By Cheryl A. Wixson
Passage of the Federal legislation S.510: FDA Food Safety Modernization Act reflects consumers’ needs and desires for assurance that their food supply is free from pathogens and contaminants that cause foodborne illnesses. Russell Libby, MOFGA’s executive director, logged countless hours in Washington, D.C., advocating for small, diversified farms as the bill was developed.
Many have speculated that S.510 will be the death of home gardeners and small farms. While the rule-making process allows for continued input, MOFGA views this legislation as an educational and marketing opportunity.
Understanding how hazards can enter the food stream and the science behind minimizing these contaminants gives farmers and gardeners the tools to grow safe, healthy, nutritious crops. Developing and implementing a Farm Food Safety Plan allows farmers to expand their markets to such institutions as hospitals and schools.
For farming purposes, the food stream is defined as the path that the fruit or vegetable takes from the beginning to the end-user, the consumer, including sourcing seed, preparing soil, planting, growing, irrigating, harvesting, processing, storing, transporting and displaying the crop at the market.
Four broad categories of sources of contaminants in the food stream are people, water and sewer systems, animals, and compost and/or manure.
Farm workers, employees, family members and visitors are the primary sources of potential hazards for food safety. Worker health and hygiene are critical to farm food safety. Does your farm have adequate toilet and hand-washing facilities for workers? Does signage encourage appropriate hand washing? Do workers understand the importance of good hygiene? Do workers who are sick or have open wounds handle food? Does your farm provide training and education? Are visitors limited to certain areas of the farm?
Carefully analyzing your farm’s food stream could lead to changes in your processes. For farmers interested in expanding their markets to institutions, a farm wellness policy, worker training and education, and standard sanitary operating procedures are all components of a Farm Food Safety Plan.
Having access to potable water to wash your crop is key to farm food safety. If your farm’s water source is a municipality, the city or town assumes this burden for you. If your water source is private, such as a well, test it annually for bacteria. Maine has several state approved laboratories, with fees usually below $100.
Irrigation water should be from a Class AA, A or B source. (Maine assigns one of four classes – AA, A, B and C – to every river and stream segment in the state and to wetlands associated with rivers and streams, based on monitoring to see which macroinvertebrates and algae they support. See Maine Department of Environmental Protection, www.maine.gov/dep/blwq/docmonitoring/biomonitoring/sampling/index.htm.) Irrigation water should not be contaminated with sewer, manure or compost run-off. Drip irrigation is the most sanitary irrigation method. The farm’s septic and sewer systems should meet all local and state codes.
All farms have an animal presence, whether family pets, livestock or wildlife. Make an effort to contain livestock and animals in ways that minimize contamination via their intrusion in the field. Flag crops that were obviously contaminated by wildlife and don’t harvest them for human consumption. Good housekeeping and appropriate trapping help control rodents and flies.
Manure and compost management plays a key role in farm food safety. For certified organic farmers, the National Organic Program (NOP) standards require a minimum of 120 days between applying fresh manure (and manure that has not been composted according to NOP standards – see next paragraph) and harvesting crops such as carrots, with edible parts that contact the soil directly, and 90 days if edible portions of crops don’t contact the soil directly (such as tomatoes).
Also as part of the Organic Farm Plan, the NOP requires proper compost management to reduce pathogens. The pile temperature must be 131 to 170 F for three to 15 days, depending on the compost system. Manure or compost piles should not be close to the crop and production area, and runoff from these piles must not contaminate a local water source or a field where food is grown. For more about manure and compost management, see the Organic Certification Practice Manual published by MOFGA Certification Services LLC at https://mofgacertification.org/, and the NOP standards at www.ams.usda.gov.
For farmers interested in supplying larger wholesale markets, such as Whole Foods or Hannaford, and institutions, such as schools and hospitals, an independently verified Farm Food Safety Plan is often required. For many of these markets, USDA’s GAP (Good Agricultural Practices) is the recognized plan. While GAP has many worthwhile components, it is not a systematic approach to farm food safety, but merely a checklist and scoring system that is not necessarily effective and useful for small, diversified farms or farms with you-pick operations.
Recognizing the need for an alternative, more scientific and rigorous plan for our farmers, MOFGA has developed a Farm Food Safety Plan based on USDA’s GAP plan but also incorporating FDA’s HACCP (Hazard Analysis Critical Control Points) approach to food safety. This plan would be an addition to the Organic Farm Plan and would be verified by MOFGA Certification Services LLC as part of the organic farm inspection. MOFGA staff and several farmers have been working with Maine General Hospital to develop and implement this process, as Maine General is committed to purchasing more local foods. As hospitals serve our most vulnerable populations, farms with verified Farm Food Safety Plans are critical to this endeavor.
For many of us, the science of food safety can seem overwhelming. To simplify, remember this: The more hands that touch your food, the more likely it will be contaminated. For the consumer interested in safe food, your best bet is to know your farmer. By knowing who produced your food, you limit the opportunities for foodborne illness. For the farmer, understanding that farm food safety is a science-based systems-analysis approach applied to agriculture is important.
MOFGA offers workshops throughout the year on Farm Food Safety. I encourage you to attend one to increase your understanding of farm food safety, help educate consumers and increase your marketing opportunities.
Cheryl Wixson is a licensed professional engineer and MOFGA’s food safety specialist. She welcomes your questions and comments at [email protected].