Artisanal Agrifood Processing and Food Safety Regulation: Responding to the Concerns of Small Processors and Regulators in Michigan

Final Report for GNC10-134

Project Type: Graduate Student
Funds awarded in 2010: $9,903.30
Projected End Date: 12/31/2012
Grant Recipient: Michigan State University
Region: North Central
State: Michigan
Graduate Student:
Faculty Advisor:
Dr. Jim Bingen
Michigan State University
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Project Information

Summary:

Artisan food processors and Michigan food safety inspectors were interviewed in a qualitative study to identify means of improving the regulatory process for small and medium food processors. The rapport between artisans and inspectors emerged as an important aspect of the regulatory process. Artisans and inspectors who formed positive relationships reported working together to identify ways for producers to comply with requirements while pursuing (where possible) their own styles of production. These findings were discussed in focus groups of artisans and inspectors. Outreach included recommendations for regulators and small and medium food processors.

Introduction:

Background of the Problem

Michigan enjoys a great diversity of agricultural production and a long tradition of small-scale processing. However, the number of small processors has dwindled over the past 50 years, creating a bottleneck for the small farmers who depended on local processing (Cantrell 2010). Consistent with the present governor’s commitment to launch an “era of innovation and reinvention” (Davis 2011), there are opportunities for small processors to be part of the reinvention and revitalization of the state’s rural economy.

More than in other North Central states, economic difficulties in Michigan offer incentive for state policymakers to encourage small agrifood entrepreneurs. Although Michigan’s cottage food law exempts some homemade products from licensing, it applies to a very limited number of home processors. The state’s food law, based upon the US Food Code used by many states, does not otherwise differentiate between small and large food businesses. The Michigan Food Policy Council recommends that the state assist small- and medium-sized agrifood businesses in navigating and achieving compliance with existing regulations (Michigan Food Policy Council 2006). In 2010, the Michigan Department of Agriculture and Rural Development (MDARD) created a Small Business Subcommittee Workgroup to discuss ways to make food regulations responsive to the conditions of small agrifood businesses. In 2011, MDARD funded Michigan Food and Farming Systems (MIFFS) to conduct a survey of and host discussion forums with small agrifood businesses to identify their perceptions of regulations and the impacts of regulations on them. MIFFS’ research evidenced confusion and frustration among food entrepreneurs as they navigated regulations and worked to communicate their plans to regulators (Buckley et al. 2011). The current study builds on both efforts with in-depth research.

Small processors consulted on the development of the proposal for this study indicated that current food safety regulations were both beneficial and constraining. While they gained valuable information about food safety and proper procedures from inspectors, food safety regulations constrained the establishment and profitability of their operations. For example, they reported that inspectors were sometimes inconsistent in identifying violations or required corrective actions of uncertain value to processing operations. At the same time, regulators consulted on this proposal wanted to encourage small agrifood businesses, but without compromising food safety standards. Regulators wanted a better understanding of processors’ primary concerns, and guidance on developing better communication. Both groups agreed on the importance of bridging their sometimes differing perspectives.

Although this report focuses on Michigan, we hope that it provides guidance for other North Central states. At the federal level, debate over provisions in the Food Safety Modernization Act demonstrates the need for systematic research on policies to foster small and medium agrifood producers (National Sustainable Agriculture Coalition 2011).

Literature Review

Small- and medium-scale processing bolsters sustainable agrifood systems. This study is predicated on the expectation that improving small processor feasibility will increase markets for small farmers in Michigan and the North Central Region, in turn increasing farm profitability and enhancing quality of life for farmers and rural areas (Sumner 2005). A broader range of markets can also diversify farmers’ production choices, contributing to environmental quality (Altieri 2009). Small and medium processors expand the range of regional farm products available to consumers and strengthen connections among consumers and producers. With more opportunities for local investment and for creative, mutually supportive livelihoods, we envision long-term improvement in communities’ problem-solving capacity, self-reliance, and vitality (Cantrell and Lewis 2010; Lyson 2004; Shuman 1998). These changes enhance agriculture’s social responsibility and enrich our society (Boyte and Kari 1996).

This study contributes to research on sustainable agrifood production in three respects. First, it adds to the growing body of scholarship that addresses small- and medium-scale processing as a component of local and alternative agrifood systems development. Second, it specifically examines artisan processing—relatively small-scale, handcraft production—in a contemporary, industrialized context. Third, the research investigates food safety inspections as a substantive component of food safety regulatory policy.

