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Small plus local doesn’t equal a free pass on food safety

There’s a revolution going on in a grocery store near you. Fueled by consumer demand, it has been dubbed the “fresh revolution” by industry heavyweights such as the United Fresh Produce Association. It’s all about fresh produce — fruits and vegetables that nutritionists are praising as “healthy foods” and that shoppers are increasingly seeking out.

“The exploding world of fresh foods at retail,” is the way United Fresh describes it in a news release about its annual conference and trade show set for June 20-22 in Chicago.


That’s good news for many small- and medium-sized farms simply because of their proximity to stores and restaurants in their areas. They can offer fresher produce to those businesses because it doesn’t have to be transported long distances. Generally, the closer the source, the fresher the food.

But there’s more to it than food miles. Retailers want food not only to be of the highest quality, but also to be free of foodborne pathogens such as E. coli, Listeria and Salmonella. They can’t risk their reputation by buying produce from a farm, regardless of size, just because it’s close by.

The numbers serve as a wake-up call. More than 70 percent of U.S. consumers are concerned about food safety, according to the International Food Information Council Foundation’s 2014 Food and Health Survey. And 40 percent switched their choices of food based on food safety issues.

Numbers also show the depth of the challenge for produce growers and shippers. The Centers for Disease Control and Prevention estimates that produce is the leading cause of food-related illnesses and attributes 46 percent of food contamination problems in the U.S. to produce.

Clearly, small- and medium-scale farmers who want to achieve wholesale success have their work cut out for them.

A variety of sources of information and training geared specifically to small- and mid-sized farms is available. That availability is expected to increase now that the Food and Drug Administration has published final rules for produce and other foods, as mandated by the Food Safety Modernization Act.

One recent example of the training sessions designed for smaller operations was “Wholesale Success: Post Harvest Handling & Food Safety,” presented by organic farmer and food safety trainer Atina Diffley and FamilyFarmed. The event earlier this month at the research center at Washington State University in Mount Vernon was one of a series of workshops scheduled in 29 cities.

A grant from the U.S.Department of Agriculture’s Risk Management Agency is helping to pay for the workshops.

Atina Diffley

Atina Diffley

Down to earth … literally
As a Midwest farmer, Diffley knows her way around the agricultural block, including planting, harvesting, packing and selling from her personal experiences in Minnesota. Her goal is to share what she has learned about food safety with small- and mid-sized farmers in a practical way that’s relevant to their own farms. An important part of the equation is profitability, she said.

“You’re competing with the bigger farms,” she told the farmers attending her workshop. “You’ve got to come up with a way to stay in business.”

In describing the training she provides, Diffley said how farmers handle their products affects the food’s safety and therefore their relationships with buyers, who increasingly expect farmers to be proactive.

Pointing to the pride in ownership that farmers have in the food they produce, Diffley said that farmers need to keep in mind “it isn’t only our food,” but that they’re food handlers growing someone else’s food.

“No matter what size the farm or its financial position, food safety must be attended to,” Diffley said.

The good news is that having a “food safety mindset” doesn’t necessarily mean you have to hire extra staff or buy expensive state-of-the-art equipment. Keep it, “scale appropriate” and “cost-effective” was Diffley’s first-hand advice.

Make a habit of record-keeping
Food safety shouldn’t be thought of as a separate job, said Diffley, but something to be integrated into the farm’s day-to-day activities. For example, no need to keep separate duplicate records for food safety; they can be part of a farm’s overall records.

A practical application of that concept would be to use a crop progress check as an opportunity to document food safety efforts. During a trip to a field to check on how soon and how large harvest will be, a farmer can add food safety items to the field checklist, such as checking for animal activity among the produce and documenting action taken.

Should there be a signs such as animal droppings or bird nests, the farmer can pull out some red flags and pop them in the soil 5 feet in every direction from the activity. That lets field pickers know not to harvest produce that may have been contaminated.


Another strategy Diffley recommends combines work organization, staff communication and accountability, and record keeping. White boards, for example, can be used in work areas to communicate with employees and track daily activities. As workers complete tasks, they add information. The main categories can be marked on the boards with permanent marker, whereas the daily information in the columns can be entered with an erasable marker.

At the end of the day when the columns have been filled in, the farmer or farm manager can take digital photos of the white boards and download them into dated files that can be referred to in case there’s a problem with food safety. A swipe of the eraser, and the boards and their headers are ready for the next day.

And, yes, record keeping is essential. In fact, Diffley refers to record keeping as the most profitable activity on a farm. And for good reason. Many good reasons, actually.

To begin with, many of the records farmers keep help them make good decisions about all sorts of activities on the farm, during the current season and future seasons. And when it comes to food safety, those records will provide valuable information in the event a farm’s food is linked to a foodborne illness.

In short, says Diffley, “record keeping must be a habit.” But, she stressed, it doesn’t have to be a headache.


