It’s time to prepare for implementation of the Produce Safety Rule.
By Travis Chapin, Michelle Danyluk and Keith Schneider
In preparation for implementing the Food Safety Modernization Act’s Produce Safety Rule (PSR), growers, harvesters and packers of fresh citrus are required to attend standardized food-safety training, such as the Produce Safety Alliance (PSA) grower training course, which outlines the minimum requirements of the PSR. The PSR requirements are almost exclusively devoted to preventing microbial contamination and are specifically related to:
- Worker training, health and hygiene
- Biological soil amendments of animal origin
- Wildlife and domesticated animals
- Agricultural water quality
Due to the diversity of the tens of thousands of farms that will need to implement PSR requirements, the rule provides significant flexibility in how farmers may approach the regulatory requirements to minimize food-safety risks in their operations.
The Food and Drug Administration (FDA) and the state departments of agriculture tasked with implementing the PSR continue to reiterate that their initial approach will be educational. State and federal regulators will work with growers, harvesters and packers to understand and meet the regulatory requirements as they begin scheduling and conducting PSR inspections starting in the spring of 2019.
The FDA released draft guidance in October 2018 on best practices to reduce risk and meet PSR requirements. In addition to implementing practices to meet the minimum regulatory requirements outlined in the PSA grower training course, looking at a few additional considerations that go beyond the minimum requirements in some cases, and paying particular attention to other key requirements, may help prepare growers for a more streamlined and efficient inspection. These include:
A written visitor policy is a convenient way to make visitors, including inspectors, aware of food-safety policies. Alert visitors to your specific policies before a planned visit to your operation.
For example, you may have a designated area for visitors to park and check in or have bio-security policies, like those in place for citrus canker. The visitor policy should also make visitors aware of the farm’s basic food-safety policies, which should include prohibiting visitors who have any signs or symptoms of foodborne illness, and preventing visitors from eating, chewing gum or using tobacco in produce or packing areas.
Visitors need access to restrooms and handwashing facilities and should be made aware of the location of those facilities. Your visitor policy should not prohibit regulatory personnel from taking pictures or collecting samples.
Although a farm diagram is not one of the required records under the PSR, it can be a useful tool to visualize potential sources and routes of contamination in relation to the location, layout and flow of your operation. During the initial inspection, an inspector will likely need to create a map or verify a map of the operation’s layout, including any structures, water sources and water distribution systems in order to assess the potential for different risks.
Although a diagram of a citrus grove block will be fairly basic in many cases, documenting the location and layout of your operation is a prudent step to show your commitment to food safety. The diagram could also include housing, septic systems, animal grazing or housing, chemical storage, locations of manure storage or composting, trash collection, adjacent land use and slope of land, including runoff potential.
An evaluation of the farm layout may also consider operational flow, including traffic patterns for waste/cull removal and employee or equipment flow between different operations (e.g., between preharvest and postharvest operations). For packinghouses, a more detailed flow diagram should be made to show operational flow within the packinghouse in addition to a diagram showing the location and layout of the property.
An inspector will need to know some details about the corporate or organizational structure of the operation in order to define the scope of the inspection. For example, many farms may appear to be a single entity, but family members, contractors and cooperatives may separately own or manage certain operations. These operations may require separate inspections if all parties cannot be present or inspected at one time.
Designate who is in charge of various operations. For example, you may indicate that you contract with grove caretakers for hedging, spraying, maintaining irrigation, etc. You may also indicate you contract with harvest companies to harvest fruit and transport fruit to a packinghouse, or that you sell fruit on the tree to buyers who make their own arrangements for harvesting.
Operations with multiple employees will want to identify the person or persons responsible for recognizing, detecting and correcting food-safety issues, and for developing any food-safety plans and procedures. Tasks that should have designated responsibility include monitoring groves for animal intrusion prior to harvest, conducting an annual inspection of the water distribution system, inspecting harvest containers for contamination prior to use and maintaining handwashing and toilet facilities.
TRAINING, HEALTH AND HYGIENE
All employees should be familiar with procedures to report illnesses and injuries. Records of worker training (for food safety) will be reviewed and should include the topics covered. Training materials may be reviewed or updated if employees don’t seem to be following general food-safety practices. Employee practices will be observed when employees are harvesting or packing, entering and exiting the grove or packinghouse, and using restroom/handwashing facilities.
Supervisors and other employees tasked with food-safety responsibilities should receive additional training and be able to describe basic food-safety practices and policies specific to your operation. For example, a supervisor of a harvest crew should receive additional training on how to carry out corrective actions in the event that contamination is identified in a harvest bin. In addition, a supervisor should know how to evaluate the potential for fruit contamination from splashes or leaks due to placement, servicing or other movement of portable toilet facilities. Some operations may choose to send multiple supervisors to a PSA grower training as a way to demonstrate that supervisors have received additional training.
SOIL AMENDMENTS OF ANIMAL ORIGIN
“Biological soil amendments of animal origin” is the phrase coined by FDA to describe soil amendments made from any type of animal by-product, such as manure, fish emulsions, bone meal, feather meal, blood meal or an agricultural tea made with any of these components. The use of these types of soil amendments is not prohibited.
Users should consider whether the soil amendments are defined as treated or untreated under the PSR and evaluate the application method of the amendments for the potential to contact the harvestable portion of the crop at any point during or after application. Although not required under the PSR, it may be helpful to document the date and method of soil amendment application. Class A or Class AA biosolids use is not restricted under the PSR.
AND DOMESTICATED ANIMALS
Ensure employees are trained and aware of policies related to harvest and animal intrusion. Contamination should be identified and removed. “No harvest buffer zones” may be used if an extraordinary event of animal intrusion occurs and a significant number of fruit on a tree are visibly contaminated with animal feces.
Although FDA has proposed to extend the compliance dates for agricultural water requirements, evaluating the potential for agricultural water to become contaminated will still be addressed during an inspection.
If using ground water, consider the construction and condition of your wells, such as being properly capped, elevated and sealed. Also consider the potential for backflow into the well and cross connections. Pay special attention to hoses or faucets connected to the well with no backflow prevention in place. If you’re not familiar with your well, have your service technician walk you through the components, taking special note of the location and type of backflow prevention devices. You want to confidently be able to describe your well and how it works.
If using surface water, examine the surrounding areas and/or upstream for potential sources of runoff contamination. Pay attention to the source of water used for crop sprays and premixed liquid fertilizers.
CLEANING, SANITATION AND POSTHARVEST PRACTICES
For harvest crews and packinghouses, it is important to evaluate your ability to document “clean breaks,” or the potential for cross-contamination between different lots of fruit. Although establishing a traceability program is not required under the PSR, evaluate your ability to track your product to the specific buyer. When evaluating a packing line or cold storage, pay special attention to the potential for dripping water or condensate onto fruit or onto fruit contact surfaces.
Travis Chapin is a state specialized Extension agent and Michelle Danyluk is an associate professor, both at the University of Florida Institute of Food and Agricultural Sciences Citrus Research and Education Center in Lake Alfred. Keith Schneider is a professor at the University of Florida in Gainesville.
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