Using Leafy Green Marketing Agreement audit data to determine non-compliance areas and preparation of training and recommendations for improvements in future growing seasons.

The purpose of the Intertox Leafy Greens Marketing Agreement (LGMA) Audit Data Evaluation Proposal is to use data collected by the California Department of Food and Agriculture (CDFA) during audits of lettuce and leafy greens producers to determine if there are more efficient and effective methods for preventing the microbial contamination of these crops. This proposal consists of four elements: the collaboration with CDFA and the LGMA Advisory Board to obtain confidential audit data for analysis; the statistical analysis of the data for trends and compliance issues; the preparation of training tools and training sessions for growers, and; recommendations to LGMA for any changes in best practices and/or the audit document. The overall objective of the proposal is to reduce audit compliance costs for producers while making leafy greens safer (and less expensive) for the consumer.

The purpose of the Intertox Leafy Greens Marketing Agreement (LGMA) Audit Data Evaluation Proposal is to use data collected by the California Department of Food and Agriculture (CDFA) during audits of lettuce and leafy greens producers to determine if there are more efficient and effective methods for preventing the microbial contamination of these crops. This proposal consists of four elements: the collaboration with CDFA and the LGMA Advisory Board to obtain confidential audit data for analysis; the statistical analysis of the data for trends and compliance issues; the preparation of training tools and training sessions for growers, and; recommendations to LGMA for any changes in best practices and/or the audit document. For LGMA grower cooperation, it is imperative that the data collected during audits and provided to Intertox contain only regional geographic identifiers. Once the data has been shared with Intertox, a variety of statistical tools will be used to determine trends and if those trends are in compliance with the LGMA best practices by region or other categorical data. The results of this analysis will be used to develop training materials that will be implemented in growing region-specific LGMA/CDFA sponsored workshops. After completion of the training sessions, Intertox will provide recommendations to LGMA and CDFA for changes to the best practices and audit methodology as appropriate. This project will enhance the competitiveness of California specialty crops by improving existing best practices and removing unnecessary or ineffective practices in an effort to streamline the audit process. It will also benefit consumers by providing more information about the efforts underway to continually ensure the safety of specialty crops.

