Food Safety Regulation Update and Washing Systems for ... · Food Safety Modernization Act. ......

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Food Safety Regulation Update and Washing Systems for Small

Operations

Scott MonroeFood Safety Educator

Purdue ExtensionSouthwest Purdue Ag Center

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CDC estimates that each year:• 48 million Americans sick from

foodborne illness• 1 in 6 people• 128,000 hospitalizations• 3,000 deaths

A significant proportion of foodborne illnesses have been

attributed to fresh produce

Source: http://www.cdc.gov/foodborneburden/

http://ww

w.cdc.gov/foodborneburden/attribution-im

age.html#foodborne-illnesses

Produce Food Safety

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Potatoes Spinach Lettuce

Winter Squash Sweet Corn Cucumbers

Zucchini Beets Radish

Eggplant Kale Microgreens

Tomatoes

Apples

Berries

Garlic

Herbs

Onions

Cooked ?Both? Raw

Microbial ‘kill step’ Wash step

Cooked vs. Raw Consumption

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ALL growers who introduce produce into the public food supply should be concerned

about food safety!

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Industry

Farmers’ Market Rules

County Health Departments

Indiana State Health Department (ISDH)

Federal Government (FDA)

FSMA

Regulation of On-Farm Food Safety

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IndustryStandards “enforced” by buyer requirements

Standards generally take the form of 3rd party GAPs certification by an auditor using an accepted audit scheme or protocol

Audits involve inspecting the farm and documentation for adherence to the farm’s written food safety plan

GAPs certifications are industry driven and are not part of FDA regulations

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Good Agricultural PracticesCertification Process

Farm Self Assessment

Written Farm Food Safety Plan

Third Party Audit

Certification

Plan Implementation

GAPs Awareness and Training

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Your GAPs or Mine?

Various GAPs guidelines are in use – similar but not identical

•USDA GAPs/GHPs•Harmonized GAPs

•Global Food Safety Initiative•GlobalGAP•PrimusGFS

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January 2011 - Signed into LawNovember 2015 - Final Produce

Rule PublishedJanuary 2016 – New Rule

Became Law

FSMA = Food Safety Modernization Act

https://en.wikipedia.org/wiki/FDA_Food_Safety_Modernization_Act

Food Safety Modernization Act

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Seven FSMA Rules Written by FDA

Preventive Controls for Human Foods

Preventive Controls for Food for Animals

Produce Safety

Foreign Supplier Verification Programs (FSVP) for Importers of Food for Humans and Animals

Accreditation of Third-party Auditors/Certification Bodies to Conduct Food Safety Audits and to Issue Certifications

Sanitary Transportation of Human and Animal Food

Focused Mitigation Strategies to Protect Food Against Intentional Adulteration

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Farm – An entity that grows, harvests, packs, or holds produce.

Mixed Type Facility – An entity that functions as both a farm AND a processing facility.

Exempt – Not held to (or covered) under the rule.

Qualified Exemption – Exempt only if certain criteria (qualifiers) are met to maintain the exemption.

Terminology

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FSMA Produce Rule –

Am I Covered???

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Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Am I a FARM or a FACILITY???

https://slowhappyliving.files.wordpress.com/2014/11/img_1784.jpg

Photo: J. Obermeyer

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Farms or farm mixed-type facilities with an average annual monetary value of produce

sales of $25,000 or less are exempt from the Produce Rule

Is my farm part of the rule?

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Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

AsparagusBeans

BlackGreat NorthernKidneyLimaNavyPinto

BeetsGarden (roots and tops)Sugar

CashewsSour CherriesChickpeasCocoa Beans

Coffee BeansCollardsSweet CornCranberriesDatesDill

SeedsWeed

EggplantsFigsHorseradishHazelnutsLentilsOkraPeanuts

PecansPeppermintPotatoesPumpkinsWinter SquashSweet PotatoesWater Chestnuts

Commodities Rarely Consumed Raw

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Food Grains

Barley BuckwheatAmaranth OilseedsCorn Cotton

Dent RapeFlint Sorghum

Quinoa OatsRice FlaxRye SunflowerSoy Wheat

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Processing crops receive a qualifiedexemption if:

A. They receive commercial processing that adequately reduces the presence of microorganisms of public health significance.

B. Accompanying documents disclose that the food is “not processed adequately to reduce the presence of microorganisms of public health significance”.

C. Written assurances from the buyer are obtained annually.

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Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

If I’m exempt,does this really matter???

FSMA Produce Rule

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Remember!!!While individuals may be exempt

from regulations,

One is NEVER exempt from liability!

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Who Sales Time to ComplyFarms >$500,000 food sales/year 2 yearsSmall Farms $500,000 - $250,000 food sales/year 3 yearsVery Small Farms $250,000 - $25,000 food sales/year 4 years

In addition to compliance times, all will receive an additional two years to comply with water testing requirements.

Compliance Timeline

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1. Is my farm covered by the produce rule?

