How To Manage Food Safety Risks
The Food Safety Modernization Act (FSMA), the most sweeping reform of food safety legislation in more than seven decades, was signed into law in January 2011. Four years and a couple of rounds of comment periods later, we are on the cusp of receiving the final Produce Rule, which is due from FDA in October.
What exactly does the Produce Rule mean for you and your operation? It means you need to understand produce safety issues, from record keeping to water testing to wildlife management, and the impact they will have on you and your farm. If you are a small operation, you may not be required to comply with the law per se, but if you are selling produce in the marketplace, your buyers may require you to do so.
According to Betsy Bihn, a senior Extension associate at Cornell University and the director of the Produce Safety Alliance (PSA), from the numerous GAPs and PSA food safety training sessions she and Gretchen Wall, program coordinator for the PSA, have held over the last couple of years, not all growers realize what is coming in October. The good news, Bihn says, is there will be staggered implementation times, allowing some growers up to four years to comply, but the important thing is to do something now.
The Price Of Food Safety
The cost to be in compliance with the law is often part of the discussion Bihn and Wall have with growers. According to Bihn, it may not be as bad as many growers might think.
“Water testing costs between $25 and $50 and that can add up quickly,” she explains. “Training your workers is an expense in time, and time is money, but this is a great investment that will pay off in terms of better implementation of food safety practices. For example, trained workers will be better at identifying food safety risks in the field such as animal intrusion and fecal contamination. This will reduce the risk of harvesting contaminated produce.
“It is also important to understand the proposed regulation is not prescriptive, but allows growers to set up practices that work on their farms,” Bihn continues.
For example, simply by using a clear plastic insert, record keeping can be made easy for workers, Wall says. The insert is used to hold record keeping sheets that are taped to the packing shed wall or another convenient location.
“Next, tie a string to a pencil so it doesn’t walk away,” she says. “Workers are more likely to fill out a record keeping sheet if it is easily accessible and they know how to fill it out.”
Prepare For The Produce Rule
To help you make sense of the upcoming regulation and determine what you need to do to be in compliance, Bihn and Wall offer seven tips on how to assess your food safety risks and get ready for the new law. (For more information on the Produce Rule, go to http://1.usa.gov/1GWO4me.)
1 Believe produce safety impacts you.
There are about 189,000 produce farms in the U.S. Of those farms, 154,000 could be exempt from the produce safety rule, but no one is exempt from the marketplace.
“If you feel you can dodge this bullet and put your head in the sand, think again,” Bihn says. She adds that food safety isn’t just about FDA imposing regulations.
“Growers need to recognize that produce safety is going to impact them because it impacts the marketplace, and it is part of doing business,” Bihn says.
2 Train your workers.
Training provides you with the biggest bang for your buck. In fact, Bihn says if you don’t have a good worker training program, you are passing up the easiest and most financially effective food safety tool.
“[You need to provide] the appropriate resources for the workers to do their jobs,” Bihn explains. “Not only do you have to train them, you have to be responsible for providing them with standard operating procedures, access to proper hygiene facilities, etc.”
3 Know the quality of your water.
According to Bihn, you will need to know the quality of surface water where it touches the edible portion of the crop via overhead irrigation or crop sprays. Initially, FDA indicated it wanted water testing every week. Later, the agency changed that to 20 times over two years to establish a baseline, she says.
“We have been telling growers in our training sessions that they simply have to test their water,” Bihn explains. “The debate continues on how many times you will need to test your water, but based on the proposed rule, FDA is clinging pretty closely to EPA’s recreational water standards as the basis for their standards.”
Bihn and Wall suggest testing your water once a month for quantified generic E.coli and compare your test results with EPA’s recreational water standards.
4 Be cautious when using manure.
Whether or not you use manure, its use is a concern for all growers, Wall says. A neighboring farm could be using manure and there could be runoff in the stream or water source you are using to irrigate.
“Knowing what is going on next door can identify potential hazards the grower may not know were impacting his or her farm,” she adds.
According to Wall, FDA initially proposed a nine-month application period for manure, but has since proposed removing the application interval and is deferring action on the use of raw soil amendments, citing the need for additional research.
In the meantime, she says FDA will promote the use of compost practices so that you get the soil amendment to a designated temperature for a specific amount of time to kill pathogens.
“There has been a lot of outreach and talk of doing a soil summit to help growers move toward composting practices to see how feasible that is as a risk-management tool,” she adds.
5 Minimize wildlife risk.
It is important to remain vigilant if you have a problem with wildlife on your farm, but know that you will not be able to control every raccoon, possum, or mouse that comes in contact with your fields, Bihn and Wall say.
“This is where the frustration comes into the discussion because growers are already trying to prevent wildlife presence in the field,” Bihn says.
“The most critical thing to do after you put your [wildlife] plan into practice to limit animal intrusion — using noise cannons, plastic coyotes, nuisance permits, etc. — is to do the preharvest assessment of the fields before you harvest,” Bihn says. “If there is damaged crop or fecal contamination, then you have to buffer it off and harvest around it.”
6 Keep postharvest water clean.
If you are using any kind of batch, bulk, communal, or dump tank water, then adding a sanitizer is in order. Part of the process, Bihn says, includes monitoring the sanitizer levels and keeping the surfaces the produce touches clean and sanitized (when possible), too.
Sanitizers in postharvest water are not meant to clean the produce but instead prevent any cross-contamination from the water or one piece of fresh produce to another, she adds.
7 Understand how produce moves around your farm and the surfaces it contacts.
Begin by creating a map that shows how produce moves around your farm, Bihn says. Identify any surfaces produce touches as it moves from the field (packing containers, sorting tables, conveyor belts, etc.) to
its entrance into the packing shed, until it is loaded on a truck. Knowing these details will help you understand where contamination could enter the system and develop an effective cleaning and sanitation program, she adds.
“Food contact surfaces should be the first line of your sanitation program, and you should be cleaning those surfaces whether they are bins or conveyor belts,” Bihn explains. “This is an action all growers can do now, before the rule comes out.”
It is also critical for growers to know the difference between detergents and sanitizers as each has a separate job to do, Wall says. “For cleaning a food contact surface, first dirt and debris must be removed by using an appropriate detergent, then follow with a sanitizer. Otherwise the sanitizer will not function properly.”
According to Wall, every grower needs to keep basic risk assessment in mind at all times. Many small growers, she says, don’t realize they are probably already handling numerous food safety tasks on the farm. “They are just not documenting [the activities], or they feel like they have to do everything all at once,” she adds.
Wall suggests setting incremental food safety goals for your operation, such as opting to train volunteer workers on the farm this year, and next year begin testing your water, for example.
“Bite off things in manageable chunks rather than scrambling to do it at the very end,” Wall says. That’s sound advice for virtually any project.
For additional information on the Produce Safety Alliance, go to ProduceSafetyAlliance.Cornell.edu.