University of Maryland Extension

Food Safety Plans and Compliance

Building a good food safety plan is a top priority for a new and beginning farm business.  Food safe is incredibly important for every farm, regardless of size, methods of production, or marketing outlets.  It is a common misconception that food safety and the need to implement the practices necessary to mitigate contamination of fresh produce are problems of scale, concerns only for larger farms. The reality is that most of the changes needed to move a farm from food contamination risk-takers to one of risk aversion via good agricultural practices are easy and require little capital investment. They also have the potential to enhance produce quality and improve labor efficiency.

The main areas of concern for food safety are water quality, manure and compost, human hygiene, wild and domestic animals in the fields and packing and storage facilities.  Irrigation and water used for washing produce should obviously not contain harmful pathogens.  To ensure levels are tolerable, water tests should be conducted.  The frequency with which a farm tests its water depends on the source – municipal, well, and surface sources all have different requirements under GAPs.  Furthermore, water-contact surfaces, such as dump tanks, wash tanks, and coolers should be cleaned frequently.   Knowing the quality of your water is the food safety equivalent to a soil test.  You wouldn’t farm without knowing the qualities of your soil and you shouldn’t sell produce without knowing the quality of the water used to irrigate and wash it.

There are three topic areas of food safety compliance and training addressed on this site:

* Fresh produce safety and the Food Safety Modernization Act.

* GAP and GMP training and certification

* Regulations for processing and marketing meat, poultry and eggs.

There are both national and state regulations which apply to farm and ranch businesses. 

For more information on your individual state’s requirements, please visit your state department of agriculture.

https://newfarmers.usda.gov/food-safety

http://onfarmfoodsafety.familyfarmed.org/wp-content/uploads/2014/11/Step-by-Step-Intro-to-Food-Safety.pdf

For federal compliance, the following resources can be useful.         

For more information on your individual state’s requirements, please visit your state department of agriculture.

Food Safety: Help With GAP Certification
USDA offers a user's guide to Good Agricultural Practices (GAP) and Good Handling Practices Audits from the Agricultural Marketing Service - as well as information about the audit process.

USDA’s new GroupGAP Certification Program makes food safety certification accessible and affordable for farmers of all sizes, from smallest to largest.

USDA and leaders from food and agriculture organizations also support a free online tool, On-Farm Food Safety Project, to help U.S. producers of all sizes achieve GAP-harmonized standards and certification. This site helps farmers design a customized manual to meet GAP-harmonized standards and certification requirements, including USDA GAP standards, and mitigate business risks by answering just a few questions.

Food Safety: Produce Safety Alliance
The Produce Safety Alliance is developing a nationwide curriculum to increase understanding of the principles of Good Agricultural Practices and to facilitate implementation of food safety regulations that will be part of the Food Safety Modernization Act (FSMA). Their website includes information about training opportunities, educational materials, regulatory updates, and national produce safety collaborators. Outreach efforts focus on fresh produce growers, packers, and grower cooperatives, with special emphasis on small and very small farms and packinghouses. Additional materials for specific processed products and sprouts may also be found here: 

  • Food Safety: Food Safety Preventive Controls Safety Alliance
    The Food Safety Preventive Controls Alliance is a broad-based public-private alliance consisting of key industry, academic, and government stakeholders. Their mission is to support safe food production by developing a broad range of materials including a nationwide core curriculum as well as training and outreach programs to assist human and animal-food production companies in complying with the preventive controls regulations that will be part of FSMA.
  • Food Safety: Sprout Safety Alliance
    The Sprout Safety Alliance is a public-private alliance developing a core curriculum, training and outreach programs for stakeholders in the sprout production community. The goal is to enhance the industry's understanding and implementation of best practices for improving sprout safety, and additional requirements for sprout producers in the upcoming rule on standards for produce safety required by FSMA.

https://newfarmers.usda.gov/food-safety

https://gaps.cornell.edu/educational-materials/

https://farmcommons.org/resources/farmers-guide-reducing-legal-risks-food-safety-incident

http://onfarmfoodsafety.familyfarmed.org/wp-content/uploads/2014/11/Step-by-Step-Intro-to-Food-Safety.pdf

The prevailing notion among both limited resource and beginning farmers is that food safety is an issue primarily for large operations and that it requires cost prohibitive infrastructural changes and burdensome record keeping and maintenance.  A general lack of discretionary capital coupled with often tenuous land situations – including short-term lease agreements and an unwillingness on the part of landowners to invest in structures only their tenants may benefit from - results in a state of complacency on many farms.  The purpose of this post is to dispel the aforementioned matters, introduce some basic food safety practices and to direct beginning farmers to more in depth resources concerning both Good Agricultural Practices and food safety more broadly.

The Importance of GAPs and Food Safety

Good Agricultural Practices, or GAPs, refer to the steps taken at the farm level to lower the risk of contaminating produce with dangerous pathogens such as Salmonella, E. coli, and Listeria.  While not typically found on fresh fruit and vegetables, these microbes contaminate fresh produce via contact with various vectors, namely people, animals, and water.  Fortunately food safe production is largely a commonsense endeavor.  While GAPs certification through the USDA is not for every farm, the adoption of the practices and precautions are universally beneficial.  By following GAPs, or a basic, striped-down version of GAPs on the farm year-round – from field preparation through harvest and marketing - the risk of contaminating produce can be greatly reduced. 

