On-Farm Food Safety Section

Keep up with the latest news on this dynamic topic that impacts growers on multiple levels. Developing a farm food safety plan is a good idea for all growers, and may be required as part of food safety audits if you sell to certain buyers.

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Food Safety Modernization Act Update:
Farm Definition & Exemptions

FDA FSMAThe Risk-Based Preventive Controls for Human Food final rule was published in the Federal Registry September 17, 2015. This is the first of two which may directly impact fruit and vegetable growers. To review the complete rule go to https://federalregister.gov/2015-21920.

This rule updates good manufacturing practices related to processing and clarifies the farm definition and exemptions. Under the original proposed rule there were several activities on farms in our region that would have had to comply with this rule. However, with the revised definition most activities are exempt or fall under the Produce Rule which will be published at the end of October.

Under the final definition there are two ways to be considered as a farm: as a “Primary Production Farm” or as a “Secondary Activities Farm.”
[Read more…]

Audit Ready: Sanitizing Surfaces in Post Harvest

sanitation product contact surfacesSanitizing product contact surfaces is important in reducing cross contamination risks.  “Product contact surfaces” means anything that comes in contact with the product such as equipment, belts, rollers, brushes, tables, bins, sinks, tools, and reusable totes.  Writing a standard operating procedure describing the specific steps of your cleaning process will help ensure that the surfaces are properly cleaned.

Proper cleaning and sanitizing of contact surfaces includes these steps:

  1. Surface is rinsed to remove any visible debris
  2. Appropriate detergent is applied and the surface is scrubbed
  3. The surface is rinsed with water that is potable (drinkable)
  4. Appropriate sanitizer is applied, following the directions
  5. Let the surface air dry

An appropriate sanitizer for use in post harvest surface cleaning is one that has an EPA registration number, states that it is food grade, and gives specific instructions for the products use as a surface cleaner.  Remember the label is the law.

Audit Ready: Equipment Maintenance Records

tractorThe harmonized audit requires a listing of equipment (2.7.1) that has the potential to come into contact with the crop, and for each piece of equipment a maintenance record.
Just how detailed of a record do they want?

Anytime there is a repair, cleaning, or fluid change there should be a record of this task.  The auditor will look at the equipment for signs that there could be a issue, such as an oil or fluid leak under the equipment.  If they see an issue they will then ask to see the maintenance record for that piece of equipment.  This falls under the “are in good repair and are not a source of contamination of produce” section of standard 2.7.2.  Remember, this is only for equipment that will go out into the field or production area.

Audit Ready: Handling Unwritten Policies

Writing Your PlanIn both the GAPs and Harmonized audits there are standards that focus on policies, yet the checklist does not indicate that a written policy is required.

You can choose to not write these policies in your plan but you and your employees need to be prepared to answer questions from the auditor about these policies.  Your answer to the auditor needs to be the same as your employees; they will verify this!

If the auditor does not find the policy or the employee answer satisfactory, you will receive a “CAN” (corrective action needed).

Audit Ready: Heads Up on Handwashing Stations, Well Water Sampling, & Traceability

Handwashing Stations

Auditors have noted that on handwashing stations some have a label which says “Not potable water.” If a grower is doing the USDA GAP or Harmonized audits, the water in handwashing stations must meet the “Microbial standard for drinking water.” If a label is on the wash station marked not potable, the grower is not in compliance. Check G-9 in the GAP or 2.2.5 in the Field Operations and Harvesting Harmonized Food Safety Standard for more details.

From Grower Self Audit for USDA GAP Audit General Questions G-1 to G-15:
G-9. All toilet/restroom facilities are clean and properly supplied with single use towels, toilet paper, and hand soap or anti-bacterial soap and potable water for hand washing.

[Read more…]

Audit Ready: 10 Tips to Help You Prepare

Birds in the rafters1. Auditors will most likely look at aerial maps of the farm prior to their visit.  They may ask about water sources, buildings etc. that they see on the online map that you might not have included in your production area maps.  Take a look at your farm on google maps to make sure you included everything required.

2. Auditors will not tell you how to fix a problem but can prompt you to solve a problem by asking questions about what they are seeing.

3. If you contract pesticide applications out to a third party you will need to have these spray records on hand during the USDA audit.  Ideally growers should have a copy of these spray records on farm, regardless of an audit. [Read more…]