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Aquaponics and Food Safety

Aquaponics and food safety has come up over the past two months in several meetings across the state. Specifically can I get a GAP certification while growing my produce with aquaponics? How do I deal with manure?

Here are some documents to help with developing food safety

On-Farm Food Safety: Aquaponics

Microbial Water Quality Related to Food Safety with Aquaponics

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Points analysis of the USDA GAP Audit Checklist

To assist farmers in passing a USDA GAP certification, I determined which categories of the USDA GAP audit checklist have the most impact on the final score. Questions in each part (General, Part 1,2,3 and 4) were placed in categories such as equipment/containers, water/ice, facilities/storage, animals/pests, product handling, worker health and hygiene, bathroom and handwashing, traceability, sewage/waste, transportation, manure, and land history.

In Table 1, questions from all parts (General, Part 1, 2, 3 and 4) are ranked into categories and points were tallied. Each question number is labeled with a color to identify what action should be taken (as defined by the USDA GAP checklist):

  • Record, red  (a record is required to be kept showing an action was taken)
  • Policy, blue (a policy/SOP must be documented in the food safety plan in order to show conformance to the question)
  • Document, black (a document is required to show conformance to the question. May be a combination of a policy and a record indicating that an action was taken)
  • Observation, green

Each question number is listed in the appropriate value column:

  • 5 points
  • 10 points
  • 15 points

In Tables 2-6, each individual part has the questions divided into ranked categories. The points for each category are broken down into which action needs to be taken: record, policy, document or observation.

We encourage any comments/responses to this analysis of the USDA GAP audit.

Agritourism and Food Safety Webinar

On Wednesday, December 14th, I participated in a webinar about Food Safety Education and Planning for Agritourism Providers. This webinar was hosted by Ben Amsden from Plymouth state university center for rural partnerships, and Lisa Chase and Londa Nwadike from University of vermont extension and focused on discussing risk management and food safety practices for those involved in agritourism activities. Most of the farmers in our project participate in agritourism events such as U-pick operations, farms stands, and community supported agriculture, and they have asked questions about how to deal with the health and hygiene practices of patrons.

The first part of the webinar focused on risk, seeking advice on risk management, and developing a risk management plan. Most farmers are familiar with general or product liability insurance however other plans are available can that cover special events, the premises, and physical damage. The second half of the webinar discussed food contamination, the impact of foodborne illness, and risk-based food safety principles. It is important to discuss issues with your employees like how to influence patrons to employ good hygiene practices when coming on your farm. The proper placement of signage and availability of  sanitary facilities will encourage patrons to follow good hygiene practices on the farm.

Agritourism is not normally discussed when talking about on-farm food safety but this is a significant source of revenue for some farming operations. This reminds me that each farm is different with different inputs (water, animals, workers, and patrons) requiring the assessment of risk on each individual farm and the development of risk reduction strategies that meet the needs of the farm.

Please find the recorded webinar, Powerpoint slides, and other resources at Agritourism:A Web-Based Resource for Farmers

How to get to Audit day…

The ultimate goal of the project is to prepare the participating farms to pass a USDA GAP certification. USDA GAP auditors are a 3rd party  (what that means is they are independent of both the organization being audited and any customers of the organization). They can offer resources to point you in the right direction to receive the guidance you need. Good resources for producers as they get ready for an audit are local extension agents, university representatives, or other farmers.

To schedule an audit in NC, complete and send this form (Request form) to NCDA&CS marketing division grading services along with your proposed audit dates (4 weeks in advance at the minimum) and a copy of your food safety manual. Before the audit day, the auditor needs to know the type of audit requested (USDA GAP audit, Harmonized food safety standard, Tomato audit protocol (T-GAP), Leafy greens audit (LGMA), and Identity Preservation Audit ; parts desired to be completed of the USDA GAP/GHP audit (Part 1&2 to be completed for GAP portion, Part 3&4 to be completed for GHP portion, Part 6 is for wholesale distribution centers, and Part 7 is for preventative food defense procedures) and reviewed your food safety manual; and, any previous audits completed. All crops the participant requests to be audited must be in production.

When the auditor arrives, the auditor will confirm with the farm the type of audit and parts to be completed, and attain records and documentation.

The audit will begin with the general questions and all parts have to pass the general questions. There will be an automatic fail if there is a high likelihood of product being contaminated, high presence of rodents or pests, observation of employee non-compliance with health and hygiene policy, or if you don’t have a food safety manual or food safety officer.

During the audit, the auditor will observe processes on the farm, including proper signage, availability of bathroom and handwashing facilities, and conditions of containers and storage, etc.

The auditors will confirm that employees are complying with standard operating procedures and policies. At times the auditor will need to review records even though the audit does not call for it. The audit will be stopped immediately if the farmer is found to have falsified records – automatic failure. Upon completion of the audit a report will be available. This report contains a completed checklist with score sheet and corrective actions. Auditors will write comments for all questions answered No or N/A.

Before the auditor leaves they will discuss the audit findings and the farmer will be able to discuss corrective actions. The auditor will also ask about the seasonality of the business so they can make arrangements for the follow-up or unannounced visit. This is important when auditing multiple crops so that the auditor can see as many things in production/harvest as possible.

In addition to an administrative cost of $50, the audit fees are $92/hour. The fees cover time on site for conducting the audit, travel time and preparatory time.

This summarizes the main things that many farmers will encounter as they get to the stage of an actual audit.  This project’s participating farmers are compiling materials and scheduling their USDA GAP audits, many for the spring.

