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Sizing Food Safety to Fit Small Farms

Editor’s Note: This article is part of a continuing series on the Vashon Island School District’s new school lunch program, and the farm-to-school movement in this Washington state community.

Most farmers would rather sift through a batch of seeds than a pile of paperwork. Yet selling to the public requires a food safety plan, which means time spent behind the desk in addition to out in the field.

Now an innovative program in Washington state aims to create streamlined guidelines for food safety that will allow small farms to profit from the local food movement without getting bogged down in bureaucracy.

Like many schools across the country, the Vashon Island School District is replacing ready-made school lunches with more nutritious meals prepared from fresh ingredients. Some of those ingredients will now be even fresher, because they will come from local farmers who have opted to sell fruits and vegetables to the district.

So on a recent Friday, representatives from 10 farms on Vashon Island met to discuss those plans. They learned that before the island’s farmers can sell to the school district, they must have a certificate of liability insurance, which in turn requires a food safety plan. 

Food Safety Certification: A Formidable Process for Small Farms

While large, commercial farms try to assure buyers of their foods’ safety through GAPs (Good Agricultural Practices) certification, the process required to obtain this certification is sometimes prohibitive for small farmers.

“The food safety certification program can be expensive and time-consuming. Larger farms hire staff just to keep the documentation in order. That’s going to stop some small farms in their tracks,” explains Tricia Sexton Kovacs, manager of the Washington Department of Agriculture’s Farm to School program.

Indeed, while Vashon farmers are enthusiastic about selling to schools, they’re not so excited about the prospect of adjusting their operations to meet a long, unfamiliar list of requirements. ”I feel like people are so frightened,” said Leda Langley of Langley Fine Gardens. “I don’t want us to start getting bogged down in our fears here.”

Making Food Safety Protocol Digestable

But the message of the workshop, led by Mark Musick, co-coordinator of Vashon’s Farm to School program, and Carrie Sikorski of the Vashon Island Growers Association (VIGA), which is overseeing the initiative, was that safe food handling procedures don’t have to be daunting. They can be boiled down to their essential elements: clean soil, clean water, personal hygiene and clean surfaces — and by adhering to these principles, small farms can ensure the safety of their products.

Musick and Sikorski have been working with food safety experts around the Pacific Northwest to distill the complex regulations of safe food handling for industrial farms into a feasible plan for small farmers. Over four hours during the March 4 workshop, they – along with other presenters – went over these food safety guidelines with the Vashon farmers.

The guidelines cover every aspect of the farming, from composting to irrigation to harvesting, and draw recommendations from the U.S, and Washington state departments of agriculture, Washington State University’s Extension Program, GAPs requirements, and other sources.

Safety Requirements Boiled Down

While each farmer’s food safety plan will be unique, reflecting their individual farms, all must address the following safety concerns:

– Water sources for irrigation must be checked for pathogens.

– Post-harvest water used to wash hands, tools, or produce itself must be the equivalent of drinking water.

– Restroom facilities must be located where waste cannot contaminate soil.

– Precautions should be taken to avoid wild animals from coming into contact with border fences and covers for exposed crops, such as berries.

– Sick workers should not work with crops until their symptoms are gone.

– Crops should not be at a lower elevation than runoff that might contain fecal matter.

– Bins used for rinsing produce should be kept clean and the water changed with each rinse.

– Compost should be kept at 130⁰F and turned regularly.

 
– Pets must be kept out of crop-growing areas.

Another key issue addressed at the workshop was documentation. “Keep as many records as you can,” advised Mike Hackett, Organic Food Inspector for the Washington Department of Agriculture.

In the event of a foodborne illness outbreak, farmers need to be able to show they were following safe handling protocol, and this includes being able to provide detailed descriptions of farm operations, Sikorski explained. Finally, documentation tells the school which farmers provided what produce, in the event of a food recall.

On the Road to Food Safety

The good news for the farmers was that most currently employ the safety precautions that will be required to supply school food. For example, when Musick asked how many people used compost probes to test the temperature of their compost, a majority of the farmers raised their hands.

Langley says she and her husband already have specific measures in place on their farm to prevent the spread of foodborne pathogens. Everyone who works on her farm wears gloves when handling crops and washes their hands frequently throughout the day. She says she doesn’t own dogs, so there is no risk of their feces contaminating plants or soil.

Setting a Precedent

The concerns that Vashon farmers face reflect those facing small, sustainable farms across the nation. If they want to sell to buyers beyond those at the local market, such as grocery stores or restaurants, they have to have a certificate of liability insurance, which, as Musick says, takes a working food safety plan as a given. 

Vashon farmers are aware that by adopting a food safety plan that is straightforward and feasible, but also addresses the risks associated with foodborne pathogens, they are creating a model for farmers across the nation who want to broaden their markets without going through the certification process geared toward large commercial farms.

“The exciting thing about this to me is that we’ll have a hand in shaping this process to our scale,” said Celina Yarkin, who owns and operates Sun Island Farms with her husband Joe. Other people around the state are saying, “Hey, can we replicate this?” said Musick.

