PSA Working Committee 4: Core Curriculum. Hazards and Preventive Control – Production

10/28/11 Minutes

Attendance: See Excel Spreadsheet of Membership and Roll.

Logistics: A Google group site will be used to upload submitted documents. Karen and Fred will work on this in the coming weeks. Before the next meeting, the available documents will be uploaded, and we can assess if some are missing.

The following topic areas were discussed, as outlined in the meeting’s agenda: Water and testing, including: definitions, regulatory issues, assessment, documentation and testing. Goals for curriculum development were also discussed. Committee discussion is captured below under “Notes”.

Next Steps: Please review our committee notes before November 18. In the coming a weeks, a survey will be distributed to rank topics identified in the notes. Instead of having a call on November 18, please set aside this time to review our notes and complete the survey. We will then compile survey results and discuss the outcomes and collected input on prioritizing curriculum content on the next call.

Congratulations for getting this far. Thank you for your active participation.

We have made great progress!!!

Fred Finney: aren Killinger:

Please contact us if you have questions.

Next Call: December 2 at 4:00pm EST

Dial In Information 1. Dial Toll-free: 866-906-98882. Enter Participant Passcode: 8140591

Notes on Next Steps

The following goals of a curriculum were identified:

Goals:

  • Food safety is important, irrespective of size or management practices
  • Growers can accomplish food safety goals (arrive at same destination), but there are multiple ways to achieve these goals
  • The curriculum should assist growers with understanding of risks and hazards, ability to identify risks specific to their operation (risk assessment), and recognize available solutions to address risk
  • Consumers expect food to be safe to eat, and in some cases, expect higher safety levels from locally and regionally produced foods produced by small farms. This places a great deal of responsibility on the small grower to achieve food safety standards
  • Emphasize that the curriculum was developed with consideration for small growers/operations
  • There will need to be some degree of flexibility of curriculum to make it regionally relevant (alligators in FL, wild hogs, etc.)

Water and Testing Notes

Overlap with WC 6 (processing water) and WC 3 (flooding)

Definitions

Tailwater – may not be used in some states, to be recirculated to headwaters

Retention pond

Recycled water

Tertiary treated water

Blended Water – mixture of ground or irrigation water and tertiary treated water

Regulatory

State, including Departments of Ecology and Agriculture

Recreational water standards

Ex. In Florida <1000fecals /100mls, but Class 4 water is left blank

WA – Class 2, <200 fecal coliforms/100ml

Reclaimed water – some states that have standards

Agricultural Waters – most states don’t have regulations, GA and FL are exceptions

Some have recommendations

Collection of rainwater for use as irrigation differs among states

Assessment

Sources and Uses of Water - How it is used and where it goes

Overhead, Drip, Produce Wash Water, Recycled Water

Flood irrigation - flood some fields during rainy, fallow season

Recycled open surface water

Tailwaters used for dust abatement

Use of reservoir or retainment ponds

Tertiary water

When and where is water being applied?

Type of crop

Status of the crop - Is the plant in floweror fruiting?

Floods

Surface run-off

Contamination of water supply

Upstream influences – chemical contaminants

All irrigation water should be given the same consideration, regardless of source

Surface water, well water, recycled water, rainwater

All must consider sanitary survey, evaluation of protection from contamination, storage issues (animal exclusion, treatment, etc.), testing and standards, proper treatment, etc.

Testing

Accepted standards – based on EPA standards

Stricter requirements for foliar application

Quantitative tests are recommended for most waters (where detection of fecal coliforms, generic E. coli, etc would be expected at some level)

If drinking water quality is needed/expected, presence/absence of total coliforms may be appropriate

Testing methods may include Colisure, MPN, plate count

Factors to Consider

Crop

Type of water (municipal, well water, open surface water)

Frequency – recommendations differ

Sample Collection Point – recommendations differ, see below

Aseptic Technique

Communication and Coordination with Testing Lab

Design of a Sampling Plan (number of samples, etc.)

