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Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Food Safety Regulation Update and Washing Systems for Small
Operations
Scott MonroeFood Safety Educator
Purdue ExtensionSouthwest Purdue Ag Center
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
ALL growers who introduce produce into the public food supply should be concerned
about food safety!
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Industry
Farmers’ Market Rules
County Health Departments
Indiana State Health Department (ISDH)
Federal Government (FDA)
FSMA
Regulation of On-Farm Food Safety
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Good Agricultural PracticesCertification Process
Farm Self Assessment
Written Farm Food Safety Plan
Third Party Audit
Certification
Plan Implementation
GAPs Awareness and Training
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
FSMA Produce Rule –
Am I Covered???
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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?
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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.
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.
If I’m exempt,does this really matter???
FSMA Produce Rule
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Remember!!!While individuals may be exempt
from regulations,
One is NEVER exempt from liability!
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Washing systems for produce
A. Deering
A. Deering
http://rvpadmin.cce.cornell.edu/uploads/doc_286.pdf
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Growers are not legally required to wash produce
Washing produce introduces several considerations that must be addressed
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
• 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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
The label is the law–Uses–Methods–Rates–Precautions–Disposal
Sanitizers are Regulated by EPA
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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?
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
MaterialNon-porousEasily cleaned
Photo: Melon Acres, Inc.
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Product Flow
Photo: Melon Acres, Inc.
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
http://rvpadmin.cce.cornell.edu/uploads/doc_286.pdf
Drainage
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Photo: Melon Acres, Inc.
Overall Construction and Design
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Cleaning Considerations
Washer should be cleaned frequently
Workers should be trained in correct procedures
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Discuss the following packing lines:
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.
A. Deering
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Photo: E. Maynard
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
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
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Amanda DeeringClinical Assistant Professor
Department of Food Science
Email: [email protected]: 765-494-0512
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Scott MonroeFood Safety Educator
Purdue Extension
Southwest Purdue Agricultural Center4369 N. Purdue Rd.
Vincennes, IN 47591(812)886-0198 (Office)(765)427-9910 (Cell)
[email protected]://ag.purdue.edu/hla/foodsafety
Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.
Questions???