The farmer food safety training was sponsored by Food Safety News.

© Food Safety News
  • Doc Mudd

    “In the event of a foodborne illness outbreak, farmers need to be able to show they were following safe handling protocol, and this includes being able to provide detailed descriptions of farm operations, Sikorski explained. Finally, documentation tells the school which farmers provided what produce, in the event of a food recall.”
    Agree. It is absolutely critical that each producer be held 100% accountable for 100% of their product. This is the only way a school feeding program can succeed. Producers who cannot abide, for any reason, pose a needless danger to our kids.

  • Michael Bulger

    I agree that this is a huge responsibility and applaud these enthusiastic farmers for taking on the challenge. I’d also like to take the time to commend Food Safety News for sponsoring the training and the Washingtonians who are committing their time to conveying the requirements. It goes to show that some people are willing to put in the hard work to change their communities for the better.

  • jmunsell

    Great article. It is eerily reminiscent of USDA’s pre-HACCP statements to the meat industry. Sounds good in theory, and if implemented properly, will work in reality. HACCP is all about food safety, and is accomplished via construction of a food safety system based in science, prevention, and corrective actions. The ability of a meat plant to create safe food is largely accomplished via the creation of written protocol, accompanied by a plethora of daily records……which can be falsified.
    Let me explain how USDA intentionally bastardized its oversight of HACCP at small meat plants, which could possibly occur if ill-meaning gov overseers manage small farming operations. If USDA/FSIS would oversee these small farmers, we can expect scenarios such as these:
    1. Scientific and sanitary farming practices utilized at one farm, and endorsed by gov officials, can be routinely rejected by the gov at other farms. You might laugh. Happens all the time at small meat plants.
    2. FSIS would hire, at great expense, recognized scientific experts to devise sanitary farming protocol for small farmers. FSIS would then authorize “some” farms to implement this protocol, while withholding authority from other small farmers to utilize the same protocol. Incredulous? You should be. As but one example, FSIS hired Dr. Dennis Buege, scientist at U of W in Madison to identify new interventions in the meat industry. FSIS paid for and endorsed Dr. Buege’s findings, and later decided that some plants could utilize the protocol, while denying the privilege to others. Dr. Buege was dumbfounded, for good reason: “science” was deemed acceptable by the agency at some plants, regularly rejected at others.
    3. FSIS would routinely send EIAO’s (Enforcement Officials) to each farm, looking for noncompliances, while initiating enforcement actions when deemed necessary. One EIAO would MANDATE that a farm discontinue one practice, while MANDATING the implementation of alternative protocol. Weeks later, another gov official would review the same farm, be aghast at protocol used at the farm which was mandated by the previous EIAO, and require different protocol. If the farmer would object, the gov could withdraw its approval of the farm’s Food Safety Plan, essentially shuttering the farm. Two months later, another EIAO would arrive, and summarily reject all mandates from ALL previous agency officials, and mandate his/her own biases. Are you laughing yet? This is laughable, except it’s not funny.
    4. FSIS would inspect produce processing facilities, which purchase produce from various farmers. Let’s assume every farmer supplier to the processing plant is fully compliant with all reg’s, has superlative written Plans, and in fact is proactive in their attempts to produce consistently safe food. And, all produce arriving at the processing plant is accompanied by paperwork certifying that the produce was produced at farms which are 100% compliant with all reg’s and commonly accepted protocol. In spite of these overlapping commitments to food safety, a consumer is sickened by ingesting E.coli or Salmonella-laced carrots. Production records at the processing facility reveal that the plant had processed carrots from 3 farm suppliers that day, and had records on file documenting that food safety certifications were on file from all 3 farms. Nevertheless, some invisible e.coli or salmonella made its way into commerce. FSIS would charge the carrot processing plant with being “Imprudent”, and charge it with INTRODUCING the e.coli or salmonella into the food chain. FSIS would “suggest” (aka “Mandate) that the processing plant test every incoming lot of every commodity before processing it. Of course, unless the processor tests 100% of every lb of incoming product, a negative lab result would merely prove that the few pounds tested were without pathogens, while proving no guarantee of the safety of the non-tested carrots. Meanwhile, FSIS would NOT require any pathogen testing at the 3 carrot farm suppliers. If you think these scenarios are but a figment of my imagination, visit with small USDA/FSIS inspected meat processing plants, and you will discover that these absurd USDA/FSIS actions are ubiquitous.
    5. Because of the “Failure” at the carrot processing plant, USDA/FSIS would mandate that the plant implement corrective actions to prevent recurrences. Let’s say the plant agrees to test every incoming lot, of EVERY item. The agency concludes that the corrective actions are incomplete, inadequate and unacceptable, and the plant remains closed. The carrot processor asks what the agency desires, but receives no answer. So the plant suggests additional steps, all of which are likewise rejected as being inadequate……while the agency does not provide workable alternatives. If you think this is absurd, so do I.
    Prior to HACCP’s implementation, USDA/FSIS publicly stated that it believed that 20% of meat plants would drop inspection because of HACCP. This estimate was low, as around 30% of small meat plants have since disappeared. We must honestly ask ourselves, with 30% of small plants now gone, has the number of outbreaks and recalls been greatly diminished?
    Let’s hope that gov officials which oversee produce production and outbreaks have a higher standard of ethics than those overseeing the meat industry. Nevertheless, we must be vigilant to ensure that gov officials in charge of produce do not duplicate actions 1 – 5 listed above.
    John Munsell

