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We use data from a national survey of fruit and vegetable growers to examine the current prevalence and cost burden of food safety practices required in the proposed Produce Rule implementing the Food Safety Modernization Act. In particular, we analyze the influence of farm size and farming practices on the probability of adopting food safety measures that would be required by the Produce Rule; and we analyze how the costs of using those food safety practices vary by farm size and farm practices. Majorities of our respondents currently employ most of the food safety practices that would be required under the proposed Produce Rule, but a large number of growers will nonetheless face significant changes to meet the Rule’s requirements. We do not find any effect of farm size on the probability of using food safety measures, but we find that food safety costs significant economies of scale. Sustainable farming practices are negatively correlated with the probability of testing and conducting field inspections, and they are associated with increased costs for testing and sampling, harvest container sanitation, and written records relative to conventional growers. While our estimates indicate that small and sustainable growers would face more significant changes and more burdensome costs to comply with the proposed Produce Rule, in our sample most of them would ultimately be exempt from the rule either based on farm size or the Tester-Hagan exemption.


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