Name this crop…€¦ · Jaquith Farm, from which they were resold at retail outlets, farm stands,...

Name this crop…

How is this crop irrigated?

Irrigation Water

Surface

Well

Municipal

Irrigation Water

Surface 3x/year

Well 1x/year

(During Production)

Municipal 1x/year

Microbial Water Testing

Name this Crop…

Commercial Arizona Cantaloupe: Field Packed

Name this Crop…

Arizona Farm Auditing Program

Good Agricultural Practices and Good Handling Practices Audit Verification Program

Kurt Nolte

Stewart Jacobson Karen Edwards

Why Certification?

• Not required by the law….yet

• Minimize the Risk of Food Borne Pathogens within Specialty Crops. Public Safety

Why Certification?



• Buyer-driven

– Produce buyers want food safety programs

– Grocery chains, restaurants, distributors

– Improved Marketability

– Approved AZ Food Source

• News emerges of an outbreak of E. Coli 0157:H7 traced to Oregon strawberries, sickening 15 in a five-county area.

• The Oregon Department of Health responds rapidly, tracing the berries to Jaquith Farm, from which they were resold at retail outlets, farm stands, and farmers markets in the region.

• The incident is a case in point why training and education are paramount for small and mid-scale producers.

• “Customers deserve to know exactly what they are buying, and farmers markets are responsible for earning and maintaining consumer trust in the direct relationships with local farmers,” says Stacy Miller, Executive Director of the Farmers Market Coalition.

Food Safety and Farmers Markets

August, 2011

November, 2006

The 2006 Outbreak

• September, 2006

– FDA issues “do not eat” order

– Over 200 illnesses traced to California grown spinach

– At least 3 people died of E. coli 0157:H7

• Samples of river water, wild pig feces, and cattle feces tested positive for the outbreak strain of E. coli O157:H7

The 2006 Outbreak Determination


• Feces of nearby, open range cattle were found on fields where the contaminated organically produced spinach was grown




• It was determined that feral pigs were entering cattle pastures and came in contact with contaminated cattle feces




• It was determined that feral pigs were entering cattle pastures and came in contact with contaminated cattle feces

• In addition to their own feces, feral pigs entering spinach fields had contaminated cattle feces on their fur which lead to the cause of the outbreak


The 2006 Outbreak • Impact on California and Arizona leafy green industry

– Sales plummeted – up to $650 M in losses

– A dramatic wake-up call for the industry

• Food safety standards were high, but the industry recognized that it could do better

Arizona Leafy Green

Marketing Agreement

California and Arizona are the only 2 states where leafy greens are grown under a unparalleled collection of guidelines

The LGMA will likely become the production model for leafy green growers in the US

Arizona Leafy Green Marketing Agreement

Field Management

Environmental Impact

Water Quality

UA Field Level, Fresh Produce Safety Research

Jorge Fonseca Charles Sanchez Kurt Nolte Chuck Gerba Channah Rock Kelly Bright Sadhana Ravishankar Jeong-Yeol Yoon

Significant Field-Level Safety Innovations

• Irrigation water metrics

• Animal intrusion metrics

• Reliable and inexpensive rapid methods of microbial assessments

• Traceability

• Behavioral Change

• Overall risk evaluation

• Arizona GHP/GAP & Audits

Why Certification?



• Buyer-driven

– Produce buyers want food safety programs

– Grocery chains, restaurants, distributors

– Improved Marketability

– Approved AZ Food Source

• GROWER Protection

• October 1, 2006. “Legal experts say the companies do not need to have known that their products were contaminated to be convicted of criminal charges, only negligent in their duties to keep tainted foods from the market.”1

2006 Criminal Investigation Timeline

1. USAToday.com 2. NYTimes.com 3. Ecnext.com


• October 6, 2006. “FBI investigated allegations that certain spinach growers and distributors may not have taken all necessary or appropriate steps to ensure that their spinach was safe before they were placed into the food chain.”2




• October 6, 2006. “FBI investigated allegations that certain spinach growers and distributors may not have taken all necessary or appropriate steps to ensure that their spinach was safe before they were placed into the food chain.”2

• October 7, 2006. “Processors operated a food-safety program in which small-scale farmers provided health and safety inspections and maintained databases of GAP/GHP audit reports. The company turned over these audit reports to the FDA and FBI.”3



• June 27, 2007. “The U.S. Attorney General’s office has determined that criminal charges are not warranted in the 2006 E. coli outbreak linked to fresh, bagged California spinach.”


Pritzkerlaw.com

• June 27, 2007. “The U.S. Attorney General’s office has determined that criminal charges are not warranted in the 2006 E. coli outbreak linked to fresh, bagged California spinach.”

• “Those involved in the sale of the spinach showed sufficient written food safety documentation that eliminated grower/shipper negligence.”