1. Develop an acceptable plan for assuring audit data confidentiality with LGMA, CDFA, and CPS. 

2. Determine if there are regional or other identifiable trends in compliance data. 

3. Prepare training tools and use them to conduct region-specific producer workshops sponsored by LGMA and CPS. 

4. Prepare recommendations for changes to the metrics and/or the audit methodology based on project results.

Training Recommendations Although average audit scores in the various categories tended to remain the same or decrease slightly between September 2008 and March 2011, actual score ranges indicate the need for further training to continue to improve performance. Based on the results of both the benchmarking and the Pareto analysis, two types of training are recommended. The first recommendation is for individual handler-specific supply chain training where all members of a handler’s supply chain are trained as a group. This type of training would integrate the supply chain companies and facilitate working as a team with a common purpose. Supply chain training could take place prior to the start of each season. The benefits of this type of training are that the team members gain an understanding of the handler’s requirements and SOPs (particularly useful if a grower works with multiple handlers and if SOPs are changed or updated), responsibilities are clearly communicated, and issues can be identified. Even if a handler is vertically integrated and already conducts training with its growers, consideration should be given to adding water testing laboratories, harvesting companies, sanitation suppliers, and soil amendment suppliers to the training groups. The second type of training recommended is functional training (i.e., training on specific functions or processes). The analysis of deviation types reveals functional training needs exist at the industry level to address issues common across many of the growers and handlers (one example is knife sanitation and testing). The LGMA is currently positioned to offer this type of training. However, to ensure success, the LGMA would require direct access to grower and harvester lists and a documented training process including metrics for evaluating the training impacts. Additional handler-specific training based on handler SOPs could be offered once industry training is complete. Handler requirements for harvesting companies could be extended to include industry level training and advanced handler-specific training. In terms of individuals that would benefit from training, the analysis demonstrates a need for harvest worker training (including field workers, foremen, and supervisors) and a need for food safety personnel management training (including managing the supply chain and documentation process planning and management). Worker training could include how to perform knife dip tests, sanitization and proper storage of knives, sanitization and proper storage of gloves, and appropriate clothing and clothing storage for harvest workers. Because of the repeated cases of worker-related violations, daily tailgate training is recommended. If handlers are already training daily, it is recommended that they consider implementing quality circles. Workers could meet at the end of every shift and review harvest events and identify issues and how to fix them. This would allow team members to learn from each other, and quality or food safety would become a daily focus. Friendly competitions between harvest crews could provide incentives for participation. The benefit of quality circles is that all workers, and not just foremen and supervisors, would have ownership in product quality. It is recommended that quality circle efforts be documented and tracked as a measurement of harvest process quality. Specific training topics recommended based on the research are: - For the harvest worker, a one day training program could be structured to include the following classroom topics: how to perform knife dip tests, how to sanitize knifes, how to properly store knives, how to sanitize gloves, determining when gloves should be replaced, and food safety issues associated with clothing, jewelry, and cell phones in the production areas. These topics could be followed by demonstrations and testing on processes (e.g., workers could demonstrate how to conduct a knife test, how to mix chemicals, and what to do if supplies are not available). The same day handler-specific training could address handler-specific SOPs for the same topics, and what to do if growers work with multiple handler SOPs. - Food safety personnel training could cover three areas: testing, documentation, and third-party or supply line management. Specific components could include: o The testing session could help establish and/or provide training regarding sampling plans and protocols for required testing, and organize a daily tracking routine that ensures that required tests are scheduled (e.g., water testing) and completed (e.g., knife, glove, product spray, harvest equipment cleaning), and that results are logged correctly with complete documentation. o Documentation training could cover water testing, daily assessments, and ranch maps. Participants could include CDFA auditors, the compliance officer, handlers/growers, and food safety personnel. A breakout session could provide handlers/growers with an opportunity to share concerns with documentation and then, as a group, discuss solutions to simplify the process while ensuring LGMA best practice compliance. (One example is how to add required details to ranch maps without producing a map that is illegible.) Other training sessions could address documentation management issues such as revisions, storage, and retention planning processes. Tools to help organize and simplify documentation required for testing could be incorporated into the LGMA website linking directly to the audit database. The benefit of online tools would be reduction of paperwork and simplified documentation management. o Supply line management training topics might include training food safety personnel as project managers assigning responsibilities, establishing requirements, working to ensure the requirements are met, and tracking performance. This type of training would be helpful when working with sanitation companies, water testing laboratories, and compost companies. Other Recommendations In addition to training, recommendations for the LGMA and its operations include: - Consider certification for LGMA supply chain participants that are not audited. Certification would benefit handlers given limited resources and staff time available to oversee supplier quality levels, and also offers handlers greater protection than letters of guarantee. - Implement a feedback process for using observations from audits to address industry issues. Details and findings recorded in the audits sometimes identify issues that are common to all handlers and growers. If the issues re-occur, a process for discussing the issues and working on industry level solutions would be beneficial. (One example is covering the metal grates on harvest equipment to prevent potentially contaminated dirt from falling on harvested produce.) - Consider developing a mechanism for scoring the audit checklist and by association the audit results; this would enable growers/handlers to focus on issues that are known to or believed to have the greatest impact on food safety. (For example, a soap dish that is not labeled is probably less of an issue than grey water leaking from a sanitation unit at the edge of a production field. Scoring would indicate the importance of the observation even if neither observation resulted in a CAP.) - For the LGMA to offer successful training programs, handlers should provide the LGMA with direct access to growers and harvesting companies. Currently, only the CDFA receives the list of growers/harvesters each season from the handler. Without such a list, it would be difficult for the LGMA to identify training targets and verify training goals. - Develop an Internet-based system to manage required documentation and testing results for all handlers/growers. An electronic system could help minimize audit time requirements and/or the work required to complete an audit after it occurs. Common templates for use by all LGMA members could reduce the time it takes to complete and maintain documentation. Summary While audit requirements and compliance with those requirements are not in and of themselves capable of measuring a grower’s or a handler’s entire food safety program, the LGMA audit results provide some insight into grower/handler food safety programs and performance. The value of this type of research is its ability to measure where the industry is in terms of ideal quality levels and then provide a means for individual growers and handlers to understand how they are positioned in the industry. By measuring and tracking performance against quality metrics, improvements can take place. Measuring performance levels in this research was not intended as a means to identify “bad actors.” The LGMA audit process monitors performance and corrects issues through corrective action plans on a regular basis. This analysis examined every deviation and every comment, whether it resulted in a deviation or not, to determine what can be learned through the history of the program, and recommend what can be improved and how improvements can be made. According to quality principles, every issue, regardless of how insignificant, should be viewed as an opportunity for learning and improvement. The results of this study can be used to improve processes and reduce inefficiencies that will lead to reduced costs for the growers/handlers and along with additional training, lead to a greater ability to understand and address food safety issues.