First, many local food system studies focus on direct farm marketing (e.g., Stephenson et al. 2008), but a growing body of work examines processing and more complex systems. NCR-SARE in Wisconsin hosted a “Scaling Up Local Good Food Systems” regional training in 2010. NCR-SARE–funded studies have explored farm to school initiatives (DeBlieck 2008; Izumi 2006), sheep’s milk cheese (Turner 2009), hard cider (Gleason 2007), organic processing (Jacobson 2006), and small meat processors (Thiboumery 2007). These investigations range from supply chain coordination and distribution to technical assistance and marketing research. The current study contributes to this work by addressing challenges facing small processors in meeting regulations.

Second, there has been little empirical study to inform food safety policy affecting artisans. Little research has focused on artisan processing in contemporary, regulated, and industrialized contexts. (For exceptions, see Paxson (2008, 2010, 2011, 2012); Terrio (1998, 2000).) Research on artisanship has focused mostly on historical and developing country contexts. There is also a dearth of research on food safety regulation and artisan processing to resolve disagreements over the impacts of the regulation of artisanship. Research in the US has been directed toward the barriers that small food business owners report (Buckley et al. 2011; Worosz et al. 2008) and has not focused equally on benefits that producers may experience.

Third, food safety inspections of these facilities have not been observed, and regulators’ own experiences of small food businesses and inspections have not been researched. Food safety regulations shape the development of sustainable agrifood systems and the opportunities available to producers, including artisan agrifood processors. To investigate the food safety regulation of artisan processing, this study focused on food safety inspections. Regulatory enforcement has been relatively neglected in the study of US food law (Law 2006). Yet food law is “made” during the enforcement of food safety regulation just as it is made in more formal policymaking processes (Lipsky 2010 [1980]). Indeed, “the actual behavior of officials [is] the only legal reality that we really know” (Commons 1924, p. 112). Studies of regulatory enforcement suggest that outcomes are the product of the discretion and interpretive flexibility that inspectors exercise, interactions between inspectors and regulated parties, and the experiences that each brings to inspection situations (Arce 1989; Gormley 1998; Lipsky 2010 [1980]; May and Wood 2003; van Zwanenberg et al. 2011).

When policy debate focuses on substantive law, that is, legislation and administrative regulations, it risks reproducing a common and yet idealized view of regulations that depicts a linear, unidirectional trajectory from legislation to enforcement. It assumes that legislative and regulatory mandates translate straightforwardly into regulatory outcomes. Yet in practice, inspections introduce issues beyond those defined in codified law. First, many regulatory requirements are broad and require interpretation by food safety inspectors, who take into account contextual details of specific facilities (Grattet and Jenness 2005; Yapp and Fairman 2006). Second, interactions between food safety regulators and producers may extend beyond strictly technical questions of compliance. Some agencies adopt a consulting approach that emphasizes cooperation and education (Braithwaite et al. 1987; Macauley 1993; May and Wood 2003; Scholz and Gray 1997). Writing on the sociology of regulation, Hutter (1989) describes an “accommodative” approach in which inspectors explain to regulated parties the reasons for requirements and discuss possible means for attaining them. “Patience and understanding underpin the whole strategy, which is regarded as an open-ended and long-term venture” (Hutter 1989, p. 155). Third, regulators work to accommodate individual producers’ notions of right and wrong as they enforce regulations (Lowe and Ward 1997). Producers’ decisions about whether and how to comply with regulations are influenced by their interaction with enforcers (Fairman and Yapp 2005; Henson and Heasman 1998).

Project Objectives:

This study aimed to generate processor guidelines to help processors meet regulations cost-effectively, regulatory guidelines for the Michigan Department of Agriculture and Rural Development (MDARD), and a stakeholder report for practitioners in both groups. The study responded to small processor concerns that regulations constrained their ability to create and expand businesses and to respond to market demand for local farm products. It investigated 1) artisan views of and experiences with regulations and inspections, and 2) food safety regulators’ experiences with and perceptions of artisan processing. The proposal was developed with the collaboration of small processors and regulators.

Following are the objectives as they appeared in our proposal.

Short-Term Objectives
  • that processor guidelines improve processors’ knowledge about regulatory compliance and inspections, help them prepare better for inspections, and prevent misunderstandings that can cost time and money.

    that regulatory guidelines identify ways in which inspector directives and trainings can be improved and increase regulator awareness of small processor educational needs.

    that the study’s stakeholder report improve both groups’ understanding of each other’s perspectives and expectations.

