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FSMA Comment Deadline Approaching Fast

12/4/2014

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The comment period for the revised proposed Produce Rule for the Food Safety Modernization Act closes Monday, December 15. And the FDA needs to hear from you.

The good news? The National Sustainable Agriculture Coalition has made it ridiculously straightforward to comment on the rule. They have a complete guide to the process, and even a Word document template that you can use to guide your comments. Everything you need is right here: sustainableagriculture.net/fsma/speak-out-today/

The other piece of good news? The voices of farmers and farm supporters made a huge difference during the original comment period – enough so that the FDA took the relatively rare step of making major revisions to their proposal and then re-opening the comment period. We need to make a similar impression this time around – the new proposal is a substantial improvement over the previous proposal, but it still has some serious flaws.

If you raise fresh produce, think you might want to raise fresh produce in the future, or just want access to locally grown fresh produce from real family farms, it is imperative that you take the time to comment on the rule. We’re going to have to live with these regulations for decades to come – the last major revision to the nation’s food safety regulations was in 1938 – so go now to sustainableagriculture.net/fsma/speak-out-today/ and use their great information and tools to make your comments.

There are plenty of issues to address in the proposed Produce Rule, but here are my top four:

Farms should be defined by their activities, not by ownership or geography.

The proposed definition of a farm – which keeps an operation or activity from being regulated under the far-more-stringent rules for processing – should be based on common sense and risk-based distinctions.

The current proposal would define a farm as being under “one ownership” and in “one general physical location.” This lacks clarity and common sense – my own farm utilized two different parcels more than three miles apart, but that certainly did not increase my food safety risk. Neither does owning the property where you grow your produce while leasing a packing shed on a different piece of property nearby.

These are not the science-based regulations that congress called for when it passed the Food Safety Modernization Act. Farms come in all different shapes and sizes and all kinds of ownership structures; the Food Safety Modernization Act needs to accommodate the creativity that farmers use in meeting their resource needs. Anything less threatens the survival of current operations, and creates tremendous barriers to entry for beginning farmers.

Farm activities are farm activities, regardless of where they happen,

The proposed rule regulates the same activity differently depending on where it happens. If you wash your produce, trim outer leaves, or put stickers on your watermelons on your farm, that’s considered to be “farming.” If you do the same activities on your neighbor’s farm, that’s also considered to be farming. But if you wash your produce in a packing house that isn’t on a farm, that’s considered to be processing or manufacturing, and falls under additional regulations.

If washing produce doesn’t present a public  health risk when it’s done on a farm, there’s no reason that it should present a public health risk when it’s done off the farm. This rule would stand in the way of the development of multi-farm CSAs, food hubs, and even farmers markets.

Testing surface water isn’t necessarily connected to safety.

The FDA has backed off of the crazy requirements for water testing that were present in the original proposal, but they are still asking farmers to test surface water 20 times per year to establish a baseline risk threshold.

Tests would indicate how long farmers need to wait between applying overhead irrigation and harvesting produce, based on… well, here’s what the FDA has to say: 

For example, if you determined (using the procedures described in proposed §§ 112.45(b) or 112.45(c), as applicable), that your agricultural water which is to be used for the purposes described in § 112.44(c) has generic E. coli levels with a GM value of 241 CFU per 100 mL and a STV value of 576 CFU per 100 mL, your water would not meet the microbial quality specified in § 112.44(c), in that your values exceed both the GM value of 126 CFU per 100 mL and STV value of 410 CFU or less per 100 mL. Under proposed § 112.44(c)(1), you would be able to use this water by applying a calculated time interval of 1 day between your last irrigation event (by direct application method) and harvest of the crop. Using a microbial reduction rate of 0.5 log per day, a 1-day time interval would be sufficient to meet the microbial quality requirements specified in § 112.44(c) because it would reduce your GM and STV values to 76 CFU per 100 mL and 182 CFU per 100 mL, respectively.

Do you really want to try to figure that out in August?

Instead, FDA should implement the common-sense solution used by growers and recommended by Cornell University – a several day wait between overhead irrigation and harvest, or cleaning crops with water treated with a wash-water sanitizer, multiple fresh water rinses, or a flowing rinse. The science backs this up, and it’s an easily implemented solution.

Not regulating raw manure use right now is just crazy.

