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Freedom Within the Produce Safety Rule
26 Plays2 years ago
In this episode, Michigan Produce Safety Technicians Landen Tetil and Micah Hutchison discuss some of the requirements (the "musts") of the Produce Safety Rule, and some creative ways that growers can go about meeting these requirements.
Funding for this podcast was made possible in part by the Food and Drug Administration through grant PAR-16-137. The views expressed in the posted materials do not necessarily reflect the official policies of the Department of Health and Human Services, nor does any mention of trade names, commercial practices or organization imply endorsement by the United States Government.
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Transcript
Introduction to Podcast and Hosts
00:00:00
Speaker
Hello and welcome to the Agri-Food Safety Produce Bites Podcast, where we discuss all things produce safety and dive into the rules and regulations surrounding the Food Safety Modernization Act Produce Safety Rule. My name is Micah Hutchison. I am the produce safety technician on the east side of the state of Michigan, and I work with produce growers on the implementation of the FSMA Produce Safety Rule.
00:00:28
Speaker
And hello, my name is Landon Titel and I do the same job, but I am located in the Upper Peninsula and I service Upper Peninsula farmers with any sort of help or technical assistance they might need in regards to on-farm food safety.
00:00:45
Speaker
We're together today in the spirit of the Fourth of July to talk about the freedom of the Produce Safety Rule.
Understanding the Produce Safety Rule
00:00:56
Speaker
It's a little bit counterintuitive because the Produce Safety Rule is a federal law. It's the federal minimum standards for food safety for fresh produce growers.
00:01:07
Speaker
But there's a surprising amount of freedom within the must or the requirements of the produce safety rule. And so that's what we're going to be highlighting today. Micah, do you want to define what the must, when we talk about the must of the produce safety rule, what does that mean? To me, it always means kind of like the bare minimum practices that have to be in place to be in compliance with the law.
00:01:37
Speaker
These are the practices that every farm has to do as set up by the law, not suggestions, not like best practices all around, but just the bare minimum of what a grower must do from compliance. How do you see it?
00:01:57
Speaker
Yeah, I really love that you called it the minimum because I think that really gets to the heart of the produce safety rule. It's the minimum requirements. And so, yeah, I think you nailed it. It's the minimum. Yeah, and I'm always, like on a side note, really surprised with how easy the must are to implement on any farm.
00:02:22
Speaker
Yeah, how minimal the minimum is. Yeah, like you said, you must wash your hands, but there's so many other things that you should do that are like kind of best guides.
00:02:34
Speaker
but not required? Yeah, you should put up wildlife deterrence, but you must at least monitor for the presence of animals. And so there's a big difference between what you can or should do to optimize your food safety versus what is the bare minimum.
Handling Animal Contamination
00:02:58
Speaker
Landon, what does the produce safety rule say about finding poop in the field? What must growers do?
00:03:05
Speaker
Well, man, I love talking about this just for the shock factor that I always get to see on farmer's faces. But you can't harvest poopy produce. You can't pick poopy produce and you don't have to eat poopy produce.
00:03:28
Speaker
So yeah, if you see poop in the field, there should be no harvesting of it. But there's lots and lots and lots of different ways that a farm can choose to go about that. Do you want to throw some of those options out there? I think one of the first options that come to mind are as farmers are assessing fields or doing that pre-harvest assessment, even when out picking, is flagging.
00:03:58
Speaker
poop to let yourself remember where you found poop in the field and anyone else working with you. It's a really great way to have a visual identifier when you come across poop in the field. Yeah, I like the flagging method too. And I actually
00:04:20
Speaker
I actually don't see that method very often in my region though. More often I see, especially with smaller farms that don't have a very large harvest crew, people just sort of picking around it. And so they'll leave a sort of radius around where the poop was found and just harvest around it, but not necessarily stick a flag in the ground.
00:04:47
Speaker
I personally run into farms asking the question, how much, how big should that radius be? What should the space around poop be? And I think that highlights to me some of the freedoms within the rule because there is no set spacing. Yeah, it's not prescriptive at all. And I get that question a lot too. And the first thing I always ask in response is like, well, what kind of poop is it? Whose poop is it?
00:05:16
Speaker
little pelleted deer poop is a different story from a big splatter of bird poop. And also, did it rain the night before? Is there a potential for splash or spread of the bacteria in the poop that maybe we can't see that we have to still take into account? I also talk to farms about that a lot, and that makes me kind of more prone to suggesting that once the poop is found,
00:05:46
Speaker
kind of focusing on proper disposal instead of like flagging and moving forward and picking it up and disposing of it later. Yeah, so how do you tell farms to dispose of it?
