By Chris Blanchard, Flying Rutabaga Works
When I got started in organic farming over twenty years ago I worked on three vegetable farms before anyone even said the words, “food safety.” But the emphasis on food safety has steadily grown over the years, to the point where fresh produce growers now face FDA regulation, and food safety audits are becoming a regular part of many vegetable farmers’ annual activities.
Teaching about food safety around the country over the last several years, I have often heard producers say, “We wouldn’t have all of this concern about food safety if we all just ate a little more dirt.” For many of us, this might well be true.
However, individual resistance to pathogens is highly variable. An increasing number of Americans have weakened immune systems; by some estimates, over a fifth of the population is affected. The very young, the very old, recent organ transplant patients, cancer patients, and others are much more susceptible to food-borne pathogens – the median age of people who died in a 2011 Colorado cantaloupe Listeria outbreak was 81.
Assuming your customers reflect at least some of this diversity, you need to take a proactive approach to food safety.
Food safety isn’t just a legal responsibility, or an ethical obligation to our customers. It’s also an obligation to the rest of the local foods community. In 2006, over 50 billion servings of fresh bagged salad greens were sold in America. That September and October, an outbreak of Escherichia coli O157:H7 associated with baby spinach sold in bags killed five people, and sickened a little over 200. Despite the overwhelming safety of the spinach supply, fresh spinach sales still haven’t risen back to pre-2006 levels. If we ever have a significant outbreak associated with a farmers’ market or a farm-to-school program, we can count on the media to make such a big deal out of it that the small farm and local food movement could be set back by decades.
Fortunately, regulators and auditors recognize that food safety is all about risk reduction. While certified organic farmers are used to a set of rules where things are either mandated or disallowed–you must rotate crops, you may not use chemical herbicides–in the world of food safety, we have a lot more flexibility in much of what we do. Even the FDA’s proposed Produce Safety Rule tries to acknowledge that there are many different paths to clean food. On different farms, and in different crops, different steps will have the biggest impact with regards to food safety. You have to do what makes sense given your crops, your scale, and your markets.
Where Contamination Happens
When you hear about somebody with the “stomach flu”–vomiting and diarrhea–it’s almost always a form of food poisoning. Food poisoning is almost always the result of some sort of fecal contamination. In other words, if you’ve got the stomach flu, chances are that somehow you ate poop. And that poop had Salmonella, or Listeria, or Camphylobacter, or any number of other human pathogenic bacteria in it.
The good news is that preventing microbiological contamination in fresh produce is pretty simple, and comes down to just a few things: first, keep the poop off the food; second, assume that the food has poop on it, and keep the poop from spreading to other food; and third, assume that the food has poop on it, and keep that poop (or the microbes in it) from growing.
Vegetables are produced out in the real world. And the real world is filled with poop: goose poop, cow poop, deer poop, people poop. Even slug poop can carry food-borne pathogens such as Salmonella.
An Easy Place to Start: Hand Washing
When it comes to risk reduction, if growing and packing vegetables was driving a car, washing your hands would be the equivalent of wearing a seatbelt. The single most important thing you can do to reduce food safety hazards on your farm is to provide proper hand-washing facilities, and ensure that you and your workers are using them before touching food or anything that touches food, and after touching anything that might be a source of contamination.
Hand-washing has two goals: to keep contaminated hands from touching produce, and to keep contaminated hands from contaminating other surfaces. For that reason, everybody on the farm – not just produce workers–must follow good hand-washing procedures. A recent study in England found that 11 percent of randomly sampled hands were contaminated with fecal bacteria at the same level as found in a dirty toilet bowl–as were 8% of sampled credit cards and 6% of paper money. A separate study found that over a sixth of cell phones were carrying fecal bacteria. In other words, we live in a contaminated world, and everybody on the farm has a responsibility to reduce the chance that bacteria will be carried from someplace innocuous into somebody’s food.
Workers should wash their hands when they get to work, and again when they are going to handle food or handle anything that touches food. Any time workers come into the packing house, they should wash their hands. The organisms that cause food-borne illnesses can survive for a long time in the soil–you don’t have to see fecal matter for those organisms to be present.
Of course, workers should wash their hands after using the toilet. It’s not so much that the act of using the bathroom somehow automatically contaminates your hands, but that lots of people use the bathroom, and you have to assume that they aren’t as clean and as careful as you. Plus, it’s a good idea to periodically get your hands clean in order to reduce overall bacterial load.
Workers who have been in contact with farm animals, or who have worked with animal waste, must wash their hands when they are done–even before working in the office or driving a farm vehicle. An employee with fecal matter on her hands who touches a keyboard or holds a steering wheel is contaminating those surfaces; the next worker who comes along is likely to end up with contaminated hands.
Running water is important to remove contamination from your hands, and to keep your hands from being re-contaminated. The water doesn’t need to be under pressure, it just needs to flow over and away from your hands, to carry away the bad stuff that you are washing off.
The basin you use for washing your hands should be dedicated to hand-washing – the act of washing your hands in it contaminates it. And potable water is a must. It doesn’t do any good to wash your hands with contaminated water!
Soap is an absolute requirement for getting the nasties off of your hands. In the same way that muddy hands spread dirt much more readily than dry but dirty hands, wet hands can spread bacteria more easily than dry hands. Sanitizers are not an acceptable substitute for soap on the farm, because clay particles and organic matter dramatically reduce their effectiveness.
For the same reason that using soap matters, drying your hands is a critical step. That means drying with a towel that isn’t contaminated–not the back of your jeans. Using a single-use towel keeps somebody else’s sloppy hand-washing from undermining your careful scrubbing. A single-use towel doesn’t have to be disposable–you could use cloth towels that are used once and laundered between each use.
Once you’ve washed your hands, the used water and the things it touches are considered to be contaminated, so you must keep it from running into the field. In a packing house, that probably means a septic system; in the field, that means a separate container for waste water.
The University of Minnesota has published plans for an inexpensive field hand-washing station at http://goo.gl/YdLQV.
This is the first in a series of articles about food safety written by Chris Blanchard, an organic farmer, educator, and consultant. Chris’ consulting and education work focuses on providing systems and tools to farmers and food businesses to help them succeed in farming, business, and life. email@example.com, www.flyingrutabagaworks.com
The Food Safety Modernization Act
The Food Safety Modernization Act (FSMA) is the first major overhaul of our nation’s food safety practices since 1938. It includes new regulations of practices on produce farms and in facilities that process food for people to eat. It represents some big changes to our food system – and it is extremely important for the Food and Drug Administration to get these regulations right. The FSMA rules relating to fresh produce and food manufacturing and handling are still in proposed, not final, form – which means that there is a critical opportunity for farmers, processors, and others affected by the new rules to provide input to FDA. Comments from farmers and on-farm processors will directly shape the final rules, and are critical to ensuring that the final rules work for small and mid-sized farmers, sustainable and organic growers, value-added businesses, and conservation systems. For information about the rule and how to comment, go to the National Sustainable Agriculture Coalition website or call (202) 547-5754.