Food Safety Plan Template for Hawai‘i FarmersFrederick Reppun

Junior Extension Agent, University of Hawai‘i

Overview. The federal Food Safety Modernization Act (FSMA) recommends, but does not require farms to create a written plan to guide their efforts to improve the safety of the food they grow. Food safety plans can help to organize the farm’s policies and practices, and can be used as a reference in communications with buyers. While numerous food safety plan templates exist, relatively few are aligned with FSMA, and many are too complicated to implement on small farms. This template is meant to provide a starting point for small farmers to develop food safety plans for their operations. It focuses on biological hazards of growing, harvesting, and packing fresh produce. Where possible, we have tried to align the template with our current understanding of the FSMA Produce Safety Rule, however this template is not meant to provide legal advice for farmers.

How to use this template. Fill in the blanks. Study and follow the sections written for you; they represent our basic recommendations. Where needed, edit the document to be more relevant to your farm. Delete the sections that do not apply. Add new sections if necessary. For example, we did not include a section on chemical hazards, as they are outside the scope of FSMA. Farmers may want to also include a section on chemical storage and application if relevant. Print the final document and keep it on hand at your farm. Print blank copies of the record templates and use them as needed.

A special note on water. FSMA requires water quality testing for non-exempt farms that use surface or groundwater for irrigation of fresh produce. The rules are complicated and may change over time. This template emphasizes the main points of the rule as it is currently written. Farmers should note that water that is unlikely to touch the edible portion of the crop presents a low risk of contamination (e.g. subsurface drip irrigation), and does not require testing according to FSMA. For help understanding and calculating figures such as the geometric mean (GM), statistical threshold value (STV), and log die-off period, please contact your local Extension Agent.

Reference. This template was adapted from S. Hardesty, Ag & Resource Economics, UC Davis, April 2012: http://sfp.ucdavis.edu/files/143901.pdf

Good luck, and please contact your local Extension Agent with any questions.

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FOOD SAFETY PLAN1

Farm name:

_______________________________

Contents

1. General Information

MapProduct Flow Diagram

2. Food Safety Modernization Act

3. Traceability

4. Human Health, Hygiene, and Training

5. Agricultural Water

6. Wildlife and Domestic Animals

7. Soil Amendments

8. Harvest, Post-Harvest and Packing

Records:

Employee Training RecordVisitor Sign-In SheetRestroom Service RecordWater Quality and Corrective Action RecordField Production RecordHarvest RecordSales RecordToilet Spill Plan

1Template developed by Frederick Reppun, University of Hawaii Cooperative Extension, May 2017. Adapted from S. Hardesty, Ag & Resource Economics, UC Davis, April 2012: http://sfp.ucdavis.edu/files/143901.pdf

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1. GENERAL INFORMATION

At _______________ farm food safety is an integral part of our entire operation and taken very seriously. We follow the requirements and recommendations of the FDA’s Produce Safety Rule under the Food Safety Modernization Act.

__________________ has been designated to oversee and implement our food safety program.

This entire food safety plan has been reviewed as of:

____________ ____________ ______________ ______________

This food safety plan addresses traceability, human health, hygiene, and training, soil amendments, wildlife and domestic animals, agricultural water, post-harvest handling and sanitation, training, and record keeping.

Farm Managers: ______________________________________________________

Farm Location: _______________________________________________________

Mailing Address: _____________________________________________________

Contact information: __________________________________________________

Total acres farmed: _______________________

Farm description (ownership, employees, land history, activities other than farming):

Crops sold include:

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Farm Map

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2. FOOD SAFETY MODERNIZATION ACT (FSMA) STATUS

The federal Food and Drug Administration has implemented the FSMA Produce Rule to regulate farms that grow, harvest, pack, and/or hold food for human consumption.

Under the Produce Rule, certain farms and commodities are exempt from full compliance. These exemptions are based on average sales of produce, average sales of total food, distribution distance, types of crops grown, and documentation of commercial processing steps that reduce microorganisms of public health significance.

Exemptions Based on Sales and Distribution

Our sales in recent years have been:

Year Produce Sales ($) Total Food Sales ($)

We sell ______________ (more than/less than) half of our produce to Hawaii retail markets or directly to consumers.

Based on our sales and distribution, our farm status under FSMA’s Produce Rule is: Exempt Qualified Exemption (must display business name and address at point of sale) Not Exempt (must comply with all Produce Rule requirements)

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Exemptions Based on Crop Type and Processing

The following rarely eaten raw crops are not covered by the Produce Rule:

Asparagus; beans, black; beans, great Northern; beans, kidney; beans, lima; beans, navy; beans, pinto; beets, garden (roots and tops); beets, sugar; cashews; cherries, sour; chickpeas; cocoa beans; coffee beans; collards; corn, sweet; cranberries; dates; dill (seeds and weed); eggplants; figs; ginger; hazelnuts; horseradish; lentils; okra; peanuts; pecans; peppermint; potatoes; pumpkins; squash, winter; sweet potatoes; and water chestnuts.

Food grains and oilseeds are not covered by the Produce Rule.

