Originally published in Issue 11
As the rules of the Food Safety Modernization Act are finalized, greenhouse growers will be required to ensure the edible crops they produce are safe for human consumption.
Recent data from the U.S. Centers for Disease Control and Prevention estimates 48 million people are sickened each year by foodborne pathogens. That’s one in six Americans. Of those people about 128,000 are hospitalized and 3,000 die each year.
Photo courtesy of Phil Tocco, Michigan State University Extension
The Food Safety Modernization Act (FSMA) was signed into law by President Obama on Jan. 4, 2011. The purpose of the law, according to the U.S. Food and Drug Administration, is “to ensure the U.S. food supply is safe by shifting the focus from responding to contamination to preventing it.” In September 2015, two of the FSMA’s rules, referred to as preventive controls rules, were finalized. These rules, according to FDA, “focus on implementing modern food manufacturing processes for both human and animal foods.”
“We’ve been working with states, food companies, farmers and consumers to create smart, practical and meaningful rules,” said Michael Taylor, FDA deputy commissioner for foods and veterinary medicine. “And we have made a firm commitment to provide guidance, technical assistance and training to advance a food safety culture that puts prevention first.”
FSMA’s seven rules are scheduled to be finalized in 2016. FDA said the rules “will work together to systematically strengthen the food safety system and better protect public health.”
The rules are changing
Phil Tocco, food safety educator at Michigan State University Extension, said FSMA is the first law in the United States to regulate food production, harvest and the movement of fresh produce at the farm gate.
“Up until now if you were a retail grocer, a retail restaurant, or if you were preparing food, you had regulations placed upon you and how you did things,” Tocco said. “If you were manufacturing a food product from raw materials, there were rules that you had to follow, particularly if you were working with potentially hazardous foods such as seafood or if there was a potential issue if you were slaughtering animals. There were regulations in place. However, there were no regulations for the harvest and transport of fresh produce at all. If you were harvesting fresh produce you didn’t have to follow any rules to do so.”
Understanding food safety
Tocco said growers need to think strategically about food safety when they first start out.
“Some of the best growers I know actually came from the retail restaurant side that went through a program like ServSafe,” he said. “All restaurants have to have at least one person on staff that has ServSafe certification. They have taken a test indicating that they are ServSafe certified. They understand the concepts related to food safety.”
Tocco said many growers he has met were successful chefs before they moved to food crop production.
“These former chefs brought their knowledge of food safety with them,” he said. “It makes a huge difference because these growers start evaluating the practices that they do. They can ask themselves if their food handling practices pass muster.
“If a grower sells his product at a farmers market, he better be able to answer the questions that consumers are going to ask about food handling and food safety. A grower can’t answer “Nobody has ever gotten sick eating any of my produce so I don’t have any problems.””
Reduce the risk of pathogens
Tocco said growers should treat packing areas as if they were cooking in a kitchen.
“Packing areas should be clean and sanitary,” he said. “The bottom line is growers are dealing with a fresh product. There is only one way to really ensure the elimination of the overall pathogen load and that is to cook them. A lot of the things that are grown, especially in a greenhouse, are meant to be eaten fresh and raw. Greens are meant to be eaten fresh and raw. Growers can’t eliminate the risk. But they can reduce the risk.”
Tocco said people are really good at spreading disease and the diseases that people pick up tend to spread relatively well.
“Outdoors on small farms there may only be one to two people that come into direct contact with the plants,” he said. “Those people may not be exposed to a lot of other people outside of their social network. I expect there are more indoor growing facilities doing production in urban areas. There is a greater likelihood that individuals who deal with indoor environments would come into contact with people with norovirus or people would come into contact with environments that could be contaminated with norovirus. The chance of someone accidently bringing in contamination into the production area is probably somewhat greater.
“We say “wash your hands” and “if you’re sick, don’t pick.” Washing your hands can only go so far. There is a potential if you come in contact with a norovirus that you’re asymptomatic.”
Water source, production site safety
Tocco said greenhouse growers who are using municipal water to irrigate and package their crops are using the absolute safest water source. The next safest water source is well water followed by pond water, considered a static water source, and water sources that move like streams, lakes and rivers.
“A water source in motion varies because the water taken out right now is very different than the water taken out 10 minutes later,” Tocco said. “If a pond is the water source, the water taken out now is usually the same water taken out 10 minutes later. With well water, the water that is taken out now is going to be the same 10 minutes from now. I can expect that a water test of well water is going to be the same whenever the test is taken.”
Tocco said many greenhouse growers who are using a closed recirculation system often treat their water. Also, the production system a grower is using will determine whether the water even touches the edible parts of the plants.
Photo courtesy of Phil Tocco, Michigan State University Extension
“A lot of the production systems that use water recirculation have a substrate like rockwool that gets between the actual edible portion of the plant and the roots. The water may never touch the leaves of the plants let alone the edible portion of the plants, such as a cucumber or a tomato crop. Even if a grower is producing greens, the water typically is only going to be touching the root system. The water is not going to be sprayed on the leaves.”
Tocco said the food safety risks encountered by an outdoor field grower are much reduced in a controlled environment warehouse or greenhouse.
“A greenhouse or warehouse grower is going to have much more control over wildlife,” he said. “There are some vertical set ups where it is going to be difficult for wildlife to climb up to eat leafy greens or to mess with the production area. Those kinds of things make a huge difference in maintaining food safety.”
Tocco said one of the factors that help outdoor production systems is sunlight, which is a good disinfectant.
“Another food safety issue is previous uses,” Tocco said. “If a grower is moving into a warehouse that has had some industrial uses there may be some existing contamination within the building. Starting to grow plants in these structures, there potentially could be a problem.
“Another issue with these old buildings is cost of conveyances. Some warehouses may have older pipes that may leach chemicals into the water supply that are coming into the production area. This wouldn’t happen in a new construction area. There are some things that growers should be cautious of when they’re taking on an indoor environment.”
For more: Phil Tocco, Michigan State University Extension; (517) 788-4292; tocco@msu.edu; http://gaps.msue.msu.edu.
David Kuack is a freelance technical writer in Fort Worth, Texas; dkuack@gmail.com.