PRODUCE SAFETY GUIDANCE: PROTOCOLS

Last Updated April 3, 2020

Identifying hazards from harvest to packaging.


As of this writing, Hodges Family Farm practices a direct-to-market sales strategy with produce production. This model means that we cannot insulate ourselves from hazards along the producer-consumer pathway, the way a dedicated or singular purpose facility could. However, this does present us with an opportunity to mitigate potential hazards every step of the way – from seed to sales – and offer our customers a level of assurance in safety and quality that can set us apart from other firms. The opening portion of this document should serve to set anchoring points and to prime the reader’s mind for efficient organization and internalization of the subsequent protocols. Safety begins and ends with the identification, isolation, and resolution of any potential hazards to the farm team or to the consumer. 

To begin, we will define some commonly used terms:

Food Safety Modernization Act (FSMA):
A federal act, signed into law in June of 2011, governing the safe production, harvest, and handling of food before it reaches the consumer.

Food and Drug Administration (FDA):
The regulating body of FSMA

Produce Safety Rule:
Regulation put in place by the FDA setting food safety standards for farms.

Covered activity:
 Growing, harvesting, packing, or holding “covered produce” on a farm.

Operation:
 For the purpose of this guidance, this term will refer to any task or set of tasks that must be performed to ensure preparation for and completion growing, harvesting, packing, or holding “covered produce” on a farm.

Order:
in this guidance, “order” will most often refer to a refer a request from a customer, including the Hodges Farm NC farm stand, for a farm product. To a lesser degree, and to to be distinguished by context, “order” will refer to a particular sequence, as in procedural or operational in nature.

End consumer:
 The person or entity that will be consuming the produce.

Produce:
 Any fruit or vegetable, and includes mushrooms, sprouts (irrespective of seed source), peanuts, tree nuts, and herbs.

Covered produce: A
ny produce that is usually consumed raw, i.e. there is no “kill-step” before it is eaten. Examples include, but are not limited to salad greens, radishes, carrots, apples, strawberries, nuts, garden beans, herbs, etc.

Non-covered produce:
 Produce that usually requires a “kill-step” before being consumed and is rarely consumed raw. Examples would include but are not limited to, pumpkins and other winter squash, grains, lima beans, sweet corn, asparagus, okra, eggplant, potatoes, garden beets, etc.

Clean:
 This refers to food or food contact surfaces that have been washed, sanitized, and rinsed with potable water so that they are visually free of debris, food or chemical residues, soil or dust.

Disinfection:
 An approved method of reducing the microbial load from the surface of fruits and vegetables.

Sanitation: A
pproved method of reducing or eliminating the microbial load from food-contact surfaces. A surface cannot be sanitized unless it is first cleaned.

Food-contact surface:
 Refers to any and all surfaces that will come into contact with fresh fruits and vegetables. Examples include field maintenance and harvesting tools and equipment, wash tables, brushes, and cleaning supplies, as well as packing supplies.

Hazard:
 Any potential source of harm. These may be chemical, biological, or physical in nature.

Risk:
The combination of the probability of occurrence of harm and the severity of that harm.

Normal operating conditions:
 Those conditions which pose no unusual risk.

Contaminant:
 Any substance that may compromise the safety or quality of produce or food.

Pathogen:
 Any virus or living organism capable of causing disease.

Drift:
 Will usually be used, within the context of this document, to refer to chemicals or other particulates that may act as contaminants carried by the wind into an otherwise insulated operational area.

Fecal contamination:
 Means poop. Pretty much sums up a goodly portion of FSMA. NO POOP ON PRODUCE.

IN THE FIELDS:


-Ensure that conditions in the fields and raised beds meet standards of “normal operating conditions”, i.e.:

-Fields and beds are free from trash, food containers, articles of clothing or other “left” items that could contaminate produce or endanger team members.

-Fields and beds within 90 days of harvest should be clear of livestock and other animals that may contribute to fecal contamination that would not have adequate time to break down biologically beyond a reasonable risk to covered produce.

-Ensure that harvesting tools and equipment are recovered from fields/beds and properly cared for to minimize subsequent contamination of covered produce.

