Waging a successful battle against the foodborne pathogens that can sicken people — or even kill them — takes some creative strategizing on the part of small- and mid-size farms, primarily because they’re so different from large farms and even from one another.
With that in mind, about 25 people took advantage of the invitation to come to Viva Farms, an incubator for new farmers near Burlington, WA, on Oct. 24, 2015, for a free morning workshop on food safety, followed by an afternoon computer session at Skagit Valley College. (Ongoing verbal Spanish translation was provided during both sessions by Kate Selting-Smith, Washington State University Extension Small Farms Program.)
Turns out that a computer and a flash drive, complete with practice sheets, templates, and checklists, can be just as useful as a hoe and a tractor when it comes to successful farming in today’s world.
Presented by Viva Farms, the Washington State Department of Agriculture, and Washington State University Extension, Saturday’s “Bridging the GAPs” workshop was designed to help small and mid-sized diversified farmers learn practical and cost-effective ways to establish food-safety practices on their farms. One of the goals was to help the farmers get started on writing a plan that would meet the requirements of USDA’s Good Agricultural Practices (GAP) and Good Handling Practices (GHP).
On hand to offer advice and information about what farmers need to do to pass a third-party audit was Wade Clark, auditor for the Washington State Department’s Fruit and Vegetable Inspection Division.
Passing a third-party audit has become increasingly important to small- and mid-sized farms as they reach out to sell to retailers and institutions, such as schools and hospitals, because many of them require an audit. Then, too, the U.S. Food and Drug Administration’s (FDA) Food Safety Modernization Act (FSMA) Produce Rule is expected to be finalized and published soon. And even though it exempts many small-scale farmers, it doesn’t exempt them from being responsible for their customers’ health — or from lawsuits if their produce ever sickens people.
Farms that pass the audits have their names put on a USDA list which buyers can access. The voluntary GAP/GHP Audit Verification Program was written in response to FDA’s “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables.” A successful audit shows a farm’s commitment to following and maintaining guidelines to help minimize the potential risk for microbial contamination of its produce.
The audit verification program examines such things as worker sanitation, field harvesting and transportation, traceback, water use, manure and compost use, the soils, and temperature controls.
In 2014, the USDA Audit Program performed more than 3,800 Good Agricultural Practices (GAPs) and Good Handling Practices (GHPs) audits in 46 states and Canada, covering in excess of 90 commodities.
Why they were there
Nic Mishouck and Gina Falcetti of Northwest Horticulture said they were at the Oct. 24 workshop because now that they’re selling food, as opposed to just ornamental nursery stock, they wanted to learn what is necessary to meet the requirements of the grocery stores to which they want to sell.
“We’re expanding now,” Falcetti said about their hydroponic lettuce-growing operation, “and we want to get to know the food-safety consultants so we can work with them.”
Senaida Soto, co-owner of a small WA blueberry farm, grew up in Mexico and worked with her father on farms. She said that, in some ways, there wasn’t much of a focus on food safety back then.
“Now in comparison, it’s better — much safer,” she said, adding that following food-safety practices benefits both the farmers and the consumers.
“I learned a lot today,” Soto said as she worked on a checklist in the “Bridging the GAPs Farm Guide” and drew a map of her farm using Google Maps during the afternoon computer session.
Francisco Sanchez-Reyes, who currently works on an Oregon blueberry farm, said he came to the workshop because he wanted to educate himself about food safety so he can have his own farm one day.
Comparing food-safety concerns here in the United States to those in Mexico, he said that “more than anything, it’s market-driven” in the U.S.
“Consumers want safe food,” he said. “Food safety has had a huge impact on the way things are being grown and harvested.”
As they worked on checklists during the afternoon computer session, Sarah Dublin and Adam McCurdy, who work at Oxbow Farm and Conservation Center in Carnation, WA, said they wanted to get up to speed on how to implement GAPs since the farm is doing more and more business with wholesalers and institutions.
“All the markets are requiring GAPs, and we also want to be ready for the regulations in the Food Safety Modernization Act,” McCurdy said.
“When we first sat down, our initial question was, ‘Where do we start?’” said Dublin. “It’s so helpful to have facilitators here to help us and a manual that’s so full of information.”
Karen Ullmann from the Washington State Department of Agriculture noted that learning how to establish good food-safety practices on a farm is important not just for the sake of consumers’ health, but also for the economic health of a farm.
“You want to protect your business,” she said. “Markets are looking for food safety and quality assurance.”
Tricia Kovacs, the department’s GAPs project coordinator, told the farmers that in crafting a food-safety plan, they “have to think creatively about what the risks on your farm are, even what’s happening next door, that can affect your farm. A lot of this depends on your situation.”
In other words, there’s no one answer that will fit every farm’s needs.
As the participants walked through Viva Farm’s fields looking at the wide diversity of crops — among them blueberries, artichokes, cabbages, tomatoes and peppers — Kovacs asked them to pretend they were microbes — the kind that can sicken people.
