GAP Mental Modeling

Luis of the Fresh Produce Industry Discussion Group caught (Do you think you know GAPs or you only fooling yourself?) a recent notice in the Federal Register that's worth comment. It sounds as if the FDA is seeking to understand how growers comprehend Good Agricultural Practices. Or more precisely, why they don't; "There is evidence that growers have not fully implemented GAPs to reduce production risk, despite intensive GAPs training programs." From the Federal Register notice:


Federal agencies are required to publish notice in the Federal Register concerning each proposed collection of information and to allow 60 days for public comment in response to the notice. This notice solicits comments on the proposed study entitled ``Mental Models Study of Farmers' Understanding and Implementation of Good Agricultural Practices.''
Mental Models Study of Farmers' Understanding and Implementation of Good Agricultural Practices.

The proposed information collection will help FDA protect the public from foodborne illness by increasing the agency's understanding of how farmers and growers use Good Agricultural Practices (GAPs) to address common risk factors in their operations and thereby minimize food safety hazards potentially associated with fresh produce. Fresh fruits and vegetables are those that are likely to be sold to consumers in an unprocessed or minimally processed (i.e., raw) form and that are reasonably likely to be consumed raw. Under section 903(b)(2) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 393 (b)(2)), FDA is authorized to conduct research relating to foods and to conduct educational and public information programs relating to the safety of the Nation's food supply. Under Title 42 of the Public Health Service Act (1944), FDA has authority to act to protect the public health.
In 1998, FDA issued a guidance document entitled ``Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables,'' available at http://www.cfsan.fda.gov/~dms/prodguid.html. The guidance addresses microbial food safety hazards and good agricultural and good management practices common to the growing, harvesting, washing, sorting, packing, and transporting of most fruits and vegetables sold to consumers in an unprocessed or minimally processed (raw) form.
There is evidence that growers have not fully implemented the GAPs to reduce production risks, despite intensive GAPS training programs. FDA is planning to conduct a study to determine growers' decision- making processes with regard to understanding and implementing GAPs on the farm, to more fully understand the barriers and constraints associated with GAPs implementation.
The project will use ``mental modeling,'' a qualitative research method wherein the decision-making processes of a group of respondents (described below) concerning the implementation of GAPs on the farm are modeled and compared to a model based on expert knowledge and experience in the implementation of GAPs. The information will be collected via a telephone interview concerning the factors that influence the perceptions and motivations related to the implementation of GAPs. A comparison between expert and consumer models based on the collected information may identify ``consequential knowledge gaps'' that can be redressed through information campaigns designed by FDA.
Description of respondents:
Respondents will be farmers or growers, GAPs trainers, and retail buyer and/or grower association representatives.
The study will involve approximately 60 respondents, including 24 farmers or growers of fruits and vegetables, 24 GAPs trainers, and 12 retail buyer or grower association representatives. FDA will also conduct a pretest using 9 respondents.