00:06:04
Speaker
Well, personally, a lot of the farms I work with are really small market farms. And with crews of like one or two people, family, small volunteers, mostly under 10, people on the crew, and I suggest that they remove it using a shovel that is designated for poop, put it in a plastic bag, and then throw it away. After that happens,
00:06:32
Speaker
I suggest that whoever removed the poop definitely washes their hands. Hopefully they're washing their hands afterwards after they're touching poop. Washing hands is something that is a must. Yes, you must wash your hands. You must wash your hands. And the produce safety rule says a lot about must washing hands.
00:07:00
Speaker
And when do they must wash their hands? Yes, they must wash their hands. And there's lots of scenarios where growers must wash their hands. What I always find interesting is that the produce safety rule talks about hand washing a lot. But what they say about hand washing stations
00:07:18
Speaker
To me is more what hand washing facilities must have. So soap, running water, some sort of adequate drying device. So single use paper towels, electric hand dryers, and then appropriate disposal of those dirty towels and waste waters. When you read the rule, how do you interpret what it says about hand washing stations?
00:07:48
Speaker
Yeah, I think that all of those elements make up a hand washing station.
00:07:55
Speaker
what that hand washing station looks like is just it could be anything and so it could be it could be an actual sink that is plumbed uh you know like hat is hooked up to plumbing and that you don't have to worry about the wastewater because it it gets drained out into your septic um or it could be
00:08:18
Speaker
um like one of those rentable hand washing stations that's like uh like one of those like rentable plastic hand washing stations with the foot pedal that you often see outside of like porta potties at events um you know you can rent those along with your porta potties to have placed on your farm it could also look like a homemade version so it could be
00:08:42
Speaker
like one of those big water coolers with a spout that you can turn on with a bar of soap next to it, or a container of soap next to it, and a big rubbermaid toe underneath to catch the dirty water to be disposed of in an appropriate place at a later time, and then paper towel in a trash can next to it.
00:09:08
Speaker
or we could get even more rustic and do like a tippy tap version where you've got a you know like one of those shepherd hooks with a an old washed out cleaned milk jug full of clean water with like little holes in the cap and you you tip the
00:09:29
Speaker
tips the milk jug with a it's like connected with a string with a little foot pedal on the ground and so you you push the foot pedal with your foot and it tips the milk jug of clean water out so you've got running water and there's soap and paper towel and a trash can nearby for all of those other things. So it could look really different.
00:09:55
Speaker
That took me right back to Girl Scout camp, if I can be completely honest. Micah, you tried to bring up worker training earlier. What does the what does the Produce Safety Rules say about worker training in terms of the musts?
Worker Training Essentials
00:10:11
Speaker
That workers must be trained. Trained on what?
00:10:17
Speaker
You know, that's something that kind of feels really ambiguous when looking at the language. But what it says about a training program is that it must include the principles of food hygiene and food safety, recognizing the signs and symptoms of foodborne illness,
00:10:35
Speaker
and the importance of personal hygiene for all personnel and visitors, and then any other training relevant to the workers' jobs. For harvest crews, there's a few other must. Harvest crews must not pick poopy produce, they must not harvest drop produce, and they must not harvest into dirty or damaged containers. Did I miss anything, Landon? No, I think you got it. And that... So...
00:11:05
Speaker
I'm glad we're talking about the worker training because that sounds like a lot of musts, right? So I can see how someone would like learn that or read that and be like, okay, where's the freedom in this one? See, I look at this, this is so interesting. I look at it totally differently. I think it's a lot of, like there's very few musts. If looking at all of the activities that farm workers do every day that they'll have to be trained on,
00:11:34
Speaker
the produce safety rule requirement seems very low to me. I think the should and the freedom really comes from how you train. And there's a lot of wiggle room in how you train. I think you're right. I think that the way a farm chooses to train their workers can look vastly different from farm to farm and still be effective in every case.
00:12:01
Speaker
I know that some farms really like to do the traditional, we're going to sit the whole crew down in the break room and we're going to go over all of these things. We're going to make everyone read the food safety plan for the farm, maybe have a little demonstration of proper hand washing, something really formal. And others are not so formal. Do you want to give some examples of the less formal ones?
