This is an expanded version of a feature that first appeared in the July/August 2013 issue of Food Manufacturing.
Interview with Peyman Fatemi, Professional Services Specialist, 3M
In Part II of this two-part series, Peyman Fatemi, Ph.D., the professional services specialist in the food safety group at 3M, discusses the latest regulations impacting the fruit and vegetable industry and how producers can improve their food safety practices.
Q: What specific food safety concerns and/or regulations impact the production process in the fruit and vegetable industry?
A: FDA’s Produce Safety Rule
On January 4, 2013, the FDA released its proposed rule to establish standards for growing, harvesting, packing and holding produce on domestic and foreign farms. The new rules, crafted under the auspices of the Food Safety Modernization Act (FSMA), seeks to establish a common set of food safety practices in the production, harvesting and marketing of fresh produce.
According to the proposed rule, these standards are set based on identified routes of microbial contamination of produce, including: (1) agricultural water; (2) biological soil amendments of animal origin (3) health and hygiene (4) animals in the growing area and (5) equipment, tools and buildings. The proposed rule includes additional provisions related to sprouts.
Q: What is Covered by the Produce Rule?
A: The proposed produce rule covers most fruits and vegetables in their raw or unprocessed state. It does not apply to commodities that are rarely consumed raw or those produced for personal or on-farm consumption, and those destined for commercial processing, such as canning, that will adequately reduce microorganisms of public health concern.
Over the years, the FDA has issued number of guidance documents to the produce industry on good agricultural practices, as well as commodity-specific guidance for tomatoes, melons, leafy greens, and sprouts. These guidance documents have in turn been used by the industry to develop on-farm food safety practices. The FDA produce rule, therefore, is a culmination of the efforts by the FDA, USDA, local and state governments, academia, and the industry in developing a science-based approach to improve the safety of produce. The LGMA mentioned earlier is an example of collaboration between the USDA and the produce industry in California and Arizona. Another example, according to the FDA, is the Model Code for Produce Safety developed in 2009 by the Association of Food and Drug Officials with input from industry, consumer groups, researchers, and state and local public health officials. Florida has recently passed state regulations for the safe production and handling of fresh market tomatoes.
Below is an excerpt from the proposed rule that highlights some of the key provisions
The rule focuses on identified routes of microbial contamination of produce, including:
- Agricultural Water. “Agricultural water” is defined as water intended to, or likely to, contact covered produce or food-contact surfaces. The proposed rule would require that at the beginning of the growing season, the agricultural water system components under a farm’s control be inspected to identify conditions that are reasonably likely to introduce pathogens to produce or food-contact surfaces. The FDA is proposing that specific criteria for the quality of agricultural water be established for water that is used for certain purposes, with proposed requirements for periodic analytical testing.
- Biological Soil Amendments of Animal Origin. Biological soil amendments of animal origin, such as composted manure, may contain pathogens of public health concern. To address this, the rule proposes three types of measures to reduce the risk: types of treatment, methods of application, and time intervals between the application of a biological soil amendment of animal original and crop harvest. The proposed rule also has provisions pertaining to the handling and storage of biological soil amendments of animal origin.
- Health and Hygiene. Bacteria, viruses, and parasites are frequently transmitted from person to person and from person to food, particularly through the fecal-oral route. The proposed rule would require that farm personnel use hygienic practices, including hand washing and maintaining adequate personal cleanliness.
- Domesticated and Wild Animals. Pathogens can be introduced into fruit and vegetable production systems via animal feces. Where there is a reasonable probability that animals will contaminate produce, the rule proposes certain requirements, such as an adequate waiting period between grazing of domesticated animals and harvesting produce from that growing area. Similarly, for working animals used where a produce crop has been planted, farms would be required to take measures to prevent pathogens from being introduced onto the produce. In addition, farms would be required to monitor for significant wild animal intrusion events both immediately before harvest, and, as needed during the growing season, and not harvest produce that is visibly contaminated with animal excreta.
- Equipment, Tools and Buildings. Among other things, the proposed rule also would set standards for certain equipment and tools, buildings, and sanitation used for produce operations on farms.
Other areas addressed in the standards include:
- Sprouts. Sprouts present a unique risk because the warm, moist, and nutrient-rich conditions required to produce sprouts are the same conditions that are also ideal for the growth of pathogens. The proposed rule would require treating seed before sprouting, testing spent sprout irrigation water (or sprouts, in some cases) for pathogens and monitoring the growing environment for Listeria species or Listeria monocytogenes.
- Training. The proposed rule would require training for farm personnel who handle the produce or food-contact surfaces, and for supervisors.
- Recordkeeping. The proposed rule would require certain records, for example, to document that certain of the standards are being met. However, it would not require duplication of records already kept for other purposes.
According to the FDA estimates, approximately 90% of covered produce acreage grown and consumed by Americans would either be covered by this regulation, consumed cooked, or sent to food processing facilities that process the product to address biological hazards associated with produce. FDA estimates that the number of foodborne illnesses that would be prevented by this proposed rule to be 1.75 million, with an associated benefit of $1.04 billion, annually.
Q: What resources does 3M Food Safety offer to help fruit and vegetable processors?
A: Fruit and vegetable processors need to continuously evaluate their testing practices to ensure that their program is in line with regulatory standards and that their chosen test methods are fast, accurate and cost effective. 3M offers complete line of microbial and pathogen tests supported by their sample handling products to provide the customer with a broad choice of testing platforms.
3M also provides a range of sample handling and media for collection, transport and recovery of target organisms from fruits, vegetables and the processing environment. 3M sample bags, quick swabs, and sponge sticks offer solutions to collect samples from products as well as locations within the plant, including those hard to reach and often hard to clean areas.
Q: What safeguards should food processors put into place to ensure the safety of their fruit and vegetable products?
A: Prevention is the key to reducing the risk and all preventive measures must be validated prior to and with some regularity, after implementation. Processors must take a multi-hurdle approach to prevent contamination of fruits and vegetables. This practice starts in the field, through the use of good agricultural practices (GAPs) and a written plan to implement these practices. This plan should address the water, soil amendments, environmental factors, work practices, and field sanitation and must be verified periodically through testing.
Processors should also take measures to safeguard against bioterrorism and intentional adulteration of their product or process. Performing field assessment for potential sources of contamination such as animal intrusion, prior to planting, before and during harvest will reduce the likelihood of sending a contaminated product to market.
At the food processing plant, facilities must establish and implement a food safety system that includes risk-based analysis and preventive controls for chemical, physical and biological hazards that are likely to occur. They must implement an environmental monitoring program to assess for the presence of pathogens such as Listeria, E. coli, and Salmonella and ensure the sanitation program is working. The written plan should also include corrective actions if a hazard occurs and verifications through testing to ensure that the issue has been resolved. Finally, all process documents and records must be kept in an accessible location. An annual review of the food safety plan will ensure the program is up to date.