Intermediate-Term Objectives
  • that small processors achieve more cost-effective compliance with food safety regulations.

    that regulatory inspections, materials, and communication with small processors improve.

    that food safety regulatory policy change.

Long-Term Objectives
  • that these changes improve the profitability and sustainability of small processor businesses, stimulate Michigan’s small agrifood sector, and enhance quality of life for agrifood producers, rural communities, and society as a whole.
Remarks on the Study's Scope and on Its Definition of "Artisanship"

The scope of the study was slightly modified between proposal submission and the beginning of the research. First, the initial proposal called for a focus on small fruit, vegetable, honey, and cheese processors. However, artisan bread bakers were (and continue to be) a growing trend in Michigan. To include them, the scope was modified to focus on bread, cheese, and jam producers.

Second, the initial proposal focused on small artisan processors. However, neither “small” nor “artisan” is defined consistently in the scholarly literature, by practitioners, or even by economic development entities. We had aimed to focus on processors who employed fewer than 10 people and who used handcrafting methods, with minimal automation. We found that some handcrafting facilities with minimal automation employed more than 10 people, and we consequently eliminated that size criterion. In the working definition of artisanship that we developed, processors emphasized handcraft production, engaged in each step of the production process, and produced at a small or medium scale.

The Use of "We" and "I" in This Report

This study formed part of the doctoral research of the project coordinator, Jenifer Buckley. Her doctoral advisor, Dr. Jim Bingen, provided guidance throughout the study. Where used in this report, “I” refers to Buckley, and “we” refers to both.

Cooperators

Click linked name(s) to expand
  • Jim Bingen

Research

Materials and methods:
Project Advisory Committee

A committee of stakeholders was assembled at the outset of the study to advise on participant selection, interview questions, and project evaluation, and to provide guidance throughout the project. We gratefully acknowledge their participation and support. They represented:

Producers
- Sue Spagnuolo, Cheesemaker, Greenbush Farms and Dolce Vita Dairy, St. Johns, Mich.
- Ron Steiner, Director, The Starting Block Incubator Kitchen, Hart, Mich.

Regulators
- Kevin Besey, Director, Food and Dairy Division, MDARD
- Siobhan Kent, Department Analyst, Food Safety Planning and Response, MDARD

Food businesses
- Natasha Lantz, Community Liaison, Marquette Food Co-op, Marquette, Mich.

Participant Selection

Artisan participants in this study were selected to represent producers of cheese, bread, and jam, three common processed products in Michigan. Managers of two incubator kitchens in which jam is produced were also included. This selection of products captured a small diversity of producers and inspectors in different parts of Michigan. The products are inspected by the two types of inspectors working in MDARD’s Food and Dairy Division: bakers and jam makers are inspected by Food inspectors, and cheesemakers are inspected by Dairy inspectors. Food and Dairy inspectors are assigned to geographic areas rather than to specific product types.

Artisans were identified through 1) the project advisory committee (see above); 2) internet searches for producers who met the study’s working definition of artisanship; 3) “snowball sampling”—that is, processors contacted early in the project recommended other processors (Corbin and Strauss 2008); and 4) the assistance of agrifood professionals and resource providers. Production approaches were further discussed during interviews. Artisan participants had been licensed for between 1 and 30 years, with an average of 10 and median of 6 years.

MDARD Food and Dairy supervisors identified inspectors whose areas included artisan facilities. Inspectors’ participation was voluntary. The 19 inspectors who participated had between 3 and 26 years’ experience, with an average of 14 and median of 16 years. (Values for 3 of the 19 inspectors were missing.)

Artisans (n = 27)
- Bread (n = 10)
- Cheese (n = 11)
- Jam (n = 6)

Inspectors (n = 19)
- Food (n = 13)
- Dairy (n = 6)

The study focused on participants as individuals, not artisans and their inspectors in pairs. The artisan clients of some inspectors did not participate, and the inspectors of some artisans did not participate. In some instances, both an artisan and his or her inspector participated. Selection was determined in part by artisans’ and inspectors’ availability during periods of the fieldwork and their willingness to participate.

Data Collection and Analysis

Data collection in the SARE-funded component of the study consisted of interviews and focus groups. Additional data were collected in subsequent field observations funding by a National Science Foundation grant. The NSF-funded component of the study is included here as it informed the SARE research.