2. Is this particular crop covered by the produce rule?

3. Will I be applying water, as irrigation or crop sprays, to the harvestable part of the crop?

Water Questions to Ask

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Surface water applied directly to harvestable part during growing20 samples within two years to establish a baseline5 samples per year thereafter

Underground water applied directly to harvestable part during growing4 samples in the first year1 sample thereafter

Sources: http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm415226.htm#water and PSA Curriculum Resources

Produce RuleAgricultural Water Standards

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Produce RuleAgricultural Water Standards

(con’t)

For all water sources:Geometric Mean ≤126 CFU generic E. coli /100 mlStatistical Threshold Value ≤410 CFU generic E. coli / 100 ml

Sources: http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm415226.htm#water and PSA Curriculum Resources

Produce Rule Training Requirement

One person from each covered farm must complete training in the APPROVED GAPs curriculum.

The approved curriculum is the Produce Safety Alliance Curriculum

The training and registrations will be managed by the Association of Food and Drug Officials (AFDO)

Purdue Extension offering trainings in 2017

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Indiana State Department of Health (ISDH)Farm Produce Safety Initiative

All wholesalers of fresh ready-to-eat produce must register with ISDH

New form created specifically for farms

Authorized under Indiana Code 16-42-1-6 of the Food, Drug & Cosmetic Act

No fee for registration

Fact sheet about initiative may be found at:http://www.in.gov/isdh/files/Produce_Grower_Registration_Fact_Sheet(1).pdf

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Washing systems for produce

A. Deering

A. Deering

http://rvpadmin.cce.cornell.edu/uploads/doc_286.pdf

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Growers are not legally required to wash produce

Washing produce introduces several considerations that must be addressed

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Water Considerations

Postharvest water must be potable

No detectable generic E. coli in 100 ml of water

Surface water may not be used for washing

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• Periodic testing of water sources will reveal the presence or absence of indicator organisms

• Presence of indicator organisms (generic E. coli) means that the water source might be contaminated with human pathogens

Water Testing

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If postharvest water:1. Doesn’t meet microbial

standards for drinking water or2. Becomes contaminated

during postharvest useThen:Treat with a sanitizer before use or reuse to meet the “No E. coli” standard.

Sanitizers for Postharvest Water

ChlorinePeroxyacetic acid

OzoneUV-C Illumination

Source: Suslow, T. 1997. Postharvest chlorination. Pub. 8003, UCDANR. anrcatalog.ucdavis.edu/pdf/8003.pdf

Postharvest Water Quality

A list of sanitizers registered in Indiana may be found at: https://ag.purdue.edu/hla/foodsafety/Pages/WashWaterSanitizers.aspx

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What they doKill microbes in waterKill microbes on surfaces

Role in fresh produce food safetyPrevent contamination of produce

• From microbes in water• From microbes on surfaces

Reduce number of microbes on produce surface

Sanitizers

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What they don’t doMake dirty water cleanKill all microbes equally effectivelyPenetrate films of dirt and slimes, “biofilms”

• (some do, some don’t)

Sterilize the product or surface

Sanitizers

Photo: W. Kline

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The label is the law–Uses–Methods–Rates–Precautions–Disposal

Sanitizers are Regulated by EPA

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1. Washing radishes in a sink with running water from a faucet. Water is potable.

2. Wash line sprays water on peppers as they go by on a conveyor; water is not reused. Water is potable.

3. Lettuce is dunked in tubs of cold water; 1st tub removes most of dirt, 2nd tub removes the rest. Water is potable at start and reused for several batches.

Do I Need a Sanitizer?

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Washer Considerations

Material (non-porous and easily cleaned)Non-porousEasily cleaned

Product FlowBatch process or continuousIn dirty/our clean

DrainageWashing unit drains nearly completelyNo standing water

Overall construction and designLack of welds or joined componentsNo sharp bends or turns that require padding

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MaterialNon-porousEasily cleaned

Photo: Melon Acres, Inc.

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Product Flow

Photo: Melon Acres, Inc.

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http://rvpadmin.cce.cornell.edu/uploads/doc_286.pdf

Drainage

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Photo: Melon Acres, Inc.

Overall Construction and Design

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Cleaning Considerations

Washer should be cleaned frequently

Workers should be trained in correct procedures

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Steps to Sanitizing and Cleaning Anything

1. Pre-rinse• Remove field soil, plant material, debris• Scrape, brush, hose down, etc.

2. Wash• Clean with a detergent solution• Soil becomes dispersed in solution

through chemical action, rubbing, scrubbing, etc.3. Rinse

• Rinse away detergent solution and soil4. Sanitize

• Mix sanitizer according to label, test• Apply sanitizer as directed on label

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Discuss the following packing lines:

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A. Deering

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

A. Deering

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Photo: E. Maynard

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https://tinyfarmblog.com/spin-cycle/

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

http://www.marketfarm.com/cfms/wash_line.cfm

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Extension Food Safety Personnel

Scott MonroeFood Safety Educator

Amanda DeeringClinical Assistant ProfessorFresh Produce Food Safety

Amanda’s Picture Here

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Amanda DeeringClinical Assistant Professor

Department of Food Science

Email: adeering@purdue.eduPhone: 765-494-0512

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Scott MonroeFood Safety Educator

Purdue Extension

Southwest Purdue Agricultural Center4369 N. Purdue Rd.

Vincennes, IN 47591(812)886-0198 (Office)(765)427-9910 (Cell)

jsmonroe@purdue.eduhttps://ag.purdue.edu/hla/foodsafety

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Questions???