Weather

Testing

Challenge: Frequency recommendations differed, examples included the following:

  • NC, CA – One time per month during the season
  • LGMA standard indicates that for well water the frequency can be reduced if a certain number (5) are consecutively negative
  • NY- Berries have a short season, so once a month isn’t appropriate, Recommend testing at the start of irrigation and highest point of irrigation (greatest volume of application)

Challenges were identified with determination of appropriate sample collection points

  • Directly from source
  • Pros – this provides an indication of the quality of the source water
  • Challenge - sediment – should the sample be collected from free flowing water or include sediment?
  • Cons – sample does not reflect the quality of water that touches the crop, accounting for piping systems, etc.
  • Could irrigation district water quality samples be used to supplement data?
  • As close to point of use (application to plant) as possible – at drip line or sprinkler

Pros – this sample reflects the quality of the water at application, accounts for potential contamination between source and field. Also, reflects potential for microbial reduction between source and application (pipes in the sun heat up the water)

  • Challenge – how many samples are needed to reflect the entire water distribution system
  • Cons – may not capture the “biology” of the source (open surface water, retention pond)

Water testing labs – Growers need to be provided with specific information on how to collect the water sample to avoid contamination and ensure an accurate test, including:

How should sample be collected?

How should the sample be shipped?

Sampling Plan – how many samples are appropriate for a small grower

Corrective Actions

What can be done if water is consistently high?

Water treatment options

Documentation

Testing Results

Keep Organized

Monitor andanalyze data

Document what you do to your water sources (how do you treat your wells, etc.) so that it can be monitored

Educational Considerations

Discussion of sampling procedures

Understanding lab reports – what is the test, what do units mean (cfu/MPN, etc.), what’s low and high

Document where samples are taken, when, how collected, when shipped and when received, etc.

Soil Amendments (Manure, Compost and Non-manure/Non-Animal)

Definitions

Raw Manure

Manure

Animal-based composts

Non-animal based composts

Raw Compost

Aged/Finished Compost

Vermicompost

Definitions of composting processes – aerated static pile, turned piles

Process to Further Reduce Pathogens (PFRP)

Laws/Regulations

  • Approved processes for composting and Federal Biosolids Laws
  • Descriptions and supporting science
  • NOP on compost and vermicompost can be utilized as resources
  • Some state forbid morbidity composting

Purchasing

  • COA for compost (relates to recordkeeping as well)
  • What are the qualifications for certified compost?
  • Requirements for finished compost testing

Treatment and Processes

  • Differences between manure-based and non-manure based materials
  • Differences between animal based and non-animal based can be confusing for growers
  • Manure and non-manure based composts may be similar in risk
  • Raw human manure and treated biosolid applications, municipal sewage sludge
  • Biosolids Class 1, 2, 3 (these are used for compost rule development, Class A, etc)
  • Potential for differences in regulations among states
  • Uniformity
  • Understanding of food safety standards for compost
  • Calibration of thermometers and other measuring devices

Handling

  • Standard Operating Procedures for handling should be in place and included in recordsTopics that should be considered and included
  • Potential for cross-contamination
  • Potential for run-off
  • Topography
  • Maintain separate tools
  • Maintain separate equipment

Application

  • Differences between application during production and off-season application
  • A challenge was identified when fields are not in production and compost is deposited near the field

Testing Methods

  • <1000/fecal coliforms/1g and negative forSalmonellaMPN
  • Testing laboratories must be accredited
  • Test every batch yearly
  • United States Composting Council resource, testing methods for the examination of composting and compost, includes protocols for sampling methods
  • From legal standpoint standardized protocols using peer reviewed, science based protocols is important
  • Challenge: Does not appear to be consensus on sample collection

Documentation

  • Certificates Of Analysis (COA)
  • Testing Results
  • Standard Operating Procedures
  • Supporting documentation (scientific evidence supporting practices)

Educational Strategies and Topics

  • Suggestion to use a checklist be used to perform a risk-assessment
  • Ex. Does this have animal products, does it have manure based, is it certified organic
  • If compost cannot be verified must be considered raw manure
  • Potential for state laws to contradict NOP

Challenges

  • Morbidity composting, animals, etc.
  • States differ in regulation
  • Clean water act
  • Terminology – animal-based, manure-based
  • Educational Message should be that formal requirements must be met to achieve compost, it is not a passive process

Animals: Domestic (Pets, Animals used in Production and Livestock) and Wildlife

Overlap with other Committees: Working Committee #3 will be addressing co-management; however, this topic is related to production topics. Working Committee #5 - Risk Assessment for animals may differ during production and harvest activities.

