Food Safety Modernization Act Question and Answer Session on Health, Hygiene and Training, subpart D.
This FDA Proposed Produce Food Safety Rule Q & A conference call, coordinated by the Produce Safety Alliance, discussed health, hygiene and training focus areas of the impending Food Safety Modernization Act produce rule.
Questions asked during this conference call were:
1. In the case of farms who sell entire fields of produce, pre-harvest, who is responsible for food safety?
If the ownership of the product in the field changes hands then the responsibility from that point forward belongs to the new owner. Just because the ownership of the crop transferred does not absolve the previous owners responsibility for the field production when it was under their ownership.
2. What constitutes a visitor? Would a sales rep be considered a visitor?
Any person other than personnel is considered a visitor. There is no set time limitation to designate who is a visitor. Growers should consider the potential for contamination from any visitors to the farm.
3. Will testing workers, now or in the future, for asymptomatic diseases be a part of this ruling?
No
4. Is there a recommendation as to the type of soap used in hand washing?
No, soap is the minimum requirement.
5. Is warm water required for hand washing?
No, there is no temperature requirement.
6. When work crews are hired to work on a farm, who is responsible for their food safety training?
The company that manages the work crew is responsible for worker food safety training, not the farm. The farm should obtain documentation from the work crew company to verify worker food safety training.
7. What is the requirement for holding onto worker health and hygiene documentation and records?
A minimum of two years past the date of creation.
8. How strict is the rule regarding eating in the field?
The rule does not cover this specifically, but is covered by hygienic practices and will be a focus of guidance documents.
9. Does eating constitute a break?
Yes. Farm workers must wash their hands after any type of break.
10. Is alcohol based sanitizer acceptable?
No, soiled hands prevent the effectiveness of alcohol based sanitizers. Hand washing has been proven to be much more effective.
11. Can break areas be a separate area, but not necessarily walled off?
Yes
For additional questions and answers visit the FDA Q&A website.