Artisans and inspectors participated in semi-structured, one-on-one interviews that lasted between 30 and 90 minutes and averaged 60 minutes. Discussion focused on the experiences that established artisan processors had dealing with inspectors and that inspectors had with artisans; factors that made the regulatory process succeed for both parties; training that participants felt was needed for themselves or others; and regulations that artisans would like to see changed. Most interviews were audio recorded and transcribed. When interviews were not recorded, notes were taken manually.

Issues that emerged during interviews were further investigated during field observations. Field observations were conducted at facilities in which 1) an inspection was scheduled within the period of the study, and 2) both the artisan and his or her inspector were willing to participate in the study. First, I observed artisan operations for between 2 and 4 hours in order to become familiar with the activities, equipment, and techniques of each artisan’s production. I conversed with artisans about their operations and their approaches to artisanship. Second, I returned to these facilities with food safety inspectors in order to observe the inspection and to converse one-on-one, at some point, with inspectors. Inspections lasted between 1 and 3 hours. Observations focused on concerns that arose during inspections, the practices involved, and interpersonal interactions between artisans and inspectors. All observation notes were taken by hand.

Interviews (n = 47)
- Artisans (n = 28)
- Inspectors (n = 19)

Field observations (n = 12)
- Artisans (n = 12)
- Inspectors (n = 10)
(1 inspector was accompanied on inspections of 3 facilities)

Interview transcripts and notes were coded for emerging concepts (Corbin and Strauss 2008) using NVivo, a qualitative data analysis program. Two passes were made through each transcript or set of notes to capture themes that emerged in the middle of this process. Notes from observations were typed and organized in Microsoft Word files. A section in each file identified themes and findings and discussed the observation in light of preliminary analysis.

Findings were discussed during two focus groups and at producer events. Focus groups provided a check of internal validity for the study. The first focus group involved MDARD Dairy supervisors and cheesemakers from around Michigan’s Lower Peninsula, and the second group involved a mix of food entrepreneurs in Detroit.

Cheese focus group
- Cheesemakers (n = 13)
- MDARD Dairy supervisors (n = 2)

Detroit food entrepreneur focus group
- Entrepreneurs (n = 10)
- MDARD Food inspector (n = 1)

Research results and discussion:
Results

A key finding of the study is in the importance of the relationship formed between artisan processors and their inspectors. Trust and mutual understanding between artisans and inspectors emerged as having considerable potential for improving the regulatory process for small and medium food processors in Michigan. In fact, the quality of the rapport between an artisan and his or her inspector appeared to be as important as the producer’s knowledge of regulations.

Artisans and inspectors generally shared the same notion of food safety, and they agreed on the importance of protecting the public health. Both saw themselves as accountable to food consumers. Some artisans took issue with specific legal definitions of food safety, such as whether linen threads represented a risk and whether flour beetles under a stove were likely to contaminate products. Yet they agreed with inspectors about the overriding importance of preventing foodborne illness.

These results are organized according to benefits and negative aspects of the regulatory process as it was experienced by both artisans and inspectors. The section concludes with a discussion of interpersonal dynamics.
___________

The regulatory process: Benefits to artisans

1) Technical assistance
Many of the artisans participating in the study looked to inspectors for technical assistance, quality assurance, and other matters not directly related to food safety. These producers’ attention was divided among the many details that running a food business involves, and they appreciated inspectors’ specific focus on food safety issues. They saw inspectors as specialists who drew their attention to possible hazards that they may have otherwise missed, such as unprotected light bulbs and allergen cross contamination. Inspectors, too, indicated that the guidance they provided on food safety often connected to broader operational matters, such as identifying methods for keeping older equipment running properly.

2) Support in enforcing their own standards
Artisans indicated that it can be difficult to enforce standards of hygiene and sanitation among their staff. As one cheesemaker put it, “I can play good cop and let [the inspector] be bad cop…And it does make it easier to manage [the operation].” At one bakery, the inspector recorded violations in part to draw these problems to the baker’s landlord’s attention.

3) Sharing of ideas
As inspectors became more familiar with artisan facilities, they broadened their understanding of the equipment and techniques that different artisans used. Many of the artisans participating in this study conversed at length with inspectors during visits. Inspectors might relay, in general terms, experiences that other producers had with specific processes or types of equipment.
___________

The regulatory process: Benefits to inspectors

1) Pride in seeing businesses succeed
Inspectors were invested in the success of the facilities they inspected. Many, though not all of them, enjoyed providing technical assistance to artisan businesses. Conversations between inspectors and artisans often veered from food safety to many other operational matters.