Keep it practical
Diffley provided workshop attendees with straightforward templates to use when designing their own Harvest, Postharvest, Transportation and Equipment, and Sanitation Action Plan.

Complete with columns, the templates’ headers use easy-to-understand phrases instead of government jargon to document food safety activities such as:

  • “What policies are being followed to reduce risk”
  • “How this is done”
  • “Who’s required to do this”
  • “When is it done”
  • “When training is done”
  • “Who, When and What records are kept for these actions”

The templates are based on good agricultural practices (GAPs) and the Food Safety Modernization Act’s Produce Rule. They can be downloaded to help growers develop a food safety system and implementation action plan.

“There are no rules requiring specific formats for food safety plans,” Diffley said. “The important thing is that plans are relevant to your farm and that they are implemented. Use a system that works for you.”

Diffley said the templates can be used to create final Food Safety Action Plans or to as pre-work for the FamilyFarmed food safety question tree.

The On-Farm Food Safety Plan Tool, developed by FamilyFarmed.org, is a free, web-based resource for developing a farm’s Food Safety Plan. Such plans must be specific to each individual farm. This tool takes farmers through a series of questions, collects information and generates a customized on-farm Food Safety Plan based on user input.

The tool is designed for use by small- to mid-scale growers, is available in Spanish and English, and includes a full set of record keeping tools to document food safety programs. There is also a sample plan to review for ideas.

As for legal challenges pertaining to food safety, Diffley shared this warning:

“If your actions aren’t documented there’s no way to verify that you’ve done them. And if you have a product liability policy and you can’t prove you weren’t negligent, the insurance company might not be able to insure your product. Also, food-safety auditors require record keeping that documents you’ve done what your plan says you will do.”

Another thing for farmers to keep in mind is that one of the tools of the Food Safety Modernization Act is expanded access to farmers’ records.

Washing produce: Keep it safe
Diffley dove into the issue of water use on farms, starting with the quality of the water that should be used to clean veggies and fruits, as required by the Food Safety Modernization Act. Pure and simple, it needs to be very clean. “Potable” is the word for it.

More specifically, water used for cleaning produce must have no detectable generic E. coli per 100 mL sample. In addition to direct contact with produce that is covered under the Food Safety Modernization Act, which for the most part is produce that will be eaten raw, the rule also applies to water coming into contact with surfaces after harvest, water used to make ice, and water used for hand washing after harvest. Untreated surface water may not be used for any of these purposes.

Production systems that keep the crop as clean as possible during growing and harvesting are part of a strategic system, Diffley said.

“Research shows that once pathogens are on produce it can be impossible to wash them off,” she said. “The best practice is to prevent contamination.”

“Keep it clean in the fields,” she said, pointing to an example of growing a living mulch of millet between rows of strawberries to reduce the berries’ exposure to the soil.

For some crops such as tomatoes, trellising to keep them off the soil and harvesting them when they’re dry can be effective and can help farmers minimize the need to wash them.


“You need to manage cut produce surfaces contacting soil and water on your farm,” she said. “Farmers are so comfortable with soil — it can be a new concept to think of the soil the food grows in as a potential source of contamination.

“It helps to remember that while produce is being grown there are not generally cut cells. Then at harvest, that changes and it becomes easier for pathogen microbes to enter or adhere to the produce.”

Diffley said farming operations of all sizes are moving away from using dunk tanks.

“Wash systems need to be evaluated for food safety,” she said. “Dunk tanks can be one of the most risky practices on farms.”

For farmers currently using dunk tanks, she suggested they think through the “why” of the dunk-tank process.

“People used dunk tanks to clean, cool, and/or crisp fresh produce,” she said. “Systems to accomplish these goals without dunking can be (used).”

Especially risky are produce crops that are “very dirty” such as root crops. They shouldn’t be washed in dunk tanks, simply because there’s too much dirt on them. “It’s too high risk,” she said.


There are other options, for example a spray-washing table or a rotating barrel-washer.

Diffley recognizes that some growers still use dunk tanks. “Before putting food in a dunk tank, get the majority of the soil off,” she said, pointing out that any dirt or unwanted matter on the produce can transfer into the water and cross contaminate with pathogens. “Most of the cleaning should be done before the crop is put into the dunk tank.”

She also said that while research on triple washing cut greens has shown it does a good job of cleaning them, it should not be interpreted to mean that pathogens can be washed off of the greens. Immersing greens in water can be a high-risk activity. If one leaf is contaminated, the water can carry pathogens to other leaves, or be imbibed internally.

And she reminded the farmers that anyone washing the produce should be wearing clean clothing, or if they’re coming in from the field, aprons over their work clothes. And they must have washed their hands with clean water.

While it’s important to use a water sanitizer, Diffley told the group that it’s also important to keep in mind that “you’re treating the water not the food.”

