No one — from the shopper in the grocery, to the diner in the restaurant, to the farmer in field — wants anyone to get sick from anything they eat. This, however, is impossible.
The best that can be done is to blend science and the realities of agriculture to come up with workable procedures that maximize food safety. This is the thought process behind the long-discussed and recently implemented Food Safety Modernization Act (FSMA) from the U.S. Food and Drug Administration (FDA).
The biggest impact for farms in Ohio is for growers of fresh farm produce and fruit.
“We put together the produce safety classes originally because the industry was pushing for it. In 2011, the Food Safety Modernization Act was first signed into law. The rule became final in November of 2015. FDA wants to take a more preventive approach than reactive approach to produce safety outbreaks,” said Lindsey Hoover, food safety program coordinator for the Ohio State University College of Food Agriculture and Environmental Sciences Department of Horticulture and Crop Sciences. “FDA has done a good job at listening to growers. There were around 18,000 comments submitted and the FDA had to review those and look at the rules from the side of the growers too. The rules did change based on the comments about some of the standards. For example, the rule started out with a 270-day pre-harvest interval from the time of applying manure and incorporating it before harvest. The FDA worked with university specialists to identify a more practical but still scientifically sound approach to the pre-harvest interval time frame. The final rule pre-harvest interval is much shorter now than the proposed 270 days.”
The program was designed to address the highest risk areas of production.
“FDA identified five different routes of contamination on the farm: water; biological soil amendments; worker health, hygiene, and training; equipment, tools and buildings; and wildlife and domestic animals. We look at how to identify risks on the farm and methods farmers can use to reduce those risks — risk assessment and risk reduction. That is what we cover in our three-hour Good Agricultural Practices (GAPs) class,” Hoover said. “Extension educators can really help growers to address the details with the language in these rules. There will be daylong training sessions available in the future for growers to cover the rule to a greater extent than what we currently do. Relying on your Extension educator to help with the more challenging parts of the rule will be important. I have heard some growers say that this rule will put them out of business. That is inaccurate. There are ways to use the strengths within the specifics of your system based on science to grow produce without contaminating or adulterating the product.”
Hoover said the two biggest areas of concern with the regulations from farmers in the GAPs classes have been in water and soil amendments.
“Up until recently water hasn’t been as much of a hot topic as it is now. We are seeing how much water can vary in quality from farm to farm. There are so many ways water can impact the microbial contamination on produce based on how you irrigate, the water source and the process in the packing house,” Hoover said. “Until this point, there has not been much oversight with water testing. To come into compliance, farms will have to use a testing program if they are not using a municipal water source.”
The water-testing program first needs to establish a baseline for water quality and then monitor changes moving forward. In addition, there are important water quality standards based on the situation the water is being used on the farm and the source. Water sources include surface water, municipal water and well water. Drip irrigation, overhead irrigation, and other water used prior to harvest including frost protection and dust prevention uses are considered production water. Post harvest water has higher quality standards. E. coli is being regarded as the most reliable indicator of contamination with fecal matter and overall quality.
“Beginning a water testing program can be a challenge. It is not just one test every now and then. There can be a lot of variability and this is something that needs to be regular water testing,” Hoover said. “Farms need a quantified test from a water laboratory to indicate the numbers of generic E. coli in their water and that is something that is new to quite a few farmers. Chances are you are going to have to work with a private lab for this.”
To illustrate the risk levels for contamination on their farms, Emily Adams with Coshocton County Extension likes to use different comparisons of possible farm situations. For example, overhead irrigation using water from a cracked, improperly maintained well has a much higher contamination risk than drip irrigation using municipal water, Adams said. With soil amendments, the highest risk situation is the use of raw manure, followed by improperly composted materials, compost teas, properly composted materials and commercial fertilizer has the lowest risk. In terms of worker health, hygiene and training, a properly trained, healthy staff with easy access to adequate hand washing stations followed by sanitizer applications is the lowest risk scenario.
And, not only do farms have to address these things, all of the practices that are implemented must be properly documented as well, Adams said.
“Good record keeping is very important. If you didn’t write it down you didn’t do it,” she said. “This is not only for if something goes wrong, a lot of this is risk analysis. Up to date farm policies for standard operating procedures and good records are the lowest risk situation for your business.”
Of course, all of these changes will take time to properly implement, particularly for small farms. The rules have been implemented but there are grace periods based upon farm size.
Compliance dates for the FDA regulations are:
• Very small businesses, those with more than $25,000 but no more than $250,000 in average annual produce sales during the previous three year period: four years, Jan. 26, 2020.
• Small businesses, those with more than $250,000 but no more than $500,000 in average annual produce sales during the previous three year period: three years, Jan. 26, 2019
• All other farms: two years, Jan. 26, 2018.
The compliance dates for certain aspects of the water quality standards, and related testing and recordkeeping provisions, allow an additional two years beyond each of these compliance dates for the rest of the final rule.
“There are compliance dates now because it takes time to put some of these practices into place,” Adams said. “The very smallest farms with less than $25,000 in average annual produce sales in the previous three-year period are exempt. But just because you are exempt, it does not mean that you are not liable if anything happens. And the places you are selling to still may have say in what you are doing. Retailers and produce auctions can demand certain practices from growers to reduce risk, even if according to FSMA an operation may be considered exempt.”
Ultimately, there will inevitably be challenges for farms implementing these practices, but Adams points out that it only takes two people getting sick after eating the same contaminated food or drink to declare an outbreak. The public has demanded fewer outbreaks and increased food safety and the government responded.
“The Food Safety Modernization Act is the most sweeping reforms for food safety in the modern U.S., affecting every part of the food system from processed foods to feed mills,” Adams said. “Our legislators tried very hard to write our laws in a good way but sometimes they don’t know everything. People were able to comment on the rules in 2013 and 2014 and in many cases the FDA did listen to the comments to make the rules practical. Not everyone is happy about all of the rules, but now at least we know what the rules are moving forward.”
For more highlights, resources, and a summary of the rule, Hoover suggests visiting the following websites: producesafety.osu.edu; gaps.cornell.edu; extension.psu.edu/food/safety; and safety.cfans.umn.edu/fsp4u.