2) Relationships with small and medium producers
Inspectors reported benefitting from their interactions with the artisans whose facilities they inspected. Providing technical assistance to smaller plants can be time-consuming. However, asked what made these plant inspections worthwhile, one inspector echoed the views of others when he replied, “The relationships.”

3) Learning about a variety of production styles
Inspectors expressed curiosity about and appreciation for the approaches used by artisan processors, although they did not always agree with these approaches. Several Dairy inspectors had taken Michigan State University’s artisan cheesemaking short course in order to learn more about techniques used by new cheesemakers in their areas.
_________

The regulatory process: Negative aspects for artisans

1) Impeding artisan techniques
When asked whether they would change any regulatory requirements if they could, most artisans in this study indicated that requirements have not prevented them from doing what they wanted to. However, some artisans reported conflicts between their approaches to production and those required by inspectors. For example, some inspectors interpreted requirements to prohibit the use of the proofing baskets in which some bakers allowed dough to rise. Many artisans used baskets made of wicker and lined with linen in order to achieve a specific quality of bread. Instead, some inspectors required baskets made of a more impermeable material such as plastic. Plastic interacts differently with the dough and affects the dough’s moisture, requiring these bakers to change their baking processes and produce what they considered to be a lesser quality bread.

2) Imposing unreasonable costs
Cheesemakers raised more concerns about the costs involved in meeting regulations than did bakers or jam producers. Sanitation rules are more detailed for dairy processing than they are for other types of food manufacture and tend to allow for less interpretation by inspectors. Many cheesemakers cited the antibiotic testing of milk as a costly and troublesome requirement. “Other than buying my milk, [testing] is probably the most expensive element to my cheesemaking,” said one. Although producers agreed that antibiotics are to be avoided in cheesemaking, many questioned the rule’s effectiveness and the costs involved.

3) Requiring unnecessary measures
Artisans described episodes in which inspectors initially interpreted regulations as requiring large-scale equipment. In some of these cases, inspectors subsequently determined that smaller or less expensive alternatives achieved regulatory objectives. Many inspectors had more experience inspecting large-scale facilities than smaller facilities. They were familiar with the equipment and facilities that larger producers use, and some expected to see the same equipment and techniques at smaller facilities.
___________

The regulatory process: Negative aspects for inspectors

1) Investment of time
Many artisan processors looked to inspectors for quality assurance, technical assistance, and business advice not directly related to food safety regulations. In contrast to operators of large facilities, they were unlikely to have staff specializing in quality control, procurement, or other matters. The inspections that were observed during this research involved often lengthy conversations about many issues. In some cases, several hours were spent at facilities measuring less than 1,000 square feet. Many (though not all) inspectors enjoyed this aspect of their jobs and often were interested in learning about artisan approaches. Yet with MDARD budget decreases, inspectors also found it difficult to invest this much time addressing broad food business matters.

2) Emotional investment in businesses that closed
Inspectors did not use terms such as “emotional,” and their relationships with artisans and other agrifood producers were defined professionally as those of regulators and regulatees. Still, inspectors spoke of the disappointment of helping food entrepreneurs launch businesses, only to see them close after a short time for lack of markets or other reasons. It was apparent that their work involved a degree of emotional investment in client enterprises.
___________

The regulatory process: Interpersonal dynamics

Research on food safety inspections generated a more complex and dynamic picture of the regulatory process than emerges from a focus on formal requirements. Processors who indicated frustration with inspectors described them as defensive or controlling. One artisan described asking an inspector to explain the rationales behind specific requirements so that he could better implement them. Yet, he stated, the questions were met as challenges and not answered. He indicated that relationships with other inspectors had been more constructive. For their part, inspectors who indicated frustration with processors described “people who believed they had nothing more to learn” about their businesses. Processors agreed with this assessment and cautioned other processors to be open to learning from inspectors.

Artisans and inspectors emphasized the importance of developing collegial, trusting relationships. With give-and-take and teamwork on the part of artisans and their inspectors, both groups reported that they were often able to identify ways for artisans to meet both artisan and regulatory objectives. Even some artisans who did not agree with the government’s role in assuring food safety nevertheless liked their inspectors as people and appreciated their help, describing in detail the ways in which inspectors had improved their operations.

Milestones: Process Evaluation

Activities
Our proposal projected the following activities. Completion dates are shown.

