In today’s fresh produce supply chain, foodborne illness is a major challenge for growers and retailers who take pride in providing nutritious and healthful fruits and vegetables to consumers. The industry has made significant strides during the past two decades to reduce the likelihood of pathogen transmission, but the ongoing prevalence of outbreaks and recalls shows that more can and should be done on this front. In this regard, we at the Equitable Food Initiative (EFI) join the produce industry in welcoming the new Food Safety Modernization Act (FSMA) produce safety rule. farmworkers On the heels of the November publication of the rule, food safety audit programs are now benchmarking their own standards and requirements to the new rule. EFI, too, wants to be sure that our certification ensures FSMA compliance and facilitates the adoption of preventive measures by produce growers. Upon first review, we are confident that our standards meet or exceed FSMA requirements, though, if necessary, we will amend our program through multi-stakeholder consultation to provide robust evidence that the farms we certify abide by the produce rule. We do want to draw attention to one particular area of the new rule. The FDA comment on revisions to Subpart C affirms “the farm worker is a key component in the food chain for ensuring the safety of covered produce.” Consequently, the rule requires worker training on the importance of personal hygiene and the link between their own health and the potential for pathogen transmission. EFI believes that to realize the full preventive intent of this measure, the industry must address the broader connection between worker welfare and produce safety. Workers who are trained to recognize and address the most common sources of pathogen contamination are the first line of defense against foodborne illness. When they understand the intent of preventive protocols and have channels to signal problems with implementation, those workers can help verify compliance with food safety measures between periodic audits. EFI’s farm-based systems for worker training and verification are designed to increase consumer assurance that safety protocols are followed on a continuous basis.  After receiving training, workers should be adequately compensated for their vital verification role. A recent Center for Science in the Public Interest (CSPI) study of pathogen outbreaks underscores the consequences of failing to invest in training, incentives and decent working conditions. Investigators linked recurring cyclospora outbreaks to cilantro from Mexico that had been contaminated with human waste in produce growing fields. The lack of adequate sanitary facilities at the growing operation directly contributed to dangerous outbreaks. Beyond that obvious failure, imagine if those workers had been trained to understand the connection between their hygiene and the safety of the produce. Imagine if they were encouraged to identify other common threats to produce safety, from animal waste to fungal infestation to handling procedures, as their work moved from harvest to the packing facility and beyond. And what if they were able to work directly with management to develop solutions that make sense for the farm and the workforce? Farmworkers are extremely skilled, and their experience and knowledge can be refined to reduce risk at the point of harvest. Tapping into farmworkers’ expertise is a vital yet under-recognized component of any effective strategy to prevent foodborne illness. The relatively simple measures they can implement, combined with ongoing surveillance and appropriate investment in training, equipment and sanitary facilities, would go a long way toward reducing the incidence of pathogen contamination in produce. That ounce of prevention would be worth a great deal to consumers. It would also generate real value for growers and retailers who lose millions of dollars each year to liability claims and supply chain interruptions caused by recalls. Some of that shared value should be reinvested in improving the wages, training and working conditions of the farmworkers whose vigilance is such a vital a part of the solution. Such investment is ultimately less expensive than the pound of cure required when a recall or outbreak occurs. Implementation of the training requirement in FSMA’s final rule is an opportunity for the produce industry to engage farmworkers in monitoring and verifying compliance with food safety protocols. EFI is working with retailers, growers, consumer groups and workers to demonstrate the value of that approach. Moreover, we encourage our colleagues across the produce industry to pay more attention to the connection between wages, working conditions and food safety. We all want to provide consumers with nutritious and healthy fruits and vegetables. Investment in worker training and verification programs will provide the public with greater assurance that stakeholders across the industry are doing everything possible to fulfill the intent of the Food Safety Modernization Act. Peter  O’Driscoll is executive director of the Equitable Food Initiative. He also has served as executive director of ActionAid USA, director of the “Private Sector in Development Project” at the Center of Concern, and Latin America director at Ashoka. He is a graduate of Harvard College and holds a master’s from Columbia University’s School of International and Public Affairs. You can contact him at or follow @EquitableFood on Twitter. (To sign up for a free subscription to Food Safety News, click here.)