While this may be more a product of an information gap among consumers, beginning farmers (as well as those with more experience) are not immune to the prejudice. Not helping curtail the perpetuation of this misjudgment, small farms and those direct marketing the majority of their produce are, at present, exempt from regulation under the Food Safety Modernization Act (FSMA). 

The USDA and FDA designed GAPs to reduce the risk of contamination of produce by various pathogens present on farms.  While not mandatory, it is becoming increasingly common among wholesale and institutional buyers to require their producers to follow GAPs.  If these markets are of interest to a farmer, GAPs compliance should be also.  Despite exemption from government regulation under the FSMA, food safety is important to the viability of farms choosing direct marketing as a significant part of their business plans as well.  The reasons are commonsense.  The economic sustainability of direct marketing farms is dependent on quality produce and customer relationships.  A one-time mistake can have devastating effects on a farms reputation or worse, result in legal problems.

Again, while a GAPs audit and certification may not be necessary, implementing the practices will go a long way in protecting a farm from contamination risks.  The potential points of contamination in the field and in post-harvest and packing areas should be a primary concern for most beginning farmers.  Generally speaking, a farm should have a food safety plan that details what measures are being taken to mitigate risks.  The farm should also keep careful records of sanitation practices including cleaning of facilities.  Hand washing and toilets should be in convenient proximity to work areas.  While all this may seem unnecessary compared to meeting your planting schedule or weeding, documentation can help limit your liability and ultimately lead to the formation of good habits maintaining your farm equipment, harvesting tools and washing station. 

The (very) Basics of Food Safety on the farm

The main areas of concern for food safety are water quality, manure and compost, human hygiene, wild and domestic animals in the fields and packing and storage facilities.  Irrigation and water used for washing produce should obviously not contain harmful pathogens.  To ensure levels are tolerable, water tests should be conducted.  The frequency with which a farm tests its water depends on the source – municipal, well, and surface sources all have different requirements under GAPs.  Furthermore, water-contact surfaces, such as dump tanks, wash tanks, and coolers should be cleaned frequently.   Knowing the quality of your water is the food safety equivalent to a soil test.  You wouldn’t farm without knowing the qualities of your soil and you shouldn’t sell produce without knowing the quality of the water used to irrigate and wash it.

Likewise, compost and manure should be managed carefully to ensure pathogens are not present at harmful levels.  In the case of raw manure, 120 days must elapse between application and harvest.  Other inputs, specifically pesticides, should always be used in accordance with their labels.  When a farmer purchases a pesticide, whether it is glyphosate, copper, or any other, the label represents a contract by which the farmer is now bound.  Following the safety precautions therein, will not only protect your health, but that of your customers.

Efforts should be made to keep domestic and wild animals out of produce fields as well.  Fences, streamers, noisemakers or other deterrents may be affective.  These precautions will not only help decrease animal-borne contaminants on fruits and vegetables, but also help limit pest damage from birds and mammals, protecting the quality of the produce.  Similarly, packing and storage facilities should be clean and free of pests such as rodents and birds.  It is also very important to consider the proximity of vegetable production areas to livestock either on the farm or on neighboring farms.

Harvest containers should be cleaned and sanitized after each use and made of food-grade plastic not wood.  Harvest knives should also be cleaned regularly.  Both practices will help avoid cross-contamination in the event that produce comes in contact with pathogens at some point.  Likewise, it is important to always remember to wash your hands after using the toilet, eating, smoking, etc.  And, finally, while it should go without saying, do not go to the bathroom in your fields.    

As for the cost-prohibitiveness of the infrastructure and equipment needed to operate in a food safe way, it seems to be a bit of a red herring – an easy target to place the blame and to continue business as usual.  The reality is that most of the changes needed to move a farm from food contamination risk-takers to one of risk aversion via good agricultural practices are easy and require little capital investment. Further more they have the potential to enhance produce quality and improve labor efficiency.  Even a food safe, GAP-modeled wash station is a relatively small financial investment.  

If you take nothing else away from this post, remember these few things: 1) always wash your hands, 2) clean your harvest containers and knives after each use, 3) keep avian and mammalian pests out of your fields and packing and storage facilities as well as possible, 4) follow the necessary precautions for manure and compost, and 5) test your water.

Some Useful Resources:

http://bfnmass.org/blog/introduction-food-safety-and-gaps-beginning-fruit-and-vegetable-farmers

Fresh produce contamination is a significant concern regardless of the produce grown, production system used, size of farm, or market outlet. Reducing contamination risks begins on the farm, and there are many practices growers can implement as a means to reduce risks. These are called Good Agricultural Practices (GAPs), and they relate to water and soil quality, especially as impacted by wildlife and livestock management; worker health and hygiene including proper produce handling during production, harvest, and post-harvest; and ensuring traceability of the product from the farm to the marketplace. Growers can incorporate these practices to reduce produce contamination. 

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