The FDA has proposed to delay the creation of a new standard for raw manure management. This makes sense – I’ve reviewed the research and it is not clear what the appropriate pre-harvest application interval would be. But the research is clear on one thing – the organic standard for raw manure application makes sense. Let’s go with the very workable, very safe 120-day waiting period if the edible portion is in contact with the ground, and 90 days if it isn’t.

Now, go.

Seriously. This is important. Go right now to sustainableagriculture.net/fsma/speak-out-today/ and follow their easy instructions.

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Probability and Seriousness in Food Safety

6/19/2014

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Risk is the sum of probability and seriousness, less the preventative and contingent actions taken to reduce it.

To get all math about it:

Risk = Probability + Seriousness - (Preventative Actions + Contingent Actions)

In the context of food safety for fresh produce, it's easy to forget this. So many resources spell out the things we can do to mitigate risk - from washing your hands and keeping food off the floor to using sanitized pallets and requiring workers to bathe daily - without providing any context about the probability of contamination.

Prevention in food safety comes down to keeping the poop off of the food. Preventative actions vary in their effectiveness. For my money, good hand washing - thorough scrubbing in running potable water with soap and drying with a single-use towel afterwards - provides the single biggest risk reduction. Everything else (except not dumping raw manure on your vegetables) pales in consideration.

Operating under the assumption that our produce is contaminated, we take contingent actions to keep the bacteria from spreading or growing. Washing in running water, sanitizing wash water, and cooling produce to slow enzymatic activity all reduce risk.

Of course, the seriousness of a food safety outbreak is high - E. coli 0157:H7 and Salmonella enterica can kill people. But the probability is relatively low - in the 2006 spinach - E. coli 0157:H7 outbreak, only three people died, and a couple hundred were sickened, despite over 250 billion servings of fresh bagged salad greens having been sold in the United States that year.

Effective food safety plans leverage preventative actions that are relatively straightforward and common sense to reduce the risk of a contamination incident, and back them up with contingent actions that reduce the risk of a single contamination incident spreading or multiplying.

When you are considering a food safety plan for your farm, focus on those preventative and contingent actions that yield a high return. A series of one-percent reductions in risk will add up, but you get far more bang for your buck by focusing first on those actions that yield big results.

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Food Safety Modernization Act Exemptions

3/30/2013

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The proposed Produce Rule for the Food Safety Modernization Act seems to be circling around out there, creating a lot of concern for some folks and not getting much notice from anybody else.

Despite the exemptions contained in the Tester-Hagen amendment to the legislation passed by Congress in 2010, many operations large and small are going to fall under the legal oversight of the Produce Rule or the Preventive Controls Rule.

Exemptions to the rule are based on a number of factors, including total food sales, the production of certain crops (including rutabagas), the kinds of customers you sell your produce to, and where those customers are located. The Produce Safety Alliance put together a one-page decision tree for determining an whether an individual operation will be exempt from the Produce Rule – you can link to that document here.

Do take note that just because an operation is “exempt” from the Produce Rule does not exempt that operation from meeting minimum federal requirements. You still can’t sell adulterated foods, and exemptions can be withdrawn if your farm products are linked to a food contamination outbreak.

In addition, if your operation buys in produce, you could fall under an additional set of regulations, the Preventive Controls Rule, with its own set of exemptions and timelines for compliance.

While the rule is still in the “proposed” phase, 2013 is not too soon to start working towards compliance. This doesn’t mean that you have to get all the way there in just once year, but it does take time to assemble and implement a food safety plan for a fresh market vegetable operation. At a minimum, developing an awareness of food-safety best practices this growing season will help even if you do the heavy lifting of operational changes in the winter.

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Local Food Lies, Part I

2/2/2012

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I’m tired of hearing about how local food is fresher than produce trucked in from California, Arizona, and Mexico. “Freshness” relates to the amount of biological activity that has occurred from the time of harvest to the time a vegetable is prepared in your kitchen. Local food can provide tremendous benefits to a community’s economic vitality, to the flavor and selection of produce, and to a more-secure, less-carbon-outputting food system; but freshness is not a fundamental quality of locally-grown produce.

When I started Rock Spring Farm, I went to a meeting of growers for local food producers in Decorah at which the produce manager of the local natural foods cooperative commented that the lettuce she purchased from local producers didn’t last very long, while the produce from California had a shelf-life of a week to ten days. I had experienced the same thing with local produce on a farm I managed in Maine, and it all comes down to temperature. In both of those times and places, local growers hadn’t invested in the equipment and systems necessary to maintain produce quality.

