Last week I was invited to speak at the biennial Missouri Blueberry School about the implications of the Food Safety Modernization Act (FSMA) for pick-your-own farms. This post summarizes that presentation.
To start, growers need to know if their farm is covered by the FSMA Produce Safety Rule. The U.S. Food and Drug Administration has a handy flowchart of six questions available at http://www.fda.gov/downloads/Food/GuidanceRegulation/FSMA/UCM472499.pdf to help growers determine if their farm is covered, excluded, exempt, or qualified exempt (where many pick-your-own farms will likely fall). I have created a video available at https://www.youtube.com/watch?v=Px_Uk3AOhUE to walk growers through this document.
A farm is qualified exempt if 1) they have between $25K and $500K in annual food sales (meat, milk, eggs, value-added products, etc. in addition to produce; that’s currently $539,982 with inflation – see https://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm554484.htm for details) AND 2) a majority of the food is sold directly to qualified end-users (like the consumer who purchases berries at a farmers market or on a pick-your-own farm; see the flowchart linked above or definition of Qualified End-User in 21 CFR § 112.3 for details). If a farm is qualified exempt, they still have a few modified requirements under the Rule (detailed in 21 CFR § 112.6) including 1) prominently and conspicuously displaying their farm name and address on food packaging labels, and/or on a poster, sign, or placard at the point of purchase and/or on documents accompanying the produce, and 2) keeping sales records to demonstrate that their farm satisfies the criteria for the qualified exemption, including a record of their annual review of these records (21 CFR § 112.7).
Understanding that many pick-your-own farms will be qualified exempt, I focused the rest of my presentation on Good Agricultural Practices (GAPs) that all produce farms should consider following, and highlighted those relevant FSMA Produce Safety Rule requirements as presented in the Produce Safety Alliance (PSA) Grower Training course (for more information or to find a PSA Grower Training near you visit https://producesafetyalliance.cornell.edu/training/grower-training-courses/).
Next, I discussed the following slide from the PSA Grower Training. Though this slide addresses routes of contamination from employees, the same routes of contamination apply to pick-your-own customers and the farm’s visitor policy should address them.
What is a visitor? Examples of visitors include pick-your-own customers, agricultural tour groups, or school groups. § 112.3(c) defines a visitor as any person (other than personnel) who enters the farm with permission. FDA’s Draft Guidance for Industry (page 54) elaborates to say that “Visitors could include consumers, delivery personnel, vendors, or others who are touring, conducting business, or observing your farm.”
What does the Produce Safety Rule require growers to do about visitors? § 112.33(a) requires that growers must make visitors aware of policies and procedures to protect covered produce and food contact surfaces from contamination by people and take all steps reasonably necessary to ensure that visitors comply with such policies and procedures and (b) make toilet and handwashing facilities accessible to visitors. Those two things are musts, meaning if your farm is covered by the Produce Safety Rule, you have to do them.
The handwashing station doesn’t have to be indoors or even have warm water, just soap, running water, and single-use towels.
Key items to review with volunteers and visitors are: 1) what parts of the farm and packing areas they can enter, 2) that they should not visit the farm if they are sick or have symptoms of illness, 3) why, when, where, and how to wash their hands, and 4) to keep their pets at home (this is not just a food safety risk, but a liability issue as well). These are GAPs that should be followed by all produce farms, but a grower may decide to not institute them on their farm and still be in compliance with the Produce Safety Rule.
I proposed the following ten rules for growers to consider including in their farm’s visitor policy.
1. Do NOT Visit the Farm When Ill
112.22(a) requires that all personnel who handle covered produce during covered activities or supervise the conduct of such activities must receive training that includes: 2) The importance of health and personal hygiene for all personnel and visitors, including recognizing symptoms of a health condition that is reasonably likely to result in contamination of covered produce or food contact surfaces with microorganisms of public health significance.
So the first rule I would suggest is to not visit the farm when ill. This should be understood by most adults, but sometimes folks need a reminder. We often see signs posted at hospitals during flu season. You could easily make something similar for foodborne illnesses to post at the farm.
2. Children Must Be Accompanied By an Adult
There are several reasons for this: 1) kids may randomly touch and contaminate produce that gets left on the plant or thrown on the ground, 2) we don’t want anyone eating produce that has dropped to the ground and unsupervised children may be tempted to taste test easy-to-reach fruit, and 3) it’s a safety issue if they disturb a snake, trip on drip irrigation, etc.
This is my son in a peach orchard. Did he get that fruit off the tree or off the ground?
3. Wash Your Hands before Picking
We’re not worried about the common cold here, we’re worried about foodborne illnesses caused by bacteria like Salmonella and E. coli, and viruses like Norovirus and Hepatitis A, commonly associated with nausea, vomiting, and diarrhea.
It would be good to post the steps of proper handwashing in the bathrooms, by the sinks. Here are the steps taught in the PSA Grower Training course.