Definitions: The following terms were recommended to be defined in a GAPs curriculum:

Animals used in production – Points that could be included in the definition:

  • Animals used as a source of power
  • Essential to growing a crop
  • The animal is controlled by the producer (not free ranging).
  • Another aspect that may need to be considered is the timing of the presence of these animals.

Co-Management: Definitions utilized by organizations include:

National Sustainable Agriculture Coalition: An approach to conserving and protecting soil, water, air, wildlife, and other natural resources that benefit public health while also reducing microbiological hazards associated with food production.

CA LGMA adopted: An approach to conserving soil, water, air, wildlife, and other natural resources while simultaneously minimizing microbiological hazards associated with food production.

Buffer Zones/Vegetative Filter Strips –Points to consider in the definition

  • include grasses and wetlands that filter waterborne pathogens
  • hedgerows and windbreaks that filter airborne pathogens.

Animal Risk Assessment

Documentation of animals (pets, animals used in production and livestock)

Factors to Consider

  • Ideal to perform prior to initiating growing/farming on the land
  • Type of crop,
  • Type of animals observed and associated risk
  • Consider both daytime and nocturnal animals
  • Document number of animals
  • Frequency or amount of intrusion
    Ex. Walking through versus eating the crop
  • Potential for dispersal of fecal matter or fecal matter “effluent” based on
  • Nature of the scat
  • Crop production practices
  • Climate
  • Irrigation practices
  • Harvest practices; particularly mechanical
  • Ability to scout and visually spot fecal matter depending on developmental stage
  • Ability to mitigate by removal and no-harvest buffers
  • Effectiveness of risk awareness training of field crews and harvest crews

Examination of habitat for animal exclusion or attraction

  • Features of landscape that encourage or discourage animal presence (water, vegetation)

Approaches to Performing a Risk Assessment

  • A committee member suggested a decision Tree approach. Starting with identifying areas of risk in an operation/environment. For each area, an assessment of specific management practices and potential positive and negative effects on risk could be considered. Decisions to balance foodborne pathogen risk with other negative consequences could then be considered.

Potential Challengesduring risk assessment

  • What is a reasonable amount assessment or frequency of assessment?
  • Observation of defined animal movement paths
  • What can be done to effectively mitigate this risk?
  • Group members offered different approaches to this observation.
  • Lowest Risk Mitigation: Do not grow crops in areas with evidence of animal movement (lowest risk),
  • Intermediate Risk Practice: Switch growing areas to “lower risk” crops(ones likely to be cooked)

Livestock

Factors to Consider:

  • Rotational Grazing Schemes- movement of livestock within a diverse operation
  • Graze a field after harvest – time between grazing and next crop (90-120days using Organic Stds, depending on crops),LGMA recommends 1 year, study in Wisconsin saying 120 days is acceptable, encourage incorporation into soil,
  • Ideal to have one standard
  • Potential for cross-contamination, chickens carrying manure from location to location
  • Grazing and positive influences on soil
  • Compost increase soil ecology, biological diversity and competitive exclusion
  • Compost has benefits
  • Rotational grazing schemes and observing a rest period after grazing
  • Tilling soil to cover manure after grazing and consideration of water applications
  • Dogs as herders for livestock (serve as a working animals)
  • Personnel – procedures in place to prevent cross-contamination between handling livestock and produce (clothes, boots, etc)

Potential Challenges/Topics for Consideration

  • Recommended times between grazing and harvest of the next crop. Is a minimum of 90-120 days an acceptable recommendation based on risk?