- Project advisory committee convened for the first of two meetings: December 2011.
- In-depth semi-structured interviews conducted: January 2012 to March 2013.
- Interview transcription and data analysis: Transcription is complete. Qualitative data analysis is largely complete but continues in some measure throughout the current dissertation writing.
- Project advisory committee convened for the second of two meetings: November 2012.
- Outputs developed and delivered: September 2012 to June 2013.
- Evaluations conducted during presentations: Complete (though insufficient—see Areas Needing Additional Study, below).

Outputs
Our proposal projected the following outputs. Completion dates are shown.

- Processor guidelines on meeting food safety regulations: Completed in June 2013.
- Stakeholder report for practitioners: Preliminary findings summarized in September 2012, article published in Michigan Good Food Monthly Update in January 2013.
- Regulatory guidelines on improving inspector directives and trainings: Presented in June 2013, document completed in August 2013.
- Two peer-reviewed papers, scholarly presentations (submitted): Scholarly presentations delivered in March 2012, October 2012, March 2013, April 2013, and June 2013.
- NCR-SARE reports: Submitted as scheduled.
- Parts of student’s dissertation: Dissertation is in progress as of this writing.

Participation Summary

Educational & Outreach Activities

Participation Summary:

Education/outreach description:
Scholarly Presentations

Buckley, Jenifer. 2013. “Can food safety regulations serve the interests of artisan processors? A study of inspector-artisan interactions in Michigan.” Selected paper, Annual Meetings of the Agriculture, Food and Human Values Society and the Association for the Study of Food and Society, East Lansing, Mich. (June).

Buckley, Jenifer. 2013. “Food safety regulation, artisan processing, and policy challenges in a growing agrifood sector: A study of inspector-artisan interactions in Michigan.” Selected paper, Association of American Geographers Annual Meeting, Los Angeles (April).

Buckley, Jenifer. 2013. “Methodological challenges and surprises in qualitative research: Stay calm, go with the flow, have fun.” Selected paper, MSU Department of CARRS Graduate Symposium (March).

Buckley, Jenifer. 2012. “Food safety inspections of artisan food processors in Michigan: The intersection of two social phenomena.” Selected paper, Michigan Sociological Association Annual Meeting, Grand Rapids, Michigan (October).
A similar selected paper was presented at the 2012 MSU Department of CARRS Graduate Symposium (March).

Outreach Presentations

Buckley, Jenifer. 2013. “MDARD’s interaction with artisan food and dairy processors.” Invited presentation, Annual Training Conference, Michigan Department of Agriculture and Rural Development Food and Dairy Division, Roscommon, Mich. (June).
Attendance: approx. 120

The following three panel sessions were presented in 2013. They brought together MDARD inspection staff (Giles-Austin, Robinson, Settimo, and Sorensen), small food processors (Brown, Kates, and Spagnuolo), and resource providers (Birbeck and Coggon). Panelists spoke to producer audiences about the licensing and inspection process, the processor-inspector rapport, and resources available to producers.

- Buckley, Jenifer (Coordinator), with Pearl Brown, Laurie Sorensen, Sue Spagnuolo, and Gordon Robinson. 2013. “Working with your food safety inspector: A webinar for Michigan’s small food processors.” Panel presentation. Online and at Michigan State University, East Lansing, Mich. (May). https://www.msu.edu/~jbuckley/events/.
Attendance: 42 that day, number of views are unknown

- Buckley, Jenifer (Coordinator), with Sue Spagnuolo, Lindsey Giles-Austin, Marcy Bishop Kates, Ken Settimo, and Matt Birbeck. 2013. “Small-scale food processing and food safety regulations: Resources and guidelines for processors.” Panel presentation. Agriculture and Natural Resources Week, Michigan State University, East Lansing, Mich. (March).
Attendance: 20

- Coggon, Garrett and Jenifer Buckley (Co-Coordinators), with Pearl Brown and Laurie Sorensen. 2013. “Guidelines for meeting food safety requirements, from farm production to value-added processing.” Panel presentation. Northern Michigan Small Farm Conference, Grayling, Mich. (January).
Attendance: 50

Outreach Publications

Buckley, Jenifer. 2013. “Research Report to the Michigan Department of Agriculture & Rural Development: Key Results and Recommendations.” Regulatory guidelines (August). https://www.msu.edu/~jbuckley/research/MDARD_Res_Rec.pdf.

Buckley, Jenifer. 2013. “Working with your food safety inspector.” Processor guidelines (June). https://www.msu.edu/~jbuckley/research/Working_w_Inspector.pdf.

