by Sally Colby
Paul Vossen, University of California Cooperative Extension farm advisor, says that small scale farmers are very interested in food safety regulations, and specifically, ‘how is this going to affect me?’
Vossen teaches core common sense methods to reduce the potential for food safety problems in produce, which are defined in what he calls the four Ws: water, wildlife, waste and workers. He also suggests that growers have a means by which products leaving their farm can be traced. “As long as you’re going to do all of these things, you might as well document it,” said Vossen. “You can become self-certified, then become certified by a third-party auditor.”
Vossen says that food safety is critical, and that breaches in food safety don’t affect just the farm or origin — a single issue with one commodity can lead to problems that affect both growers and consumers. Small-scale farmers may think they won’t have food safety issues, but that isn’t the case. Vossen cites the case of local fresh strawberries in 2011 in NW Oregon — that incident was most likely the result of deer feces.
“Over a 13 year period, from 1996 to 2009, based on 532 outbreaks, 70 percent of those outbreaks were bacterial,” said Vossen. “Bacteria are causing most of the problems.” Produce associated with outbreaks during that period were primarily leafy greens, melons and tomatoes; along with some cases traced to berries, green onions and herbs.
The USDA responded to foodborne illness originating in produce with GAP (Good Agricultural Practices). Federal legislation in the form of the Food Safety Modernization Act (FSMA) was passed by Congress in 2010 and applies to fruit, vegetables and processed food. “It was released in January, 2013,” said Vossen, “and we’re still in a comment period that’s extended to Sept. 16, 2013.”
Three areas of concern for produce safety practices for fruit and vegetables including harvest, facilities used for packing, and traceability and record keeping.
“There’s an exemption for small farms if you can meet all of the following criteria,” said Vossen. “50 percent direct marketed (within the same state or 275 miles) to consumers, stores and restaurants. Total sales have to be less than $500,000 gross over a three-year period, and you have to be able to provide your name, address and phone number to customers.”
Vossen says while that exemption sounds good, growers may be subject to local and state requirements that may be more stringent. In addition, customers (such as schools and restaurants) who purchase products will likely require third party certification for assurance that the products are safe. Some insurance carriers may increase premiums on farms that don’t have documented certification.
Commodity groups have specific GAP manuals and food safety audit checklists, and Vossen suggests growers obtain the appropriate materials from those groups.
So how much should farmers do? Begin with common sense good agricultural practices, develop a food safety plan on your farm, and conduct a self-audit. If you’re required to, hire a third-party auditor to come in and make sure you’re in compliance.
Common sense GAPs begin with a map of your farm and surrounding area, including where schools are located, other nearby agricultural and/or livestock operations, the location of wells, ponds lakes, ditches and buildings. Maps can be hand-drawn, downloaded from Google or obtained from the appropriate NRCS office. Vossen noted that maps should include what is being grown in each field, which means that maps will have to be updated as needed to reflect changes from year to year.
Once a map is established, document what has been done on the farm in the past. “If it’s a new farm, you’ll want to know what was applied in the past,” said Vossen. “Document that and write it in your plan, and indicate what’s been done to mitigate the problem.”
After the initial steps are taken, it’s time to consider the first ‘W’ — water — which starts with knowing the water source. “If you’re pulling water from the surface, you’ve got potential source of contamination from all kinds of things,” said Vossen. “You need to know what’s upstream.” Vossen noted a 2006 E. coli outbreak that was traced to irrigation water that was contaminated by the feces of feral pigs. “Contamination can come from a lot of different things,” he said. “Bacteria, viruses, waste, nitrates, organic and synthetic chemicals, heavy metals.”
Wells should be designed such that they cannot become a source of contamination. Be aware of animal burrows that are near wellheads, especially in times of heavy rain. The primary step for small-scale farmers is water testing. “Keep records of microbial testing,” said Vossen. “If you have well water, test at least once a year at the beginning of the season. If you have canal or river water, test every few months. For municipal water, get records from the municipality.”
The next ‘W’ — waste — can come from wildlife or from livestock on farm. Agricultural products can become contaminated at any point from the farm to the end consumer. “The primary problem is animal feces,” said Vossen. “This is the primary source of bacterial contaminants that have caused a lot of outbreaks. How are you managing waste, or how are you excluding wildlife from your farm?”
Potential waste contamination can come from untreated or improperly treated manure, manure composting or storage areas, or livestock or poultry operations. “Keep compost and manure handling as far away from the produce production facility,” said Vossen. “Use barriers or physical containment — a ditch or a berm that prevents runoff from manure or compost piles. Compost should have reached the minimum temperature of 140 to 160 degrees, and maximize the time between application and harvest.”
Keep compost and manure as far away from production areas as possible, and use a physical barrier such as a ditch or berm to prevent contamination. Raw manure should be applied two weeks prior to planting or 120 days prior to harvest. Mature compost can be applied 45 days prior to harvest.
Make sure that livestock won’t contaminate fields, and prevent runoff from livestock areas after rain. If livestock are present in fields, remove them 120 days prior to harvest. Vossen noted that animals such as deer and wild turkeys can’t be controlled, but producers should monitor fields for the presence of wild animal fecal matter. Fields in which fecal matter is present should not be harvested.
Wildlife can be excluded with fencing, or managed with propane canons, but vigilance for signs of animal contamination is critical.
The next ‘W’ is for worker health and hygiene. “The human body carries a wide variety of pathogens, primarily from human feces,” said Vossen. “Worker contamination of produce is a serious issue — 93 percent of outbreaks related to food handlers involved sick workers.” Vossen suggests having a policy stating that sick workers do not come to work, or are assigned to work in an area not directly involved with food handling.
Workers should have basic first aid training that includes how to appropriately handle blood, cuts and wounds. “They need to know where the first aid kit is, and something about dressing wounds,” said Vossen. “If produce is contaminated with blood or fluid, that produce cannot be shipped.”
OSHA regulations for toilet facilities are appropriate for produce production areas. Keep toilets clean, and post cleaning dates. Make sure that water from toilet cleaning doesn’t get into fields. If a stream of water from outhouse cleaning runs out and a tractor drives by and into a field, that field is potentially contaminated. “You have to think of all the different possibilities,” said Vossen. “The basic idea is to keep bacteria out of fields and off the hands of workers so it isn’t transmitted to produce.”
Have a written washing policy, and train workers on when and how to wash hands (before work, after breaks, after using the toilet, after handling garbage, working with soil or rotten produce). Have appropriate break areas for workers, and equip those areas with hand washing stations. Farms should maintain a no smoking, chewing tobacco, gum or eating other than in the designated break area.
Vossen emphasizes the importance of training all workers, documenting that training and keeping records of illnesses and injuries.