Become a Creator today!Start creating today - Share your story with the world!
Start for free
00:00:00
00:00:01
Regenerative Agriculture & Food Safety
16 Plays2 hours ago
This episode features Carrie Fitzpatrick, a Food Safety Consultant through Wilbur-Ellis, and Morgan Anderson, a Produce Safety Technician with the Ottawa Conservation District. Together, they break down what regenerative agriculture really means, address common misconceptions about balancing regenerative practices with food safety, and compare PRIMUS and GAP audit expectations with the requirements of the FSMA Produce Safety Rule.
Additional Resources:
Regenerative Agriculture & Compliance Table
Recommended
Transcript
Introduction to Produce Safety
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.
Meet the Experts: Morgan and Carrie
00:00:13
Speaker
Hello everyone, my name is Morgan Anderson. I'm a produce safety technician at the Ottawa Conservation District serving the West Michigan area. And what that means is that I'm a free, confidential, voluntary resource to discuss what food safety looks like on your operation. And today we have Keri joining us. So Keri, you want to introduce yourself?
00:00:34
Speaker
Hi everybody, I'm Carrie Fitzpatrick. I work for Wilbur Ellis out of Sparta, Michigan and I am a food safety consultant for the state of Michigan through Wilbur Ellis. So I am working with growers on their food safety programs for their farms and helping with their food safety books, audits, and all the food safety questions and regulatory questions that they have on their farms.
Regenerative Agriculture and Food Safety Compatibility
00:00:59
Speaker
Yeah, I'm excited to have Carrie today because i have more experience in the produce safety rule, which is a federal law um adopted here in Michigan as well. And I can help a little bit with GAP, but Carrie is really the go-to for me, honestly, for GAP-related questions, primus questions, the audits that kind of go a little bit above and beyond of the federal standards. So today we're going to be talking about regenerative agriculture because both Carrie and I have had that come up a lot lately in our food safety worlds and how can we make regenerative agriculture and food safety symbiotic and there are ways to make them symbiotic. I think there's maybe some misconceptions out there that you can't do one or the other, vice versa. And so we're going to be talking a little bit about that today. um So, Carrie, I'm interested, what in your mind is regenerative agriculture? Big question, but maybe to kind of set the tone before we get talking about what are some practices that we see.
00:01:58
Speaker
to me, and it's hard put definite definition on it just because there's so many different ideas about it. um But for me, it's just using better practices, working with the soil, making sure that you're you know not spraying anything too harsh that's going to harm your beneficial insects. So just working, i think, with the environment that you have, using practices that are not harmful to the ecosystem that you're in or the people that are working for you,
00:02:36
Speaker
Yeah, like definitely kind of like a more holistic approach. Yeah. yeah That's kind of what my definition was going to be was also like a holistic approach to soil health. Also, the people health ah on the farm, which you just touched on. um And I know sustainable agriculture has also been another buzzword. And I think to me, regenerative goes beyond that because you're not just sustaining the environment, whether that's the soil health, the workers' health, etc., but you're working to rebuild and regenerate and improve upon that.
Regenerative Practices: Techniques and Regulations
00:03:10
Speaker
So with that, what are some practices that you've been seeing, Carrie, of folks who are wanting to do some, quote, regenerative agricultural practices on their farm? A lot of what I'm seeing is more of just using products that are working with the environment instead of against the environment. Relying, like I said, relying more on your beneficial insects. Incorporating more manures and biologic products into the orchard or into the farm um to kind of help boost that soil biome that's maybe there or you're working to build it. That seems to be kind of where I'm seeing more um doing more mowing and mulching, growers asking more questions about how do we incorporate birds into our system and still meet food safety standards, more growers looking at using mulch under the trees to kind of help keep the soil moisture in the ground.
00:04:05
Speaker
Yeah. I want to touch on the manure one you mentioned first. um I think for me, one way people are incorporating manure is introducing grazing animals onto the orchard or whatever produce setting they are at for the sake of pest control we control. Then of course, the manure builds the soil like you're saying. And so for the produce safety rule, that is allowed. There is the National Organic Program standard that the FDA and the Produce Safety Rule refer to of you got if you're introducing some kind of raw manure like that, it has to be 90 to 100 days before harvest. So that can kind of narrow the window of when those animals are in the orchard. But I'm curious from the GAP primus point of view, what those audits are saying about that practice as well.
00:04:55
Speaker
So according to Primus and Gap, there is going to be some PHI rules that are going to cut or pre-harvest interval rules that are going to come into play. Untreated manures, 120-day PHI. Primus has a little nugget in there about ideally nine months wow before harvest. So I'm going to stick with that 120 Where does nine months come from? Because that that is a long time.