-Observation is key. Resolve or report and potential risks that are identified or suspected in production fields and beds.

PERSONAL HYGIENE:


-The field team should be generally clean and should take special care of any potential food-contact surfaces about their person, even to the point of sanitation if necessary. Examples might include hands, boots, sleeves or other articles of clothing that might come into contact with produce, knives, cell-phones, etc.

-Harvesting tools and equipment as well as field maintenance equipment:

-The Produce Safety Rule specifically excludes fork-lifts, tractors, pallets and the like from the “food-contact surface” portion of the guidance. However, we have observed potential risks associated with; leaking hydraulics and other vehicle fluids, manure and other contaminants on tires, buckets, and forks, as well as a potential contamination point when “resting upon” with one’s person or harvest tools.

-The Produce Safety Rule also neglects field maintenance equipment, which may include hand tools such as rakes and weeding implements. We have observed, and should, therefore, be wary of, potential risks including, but not limited to; storage of tools under roosts (fecal contamination hazard), stored near chemical contaminants, or used for tasks that may inherently cross-contaminate field conditions such as turning raw compost materials and stall cleaning.

-Harvest tools (knives, shears, clippers, pruners, etc.), as well as harvest containers, should be both cleaned and sanitized before and between harvest operations. The separation of harvest lots and operations with procedure and recalibration can greatly reduce the risk of contamination.

-Personal gear (gloves, hats, boots, pants, shirts, etc.) should be clean, i.e. free of debris or residue that may pose a contamination risk. An often overlooked example might include grass clippings from grounds maintenance falling onto salad greens.

SPECIAL CONSIDERATIONS:


-Cell phones and other personal items. It is to follow all of the protocols just to have them negated by an action such as handling a contaminated item without revisiting sanitation steps. One of the most common is the use of cell phones. Cell phones are often overlooked when sanitizing equipment, keeping up with personal hygiene, and reducing risk during field and packing operations. Wallets, purses, notebooks, pens, cassette-tape players and other personal items would fall into this category as well.

-When preparing for field maintenance, harvesting or packing operations, steps should be taken to sanitize or remove personal items for the duration of and between operations. If you or another team member accidentally contaminate hands, tools or surfaces with personal items, then sanitation steps should be revisited before returning to operations.

What happens if covered produce is compromised?


-Without question, the compromised produce is removed from the operation altogether.

- Depending on the type and severity of the contamination, produce may be composted or fed to approved animals. This consideration would be made to reduce unnecessary waste and should be handled on a case by case basis.

HARVEST, WASHING & PACKING:


-One-piece flow:

-As a procedural mechanism of both efficiency and accountability, the bulk of orders will be processed, from harvest to packing, by individual team members, or small crews. This methodology helps to isolate breaks in the general procedure, while at the same time mitigating against order mistakes and general order-fulfillment quality. 

-The procedure will generally take the following form: an order is claimed by an individual or team as their task, harvest, washing, and packing are done by that individual and a digital, written, or alpha-numeric signature is applied to that order to encourage both a sense of accountability and pride concerning fulfillment.

-Alterations to this procedure will be considered on a case-by-case basis but must be in compliance with all federal, state, and city regulations, as well as overall Hodges Family Farm policies and standards.

HARVEST:


-All harvest tools (knives, shears, etc.) should be cleaned (including of rust) and sanitized before every operation, or reasonable set of operations. I.e., knives and shears used in the harvesting step of order fulfillment should be placed in the “to be cleaned and sanitized” container provided before moving to the washing step and those tools should be cleaned and sanitized before moving on to the next order.

-Harvesting should be completed in a timely manner to ensure crop quality, as well as the fulfillment of customer obligations. Some crops, such as lettuce, should be harvested in the early morning to prevent wilting before or shortly after reaching the customer. All crops should be carefully considered for their individual qualities and harvested accordingly. At a bare minimum, all crops must be harvested pursuant to the Federal Code of Regulations (CFR) Title 21, part 112 (copies readily available for all team members). The second time restraint involved with harvesting is that of obligation to customers, which should be plainly described in every order summary.