GAP Audit Worksheet

Throughout this project, our participants are encouraged to make self diary entries discussing certain food safety topics and the GAP certification process. One of the reoccurring themes discussed by participants in their self diaries is the difficulty they have in comprehending and navigating the audit verification sheet.  This confusion causes participants to feel frustrated. In an effort to make the USDA GAP audit more manageable, I’ve put together a GAP audit worksheet that separates the audit content into three sections, Records (logs), Policy/Documents, and Observations.

There are three forms of in which an auditor will be determining conformance on page 3 of the USDA GAP Audit.  They are record, policy, and document. A record will show an action was taken (Records (logs) column in worksheet). A policy or standard operating procedure will be documented in the food safety plan (Policy/Documents column in worksheet). A document can be a combination of a policy in the food safety manual and a record showing an action was taken (These are indicated by # in Policy/Documents column in the worksheet). Thus documents can be a combination of a policy and a record. In the USDA GAP audit, there are several instances where an auditor will need to observe to determine compliance (Observations column in the GAP Audit worksheet document). We encourage any comments/responses to this GAP audit worksheet.

Signs, Signs, Signs…

Recently a farmer asked me, ‘where can I get signs for my farm?’ I responded, ‘I am not sure.’ I have one farmer ordering their signs so they can personalize them for their farm. But no one else has asked me this question. So I decided to performed several internet searches and this is the result. My boss recommended Home Depot so that is where I started.

Home Depot – no smoking sign

Safetysign.com – all kinds of signs

Compliancesigns.com – handwashing signs

Healthcaresigns.com – handwashing signs

Justbathroomsigns.com – bathroom signs

Emedco.com – handwashing signs

Staples.com – policy signs

 

 

 

 

 

You want me to call my buyer and say what? Mock Recall

During my visits, I am working with farmers to build their food safety manual (Manual template 1, Manual template 2, Manual template 3). Going over the food safety logs (Logs 1, Logs 2, Mock Recall Log) a farmer asked me ‘Why do I need to complete a mock recall I am very small?’ There are not a lot of examples of how small farms recall product because the media usually follows the big companies associated with high numbers of illnesses and affected product.
During June, a small farmer producing sprouts received an email about 12 hours after Germany announced the E. coli outbreak had been linked to sprouts. The email was from a community supported agriculture (CSA) customer claiming to have received foodborne illness from their sprouts and therefore no longer trusted the farm’s produce. The farm immediately stopped production and began implementing their good agricultural practices (GAPs) traceability system. The farm proceeded by contacting their customers and canceling all orders that were due to be delivered the next day.  Additionally, they asked wholesale customers to remove their sprouts from sale immediately and record the amount disposed of so that the farm could reimburse them. The farm did not bother with individual customers since they had no way of contacting them personally. The farm took the remaining sprouts that were due to be delivered the next day to the dump.
Aside from one customer complaint which was not confirmed, the farm received no other complaints but this farm no longer intended on selling sprouts. Here are some examples of mock recalls preformed by larger companies (Mock recall 1, Mock recall 2).

To be prepared for a recall situation, farmers can complete a mock recall annually to test the plan they have in place.  A mock recall is a simulated recall exercise with a time limit to complete the entire exercise (i.e. 2 hours). Recalls are voluntary procedures conducted to identify and recover potentially adulterated, misbranded, and/or hazardous foods from trade and/or consumer channels effectively. For information on currents recalls go to the FDA recall website.
To perform a recall, you will need to be able to trace each load leaving your farm to the field of origin and date of harvested. You will need to establish a code lot numbering system (i.e., lot or product codes). Every package of outgoing product must have a traceability code, such as a Julian date or a specific sequential code. Regardless of how the code is made, it should provide the farm with information on how to identify the produce. In fact it can separate the amount of product implicated in a recall such as if one day is a lot then the minimum quantity implicated would be the entire day’s production.

Here is a checklist for your recall plan:
1)    Be sure names and phone numbers of customers who need to be contacted are available and current.
*For farmers with only one CSA program, you should know their main contact and a back up for them.
2)    Be sure of names and phone numbers of media representatives, proper authorities (FDA, NCDA, etc.), and legal council.
3)    Identify the problem and assess the health risks.
4)    Determine the products and lot numbers involved.
5)    Determine quantities involved.
6)    Determine current inventory on the premises.
7)    Determine the amount of product in the marketplace.
8)    Identify the customers who have received the product.
9)    Collect pertinent documentation regarding the affected product.*Inputs and outputs of affected field, notes on unusual events (flooding, wildlife activity, etc).
10)    Determine the percent effectiveness of the mock recall
The total amount of suspect product must equal the sum of the product shipped and the amount still in inventory.
A – total amount of product produced
B – Amount still on inventory
C – Amount delivered to customers
D – Incidental usage (product dropped on ground, etc.)

11)    Outline the shortcomings in our recall plan and what corrective actions will be taken. *For example, taking longer than 2 hours and not being able to account for 100% of the product.
*Testing these programs is the best way to ensure their effectiveness and to best ensure preparedness for an actual recall.

A majority of our farms sell directly to the consumer through roadside stands and farmers’ markets. In the event of a recall contacting these types of customers can be difficult to unrealistic. During my visits I brainstorm with farmers ways of contacting these types of patrons, such as through email sign up sheets, website notifications, and signs at the stand/farmers’ markets.