Policy Amendment for Same-Language Policy
Version 1: January 2022
The original Produce Safety Alliance (PSA) “Same-Language Policy” governing delivery of the PSA Grower Training Course limits course delivery to languages in which a translation exists. The Same-Language Policy as it appears on the PSA Grower Training Course Registration Form states:
The PSA Grower Training Course Manual is currently available in English, Spanish, Chinese, and Portuguese. All participants must receive training in a language that they understand. This includes having a PSA Grower Training Manual that is written in the same language that participants easily understand and is in the same language in which the course is delivered.
The PSA has identified situations under which the current Same-Language Policy and available Approved PSA Manuals (see definitions box) and corresponding presentation slide sets will not meet the needs of all potential course participants because some ‘supervisors or responsible parties’ at farms covered by the Produce Safety Rule do not speak or read one of the languages in which the PSA curriculum is currently available. A policy amendment is described below to guide PSA Trainers, Lead Trainers, and Trainers-of-Trainers who may encounter these situations.
In all instances described under this policy amendment, it is critically important that training organizers include a statement of language expectations in the course promotional materials (e.g., announcements, registration pages) so that participants are aware of the policies and expectations. This can help prevent any unnecessary travel or other costs incurred by the participants if they travel or pay to attend the course, but then realize they cannot understand the Written Language and/or the Delivery Language. According to PSA policy, participants who cannot understand either the Written Language or the Delivery Language of the course are not eligible to receive the PSA/AFDO certificate of completion.
Select the Alternative Language Delivery Option That Applies to the Training and Audience
Examples of training situations that would fall under an Alternative Language delivery option are described below. Trainers should select the delivery option that best fits their situation. Under each delivery option is information to help guide decision-making with regards to whether the Written Language and Delivery Language are appropriate for the course participants. Each example is followed by policy expectations. The primary goal of this policy is to ensure that all participants receive a high-quality training experience that enhances participant understanding.
Option 1: Bilingual participants prefer an Approved PSA Manual in an Alternative language
This option applies to situations where one or more training participants are bilingual and prefer to use an approved, printed PSA Manual that is in an Alternative Language to the Delivery Language of the course.
For example, the Delivery Language for a course may be English and the participants understand English but prefer to read and make notes in Spanish. There is an Approved PSA Manual currently available in Spanish.
Policy: For bilingual participants, trainers may provide an Approved PSA Manual in an Alternative Language if the participant understands the Delivery Language and the Alternative Language.
Rationale: The use of a different Approved PSA Manual by some participants in the course session has no effect on the course delivery or the educational experience of all participants in the course and results in a better learning experience for the participants who prefer a different Approved PSA Manual.
Trainer Responsibilities: For this option to be utilized, course organizers will need to prepare in advance and follow the policies below.
- All course promotional materials (e.g., announcements, registration pages) must clearly state the Written/Delivery Language. Trainers may want to add information to the registration materials asking about language preferences for the Approved PSA Manual if they know they may have a bilingual audience.
- Participants should notify the trainers prior to the training that they prefer an Approved PSA Manual in an Alternative Language.
- It is critically important that all participants can understand and communicate in the Written/Delivery Language of the course (e.g., English). The PSA Lead Trainer is not required to test participants for comprehension in the Written/Delivery Language, but the PSA Lead Trainer is expected to confirm that each participant does understand the language in which the course is being delivered to ensure participants get the information they need as well as ask questions and receive answers they understand. This can be done in many ways, including informal discussions with participants at the beginning of class or during the registration process.
- Each participant must receive a printed, approved PSA Manual in a language they understand.
If Option 1 best fits your situation, follow the trainer responsibilities outlined above and skip down to Course Registration for more delivery details.