“They want to move from place to place,” she said, adding that’s why a farmer needs to look at his or her entire operation and assess how these microbes could get from place to place and contaminate the produce.
Something as basic as knives used on the farm need this sort of diligence. Keeping them clean and putting them in sanitation buckets is part of this, but putting them in a leather sheath is not a good idea because a leather sheath can’t be sanitized.
That’s just one small part of the overall picture. Another example is assessing hand-washing stations and making sure the water doesn’t pool on the floor, which could allow any pathogens in the water to be picked up by a worker’s boots and transported to other areas of the farm.
Also important is thinking about what’s on the bottoms of the bins where food is put when being harvested. If the bins are put on the ground and dragged along, then dirt will be moved from one place to another.
“It only takes a few cells of E. coli O157:H7 to make people sick,” Kovacs said.
The bottom line, she said, is that farmers need to “think through what can go wrong here,” when assessing all of their farm’s practices.
A typical audit, which occurs during harvest season, takes from 2 to 7 hours and starts with a look at the farm’s paperwork. The typical cost is $92 per hour, plus mileage and transportation time.
Clark said an auditor will be looking at a farm’s policies and procedures and also at documentation showing that these procedures are taking place.
“We have to verify that you’re actually doing it,” he said. “The documents corroborate that you’re doing what you say you’re doing.”
After the sit-down session, the auditor goes out into the field to see what’s happening there.
An automatic failure, which can end an audit, could result from employees not washing their hands, rodents, fecal matter, and water running from pipes in a cooler onto the produce. But a farmer can fix those problems and ask for the audit to resume.
Kovacs assured the group that, “We’re never here to shut you down.”
Passing an audit requires an 80-percent grade in each of the audit categories. In all of them, cleanliness is paramount. Also, a written food-safety plan is required to pass an audit.
One step forward, one step back is what farmers need to document when selling their produce to buyers. If anyone gets sick, someone will call, and a farmer will want to be able to say where the food came from, and, better yet, what part of the farm it came from.
The more detailed the information is about just where the produce came from, the less a farmer will have to recall.
Rob Smith, operations and incubator director for Viva Farms, explained how the farm’s produce is labeled, which includes a code number showing the date and location of where the crop was harvested. That’s the “going one step back,” he said. Using invoices is the “going one step forward.”
“There are definitely a lot of good reasons for all of this,” Kovacs told the farmers as they stood outside the farm’s cooler.
In the afternoon, the farmers sat at rows of computers at Skagit Valley College — some of them with people who could help them navigate Internet technology — while Ullmann told them that the session was designed to provide a “deeper dive” into the “GAPs Farm Guide.” Each workshop participant received a free guide and a free flash drive with all the templates and checklists in the guide.
Kovacs and Ullmann explained how farmers could use the checklists, practice sheets, and templates to craft their own food-safety plans. Because they could take the flash drives home, they can keep working on their plans.
Once the farmers draw up a plan for water use, Kovacs said it’s helpful to go back to the audit checklist to make sure it meets all the requirements an auditor will be considering. For example, don’t forget to mention if the water provided for hand-washing is potable (meaning it’s safe to drink) and if there are signs posted showing the proper hand-washing techniques.
Other things an auditor will be looking for: clean soil, clean water, clean hands, clean surfaces, and how the food is packed, handled, and stored.
Farmers were advised to draw up their food-safety plan in the order of the checklist in the guide to make it easier for the auditor to work through each item.
About the GAPs guide
“Bridging the GAPs Farm Guide: Good Agricultural Practices and On-Farm Food Safety for Small, Mid-sized, and Diversified Fruit and Vegetable Farms” was developed as a resource to assist farmers as they implement good agricultural practices and prepare for GAP/GHP audits.
Writing a food safety plan using the resources and templates in the guide is a good place to start, although it does not guarantee a successful audit. Throughout the guide are helpful tips about various topics from auditors.
The guide is also available in Spanish.
Other audit resources
- On-Farm Food Safety: This site will walk a farmer through a self-audit.
- Buenas Practicas Agricolas
- A Food Safety Plan for You, Templates and Log Sheets (also in Spanish)
Timeline on FSMA rules
The first two of the seven FDA FSMA rules — Preventive Controls for Human Food and Preventive Controls for Animal Feed — were finalized in mid-September and are now up on the Federal Register. The effective date for compliance for some companies starts in September 2016.
Broadly, the rules governing human food require registered food facilities to maintain a food-safety plan, perform a hazard analysis, and institute preventive controls for dealing with those hazards. Facilities also have to verify and document that their controls are working.
The Produce Safety Rule is expected to be finalized this month. This rule establishes science-based minimum standards for the safe growing, harvesting, packing, and holding of produce on farms to minimize contamination that could cause serious adverse health consequences or death.
More workshops coming
Kovacs said that the department will be offering more of these free workshops for farmers around the state. For more information, contact her at (206) 256-6150, or email to firstname.lastname@example.org. Ullmann can be reached at (206) 256-6151, or email to email@example.com.
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