When talking about sanitizers, she said that hydrogen peroxide based formulations have some benefits that chlorine doesn’t. For example, it leaves no taste residue, there’s no need to test the pH of the water, it can be effective longer than chlorine, and can be less affected by organic matter.  Also, they may provide the benefit of managing decay organisms. Some formulations such as Sandiate 5.0 and StorOx 2.0 are approved by the National Organic Program.

Farmers using chlorine, which Diffley said is harder on equipment than hydrogen peroxide based products, can find helpful information on the University of California-Davis food safety website.

As for water temperature management, Diffley has links on her website to crop specific research and guidelines for water use with cantaloupes, tomatoes and mangoes.

Cooling produce: Keep it safe
“Immediately removing field heat is key to maximizing shelf life,” Diffley said. “Farmers need to cool produce to ideal storage temperature.”

The need to quickly cool produce to storage temperatures can be reduced by harvesting in early morning to minimize field heat. Produce can be cooled in forced air coolers or by using portable cold vehicles in the field. If produce is cooled quickly, moisture levels can be managed at the production stage and maintained after harvest by slowing respiration with quick cooling and with humidity management.

Simply placing produce into a cold storage room is generally too slow for high-respiration crops with field heat in them, which is why many farms use forced-air systems for quick cooling.

“In a forced air system you’re pulling out the heat, rather than blowing cold air in,” Diffley said.

Before forced-air technology, many wholesale requirements called for packing certain crops in ice, which caused food safety issues. However, ice can be useful to small farms that often lack refrigerated delivery vehicles or sell in settings without electrified cold displays, such as farmers markets.

“Ice can make a really big difference in keeping produce fresh,” she said. “Ice machines are expensive new, but can often be found used at bargain prices.”

Water used to make ice must be potable, and the machine and scoop needs to be washed and sanitized.

“You want to be sure you address food safety right from the start,” she said, pointing out that you don’t want to stack iced produce where it can drip down on other produce.

Storage and transportation
If you don’t have a refrigerated delivery vehicle, at a minimum, insulate your vehicle, advised Diffley. If produce is cooled before loading and covered with clean and sanitary insulating material, vehicles are insulated, and delivery times are scheduled during the cool of the day, delivery can be made without produce warming up excessively.

Whatever system is used, said Diffley, temperatures readings should be documented for different parts of coolers and vehicles. Automatic digital data recorders are available for about $30.

How to prevent back flow
Diffley emphasized the importance of preventing contaminated water from back flowing into wells from dunk tanks or chemical tanks.

“Hose ends should not be inserted into the water in dunk tanks or chemical spray tanks,” she said. “Garden hoses can harbor and breed bacteria. Every single faucet should have a back-flow preventer.”

She urges farmers putting in new systems to install back-flow preventers in line between hydrants and wells.

Co-management of food safety and conservation practices
Diffley said food safety requirements and conservation practices are not mutually exclusive. She pointed out that the Produce Rule does not require farms to exclude wildlife from outdoor growing areas, to destroy wildlife habitat, or to clear borders around growing or drainage areas.

Even so, because wild life could create food safety risks, measures should be taken to minimize wildlife incursions into growing fields. However, removing conservation habitat can be not only environmentally damaging, it can increase food safety risks.

“There can be many food safety benefits to co-management,” she said.

UC-Davis researchers, for example, found that wetlands or several meters of grass can filter up to 99 percent of E coli during rain events. Other research includes a study pointing to the importance of biological diversity — a reduction in rodent species diversity may cause increased pathogen prevalence in the individuals that remain, and biodiversity loss frequently increases disease transmission.

Diffley said farmers should map the sources of potential contamination and then identify how pathogens can be moved on to produce, such as in water or with wind, or on equipment or people. She also discussed the impact of sunlight and UV light on microbe survival and reproduction.

Using Wild Farm Alliance materials can help farmers co-manage to minimize the chance that their produce could get contaminated while protecting natural resources and habitats.

Rob Smith

Rob Smith

Farmers’ comments
Susan Schuh, co-owner with her husband Steve of Schuh Farms, a 300-acre farm near Mount Vernon, WA, said she attended Diffley’s training session because the safety of her produce has always been important to her.

“We don’t want to get people sick,” she said. “We know we have to be careful about it. I’m here so I can learn more about it and write a food safety plan.”

Although the farm uses city water, which is potable, she said she was surprised to learn that washing produce can pose a problem.

Rob Smith, operations director of Viva Farms near Burlington, WA, said that food safety is an important part of doing business as a farm.

“It’s gone from the realm that a farm probably should do a food safety plan to that a farm definitely needs to,” he said. “That’s a big shift.”

Matthew Aamot

Matthew Aamot

Matthew Aamot, who currently works with Growing Washington, a farming operation that will be doing some wholesaling, is also starting his own farm, Kickerville Community Farm, in northwest Washington.

“Food safety is truly more important than it ever has been,” he said.

“You don’t want to comply with the law at the last minute. What we do now is important so that we’re ready. Ships don’t turn on a dime.”

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