Option 2: All participants and trainers are bilingual and prefer an Alternative Language for delivery and discussion
This option applies to situations where the training involves a completely bilingual group, including the PSA Lead Trainer, PSA Trainer(s), and all participants, and participants prefer an Alternative Language as a Delivery Language (i.e., different from the Written Language). In the examples below, the Alternative Language is not available in a currently approved translation of the PSA Manual. All participants must be fluent in the Delivery Language and provided with an approved, printed PSA Manual in a language they understand.
For example, this policy would be appropriate for:
- A training for a Plain grower community where participants prefer an Alternative Language (e.g., Pennsylvania Dutch) as the Delivery Language. All participants can read English and there is an Approved PSA Manual in English. The participants and trainers also speak Pennsylvania Dutch. In this example, there is no option of having the Written Language match the Delivery Language because there is no approved PSA Manual in Pennsylvania Dutch.
- A training for growers in a foreign country (e.g., Italy,) where they can speak and read English, but are more comfortable with the Delivery Language being in their native language (e.g., Italian).
Policy: Trainers may use a Delivery Language in an Alternative Language for a course session where ALL participants speak the Alternative Language and are also able to read the Approved PSA Manual and any corresponding presentation slide sets used during the training. All participants must understand both languages.
Rationale: In situations where an entire group is more comfortable speaking an Alternative Language, (i.e., a language for which there is no approved PSA Manual) the learning experience is enhanced by being able to discuss concepts in the Alternative Language.
Trainer Responsibilities: The PSA Lead Trainer(s) and PSA Trainer(s) must be able to communicate in the Alternative Language of the Delivery Language and the Written Language to be able to oversee the quality of delivery, and to receive and answer questions from participants. In addition:
- It must be clear in all course promotional materials (e.g., announcements, registration pages) that all or parts of the course will be delivered in an Alternative Language.
- There should be a confirmation box on the registration form indicating that all registrants are aware of the Alternative Language that will be used for discussion.
- Each participant must receive a printed, approved PSA Manual in a language they understand.
- If a participant is not able to take part in the discussions because they do not understand the Alternative Language, the Lead Trainer must inform that participant that they are not eligible for a PSA/AFDO certificate of completion.
If Option 2 best fits your situation, follow the trainer responsibilities outlined above and skip down to Course Registration for more delivery details.
Option 3: One or more participants are unable to understand the Delivery Language and/or any Written Language of the Approved PSA Manuals; use of interpretation services may be necessary.
This option applies to situations where the course includes participants who cannot read any of the Written Languages in which the Approved PSA Manual has been translated. In some cases, interpretation services might be available for an Alternative Language as the Delivery Language that all participants understand. In all cases, participants must still be provided with an approved, printed PSA Manual most likely to be understood by them or others on their farm.
For example, this policy would be appropriate for:
- A community of Hmong-Americans who do not read or speak English or any other language in which there is an Approved PSA Manual.
- Growers in India who only speak Hindi or another language of the subcontinent in which there is not an Approved PSA Manual.
- Participants who either cannot read or have trouble understanding/reading any of the Delivery Languages of a PSA Grower Training Course and Written Languages of the Approved PSA Manuals.
Policy: The PSA Grower Training Course may use any language as the Delivery Language while using an Approved PSA Manual for reference and note taking. This requirement applies even when course participants cannot read or understand any Written Language of an Approved PSA Manual. The PSA Lead Trainer(s) must be able to communicate with all participants and understand their questions. All participants must be able to understand the material presented. This can be done either by using a PSA Lead Trainer and PSA Trainer(s) who are fluent in the Alternative Language of the Delivery Language or through the use of an interpreter.
For example, if the Delivery Language is English, but participants speak an Alternative Language (e.g., Hmong), then an interpreter will be required to translate the Delivery Language (e.g., English) into the Alternative Language (e.g., Hmong). The interpreter(s) will also need to be able to translate participant questions in the Alternative Language back to the Delivery Language so that PSA Lead Trainer(s) and PSA Trainer(s) can communicate with the course participants. In this option, no approved PSA Manual is available in the Alternative Language (e.g., Hmong). Nevertheless, participants must be provided with a printed, approved PSA Manual for reference.
