impact will be measured by establishing baseline use trends through Google Analytics. Specifically, unique and recurring visitors, bounce rate, unique pageviews, geographic region, and click-throughs will all be used to assess the popularity of the site, growth, and which sections of the site are popular or unpopular. By collecting and charting data over the course of the intervention, we will be able to measure an increase in meaningful user interactions and active use of the resources delivered by the site. Google Analytics can also be used to tag outreach events in the site's metrics, thus highlighting the immediate impact of outreach. Additionally, a newsletter signup form can be used to collect user information such as role in the food community and contact information seek out qualitative evaluations of the site and its role in improving SMP awareness and implementation.

Progress 09/01/23 to 08/31/24

Outputs
Target Audience:The target audience for the project is small andmedium food processors (SMPs) topursuecompliance with FSMA's Preventive Controls (PC) forHuman Food requirements.In this reporting period, our Target Audience was primarily members of the Food Safety Community who have experience engaging with small and medium size food processing businesses that are subject to requirements of FSMA's Preventive Controls for Human Foods Rule. Changes/Problems:Activity A.1. Due to a lack of available and qualified graduate student, we were not able to hire for the grad RA role. We will revisit this position in the future, and in the meantime the project PI is taking on relevant additional tasks. Activity 1.1. Baseline metrics data collection began. This required a deeper dive into the website organization and management than we had intially realized in our proposal. The web platform that is used underwent a system-wide transition, causing us to put this on hold until the new system was underway to avoid duplicative efforts. This began at the end of the project year and is ongoing. Activity 1.7 We determined that the process used to conduct the SWOT was not suffcient for compettitve peer-review journal, and so returned to issuing a report. Activity 2.2. We did recieve updated FOIA request results, but they were not robsut enough to use for the project as intended. Most of the project period effort was spent going through several other potential sources for this aspect of the project. After many dead ends, we believe that we have found a good process to obtain this. What opportunities for training and professional development has the project provided?Participated in International Workshop - Survey Design & Experimental Methods in Applied and Agricultural Economics - Michigan State University - May 20-24, 2024. The worshop provided an update on cutting-edge best practices for theoretical and practical knowledge to enable participants to design surveys and employ experimental methods. The workshop was led by leading scholars in the field of survey design and experimental methods in the food business and agfricutlrual economics field. How have the results been disseminated to communities of interest?The SWOT draft report has been shared with the PCWG and lead centers. What do you plan to do during the next reporting period to accomplish the goals?Objective 1: Activity 1.1. Baseline metrics data collection required a deeper dive into the website organization and management than we had intially realized in our proposal. This is in progress. Activity 1.5: We have determined that given the results of our FOIA request and the potential bias of a focus group recruited from programmtic contacts, we will pivot to obtaining validation/ correction of identfied success & challenges with engaging SMPs in PC content delivery. Objective 2: Activity 2.1 Engage NECAFS PCWG to refine research questions, given changes in availability of contact list. Use increased input from PCWG and results from Obj. 1. to design & obtain IRB approval for an online choice experiment to test the efficacy of different motivators to engage SMPs in PC compliance Activity 2.2 Prepare contact list for eligible SMPs. Activity 2.3 Contract with vendor such as Forthright, Dynata, or Prolific to field experiment with national sample. Activity 2.4 Use subset of contact listto field-test the experiment with at least 50 respondents; revise Activity 2.5 Work with NECAFS PCWG to field-test experiment with at least 25 SMPs; revise Activity 2.6 Field experiment with SMP sample Activity 2.7 Begin to analyze experiment results

Impacts
What was accomplished under these goals? Administrative Activity A.1 Determined that there are no suitable RAs at this time. We will review during the next academic year. A.3 Shared project reports at two conference/technical meetings. A.4. Issued required reports and updates. Objective 1: Activity 1.1. Baseline metrics data collection began. Activity 1.5 Determined that our ability recruit nuetral SMPs to participate in focus groups is limited. Pivoted to conducting small sample surveys to vet identified successes & challenges wtih SMPs in PC content delivery. Activity 1.7 Disseminated internal report to regional center leads. Objective 2: Activity 2.1 Expanded literature review, used results from Obj. 1, literature review, and stakeholder interviews to identify core questions to test with SMPs. Activity 2.2 Followed up with FDA to obtain full FOIA request. Determined FOIA content is insufficient for data collection, as is. Pivoted to exploring several different options instead of/ in addition to FOIA. Identified several potential sources and methods to obtain needed information, began to prepare information. Identified several paths forward, depending on data quality. Activity 2.3 Participated in national workshop to improve methodogical approach; identified concerns with the use of Qualtrics as the vendor for this porject. Identified several potential vendors, including Dynata, Prolific, and Forthright.