The following list of produce grown on our farm is not covered by the Produce Rule:

Exemptions Based on Commercial Processing

Produce that goes through a commercial processing step that “adequately reduces the presence of microorganisms of public health significance” (e.g. cooking) exempt from the Produce Rule as long as written assurance is obtained from the customer.

The following list of covered produce grown on our farm undergoes such a commercial processing step:

Produce Item Processing Step Customers

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3. TRACEABILITY:

A traceability program has been developed and adopted. We can track one-step forward and one-step backward for all fresh produce at our farm. Our product tracking system includes information about production area, harvest date, type of crop, place of storage, and where product is sent after leaving the farm. This information can be retrieved from copies of our sales invoices and production records linked to them.

Recall procedure:1. A customer calls farm to report potential foodborne illness from produce sold to them

during a certain date range.2. Copies of all sales invoices for that customer and date range are retrieved from the filing

system.3. Trace back: invoices used to identify which crops are suspect, where they were grown,

and which date they were harvested on. Farm manager inspects fields and packing facility, and asks workers who were present if they noticed anything on those harvest dates. Probable source of the problem is identified.

4. Trace forward: The affected crops and harvest dates are used to retrieve invoices for all other customers who received produce from the same batch or lot. Contact information for those customers is retrieved and calls are made to alert them to recall the affected products.

We performed successful mock recalls on the following dates:

______________ ______________ ______________ ______________

______________ ______________ ______________ ______________

______________ ______________ ______________ ______________

To help our customers contact us, we display our farm name and address in the following ways:

on produce labels on bins/boxes on a sign displayed at markets on all invoices/receipts other (describe): _________________________________________________________

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4. HUMAN HEALTH AND HYGIENE

TrainingAll new employees are trained on the contents of this food safety plan. See employee training record for dates of training.

General HygieneReadily understandable signs are posted to instruct employees to wash their hands before beginning or returning to work.

All farm personnel must follow good hygiene practices, including: Smoking, eating, and chewing tobacco is allowed only in designated areas. Proper Hand washing: Hands must be washed with soap before beginning or returning to

work, and after the following activities:o using the restrooms,o smoking or tobacco use,o taking breaks,o handling trash containers or disposing of trash,o using the telephone,o handling money,o touching face or head with hands

Clean work clothes. Clean and cut nails. Take a daily shower. Do not take gloves to lunchroom or restrooms. Dangling strings and/or jewelry are prohibited. If long hair is worn, it must be tied back.

Illness and InjuryAny employee who is ill or appears to be ill with diarrhea or another possibly communicative disease must tell their supervisor. They will be sent home or assigned a task away from harvest and packing areas.

If an employee has an open wound or cut, it must be bandaged and covered to prevent contact with produce. He/she must stop working immediately, contact his/her supervisor, and have it attended to. A first aid kit is available on the farm for injuries (see farm map). Produce that has come into contact with blood or other bodily fluids will be discarded. If any bodily fluids come into contact with food contact surfaces (e.g. harvest bins), these surfaces must be disinfected as soon as possible.

All workers are aware of the location of first aid supplies and what steps they should take in case of a first aid emergency to stop work and avoid bodily fluid contact with others or product.

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ToiletsField sanitation units (toilet and hand-washing facilities) are located within a 1/4 mile or 5-minute walk, for all workers. One toilet facility and one hand washing facility shall be provided for each twenty (20) employees or fraction thereof (working more than three hours during the day, including travel time). These sanitation units are in a location that minimizes the potential risk for product contamination. If there are fewer than eleven employees, a toilet facility must be readily available for all workers; home toilet facilities may be used.

All employees and visitors must use restroom facilities provided. They are equipped with hand-washing facilities with

potable running water, single use hand towels, toilet paper, and hand soap

Toilets are maintained on a scheduled basis that is indicated on the unit, or more frequently as necessary. If restroom facilities are not properly maintained, any employee or visitor should notify the onsite supervisor.

Cleaning of restroom facilities includes the following: Wash walls from top to bottom, as needed. Sanitize toilets, urinals, doorknobs, and any other surface inside unit. Fill paper products and soap dispensers. Remove trash to dumpster. Record initials and date of cleaning on “Service Record” sheet when unit is serviced. Brushes and any other cleaning utensils used to clean the restrooms must be identified for

this use and stored separately from any other cleaning utensil.

Field sanitation units are directly accessible for servicing and directly accessible in the event of aspill or major leak. In the event of a major spill or leak of field sanitation units, a response planis in place (see Toilet Spill Plan in records section).

VisitorsVisitors are informed of the farm’s food safety policies and the location of the restrooms.

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5. AGRICULTURAL WATER

Pre-harvestAll irrigation sources and water lines are inspected _____ times per year for unauthorized use or potential contamination.

Irrigation Water Sources:

Irrigation methods:

Water quality testing (check one):

Water quality testing not needed because ______________________________________

_______________________________________________________________________.

Water is tested _____ times per year). Samples are submitted to

__________________________ lab for analysis.

Corrective actions: As per FDA regulations, the farm must take certain corrective actions if water that

contacts the edible portion of covered produce contains generic E. coli levels above a geometric mean of 126 CFU/100mL or an STV above 410 CFU/100mL.