-During harvesting operations, especially during periods of increased risk such as “flu season”, should do their part in preventing the spread of disease and wear food preparation or other sanitary gloves, face masks or shields and practice general disease prevention techniques such as turning away from produce to sneeze or cough. 

-If a transmissible illness is confirmed or suspected, that team member will not participate in any operations concerning the harvest, washing, or packing of covered produce. There will not be exceptions to this rule.

-Again, personal hygiene and contamination discipline should be a priority for all team members participating in harvesting operations.

WASHING:


-Water:

-Any water used in all food production operations, including washing, should be potable and meet all local and federal standards, especially pursuant to CFR Title 21, part 112.

-Water is one of the most common mediums of transmission for bacterial, fungal and viral pathogens.

-Observation is key. Even if all tests have been satisfied and a water source has been cleared for production use, visual, olfactory, or other sensory cues should not be ignored. If the color, smell, taste or quality of water seems to be compromised, in any way, this should be reported immediately and all food-related operations should be halted from that source.

TOOLS & SUPPLIES:


-The FDA and FSMA allow for a range of chemical sanitizers and cleaners to be used to produce washing operations. However, Hodges Family Farm is committed to ensuring top quality and safe produce and production methods, meeting or exceeding United States Department of Agriculture Certified Organic standards as a minimum guideline. A “minimum guideline” should be emphasized here as even Certified Orangic chemicals can be harmful if consumed, sometimes as much or more-so than conventional equivalents. Although we do not usually use any chemicals, Organic or conventional, on or around our growing fields and beds, a certain level of risk remains from natural contaminants (fecal, pollen, dust, dander, etc.) as well as drift from neighboring operations. For this reason, produce will, at a minimum, be considered “clean” before packing and packaging materials and literature will encourage consumers to “wash before use”. Kill-steps, such as water heated to a temperature of 165 degrees, or other approved chemical or biological controls will be used when reasonable and prudent.

-All tables, sinks, brushes, hoses, and similar potential or eminent food-contact surfaces must be cleaned and sanitized before, between, and after all operations. As emphasized in other sections, one-piece flow and small batch/single order protocols can help to mitigate the potential risk of contamination. At a minimum, an interval should be established, during which equipment, tools, and supplies will be inspected, cleaned and sanitized before resuming operations.

PRODUCE:


-All covered produce will be clean and proper instructions provided before reaching the end consumer.

-All special considerations will be taken into account for each fruit or vegetable to ensure safety and quality. Examples would include removal or mitigation of “field heat” – the latent heat remaining in a vegetable with a permeable or semi-permeable outer membrane – so that temperature differentials between washing conditions and that of the produce do not result in contaminations being pulled into the crop itself. Tomatoes are a prime example. Mitigation of this effect may be achieved through placement in a cold environment and allowing sufficient time for temperature equilibrium, or by using water/wash solution of a temperature greater than the field heat reading of the produce.

-Covered produce should be clean and dry before moving on to the next operation.

PACKING:


-Once reasonable precautions have been taken to ensure safe harvest and cleaning of covered produce, team members may move forward to the packing process.

-The produce being packed should be inspected for quantity, variety, and timeliness congruent to the customer’s order, as well as for the quality standards for Hodges Family Farm.

-Packaging materials should be clean and consistent with website and order form descriptions.

-Packaging should, at a minimum, clearly display the following information:

-Applicable washing/preparation instructions for the end consumer

-Order details including customer name, packaging accountability identifiers (team member name, farm details, batch numbers, etc.), applicable dates (packing and pickup).

-Once packaging is complete, each order should be held in an appropriate area to await pickup. An “appropriate area” should include considerations for potential contamination risk, climate control, ease of accessibility, and any applicable regulations.

TRAINING:


-A “team member” should be considered any person involved with any level of produce operations.

-Every team member should be familiar, not only with this document but with FSMA promulgations, FDA and USDA regulations, applicable Federal Code of Regulations (such as title 21, part 112), and have been physically introduced to each step of an operation by a more experienced team member.

-Without a sufficient level of training, it is difficult or impossible for Hodges Family Farm to ensure customers of the quality and safety of farm products. Therefore, it is paramount that each team member take their training seriously and apply those principles to every operation that is involved with the farm business.