Food Safety Regulation Update and Washing Systems for Small Operations

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1 Food Safety Regulation Update and Washing Systems for Small Operations Scott Monroe Food Safety Educator Purdue Extension Southwest Purdue Ag Center

2 Produce Food Safety CDC estimates that each year: 48 million Americans sick from foodborne illness 1 in 6 people 128,000 hospitalizations 3,000 deaths Source: A significant proportion of foodborne illnesses have been attributed to fresh produce

3 Cooked vs. Raw Consumption Cooked?Both? Raw Microbial kill step Wash step Potatoes Spinach Lettuce Winter Squash Sweet Corn Cucumbers Zucchini Beets Radish Eggplant Kale Microgreens Tomatoes Apples Berries Garlic Herbs Onions

4 ALL growers who introduce produce into the public food supply should be concerned about food safety!

5 Regulation of On-Farm Food Safety Industry Farmers Market Rules County Health Departments Indiana State Health Department (ISDH) Federal Government (FDA) FSMA

6 Industry Standards enforced by buyer requirements Standards generally take the form of 3 rd 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

7 Good Agricultural Practices Certification Process GAPs Awareness and Training Farm Self Assessment Written Farm Food Safety Plan Plan Implementation Third Party Audit Certification

8 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

9 Food Safety Modernization Act FSMA = Food Safety Modernization Act y_modernization_act January Signed into Law November Final Produce Rule Published January 2016 New Rule Became Law

10 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

11 Terminology 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.

12 FSMA Produce Rule Am I Covered???

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14 Am I a FARM or a FACILITY??? Photo: J. Obermeyer

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16 Is my farm part of the rule? 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

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18 Commodities Rarely Consumed Raw Asparagus Beans Black Great Northern Kidney Lima Navy Pinto Beets Garden (roots and tops) Sugar Cashews Sour Cherries Chickpeas Cocoa Beans Coffee Beans Collards Sweet Corn Cranberries Dates Dill Seeds Weed Eggplants Figs Horseradish Hazelnuts Lentils Okra Peanuts Pecans Peppermint Potatoes Pumpkins Winter Squash Sweet Potatoes Water Chestnuts

19 Food Grains Barley Amaranth Corn Dent Flint Quinoa Rice Rye Soy Buckwheat Oilseeds Cotton Rape Sorghum Oats Flax Sunflower Wheat

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22 Processing crops receive a qualified exemption 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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25 FSMA Produce Rule If I m exempt, does this really matter???

26 Remember!!! While individuals may be exempt from regulations, One is NEVER exempt from liability!

27 Compliance Timeline Who Sales Time to Comply Farms >$500,000 food sales/year 2 years Small Farms $500,000 - $250,000 food sales/year 3 years Very 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.

28 Water Questions to Ask 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?

29 Produce Rule Agricultural Water Standards Surface water applied directly to harvestable part during growing 20 samples within two years to establish a baseline 5 samples per year thereafter Underground water applied directly to harvestable part during growing 4 samples in the first year 1 sample thereafter Sources: and PSA Curriculum Resources

30 Produce Rule Agricultural Water Standards (con t) For all water sources: Geometric Mean 126 CFU generic E. coli /100 ml Statistical Threshold Value 410 CFU generic E. coli / 100 ml Sources: and PSA Curriculum Resources

31 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

32 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 of the Food, Drug & Cosmetic Act No fee for registration Fact sheet about initiative may be found at:

33 Washing systems for produce A. Deering A. Deering

34 Growers are not legally required to wash produce Washing produce introduces several considerations that must be addressed

35 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

36 Water Testing 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

37 Postharvest Water Quality If postharvest water: 1. Doesn t meet microbial standards for drinking water or 2. Becomes contaminated during postharvest use Then: Treat with a sanitizer before use or reuse to meet the No E. coli standard. Sanitizers for Postharvest Water Chlorine Peroxyacetic acid Ozone UV-C Illumination Source: Suslow, T Postharvest chlorination. Pub. 8003, UCDANR. anrcatalog.ucdavis.edu/pdf/8003.pdf A list of sanitizers registered in Indiana may be found at:

38 Sanitizers What they do Kill microbes in water Kill microbes on surfaces Role in fresh produce food safety Prevent contamination of produce From microbes in water From microbes on surfaces Reduce number of microbes on produce surface

39 Sanitizers What they don t do Make dirty water clean Kill all microbes equally effectively Penetrate films of dirt and slimes, biofilms (some do, some don t) Sterilize the product or surface Photo: W. Kline

40 Sanitizers are Regulated by EPA The label is the law Uses Methods Rates Precautions Disposal

41 Do I Need a Sanitizer? 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; 1 st tub removes most of dirt, 2 nd tub removes the rest. Water is potable at start and reused for several batches.

42 Washer Considerations Material (non-porous and easily cleaned) Non-porous Easily cleaned Product Flow Batch process or continuous In dirty/our clean Drainage Washing unit drains nearly completely No standing water Overall construction and design Lack of welds or joined components No sharp bends or turns that require padding

43 Material Non-porous Easily cleaned Photo: Melon Acres, Inc.

44 Product Flow Photo: Melon Acres, Inc.

45 Drainage

46 Photo: Melon Acres, Inc. Overall Construction and Design

47 Cleaning Considerations Washer should be cleaned frequently Workers should be trained in correct procedures

48 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 soil 4. Sanitize Mix sanitizer according to label, test Apply sanitizer as directed on label

49 Discuss the following packing lines:

50 A. Deering

51 A. Deering

52 Photo: E. Maynard

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55 Extension Food Safety Personnel Amanda s Picture Here Amanda Deering Clinical Assistant Professor Fresh Produce Food Safety Scott Monroe Food Safety Educator

56 Amanda Deering Clinical Assistant Professor Department of Food Science Phone:

57 Scott Monroe Food Safety Educator Purdue Extension Southwest Purdue Agricultural Center 4369 N. Purdue Rd. Vincennes, IN (812) (Office) (765) (Cell)

58 Questions???

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