  • John Munsell

    Great article. It is eerily reminiscent of USDA’s pre-HACCP statements to the meat industry. Sounds good in theory, and if implemented properly, will work in reality. HACCP is all about food safety, and is accomplished via construction of a food safety system based in science, prevention, and corrective actions. The ability of a meat plant to create safe food is largely accomplished via the creation of written protocol, accompanied by a plethora of daily records……which can be falsified.
    Let me explain how USDA intentionally bastardized its oversight of HACCP at small meat plants, which could possibly occur if ill-meaning gov overseers manage small farming operations. If USDA/FSIS would oversee these small farmers, we can expect scenarios such as these:
    1. Scientific and sanitary farming practices utilized at one farm, and endorsed by gov officials, can be routinely rejected by the gov at other farms. You might laugh. Happens all the time at small meat plants.
    2. FSIS would hire, at great expense, recognized scientific experts to devise sanitary farming protocol for small farmers. FSIS would then authorize “some” farms to implement this protocol, while withholding authority from other small farmers to utilize the same protocol. Incredulous? You should be. As but one example, FSIS hired Dr. Dennis Buege, scientist at U of W in Madison to identify new interventions in the meat industry. FSIS paid for and endorsed Dr. Buege’s findings, and later decided that some plants could utilize the protocol, while denying the privilege to others. Dr. Buege was dumbfounded, for good reason: “science” was deemed acceptable by the agency at some plants, regularly rejected at others.
    3. FSIS would routinely send EIAO’s (Enforcement Officials) to each farm, looking for noncompliances, while initiating enforcement actions when deemed necessary. One EIAO would MANDATE that a farm discontinue one practice, while MANDATING the implementation of alternative protocol. Weeks later, another gov official would review the same farm, be aghast at protocol used at the farm which was mandated by the previous EIAO, and require different protocol. If the farmer would object, the gov could withdraw its approval of the farm’s Food Safety Plan, essentially shuttering the farm. Two months later, another EIAO would arrive, and summarily reject all mandates from ALL previous agency officials, and mandate his/her own biases. Are you laughing yet? This is laughable, except it’s not funny.
    4. FSIS would inspect produce processing facilities, which purchase produce from various farmers. Let’s assume every farmer supplier to the processing plant is fully compliant with all reg’s, has superlative written Plans, and in fact is proactive in their attempts to produce consistently safe food. And, all produce arriving at the processing plant is accompanied by paperwork certifying that the produce was produced at farms which are 100% compliant with all reg’s and commonly accepted protocol. In spite of these overlapping commitments to food safety, a consumer is sickened by ingesting E.coli or Salmonella-laced carrots. Production records at the processing facility reveal that the plant had processed carrots from 3 farm suppliers that day, and had records on file documenting that food safety certifications were on file from all 3 farms. Nevertheless, some invisible e.coli or salmonella made its way into commerce. FSIS would charge the carrot processing plant with being “Imprudent”, and charge it with INTRODUCING the e.coli or salmonella into the food chain. FSIS would “suggest” (aka “Mandate) that the processing plant test every incoming lot of every commodity before processing it. Of course, unless the processor tests 100% of every lb of incoming product, a negative lab result would merely prove that the few pounds tested were without pathogens, while proving no guarantee of the safety of the non-tested carrots. Meanwhile, FSIS would NOT require any pathogen testing at the 3 carrot farm suppliers. If you think these scenarios are but a figment of my imagination, visit with small USDA/FSIS inspected meat processing plants, and you will discover that these absurd USDA/FSIS actions are ubiquitous.
    5. Because of the “Failure” at the carrot processing plant, USDA/FSIS would mandate that the plant implement corrective actions to prevent recurrences. Let’s say the plant agrees to test every incoming lot, of EVERY item. The agency concludes that the corrective actions are incomplete, inadequate and unacceptable, and the plant remains closed. The carrot processor asks what the agency desires, but receives no answer. So the plant suggests additional steps, all of which are likewise rejected as being inadequate……while the agency does not provide workable alternatives. If you think this is absurd, so do I.
    Prior to HACCP’s implementation, USDA/FSIS publicly stated that it believed that 20% of meat plants would drop inspection because of HACCP. This estimate was low, as around 30% of small meat plants have since disappeared. We must honestly ask ourselves, with 30% of small plants now gone, has the number of outbreaks and recalls been greatly diminished?
    Let’s hope that gov officials which oversee produce production and outbreaks have a higher standard of ethics than those overseeing the meat industry. Nevertheless, we must be vigilant to ensure that gov officials in charge of produce do not duplicate actions 1 – 5 listed above.
    John Munsell