00:12:26
Speaker
I would love to. I adore less formal training. An example to me would be instead of sitting down your whole crew to spend a whole day devoted to training would be to break it up, would be to say these are our training topics at the beginning of each shift and then cover the topics that way. So hey, today we're going to do
00:12:50
Speaker
hand washing. So it's just a really simple demonstration of hand washing. The person training could have everyone kind of, after they explain it, counting to 20 seconds together. So it kind of gives that, this is the pace, this is how long you need to be rubbing your hands together in hand washing before they explain the next steps. And then maybe two weeks later, coming back to the crew that was trained
00:13:19
Speaker
and asking someone to demonstrate proper hand washing to kind of reinforce and re-engage the crews on the topic that they trained on. I love that idea of, you know, I've shown you and now you show me to make sure you understand. I love that idea. Yeah. And I think by the you, I've shown you, you show me, you can bring some humor and kind of spend some time together that isn't just
00:13:50
Speaker
the trainer talking at the workers in a way that can be kind of authoritative and boring, it's really engaging and it creates those connections.
00:14:02
Speaker
Yeah, and there are also a lot of different resources available for farms. So if a farm is strapped for time or maybe a little bit anxious about coming up with their own worker training program, there's lots of resources available that they can draw from. So do you want to talk about some other resources that I think you, I know you're a part of one, right? Yes, I am.
00:14:30
Speaker
as part of our team Michigan on Farm Produce Safety in collaboration with Michigan State University Extension created a text training program where farms can sign up for text training. Their workers will receive a text on a topic that's required for training under the produce safety rule. One of those must and then as part of this text training farm workers then can get
00:14:58
Speaker
the records of who got these text training and keep those records for the rule requirement of record keeping.
00:15:07
Speaker
Yeah, and that's a free service, right? Yes, it's free. Amazing. Who doesn't love getting a text saying, remember to wash your hands and don't pick poopy produce? Who doesn't love not having to worry about record keeping? Yeah. And I'm curious, Micah, in your eyes, does that texting service, would that serve as like a full training program or do you see it more as a supplement?
00:15:38
Speaker
I think it's more of a supplement. It gives that initial training so that here's the rule, here's what you must do kind of aspect. I think that for a good training program, it has to be more than just that piece of education. It needs to be engaging, it needs to be fun, and it needs to kind of be tested. So if a worker receives a text this week on, say,
00:16:07
Speaker
you must not pick dropped produce. I think a comprehensive training program would have the trainer coming back and again, engaging and asking questions of their workers like, so what produce shouldn't you pick? And then hopefully the answer would be dropped produce. And poopy produce. And poopy produce.
00:16:29
Speaker
Yeah, so texting, videos. Demonstration. Demonstrations or discussions. Songs. What's that? Songs, maybe someone could sing it. Yeah, let's rap about hand washing. Training opera.
00:16:53
Speaker
Whoever can make the most amount of vegetable ponds while they're training can make a competition. Challenge accepted. I think in other aspects of the rule, there's a little less freedom than training. Packing containers comes to mind for me.
00:17:14
Speaker
that the rule says that, you know, you must harvest into and pack into clean containers that are free of visible filth. That always kind of makes me feel like there's a more standard requirement than something like training that only new single use containers or cleaned reusable containers must be used to pack produce.
00:17:40
Speaker
Yeah, so I think that this is more of a stringent rule. And with harvest containers, I think it is pretty cut and dry. It needs to be a container that's cleanable enough to be free of visible filth.
Sustainable Packaging Options
00:17:58
Speaker
But in terms of packing containers, so the end packaging that the produce is gonna leave the farm in, the rules gives two options.
00:18:08
Speaker
That's it. It's either a new single-use container or it's Maybe a reusable container, but it has to be cleaned Which means it has to be made out of a material that can be cleaned You know some sort of like durable plastic or other smooth surface like that Yeah, I run into a lot of questions about this while working with farms it seems that the
00:18:38
Speaker
biggest freedom comes maybe from those cleanable containers because you can use them again, especially for farms, like really focusing on sustainability. But this is where I feel like there's less shoulds, like you said, and there's less options for growers.
00:19:04
Speaker
Yeah, and I mean like, I guess there are a lot of different options in terms of like, what you can use as a single, single use container. You know, you could use like, like those little green berry boxes, you can use single use, or you could do a plastic box liner or other container liner as a single use container, or you could use
00:19:33
Speaker
paper bags as a single use container.
