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Abstract

We use data from a survey of leafy greens and tomato growers in the Mid-Atlantic region to investigate the prevalence and cost of produce safety practices required under the proposed Produce Rule implementing the Food Safety Modernization Act. Majorities of our respondents currently employ most of the food safety practices that would be required under the proposed Produce Rule. But the Produce Rule will nevertheless require changes on the part of a large number of growers. We find no evidence that the use of any of these practices is correlated with farm size. We do find some evidence that the shares of product sold to grocery/retail and to restaurants are positively correlated with the probability of testing water, soil amendments or product, consistent with theoretical literature suggesting that traceability increases incentives to take precautionary measures. We find that all of these practices exhibit substantial increasing returns to scale, implying that the burden of complying with the provisions of the Produce Rule is much lower for large operations than small ones. Our estimates suggest in addition that compliance costs are likely to be burdensome only for a handful of practices, notably testing of soil amendments, employee training, facility sanitation, and sanitizing harvest containers; further, that burden is likely to be much greater for small and very small operations than for large ones.

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