You can often get colorful signs from your local health department to post on the farm. This one is available from Missouri Department of Health and Senior Services.
4. Use the Toilets Provided
I know, this one may seem like common sense, but it’s a good idea to remind customers that they should use the provided bathroom facilities rather than “go” in the field. Signage could say things like “please don’t water our plants” and “please don’t change diapers in the field.”
5. No Eating, Drinking, Chewing Gum, or Smoking in the Field
Body fluids can contaminate produce, even saliva, so visitors should be discouraged from eating, drinking, chewing gum, or smoking in the field. It’s up to you to decide how restrictive to be with visitors on your farm. You may want to set up a picnic area away from the field and encourage visitors to use it.
6. Do NOT Litter
This is another one that seems like common sense, but folks may need a reminder. A “no litter” policy helps prevent contamination of produce and also helps with pest control (by not serving as an attractant). Often, if visitors are aware of the “why” behind a farm’s policy, they are more likely to comply.
7. No Pets Allowed
All pets, not just dogs, can pose a food safety risk. If you have signage that says “no dogs,” I guarantee that someone will try to challenge it by showing up with other pets like raccoons or pot-bellied pigs.
If you have a farm dog think about whether or not the risk it poses is worth letting it run in the field. It may play an important role, such as chasing deer away in the evenings, but if it doesn’t have a job, it shouldn’t be in the field.
Guide or service dogs may be allowed, but you’ll want to be sure their handlers are aware of the potential for dogs to carry contamination and that they will be responsible for minimizing the likelihood of their dog becoming contaminated before arriving at the farm.
Many pick-your-own farms also have petting zoos. This is my youngest daughter who loves animals. If given the choice, she would hang out with the animals and then pick strawberries.
She picked first, and then touched the animals on this farm. Something else to consider adding to your visitor policy. You may also want to locate a handwashing station outside the animal enclosure with signage to remind visitors to wash their hands.
8. Do NOT Drink Water from Hoses or Sprinklers
It is likely not potable and most hoses are not food grade material. Signage could direct visitors to a water fountain or water bottles available for purchase on-site. Also, if the farm has any open water sources like ponds, the grower should consider signage telling visitors to keep out.
9. Use Provided Picking Containers and Liners
These could be single use containers like my daughter had of strawberries, containers that are cleaned and sanitized between uses, or containers with single-use liners like grocery bags (growers should try to find food grade plastic liners).
The main thing is that we don’t want visitors bringing their questionable containers to the farm. We don’t know that they have our same high cleaning and sanitizing standards.
10. Only Harvest from Designated Areas
You may want to flag or rope off areas not yet ripe or that have received recent pesticide applications. Again, this is as much for visitor safety as to prevent contamination of the produce.
Additional safety tips to consider adding to the farm’s visitor policy:
- No running as we have uneven ground
- Wear close-toed shoes
- Remove jewelry
- You may see insects and wild animals on the farm that can sting or bite – please respect their space
- A first aid kit and phone are available at the cash register, shop, entrance gate, etc. in case of emergency
From the GAPs Worker Health, Hygiene, and Training Decision Tree: A first aid kit should be stocked and available to all workers and visitors. Workers who have cuts or other injuries could contaminate fresh produce with bodily fluids such as blood. All workers need to be trained to respond to injuries including knowing the location of first aid supplies, how to wash and bandage minor cuts, and to wear gloves or other covering to provide a secondary barrier between the injury and produce they handle. All contaminated produce must be thrown away and the injury should be written on the injury reporting log and kept on file.
As a reminder, the above suggested policies are GAPs and based on my own experience on farms, not necessarily required for compliance with the FSMA Produce Safety Rule. If you operate a farm covered under the FSMA Produce Safety Rule, the two requirements are 1) that you make visitors aware of policies and procedures to protect covered produce and food contact surfaces from contamination by people (it’s up to you to determine your farm’s policies and procedures) and take all steps reasonably necessary to ensure that visitors comply with such policies and procedures and 2) that you make toilet and handwashing facilities accessible to visitors (21 CFR § 112.33).
Making Visitors Aware of Your Policies
Policies can be reviewed with visitors through the use of posters, handouts, short policy summaries, or verbally when they enter the farm. FDA’s draft guidance (pages 55-56) provides examples of ways that farms can make visitors aware of policies and procedures to protect covered produce and food contact surfaces including 1) supervisor explains to visitors and 2) signage where visitors will be on the farm.
The National GAPs Program publication Food Safety Begins on the Farm (available for download at https://gaps.cornell.edu/educational-materials/) contains chapters on U-Pick Operations and Petting Zoos to help growers make short-term improvements on the farm while making long-term plans to move toward best practices.
The PSA factsheet Records Required by the FSMA Produce Safety Rule describes all the records required for compliance and provides templates that growers can download and alter to meet their farm’s needs (including a Qualified Exemption Review Template). While covered farms are required to make visitors aware of their food safety policies, sign-in sheets are not a required record.