00:19:37
Speaker
But I run into that a lot too, Micah, where farms would like to act more sustainably and provide a more sustainable packaging option for their customers. And so maybe that means that they're using the compostable plastic single use bags, but maybe they are trying to find something that's reusable. What have you seen on farm for folks who are reusing and cleaning containers?
00:20:05
Speaker
I mean, you brought up the green berry boxes. I feel like this is one of my heart almost sinks every time I see farms reusing them. And I've seen it quite a bit. I see it too. And it's like, Oh, no. You can't clean a berry box. It's like cardboard.
00:20:27
Speaker
Yeah. And it gets wet and it falls apart. And they get stained and like visibly dirty. I feel like I've never seen one that has been used that is not visibly dirty after one use. Right. Yep. They're not meant to last. They're not built for the duration. No, they're not. I love that you said,
00:20:54
Speaker
compostable plastic bags. I'm seeing those a lot more at market and on farms. Maybe that compostable bag is in that green berry box. So then if you're selling at market, the buyer can take the compostable bag with them and then those berry boxes are clean. Nothing touched them. I also really like your paper bag suggestion.
00:21:23
Speaker
Yeah, I've seen that a lot with CSA farms where they'll pack their CSA into a paper bag and then, you know, the paper bag can just be recycled. So it's kind of a win-win. It is a single use item, but it's easily recyclable. Or compostable. Yeah.
00:21:41
Speaker
Yeah, lots of different packaging options, even though there's only really two choices. So I guess there's freedom in how you interpret the two choices. Yes, and what kind of packaging you'd like to spend your money on.
Efficient Record-Keeping
00:22:00
Speaker
Landon, earlier we talked about record keeping around training. As a training requirement, yeah. Yeah, where else is there freedom and wiggle room?
00:22:10
Speaker
This is one of my favorite things to talk to farms about in terms of like,
00:22:17
Speaker
I feel like the produce safety rule is so easy going in terms of record keeping, especially when compared to other audit programs like GAP or Primus where there's just millions of records that a farm has to keep. I think there are only seven required records for the entirety of the produce safety rule. It's so doable. The minimum is so doable. Yeah, there's seven records, but if you don't say compost,
00:22:48
Speaker
I always interpret that as a record you don't have to keep. Oh, exactly. Yeah, you're right. In some cases, maybe not even all seven will apply to you. I always suggest to growers that they should keep as many electronic records as they can. Have something that is easily accessible when working, so a piece of paper, pencil, out with them, but then
00:23:17
Speaker
as much as they can get down in an electronic document is my suggestion. What do you suggest, Linda? I find that in my area, so I'm in the Upper Peninsula, which is a pretty rural part of the state.
00:23:33
Speaker
part of the country and I find a lot of times that there isn't adequate cell service out in the fields to do that on an electronic device if it needs the internet. But I have suggested that to a lot of farms and
00:23:49
Speaker
More often than not, it's like, my phone doesn't even work out in the field. So in those cases, my recommendation is buy seven clipboards and tie a pencil with a string to that clipboard with that record. Maybe put it inside one of those like plastic paper sleeves and so it can withstand a little bit of weather and hang it next to wherever that job most often gets done.
00:24:19
Speaker
I love that and I love that plastic sleeve so it can withstand a little bit of weather. I also like for paper records, the storage, once that clipboard is filled up, having one of those plastic-ish file folders and keeping all of those documents together.
00:24:42
Speaker
Yeah, I love that being a little bit more organized. I've definitely been on farm where it's like, here's my food safety plan and the last eight years of records that I've kept. And I'm always like, I'm very proud of you, but I don't want to look at these.
00:24:59
Speaker
And no one needs to look at eight years of records. No. Actually, that is a good point to bring up because the protostacy rule does put a number on that. Doesn't it? It has a specific year requirement of how long you should hold on to your records. I feel like it's two.
00:25:21
Speaker
I think it's two, yeah. I think it's two years from the date of the record. Yes. I hope this is freeing some people up from eight years of paperwork.
00:25:35
Speaker
I hope so too.
Episode Resources and Conclusion
00:25:38
Speaker
Links to anything referenced in this episode are provided in our show notes, which can be accessed on the website at canr.msu.edu slash agri-food underscore safety. Thank you to everyone for listening, and don't forget to tune in next month for another episode of our Produce Bites podcast.