Pritzkerlaw.com

• In 1996, an E. coli outbreak linked to organic lettuce did lead to criminal charges for violating food-safety laws

Pritzkerlaw.com

Criminal Charges, 1996 NOT Related to the 2006 Outbreak


• In that case, an E. coli outbreak in the Eastern United States was traced back to Fancy Cutt Farms in California

Pritzkerlaw.com




• According to the criminal complaint, organically grown lettuce was processed in unsanitary conditions that led to bacterial contamination

Pritzkerlaw.com




• According to the criminal complaint, organically grown lettuce was processed in unsanitary conditions that led to bacterial contamination

• The company was rinsing lettuce in dirty, bacteria-laden water close to cattle. It was believed that dust-borne manure contaminated with E. coli got into the rinsing water

Pritzkerlaw.com


What is the GAP/GHP Program? • Good agricultural practices (GAPs) encompasses

the general procedures growing and harvesting of crops.

• Good Handling Practices (GHPs) refers to all post-harvest procedures including washing, packing, storage, repacking and distribution.

• Nomenclature Quirks… – Some use “GAPs” as a comprehensive term

– For others, “GHP/GAP” is a term which describes the food safety programs.

PREVENTION is the Key to Reducing Microbial Contamination

of Fresh Fruits and Vegetables

AZLGMA

Industry GAPs

USDA Harmony Gap

USDA Global GAP

USDA GHP/GAP

US Produce Safety Programs

Strict

Lenient

History of GAP/GHP Audits

• 1998 - FDA and USDA issue “The Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables”

• Wholesalers want assurance

• Shippers and Growers approach USDA to develop an audit system

• Result: GAP/GHP Audit system was developed by USDA and FDA

Audits

• Six components

• Plus a general questions section that must be passed first in order to move on to one or all of the six components

• Must score a minimum of 80% to pass

If you did not RECORD IT,

you did not do it

• Record keeping allows you to keep track of farming operations and worker training.

• Record keeping documents your activities should this information ever be required.

• Use log sheets for daily activities.

Audit Components

D = Documentation

R = Record

P = Procedure

A policy, “P” indicates that a policy/standard operating procedure (SOP) must be included in the food safety plan.

Policies, Documents and Records…

Policy Examples: • Workers will shower daily… • Eating and smoking are confined to designated areas… • Gloves will not be taken to the restroom… • Wearing Jewelry is prohibited… • Long hair must be tied back and contained within a hair net… • Product containers are not intended for personal use…

A document, “D” indicates that a document(s) is required. A document may be a combination of a company policy and a record indicating that a particular action was taken.


Policy (example): Restrooms will be cleaned every 2 hours. Document shows adherence to policy.

A record, “R” indicates that a record is required to be kept showing an action was taken.


Seven Components

• General Questions (all audits) • Part 1: Field Production • Part 2: Field Harvesting & Field Packing • Part 3: Packing and Processing Facilities • Part 4: Storage and Transportation • Part 5*: Traceability (Embedded within all other parts) • Part 6: Wholesale Distribution/Warehouse • Part 7: Preventative Food Security Procedures *Traceback questions are incorporated into each

component.*

General Questions

• Mandatory component of all audits

• Covers employee & visitor hygiene practices

• Training of employees

• Sanitation of farm/facility

• Traceability

Part 1 – Field Production • Water

• Manure

• Animal/Wildlife

• Land Use

Part 2 – Field Harvest and Field Packing

• Field Sanitation

• Field Harvesting and Transportation

Part 3 – Packing & Processing Facilities

• Water use

• Packing Line Operation and Sanitation

• General Facility Sanitation

Part 4 – Storage and Transportation

• Containers and Pallets

• Pest Control

• Temperature Control

• Transportation/Loading

Part 5 - Traceability

• Contained within all other audit parts

Traceback

• One step forward, one step back

• If you had to identify a potentially contaminated load/lot/bin could you find out which field it came from, how much was picked, when it was picked, maybe by whom, and where it went?

• Documentation through record keeping

Part 6 – Wholesale Distribution Center/ Warehouses

Part 7 – Preventive Food Defense Procedures

• Based on FDA’s “Food Producers, Processors, and Transporters: Food Security Preventive Measures Guidance for Industry”

• Audit-based

Automatic Failure

• Immediate food safety risk

• Presence of rodents, pets, etc.

• Employee practices that might jeopardize the safety of produce

• Falsification of records

• No Quality Manual (Question G-1)

• No one designated to oversee an established food safety program (Question G-2)

GHP/GAP Training

Food Safety Plan

3rd Party Audit

USDA Certification

UA/ADA

Growers

ADA

• Sales to end users within 275 miles= EXEMPT

• Average annual sales of “all food” <$500,000= EXEMPT

• Farmers markets, roadside stands, CSA’s= EXEMPT

• Exemption withdrawn if foodborne illness is directly linked to exempted farm

• Food must be labeled w/farm identification--name and business address of the farm

• Does not preempt state/local food safety laws or buyer requirements

Small Farms

Audit Fees

• $92 per hour

• $50 administrative fee (each time)

• Billing starts when inspector leaves office until inspector returns to office

• Grants available

• Travel time can be shared between multiple producers in same area

GAP/GHP

Where to find GAP/GHP Audit Info

USDA website

www.ams.usda.gov/gapghp

University of Arizona website

http://cals.arizona.edu/fps/

http://www.ams.usda.gov/gapghp

http://cals.arizona.edu/fps/

Name this crop…€¦ · Jaquith Farm, from which they were resold at retail outlets, farm stands,...

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Transcript of Name this crop…€¦ · Jaquith Farm, from which they were resold at retail outlets, farm stands,...