As another example, the Delivery Language might be English, and all participants speak English but some participants cannot read English or any other language of the Approved PSA Manual.In this example, any participants that are unable to read are still eligible for a PSA/AFDO certificate of completion. These participants must be provided with a printed, approved PSA Manual for reference.
If not all participants and trainers speak the Alternative Language:
- Interpretation services must be provided.
- All discussions must be facilitated so that all participants and trainers in the course can understand, including incorporation of appropriate time for interpretation services.
- More time should be scheduled for the training to accommodate interpretation. See best practices section below.
Rationale: There are many reasons for this option. These include 1) some languages do not have a universal written form, 2) there are not available translations of the PSA Grower Training Manual in every language used by every produce grower or packer that is affected by the FSMA Produce Safety Rule, and 3) there is a need to accommodate participants who do not read. A printed, approved PSA Manual must be given to these participants for them to be eligible for a PSA/AFDO certificate of completion even if they cannot read it. This is because evaluation data indicates participants value the printed manual and because it may be used by others at their farm or business such as a member of the participant’s family who can read the Approved PSA Manual.
- It must be clear in all course promotional materials (e.g., announcements, registration pages) if all or parts of the course will be delivered in an Alternative Language as the Delivery Language.
- There should be a confirmation box on the registration form indicating that all registrants are aware of any Alternative Language that will be used. This may require use of translation services, or it may limit participation in the course to only those individuals that understand the Alternative Language.
- Each participant must receive a printed, approved PSA Manual.
- All discussions must be facilitated so that all participants in the course can understand, including incorporation of appropriate time for interpretation services.
- At least one PSA Lead Trainer must be able to understand the Delivery Language and the Alternative Language, if different, to be able to receive and answer questions from participants. This can be done using an interpreter.
- The PSA Lead Trainer must ensure that the time available for this type of training is sufficient to allow time for interpretation, if necessary.
- Additional PSA Lead Trainer(s) or PSA Trainer(s) affiliated with the course should be able to understand both languages so that they can follow the conversation and help answer questions. If they do not, interpretation services should be provided.
- The PSA Lead Trainer should prioritize use of interpreters who know the terminologies of agriculture and the FSMA Produce Safety Rule in both languages.
Supplemental educational materials in the Alternative Language may be provided during the course as one way to enhance learning. The PSA Lead Trainer(s) and PSA Trainer(s) may also want to add more images to the presentation to improve understanding since reading slides may be a challenge for participants. Consider using hands-on activities and visual learning opportunities such as a farm visit to improve participant understanding of the information in any course presented under this option.
If Option 3 best fits your situation, follow the trainer responsibilities outlined above and skip down to Course Registration for more delivery details.
For courses that are conducted in languages other than those which have an Approved PSA Manual, please be sure to denote this on the course registration form. Under the question ‘What is the primary language of your course participants and the language the course will be conducted (i.e., Delivery Language)?’ select ‘Other language in consultation with PSA’ and provide details about the language and course delivery.
The PSA anticipates that there may be additional situations which have not been considered in this policy. As more translations of the PSA Manual become available, this policy may not be needed for as many audiences. If you have questions about the Alternative Language Policy, please contact Donna Clements at PSA (email@example.com, 909-552-4355) prior to registering the PSA Grower Training with AFDO so that we may help you determine whether your situation aligns with a current policy.
Paper evaluations for in-person courses and Qualtrics evaluations for remote courses are available in English, Spanish, Portuguese, and Chinese. Courses which are conducted in languages other than those with an Approved PSA Manual will need to provide translation assistance for participants. This may mean translating the evaluation into the language that the participants understand or using an interpreter to read the evaluation questions. Participants may need assistance filling out the evaluation or may need additional time.