00:05:22
Speaker
Yeah, I think it's more of a probably just a rather be safe than sorry. Yeah, that makes sense. But yeah, that's um almost the whole year. Yeah, yeah.
00:05:34
Speaker
Yep. So then for a treated manure, they're still wanting that 120 days potentially. But if it is treated, you have proof that it's treated and you have a clean pathogen test, then you can go down to 45 days pre-harvest. So that is one that, especially for some of my organic guys that have are ah doing a summer blend of some kind of manure, then if they have all of those things, then according to the primus and gap rules, they can be at a 45-day PHI.
00:06:06
Speaker
That's
The Role of Documentation in Compliance
00:06:07
Speaker
interesting. Because for the product safety rule, for a quote treated manure based compost or product to use it outside that 90 to 100 days pre-harvest interval or PHI, it just has to reach a certain temperature and number of turnings. And that all has to be recorded, which is a big part of it. Like you can do all that you can do it right. But if you don't have it recorded to validate you're doing what you're saying it's doing and that it's treated, then it will nullify all those efforts. So that's always one I like to hit hard is you can be doing all of it right, but make sure you're writing it down to cover your butt.
00:06:44
Speaker
Yeah. Yep. And I will say too, there are some products out there. it is a manure product. However, because they go through the process, the treatment process to take all of the pathogen pathogens out of it, it comes back with a clear pathogen test. So in that case, according to Primus and Gap, you can apply it pretty close to harvest because it is, it doesn't have any pathogens in it.
00:07:10
Speaker
So yeah. And I'm looking at our chart here, which we're also going to include that Carrie and I made for Great Lakes Expo this year. That pathogen test is not just for like manure, treated manure, um but also things like compost teas, blood meals, anything really it sounds like of animal origin. Yep.
00:07:29
Speaker
Yeah, we no pathogen tests for produce safety rule, the federal standard here, just that treating of days and churnings, which is really interesting. um Another thing you touched on earlier in that list when I said what are some practices you're seeing, we're creating bird habitat or bat houses.
Balancing Wildlife Habitats and Safety Risks
00:07:49
Speaker
I know has also been a thing for certain audit schemes, so I'm curious what your experience and steps with that have been as well.
00:07:56
Speaker
So with that, everybody that I have talked to say that they don't really see any issues with it as long as it is outside of the growing area. So if it's along the fence, if it's in the tree line. So pretty much as long as it's not right in the growing area. Okay.
00:08:15
Speaker
Everybody's fine with it. As long as you have it addressed in some sort of a risk assessment or you have mitigation measures that are in place. That you can say, okay, we're not picking, our crews are inspecting the produce before they pick it, which should be anyways. um But if there's any poop on them, then they're not using them, as should be the case anyways. So just kind of having some of those mitigation measures in place.
00:08:41
Speaker
So, yeah, it seems like it's one of those that it's best to just acknowledge, just to say, hey, we are doing this. Here's our here's our plan if something happens. But nobody has really said, no, that's not, you can't do that. okay Yeah, same with.
00:08:59
Speaker
the produce safety rule and FSMA. I don't know if, phzza I don't think FSMA goes as far to restrict like what area of the fields it could be in. Like you're saying it cannot be strictly in production areas. it could be on buffer zones per se.
00:09:12
Speaker
FSMA doesn't have that type of language. It just has what you were talking about, the risk mitigation measures. Like, okay, if you're going to create habitat for birds, bats, or whatever animal, wildlife animal you're trying to either bring into the farm, Just acknowledge that that introduces a risk and what kind of risk is that. And then, of course, make sure you're and inspecting prior to harvest to make sure you're not going to harvest any poopy produce because that's like the number one rule.
00:09:40
Speaker
and then as you're harvesting as well so that the people are trained to identify that and they know what to do if they find poop on produce, etc.
Training and Protecting Water Sources
00:09:48
Speaker
Which kind of and then also brings me to my next thing about the people doing this work, doing the practices, helping them get established in the regen practices. What are the Primus Gap worker training requirements for that? They don't have anything specifically spelled out. um However...
00:10:08
Speaker
What I usually advise growers to do, so we have a list of health and hygiene policies that we have built. So we just kind of add that to our health and hygiene policies, and then the growers can expand on that when they're doing their trainings um and just kind of cover those additional practices.
