The FDA Proposed Produce Food Safety Rule Q & A conference call, coordinated by the Produce Safety Alliance, discussed the growing, harvesting, packing and holding of produce.
Here are the questions and answers from that call:
1. Will growers be expected to use food grade containers?
Containers do not have to be food grade. Wooden containers and canvas bags are acceptable but they must be sanitary.
2. Wood is difficult to sanitize.
Wood does not have to be sanitized but it does need to be sanitary.
3. How do you define sanitary in regards to wood?
Sanitary wood would be wood that is likely to not contribute to contamination.
4. Can galvanized metal buckets be used for harvest?
Yes, they need to be clean and sanitary.
5. What regulations do the sanitizers fall under?
Sanitizers used on surfaces and in water need to contain an EPA pesticide label, and they must be used according to that labels directions. If the sanitizer is going to be used to kill microbes (on fruit, on surfaces etc.) then it must have a label that specifies that use.
6. Would trimming lettuce cause a farm to fall under the definition of a facility? What does this mean for this farm/facility?
Typical trimming of produce (removing outer leaves) does not cause a farm to fall under the category of a facility. Whene the actual raw agricultural commodity is cut (trimming ends of green onions to be uniform in length etc.) that activity would cause a farm to fall under “facility” and therefore the preventative control rules. More information on the preventative control rules can be found at the FDA FSMA website . FDA would like comments related to trimming as a general practice at or after harvest for specific commodities.
7. Would a seasonal open air packing facility, with a wood floor, canopy overhead and a dunk tank and cooler below be acceptable?
Yes, as long as the facility is not a source of contamination.
8. Does the requirement to keep produce contact containers/surfaces clean during the season apply to the off-season?
No. The containers should be clean when taken out of storage and if they are not, appropriate measures should be taken to clean them or discard them. Measures should be taken to exclude pests from storage areas during the entire year.
9. Food Hubs often have store fronts which sell fresh produce as well as trim and package items for sale. Does this fall under the preventative controls rule?
No, the food hub would be considered a retail establishment and would need to comply with the state’s food code.
10. Can boxes be reused?
Yes, as long as they are not a source of contamination.
11. How does the rule apply to ladders used in orchard harvests?
Ladders should be clean and sanitary. Could they become a source of contamination in the way that they are used? Workers should be trained on how to avoid cross-contamination.
12. Page 3568 includes the statement that hands that contact produce must be free of microbial contaminants. This statement is impossible.
Yes, this is a word choice error and should read that hands must be free of pathogens.
The final conference call on May 13 will cover Recordkeeping, Compliance and Enforcement. Anyone can participate by dialing toll-free 866-906-9888 and entering the pass code: 8140591. To hear the recorded tapings of these conference calls visit the Produce Safety Alliance