Animals used in Production (used as a source of power)

Factors to Consider:

  • Location that animals graze
  • Potential for cross-contamination
  • To reduce risk, horses should not be stabled with ruminants
  • Study by Lejeune indicated pathogen transmission from ruminants to horses was low, but possible
  • Time between animal use and harvest. At harvest or within days before harvest, horses should be kept in drive line instead of in the crop itself
  • Personnel – procedures in place to prevent cross-contamination, clothes, boots, etc, not direct handling produce

Ag Tourism Animals – Petting Zoos

Factors to Consider:

  • Potential for Cross-Contamination

Clients or Personnel – Contact with animals followed by contact with produce or moving into fields/packing areas

  • Emphasis on handwashing for clients
  • Supply adequate handwashing stations and signage to encourage washing

CDC recommendations

  • Notifying clients that personal pets are not allowed in fields

U-Pick

  • Emphasis on handwashing for clients
  • Supply adequate handwashing stations and signage to encourage washing

CDC recommendations

  • Notifying clients that personal pets are not allowed in fields
  • Signs for “no animals allowed in production , sale area”

Domestic Pets

Factors to Consider:

  • Pets (dogs and cats) can be attracted to garden areas (plowed fields, piled soil, etc)
  • Provide information or recommendations on keeping animals out of fruit and vegetable production
  • Use of dogs to keep out or deter deer intrusion or other pests

Use of Animals for Pest Management

Potential Challenges

  • Recommendations for some types of animals to be used for pest control
  • Encouraging birds of prey for rodent control
  • Encouraging some types of birds for insect control
  • Wild turkeys,chickens, geese to weed strawberry fields
  • Sheep and geese for wineries and other crops

Insects and Pollinators

The role of insects in potential pathogen cross-contamination is an area of currently scientific study and represents an area where knowledge gaps exist. It should be acknowledged that insects present a potential vector for pathogen transmission, and that not all risks can be completely controlled. In many areas of GAPs, benefits and risks must be considered and balanced to create a viable farming operation in which pathogen risks are identified and minimized.

Factors to Consider

  • Insects are attracted to harvested fields and manure
  • Risk assessment of the operational and neighboring land use to identify potential insect attractants that might contribute to pathogen contamination
  • Is there a way to classify insects? Flies versus pollinators
  • Insects that play a positive role in farming operation
  • Insects that should be discouraged (flies)

Pollinators

Factors to Consider

  • NRCS program for encouraging pollinator habitat
  • Bees are involved applicationof fungicides for some crops, like strawberries during bloom

Preventive Measures and Mitigation

Types:

Vegetative Filter strips

Bare Ground Buffers

Other buffers

Physical Barriers and Other Physical Exclusion

Fencing

Trapping

Noise and Sound

Factors to Consider:

  • Identify the purpose or function of the buffer (movement of dust, water or animals)
  • Provide examples of what has been done to mitigate risk

Potential Challenges

  • How much exclusion is “enough”
  • Which mitigation strategy should be utilized?
  • Utilize the risk level involved as guidance. Although fencing is an expensive strategy, it may be needed if high risk is involved.
  • The risk may differ depending on the activity involved. For example, the risk during production may be lower, yet higher during harvest.
  • The use of fences and bare ground buffers should be a last resort after other mitigation measures are tried such as trapping noise/sound, sprinklers activated by motion sensors, scare balloons, food attractants placed in other areas, and minimizing presence of animal attractants such as cull piles.
  • Avoid removing vegetation in and around growing areas, especially plants used in conservation practices, established riparian zones, or other natural areas. Removal may increase pathogen risk, have adverse impacts on air and water resources, and be in conflict with local, state and federal regulations.
  • Buffer Zones between fields and livestock – LGMA
  • What distances are appropriate?

PSA Working Committee 4. Core Curriculum. Hazards and Preventive Control – Production

Notes 4.1.3 Chemicals

Definition of Terms: The committee felt that a list of terms and definitions would be useful to help clarify terminology, especially to identify terms for compounds that can crossover between conventional and organic methods. A point was made that overall, it may be important to emphasize in definitions the intended use of a particular compound in order to develop definitions that can be utilized for both organic and conventional management systems. The National Organic Standards has a list of definitions that may be useful.