00:10:27
Speaker
When you have a grower that's doing regenerative practices, I think it's just a little bit of additional training to cover and what happens in certain situations. Yeah. I would say the taking a little more time during that training period to be like, all right, you guys probably know the you know the foundation, know the basics, but maybe we're doing something little special here on this farm that you need to learn, which honestly – It's true for every farm because every farm is a little bit special and different. so um But really taking that time and that initial training. And then I think a big piece for me that I've seen personally is you can do all the training in the in the first place upon hiring, but you also need to be monitoring the employees and the people on the farm to make sure that it's actually getting done the way you initially trained about it or that people have the tools that they need to get the job done. So I would really emphasize like Yes, this one time, you know, training upon hiring, but really also just watching and making sure that that's realistic and it's working for the team.
00:11:28
Speaker
Which speaking of which that made me think about water source protection um for if you are having animals out in the field. If you do use some kind of surface water for irrigation or frost protection, just making sure the animals are staying away from that as much as possible, whether that's fencing, having a ah good buffer between where they're grazing and the water source. making sure maybe the well isn't in the middle of where they're going to be grazing, protecting things like that. So I was curious if you had any notes about that as well, because water is a pretty big deal given the new water rule, which we've also put out a bunch of resources for as well.
00:12:09
Speaker
I would kind of just go along with the lines that you've stated already. um I can't say i have a lot of experience with growers using using surface water. Most of my growers are all using well water as of right now.
00:12:22
Speaker
But... what I would say is just kind of protecting those surface water sources. There's already enough risk with wildlife and everything else, let alone introducing animals.
00:12:34
Speaker
Right. Once again, taking that holistic risk assessment approach of we're introducing animals for this regenerative soil health reason, but let's take a whole picture of what risks they may present or already are on the farm before we even introduce them and the balancing of those risks and how we're going to manage them going forward.
00:12:53
Speaker
So with that, is there anything you wanted to leave last minute practices before we kind of talk about what an inspection and audit looks like with with these practices? The only thing that I can say is documentation is key. um Going back to that standard rule, if it's not written down and didn't happen, that is going to be kind of the golden rule as you're dealing with some of these regenerative practices in any fresh produce or produce situation. Yep.
00:13:22
Speaker
And there's no set way that has to look. It could be for FSMA paper and pen. It could be a digital record keeping like a Google forum log or something. It's just some way to record what happened or is happening so you can cover your butt like you said. So, yep.
Engaging with Regulators and Closing Resources
00:13:37
Speaker
With that, I will say when FSMA inspector or us technicians come on your farm, it's just going to be a conversation about, you know, why, why are you doing these practices? And then once again, how are you mitigating those risks? So I will say internally, us technicians and the Michigan department of ag inspectors here in the state of Michigan have had previous conversations of like, can people do grazing and, and, That's not the question. The question is not can people. It's yes, they can do it. It's just what are we then expecting people to do? And it's just the things we talked about today, the the record keeping, identifying the risk and how you're going to mitigate that risk and staying within those black and white 90 to 100 days, at least for the FSMA.
00:14:23
Speaker
um So I also was, do you have any words of wisdom for GAF and Primus Audits in relation to that? Yeah, I would just say if there's um something that you're thinking about implementing in your operation, don't hesitate to call the Primus Quality Assurance or your GAP contact, your USDA GAP contacts and ask them or your FSMA produce inspectors. Like, don't hesitate to ask those questions. They're more than happy to answer some of those questions. Well, should say answer your questions um because they'd rather have you do things correct the the first time rather than show up to an audit and the auditors ask for yeah all of this paperwork and you don't have it. And then it's potentially costing you another $1.
00:15:12
Speaker
time for the auditor to come out. So then it's also more expensive for you if you're paying for these audits. Right. And no auditor wants to go to a farm and purposely fail anybody. Right.
00:15:24
Speaker
don't hesitate to ask. I would say the same as well for whether it's us technicians here in Michigan, you're a regulator inspector for FSMA, or even here in Michigan, there's MSU extension as well. Like ask that's what we're here for or anytime there is a regulator on the farm you can ask questions like where does it say that in the law like it's your time too so take advantage of it for sure um but thank you so much for joining us i appreciate it and we will be sharing in this podcast as well the chart that we made so people can have some reference and kind of visually organize what we shared as well
00:15:58
Speaker
Thank you for having me on today. I really appreciate it. Yeah, thank you. Links to anything referenced in this episode can be found in the podcast description. For more produce safety resources, tools, and upcoming trainings, visit the MSU Agri-Food Safety website at gaps.msu.edu.
00:16:15
Speaker
That's G-A-P-S dot M-S-U dot E-D-U. We hope today's episode helped you take another step towards safer produce.