Publications


    Progress 09/01/22 to 08/31/23

    Outputs
    Target Audience:In this reporting period, our Target Audience was primarily members of the Food Safety Community who have experience engaging with small and medium size food processing businesses that are subject to requirements of FSMA's Preventive Controls for Human Foods Rule. Changes/Problems:Due to delays in award processing our project began three months after the official award start date. This has led to some delays and timing mismatches. Activity A.1. Due to a lack of available and qualified graduate student, we were not able to hire for the grad RA role. We will revisit this position in the future, and in the meantime the project PI is taking on relevant additionaltasks. Activity 1.1. Baseline metrics data collection required a deeper dive into the website organization and management than we had intially realized in our proposal. This is in progress. Activity 1.2, 1.3. There were significantly fewer national activities that focused on PC outreach campaigns than we had expected, and regional center leads did not turn out to be the proper way to map the campaigns. After pursuing these activities with meager results, we changed strategies and instead systematically reviewed funded USDA projects and registerd PCQI events to identify projects and individuals engaged in this work, and then fielded an online survey targeted directly to these individuals. Activity 1.5 This is pushed back to Y2 Q1 for tworeasons. First, due to our delayed start, this activity would have been pushed to the busiest time of year for processors that work with local/regional foods. Second, in analyzing our SWOT results, we observed a need to be more deliberate about our selection criteria for which processors to recruit, and in particular to recruit processors with no relationships to food safety experts. For this reason, we preferred to wait for our FOIA request to be returned (see update below.) Activity 1.7 In reviewing our SWOT report and after circulating a draft to the SWOT participants for review, we determined that the results are substantive and that we would pursue peer-review for this paper, instead of disseminating the report as a white paper through the regional center leads. Activity 2.2. Our FOIA request took significantly longer to process than guidelines indicated, and the report that we received did not return all of the variables requested. We have submitted follow-up communications to determine whether it is possible to obtain the full request. What opportunities for training and professional development has the project provided? Nothing Reported How have the results been disseminated to communities of interest? Nothing Reported What do you plan to do during the next reporting period to accomplish the goals?Administrative Activity A.1Continue to pursue hiring RA Activity A.3 We will share project reports at conference/technical meetings. Activity A.4 We will issuerequired reports and updates. Activity A.5 We will convenethe Advisory Board. Objective 1: Activity 1.5Conduct 2 online focus groups Qualified Exempt SMPs to validate/ correct identified successes & challenges with engaging SMPs in PC content delivery. Activity 1.7Disseminate peer-reviewed paper to regional center leads. Objective 2: Activity2.1Use results from Obj. 1. to design & obtain IRB approval for an online choice experiment to test the efficacy of different motivators to engage SMPs in PC compliance Activity2.2 Continue to follow up with FDA to obtain full FOIA request Activity2.3Contract with Qualtrics LLC (or other vendor) to fieldexperiment with national sample. Activity2.4 Use project team networks to field-test theexperiment with at least 50 respondents; revise Activity2.5Work with NECAFS PCWG to field-test experiment with at least 25 SMPs; revise Activity2.6Field experiment with SMP sample Activity2.7 Begin to analyze experiment results Objective 3: Activity 3.1Use results from Obj. 2 to work with contracted marketing firm & graphic design firms to develop engaging, broad-based outreach campaign Activity 3.2Work with graphic design firm to design outreach materials for events, direct outreach, online promotion, & print advertising as determined by strategy; purchase materials Activity 3.3Use results from Obj. 2 & existing PC food safety content, generate an integrated quality improvement program to improve outcomes measured in-site, such as the user clickthrough rate & bounce rate.

    Impacts
    What was accomplished under these goals? Administrative Activity A.1 Initiated team, set up data management, team structure. Activity A.2Built interdisciplinary Advisory Board with industry and public sector representation. Activity A.3 Shared project reports at two conference/technical meetings. Activity A.4 Issued required reports and updates. Activity A.5 Recruited and convened the Advisory Board. Objective 1: Activity 1.1 Embarked on a deeper dive to structure the website architecture to provide user-generated information that will help us identify more specific information about website users. Activity 1.2 Convened the NECAFS PCWG to map previous PC outreach campaigns. Activity 1.3 Reviewed all USDA funded projects and PCQI courses to identify individuals across the country with any current or past PC outreach campaigns and developed and disseminated an online survey of these campaigns. Results were used to inform the SWOT analysis design. Activity 1.4 Used results of activities 1.2 and 1.3 to conduct a SWOT analysis to anlayze previous PC campaigns. Activity 1.6 Generated a report outlining our findings from activities 1.2-1.4 and submitted the report for peer review in September 2023. Objective 2: Activity 2.2 Made FOIA request to identify target sample for experiments.

    Publications

    • Type: Conference Papers and Presentations Status: Other Year Published: 2023 Citation: Fitzgerald, A. (2023, May 31). Engaging Qualified Exempt SMPs to Comply with FSMA Preventive Controls for Human Food [Conference presentation]. USDA Food Safety Outreach Program 2023 National Project Directors Meeting, Tampa, FL, United States. https://conference.ifas.ufl.edu/fsop/presentations/2-4-Annie-Fitzgerald-Univ-of-Vermont.pdf
    • Type: Conference Papers and Presentations Status: Other Year Published: 2023 Citation: Northeast Center to Advance Food Safety, Annual Meeting. 2023 Invited Facilitator SWOT Analysis for Preventive Controls Educator Program