If tests and/or inspection show potential contamination, the farm will (check one):

use a pre-harvest die-off period (period of no use of contaminated water) to allow

potential pathogens to reduce in number on produce.

treat irrigation water using ___________________________________________.

The corrective actions remain in place until the contamination is fixed or further testing indicates that E. coli levels have dropped below the required values.

All test results and corrective actions are recorded on the Water Quality and Corrective Action Record.

Harvest and Post-HarvestAll water used during harvest, washing, and cooling (ice) of fresh produce is potable (i.e. no detectable generic E. coli).

Water sources:

Water quality:

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6. WILDLIFE AND DOMESTIC ANIMALS

Crop production areas are not located near or adjacent to dairy, livestock or poultry production facilities. No manure lagoons are located on or near the crop production areas. Domestic animals are not allowed in the crop production areas.

All fields are routinely monitored for unusual presence or signs of entry by wildlife or neighboring domesticated animals to the fields. When needed, measures will be taken (trapping, fencing, and deterring) to reduce entry by wild and domesticated animals to minimize the risks of potentially contaminated product or production areas.

7. SOIL AMENDMENTS

Example: Fish/Bone MealSource: Island Commodities, Inc.

Components and treatment: fish and cow parts properly treated by cooking and rendering to lower the level of any pathogens that may be present.

Application: _______ weeks before planting.

Storage (location, method):

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8. HARVEST AND POST-HARVEST HANDLING AND SANITATION

HarvestWe conduct a pre-harvest assessment of each production area prior to harvesting any

crop; risks and possible sources of crop contamination are assessed. Crops within a 3-foot radius of any known animal feces are not harvested.

Harvest EquipmentAll harvest equipment is kept clean:

Harvest equipment is used only for harvesting produce. All harvesting equipment, including hand harvesting implements and bins, is maintained,

cleaned and washed ______________________ (frequency). Hand implements are disinfected _____________________ (frequency). During harvest, equipment is kept as clean as practical, and maintained to prevent

contamination by leaking oil, grease, loose parts, and any other source of foreign material contamination.

Harvest equipment is stored in a covered area off of the ground.

Washing and PackingReceiving (describe):

Washing (describe):

Packing (describe):

Post-harvest equipment:Tubs, coolers, scales, shelves, tabletops, and all other food contact surfaces are

cleaned/sanitized regularly following a pre-rinse, wash, rinse & sanitizing protocol. All packing materials are stored in plastic totes off the ground.

Packing facility maintenance:Facility is regularly inspected for evidence of animals, leaks, or other sources of

contamination. Rodent bait stations are kept stocked around the outside of the facility.

TransportationVehicles transporting product are cleaned on a regular basis, and as needed.

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EMPLOYEE TRAINING RECORD

Food Safety Trainer: ______________________________

Employees acknowledge that have been informed and trained in the requirements of the Food Safety Plan for ABC Farms.

Employee Name Employee Signature Training Date

Trainer Initials

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VISITOR SIGN-IN SHEET

Visitors acknowledge that they have been briefed on the farm’s food safety policies and location of restrooms.

Name Purpose of Visit/Group Date

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RESTROOM SERVICE RECORD

Tasks: clean surfaces; empty rubbish bin; check/restock toilet paper, soap, and paper towels.

Name Date Name Date

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WATER QUALITY AND CORRECTIVE ACTION RECORD

Water is tested by taking a single sample at the spigot farthest from the source. Water is run for 3 minutes prior to sampling to flush line. Rolling geometric mean (GM) and statistical threshold value (STV) of most recent 5 samples is calculated.

Farm must take corrective actions if water that contacts the edible portion of covered produce contains generic E. coli levels above a GM of 126 or an STV above 410 CFU/100mL.

Sampling Date

Generic E. coli (CFU/100 mL)

GM STV Corrective Action?(yes/no)

Corrective Actions (begin date, description of action, end date):

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FIELD PRODUCTION RECORD

Record additions of soil amendments (type, amount/rate, method of application), planting of crops, pest/weed control actions (product, amount/rate, method of application, water source used for spray dilution), and any other details.

Date Field Action

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HARVEST RECORD

Harvest Date

Field Product Amount Notes

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SALES RECORD

Lot No. includes harvest date and field in this format: MMDDYY-Field.

Sale Date Product Lot No. Quantity Sold

Customer

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TOILET SPILL PLAN

1. Notify farm manager __________________ (phone)2. Call portable toilet company __________________ (phone)3. Put on appropriate protective equipment (waterproof gloves, boots, eye

protection)4. Evaluate cause of spill and areas affected, and stop new leakage if possible.5. Use shovels, tractor to build dam of soil around the spill area to prevent

spread if necessary6. Secure area against unauthorized entry (at least 20 days)7. Wash and sanitize tools and equipment away from crop production areas8. Wash hands with soap9. Record spill below

Date Source and Cause of Spill Actions Taken Date Safe for Reentry

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