Buckley, Jenifer. 2013. “Artisan food processors see food safety inspectors as resources.” Stakeholder report (January). Michigan Good Food Newsletter 16:1–2. http://www.michiganfood.org/assets/goodfood/docs/MichGoodFood_Newsletter_Jan_2013.pdf (last accessed August 28, 2013).

Buckley, Jenifer. 2012. “Artisan Processing and Food Safety Regulation in Michigan:
Preliminary Summary of Research Findings from Interview Data.” Stakeholder report (September). https://www.msu.edu/~jbuckley/research/Prelim_Findings_Interviews.html (last accessed August 28, 2013).

Project Outcomes

Project outcomes:

This section is organized according to outcomes identified in the Evaluation section of the logic model in our proposal.

Short-Term Outcomes

Short-Term Outcome #1

Proposed: Processors rate the extent to which processor guidelines improve their knowledge about complying with regulations in cost-effective ways.

Progress toward this outcome: Evaluations were issued at three presentations to producer audiences. The return rate for audience evaluations ranged from 7 percent (3 evaluations from 45 attendees) to 45 percent (9 evaluations from 20 attendees). Attendees included current and prospective processors. Intent to change—one of our projected metrics—appeared to be affected by whether and for how long they had operated. Responses were generally favorable, but response numbers were too low to present meaningful statistics on audience evaluations.

A selection of narrative comments from evaluations and emails includes these:
- Food entrepreneur: Thank you so much for this information. It is extremely helpful and has made the unknown not so scary.
- Farmers’ market manager: This is great! Thanks for sharing! I am looking forward to viewing and sharing with my vendors!
- Incubator kitchen coordinator: I found the session re-affirming and confidence building.
____________

Short-Term Outcome #2

Proposed: Regulators rate the extent to which regulatory guidelines a) increase awareness of small processor educational needs and b) identify improvements for inspector directives and trainings.

Progress toward this outcome:

a) Increasing awareness of small processor educational needs: As data collection progressed, it appeared that this first part of the outcome was unnecessary. Inspectors routinely addressed the educational needs of small processors during inspections, and they spoke in detail of educational needs during my interviews with them.

b) Identifying improvements for inspector directives and trainings: This outcome was evaluated informally. Response was positive:

- A local health department inspector who watched the webinar (see Publications/Outreach, below) wrote: “This was a very comprehensive discussion and all parties were very forthcoming with lots of details. What a great resource this is.”
- At MDARD’s invitation, I presented the results of the study to over 100 MDARD Food and Dairy inspectors and senior staff at the Food and Dairy Division Annual Training Conference in June 2013.
- The Food and Dairy Division has also invited me to present the study to other regulatory staff and policymakers.

Intermediate-Term Outcomes

Intermediate-Term Outcome #1

Proposed: Small processors implement processor guidelines, leading to more cost-effective compliance with regulations.

Evaluation method: Processors specify practical ways in which processor guidelines will help them comply with food safety regulations more cost-effectively.

Indicator of success: Evaluation surveys—audience evaluation forms described above included this question.

Progress toward this outcome: Only two processors provided information on how they would implement what they had learned. Both indicated that they would work with their inspectors. One indicated that he or she would implement a HACCP plan and recall plan.
____________

Intermediate-Term Outcomes #2 and #3

Proposed:
#2: Regulators implement regulatory guidelines, leading to improved inspections, materials, and communication.
#3: Regulatory guidelines facilitate changes in food safety regulatory policy.

Evaluation method: The implementation status of the regulatory guidelines delivered to MDARD will be noted at project completion.

Indicator of success: Communication with MDARD Food and Dairy Division senior staff.

Progress toward this outcome: MDARD Food and Dairy Division senior staff members have responded positively to the study’s findings, as evidenced (see above) by their invitation to present at the Division’s annual conference in June, and to present to other regulatory staff and policymakers.
It is premature to evaluate progress. Moreover, effective implementation of the study’s recommendations requires MDARD budget increases.

A Possible Unanticipated Impact

One impact may lie in a gradual shift in the views and fears that many food entrepreneurs have of inspectors. The study fostered improved connections and mutual understanding between artisans and inspectors. These were evident during the focus groups, which provided networking opportunities for the participants as well as checks on the study’s internal validity. They were also evident on the faces of audience members during presentations and in the emails that I received from people who had viewed the webinar. We hope that this understanding and these connections will continue into the future.