Within the range of temperatures where plants survive, the rate of chemical and biological processes approximately doubles for every ten-degree increase in temperature. That means that produce stored at 45 degrees will last half as long as produce stored at 35 degrees; and produce stored at 55 degrees will last only a quarter of the time. When we pick a vegetable, we separate it from the source of energy and sustenance that comes from having its extensive network of roots expanded throughout the soil – at this point the portion of the plant we’ve picked begins the process of dying, which in vegetables is characterized by a decline in “freshness” and quality.

Getting produce cooled to the proper storage temperature is the first essential step in ensuring freshness; keeping it at the proper temperature is the second. The large-scale production systems in the vegetable-producing regions of this country dedicate a tremendous amount of infrastructure and energy to getting produce cold and keeping it that way. It is not unusual for a harvest operation to include refrigeration units right in the field, climate-controlled packing facilities, and refrigerated transportation from harvest right to the point of sale.

Furthermore, it’s not just the air temperature of the storage environment that matters – it’s the interior temperature of the produce. Grocery store coolers and home refrigerators do not have the power they need to actually suck the heat out of warm produce – that needs to be done by the farmer. And dunking in cold water (ground water comes out of the tap at around 45 degrees on the Iowa-Minnesota state line) and storing at ambient temperatures just can’t do that.

At Rock Spring Farm, we’ve invested in the cooling facilities and harvest systems that get produce cooled quickly, and keep it cold until it’s sold. Whether it’s planning for harvest to allow time for equipment to cool the produce, our rapid harvest techniques and shading in the field prior to transport to our insulated packing facility, adequate potable water to provide a continuous supply of cold water for initial cooling, our commercial-grade walk-in cooler, or the cold chain our delivery partners maintain throughout the delivery process, we work hard to ensure that vegetables will stay alive – and stay fresh – for as long as possible.

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Good Food, Good Systems

12/15/2011

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Over the last twelve years, I’ve worked hard to develop systems at Rock Spring Farm that consistently provide our customers with clean, ready-to-use vegetables and herbs. As the farm grew beyond the size that could be operated by just one or two individuals, I’ve had to learn how to communicate the how-and-why of what we do to an ever-growing and ever-changing crew of individuals who flow through this operation from year to year.

I’ve had ample opportunity over the last few years to learn that I can’t possibly do it all myself. This wasn’t an easy lesson for this farmer to learn. I didn’t get into this business to manage people – in fact, like most farmers, I didn’t get into this business to manage a business! I got into this business to drive tractors and dig carrots and listen to the birds sing. But having employees on the farm enables me to make a living at the same time that it allows me the flexibility to pursue other projects beyond the day to day work of growing rutabagas.

Having well-trained and empowered employees also has a tremendous impact on my and my family’s quality of life. Without a competent and invested crew, I wouldn’t have the ability to leave the farm for days at a time on vacation, or even to attend mid-day events in town on days when we need to pack CSA boxes. And it’s not just vacations, but my ability to have an impact on the world of organic farming by serving actively on non-profit boards and providing education, outreach, and consulting to farmers around the country (not to mention co-directing the MOSES Organic Farming Conference).

On a small, diversified operation like Rock Spring Farm (we are the largest organic vegetable farm in Northeast Iowa, but still a rather small operation in the overall scheme of organic produce), everybody plays a variety of different roles on the farm. We don’t have a food safety manager who dedicates all of their time to watching out for regulatory and common-sense compliance; even a packing shed manager ends up riding on a transplanter. The fact that everybody has complicated and multi-faceted roles to play on the farm means that everybody needs access to a diverse array of knowledge about how to accomplish just about every task on the farm.

Last fall, when we decided to pursue a food safety certification through the USDA-GAPs program, we had to begin to document our procedures and improve our record-keeping to demonstrate that we did indeed implement the procedures we had documented. This has led to an effort to document our practices throughout the farm, an ongoing process that we expect to finish this winter. While’s it’s not a substitute for elbow-to-elbow training, a good operations manual will help ensure the continued smooth operation of the farm, and the consistent production of good food, good soil, and a great quality of life for everybody involved in the farm.

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Purple Pitchfork is a project of Renewing the Countryside, a non-profit dedicated to rural revitalization and collaborative farmer education that serves as the home for these resources Chris Blanchard created.
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