The FDA Proposed Produce Food Safety Rule Q & A conference call, coordinated by the Produce Safety Alliance, discussed equipment, tools, buildings and sanitation practices that will be affected by the impending Food Safety Modernization Act produce rule.
Here are the questions and answers from that call:
1. Are cats permitted in packing houses? They serve as effective rodent control.
There is no rule that cats cannot be used for rodent control but you must consider the potential for contamination of product or product contact surfaces by the cat.
2. Where does OSHA come into play with the Food Safety Modernization Act?
The FDA used 29CFR (OSHA standards) as guidance for toilets and handwashing stations. However, the rule is not exactly the same as OSHA.
3. Is a household toilet facility OK if it is in compliance with OSHA regulations?
Yes, that is OK, but it should be supplied with soap, single use paper towels, toilet paper and a trash can. Cloth towels should not be used.
4. Are cement floors required in a packing house?
No
5. Should hand washing stations be located inside of a portable toilet?
Yes they should but it is not mandated. FDA would like comments on whether the handwashing station should be located outside the portable toilet.
6. What guidance is given regarding rodents?
The FDA wanted to take a holistic approach with rodent control, so that growers can take care of problems as they occur. No specifics are given as to the methods of rodent control so that it can work with existing systems already in place.
7. Are there specifics on how to clean equipment in a packing shed?
The goal is to prevent contamination of product and product contact surfaces. Guidance will be coming on this topic after the final rule is written.
8. Are instruments required for testing to determine how clean equipment is maintained?
No testing is required.
9. Do wooden tables need to be sanitized?
Wooden bins, tables etc. need to be sanitary not sanitized.
10. How about wood surfaces where produce is cut or packed?
Product contact surfaces must be sanitized – how an operation gets to that point is up to them.
11.When picking buckets are emptied, cleaned and returned to the field how should they be transported (upside down on the wagon, right side up, stacked)?
The grower must consider the likelihood of contamination and reduce that likelihood.
12. What is recommended for the disposal of grey water from a hand washing station?
The rule states that it should be disposed of in a way that prevents it from becoming a potential contaminant.
13. What pest control methods are required for packing sheds that are not fully enclosed or enclosed at all.
Measures should be taken to prevent pests from becoming established. These areas should be monitored and if pests are noticed they should be removed and prevented from posing additional problems.
14. Can harvest bins be stored in the field overnight?
Yes, measures should be taken to prevent contamination such as covering the bins. Bins should be inspected before their use and not used if contamination is evident.
15. How stringent is the rule regarding seams of equipment or tools?
Seams should be smoothly bonded or maintained so that they do not pose a contamination risk. In older equipment retrofits may be required.
16. Alternative methods are discussed repeatedly in the rule, and during the last Q&A it was suggested that alternative methods would be applied to groups. Can alternative methods be applied to individual growers?
Alternative methods are appropriate for groups as well as individuals provided they are science based.
17. Vegetable washers often have brushes or sponges that are tough to take apart and clean, what should be considered in this situation?
The FDA would like comments on specific washing practices and equipment. Close attention should be paid to the equipment used for washing produce to determine the potential for it to contaminate produce.