Economic Analysis

N/A

Farmer Adoption

The following items are addressed elsewhere in this report:

Adoption of the study's findings and recommendations by its target audiences (artisan processors and regulators): See Impact of the Results/Outcomes.

Number of stakeholders reached: See Publications/Outreach | Outreach Presentations.
Due to the low evaluation response rate, we do not know how many of our audience members were farmers, processors, resource providers, or others.
Outreach publications were disseminated through listservs reaching hundreds of stakeholders (or more).

Recommendations: Provided in the publications listed in Publications/Outreach | Outreach Publications.

Recommendations:

Areas needing additional study

This section describes issues that arose during the study, and limitations of the research that may be addressed in further study.

Issues for Further Study

1) How do food safety agencies differ in culture and enforcement style?
Further study should examine differences in culture and enforcement style among agencies that enforce food safety regulations. The application of this study’s findings may be limited by the culture of an agency and the approach that it encourages among its inspectors. Some of the artisan participants in this study indicated that MDARD food safety inspectors take a more constructive approach to their work than do inspectors with other agencies.

2) How do inspector age and years of experience impact inspector styles?
Artisans and inspectors both spoke of the difference that age and experience make in an inspector. Younger inspectors were generally characterized as stricter, more "by the book," and harder to work with. A middle-aged inspector stated firmly that if he had started directly out of college, he "absolutely would have failed at this job" because he saw the world in black and white. Inspectors who had children or who had taught K-12 spoke of the crucial difference those experiences had made in the greater flexibility and understanding that they brought to inspections.

3) Food entrepreneurship: How do start-ups make it over the hurdles?
Conventional wisdom has it that regulations impede small food businesses. In other research that I have conducted with agrifood entrepreneurs, it has not been hard to elicit criticism of regulations. Yet even when asked, virtually none of the artisans who were interviewed in this study reported that regulations had “gotten in their way.” Why, then, is what I heard in this study so different from everything I knew about regulations and small business?

This may be partly because I selected processors who were already licensed. Many (though not all) processors in the current study spoke of regulations as only one among many other costs of doing business, one among many other hurdles in operating a food business. It is worth noting that regulations are among the first hurdles that start-ups run into—before they deal, for example, with distributors and retail buyers—which may be partly why problems are often attributed to regulations. There are undoubtedly studies of the ways in which start-ups think about the many barriers that they encounter. If there are not, this would be an excellent area of investigation.

4) Is the rapport between an inspector and small or medium producer a predictor of regulatory compliance?
This study suggests that this rapport makes at least as a great a difference for compliance as does the producer’s knowledge of regulatory requirements. A producer who does not know regulations will learn them if he or she has open, constructive communication with an inspector. But producers who have poor relationships with inspectors may well have other problems, regardless of how well they know regulations.

Addressing the Study's Limitations

1) Broader selection of inspectors
This research should be broadened to include a wider and more systematic selection of inspectors. Inspectors participated in this study voluntarily, and there was a likely self-selection bias. I am not sure what its implications for the study were. Some inspectors with excellent reputations among artisans declined to participate.

2) Evaluations
The evaluation surveys used in this study provided a poor means of evaluating impacts. Response rates were low, and very little narrative detail was provided on surveys.

Acknowledgements

Many thanks to MDARD's Food and Dairy Division and to the artisan processors and MDARD Food and Dairy inspectors whose generous participation made this research possible.

In addition to the participation of Project Advisory Committee members listed above in this report, we thank the following for their input, support, and assistance with outreach:
- Marquette Food Co?op
- Michigan Cheese Makers Cooperative
- Michigan Food and Farming Systems
- Michigan Good Food
- Michigan Land Use Institute
- Michigan State University (MSU) Center for Regional Food Systems
- MSU Extension
- MSU Product Center
- Northern Michigan Small Farm Conference
- Organic Processing Institute
- Starting Block Incubator Kitchen
- Upper Peninsula Food Exchange

In addition to this NCR SARE grant, funding was received from:
- The National Science Foundation under Grant No. SES-1230878
- Funds from a grant to Michigan State University from the W.K. Kellogg Foundation to establish a pasture-based dairy program at the Kellogg Biological Station

Any opinions, findings, conclusions, or recommendations expressed within do not necessarily reflect the views of the SARE program, the U.S. Department of Agriculture, or the National Science Foundation. USDA is an equal opportunity provider and employer.

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Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the view of the U.S. Department of Agriculture or SARE.