Improving Risk Communication

This research supports FDA’s risk communications initiative by providing insights gained from in-depth interviews with Dairy Farmers that can be used to develop focused risk communications strategies and messages for dairy farmers, and other key stakeholders, such as veterinarians. Table 7.2 provides a disciplined approach for distilling the key insights that are most pertinent to developing an informed risk communication strategy. A list of guiding questions supporting strategic risk communications provides insight on what Farmers know, don’t know, want to know, and what communications processes they trust.

Variances Between Violators and Non-violators

A key finding of this research is that there were no substantial differences in practices or decision-making behavior of Violators and Non-Violators. The differences noted between those who had experienced a violation and those who had not were few in comparison to the similarities with generally only modest differences in frequency of mention toward a particular side of an issue. The most substantial differences expressed include:

  • • Violators were more likely to believe that it is “very likely” that culled cows containing residues would be detected during inspection.
  • • Violators were twice as likely to mention that the protocols used on their farm were developed with the veterinarian.
  • • Violators more frequently stated that they consult labels “very often.”
  • • Some Violators commented that they either “have no Internet access” and/or are not computer literate.
  • • Many Non-Violators and a few Violators described withholding their cows longer than the stipulated withholding times.

One other variance noted was that Farmers from small farms tended to describe less formal systems for documenting and managing cow treatments. Only two of the

Table 7.2 Mental models assessment summary

Guiding questions

Dairy farmers: violators and non-violators

What do they value?

Dairy farmers are focused on providing safe, quality food products that are trusted by consumers. They value their role in the food system, including their:

  • • Rep3utation—their own and that of the industry
  • • Responsibility to public health and safety: “Most farmers really want to do what is right”

What do they know now about the topic/risk that is correct?

Dairy Farmers expressed detailed knowledge of:

  • • When treatment is needed and when to consult their veterinarian
  • • Selection of drugs that minimize or eliminate withholding times
  • • Importance of adhering to methods for drug administration and withholding times listed on drug labels
  • • Importance of observing withholding times
  • • Importance of keeping detailed records for each cow treated (Their behavior is consistent with the 6 Decision Steps pertaining to decision made on the farm, illustrated the decision tree model, Fig. 7.1)

What are the key factors that they consider when making culling decisions?

Culling because a cow does not respond to treatment is less frequent than culling for other reasons. Key factors considered in deciding to treat or cull are:

  • • Cow health, productivity, age, ability to breed
  • • Economics-input costs vs. productivity
  • • Withholding times for treated cows
  • • The need for caution-uncertainty in residue levels, particularly for very sick cows that might metabolize drugs more slowly, and “Accidents do happen”
  • • Knowledge that drug tissue residues are important to customers
  • • Commitment to and concern about public health, industry reputation, and their business success
  • • FDA rules, which are regarded as necessary and generally appropriate

What don’t they know or misunderstand that is consequential?

Dairy Farmers expressed limited knowledge of decisions made by others once a cow is culled, including the consequences of a violation; however, this knowledge does not appear to be consequential to treatment and culling decisions. Key questions expressed by Farmers as consequential to their decisions include:

  • • Are withholding times applicable for sick cows suspected of slower drug metabolism rates?
  • • How are meat residue standards derived? Clarify the health protection goals used to establish standards. Reconcile interest in safe, untainted food and the technical basis for an allowable residue


Table 7.2 (continued)

Guiding questions

Dairy farmers: violators and non-violators

What do they want/want to know?

Beyond specific technical questions that are consequential to their decisions, Dairy Farmers wanted to know:

  • • Best practices—they suggested FDA develop and communicate those practices that are known to produce results
  • • Rules and regulations—beyond drug administration and withholding time requirements, they suggested FDA could make important points on rules and regulations more accessible and understandable. For example, rules pertaining to feeding milk from treated cows to calves
  • • On the farm tests—they suggested FDA could develop a test to determine if cow tissues have residues, as is available for milk
  • • If FDA listens to and understands dairy farming operations and challenges

Who do they trust and why?

Dairy Farmers use a range of information sources such as journals, other farmers, drug representatives, and the Internet; however, they rely most frequently upon two sources:

  • • They tend to trust and rely on their veterinarians for new information and technically complex topics, and
  • • They rely on drug labels for routine checks on procedure, including withholding times

What communication methods do they prefer?

Farmers noted that dairy farming is a competitive, challenging business and farmers have limited time for nonfarming tasks. They prefer:

  • • Face-to-face, two-way dialogue to solve problems and address new and important topics. They prefer their veterinarians to be involved in such discussions
  • • Bulletins, fact sheets, etc. for routine updates (i.e., on violation rates) or to explain well-accepted facts (e.g., regulatory requirements)
  • • Courses, if focused on topics of interest and convenient to accommodate farmers’ work schedules

What do they recommend—their advice to FDA?

Farmers support FDA’s efforts to ensure public confidence in a safe food supply, but they want to be treated respectfully regarding infrequent violations and seek meaningful involvement in future development and communication of “best” practices for minimizing drug residue violations. Citing lack of documentation, off-label drug use, human error, and questionable motives as principle causes of violations, Dairy Farmers suggested the following solutions:

  • • Engage in two-way dialogue
  • • Provide education
  • • Develop and communicate clear guidelines
  • • Recognize accidents happen, but be tough on repeat violators
  • • Develop a drug residue test (for meat) to be used on the farm
  • • Promote prevention
  • • Improve culled cow tracking procedures
  • • Keep up the good work

six Farmers on small farms (less than 100 milking cows) reported using written procedures for documenting cow treatment and none of these mentioned having developed a standard written protocol for cow treatment.

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