Paper evaluations can be returned by mail to the PSA at:
Produce Safety Alliance – Attn: Evaluation Processing
Food Research Laboratory,
665 W North Street, Geneva, NY 14456
Or by scanning and uploading them to the PSA website as outlined in your course approval email from AFDO.
The following information is provided as guidance to PSA Trainers, Lead Trainers, Trainers-of-Trainers, and course organizers to meet language needs of participants and enable the training to run smoothly.
Allow more time on the agenda to achieve training goals.
- Delivering the PSA Grower Training in an Alternative Language or with interpretation services will require a significant amount of extra time on the agenda. Plan appropriately to allow extra time for questions, review of materials, and reading of course evaluation questions to participants if they are not literate or do not understand the language in which the evaluation is available. In pilot trainings using this policy, some trainers reported needing double the time to complete the delivery of the curriculum content and evaluations. Trainers should also be cognizant of the pace of their presentation delivery to ensure that interpreters and course participants are able to follow the content.
Meet with the training team well in advance of the course to adapt programming and resources.
- As with all PSA Grower Training Courses, coordination of training logistics among the training team members is important. Additional considerations may be necessary to ensure the Alternative Language vocabulary is consistent, cultural needs are addressed, and teaching strategies are appropriate. Keeping the course content simple and refraining from extraneous discussion/conversations will help participants follow the course content more effectively. Trainers should also consider whether additional visual aids such as pictures, illustrations, or hands-on activities may be beneficial to communicate complex topics which may not translate well for the target audience in other languages. Color coding of materials (e.g., colored tabs to separate modules) can also aid in navigating the curriculum manual and course materials if numerical or written denotations are challenging.
Know your audience’s needs and consider having extra support.
- Additional personnel may be necessary to organize, host, and deliver the course. This might include having an extra PSA Trainer or Lead Trainer available to answer participant questions or provide interpretation assistance. Administrative and organizational help may also be warranted if the target audience requires a special means of communication to inform them of course requirements, prepare them for attending the training, and/or provide a comfortable environment for learning. Consider enlisting the help of known and trusted individuals within the community you are working. They may have insight into how to make the training successful, suggested means of communications (e.g., group prefers to receive information from one person or community leader rather than e-mail), or other specifics about the community that are critical for success.
Utilize translation and interpretation services, where appropriate.
- Use of translators and interpreters is encouraged when the participants may need additional assistance in registering for the course, understanding or translating the course materials, and filling out evaluations. Prior to selecting a translator or interpreter, be sure to vet their fluency and competency to provide the services needed. Providing the course materials to these individuals ahead of time will allow them to become familiar with the content and allow time for them to ask clarifying questions to ensure the delivery is accurate. FSMA Produce Safety Rule concepts (e.g., pathogen die-off, statistical threshold values, co-management) may require particular attention since legal definitions and scientific principles are often not commonplace or do not have a direct translation. Discussing these concepts ahead of time will allow the training to flow smoothly.
Provide timely and clear communication to course participants about training expectations.
- Trainers should provide clear information about the language the trainers and/or interpreters will be using to deliver the curriculum content, the language of the Manuals which will be available, and whether interpretation assistance will be provided. This will help participants gauge whether the course is appropriate for their learning needs. Be sure to provide a private means of communication for participants to express their needs or concerns prior to the course, such as literacy or language barriers.
Confirm participant addresses/e-mails for receipt of the PSA/AFDO Certificates of Course Completion and contact PSA if the group requires an alternative mechanism of certificate delivery.
- In some circumstances, participants may not have a physical address or have access to a computer/e-mail for receipt of electronic certificates. If this is the circumstance, please contact PSA to arrange a different delivery mechanism of certificates from AFDO to the course participants. For example, some groups have preferred that all training certificates go to the PSA Lead Trainer to be distributed to each participant. This will require that the PSA Trainer and/or Lead Trainers delivering the certificates to confirm with AFDO when all certificates have been delivered. This can be achieved by having participants sign off when they receive their copy and providing this documentation to AFDO upon course close out.