Food-safety rules stress training, hygiene

Issue Date: August 28, 2013
By Steve Adler
Garrett Patricio of Westside Produce stands by a pallet of cantaloupes that were harvested near Firebaugh that morning. They will be shipped to distributors within 24 hours of harvest.
Photos/Steve Adler
Photo shows traceback sticker that identifies the actual location where the melons were picked and the crew that picked them.
Photos/Steve Adler
Juan Martinez, loading supervisor at Westside Produce in Firebaugh, washes his hands prior to working with a shipment of cantaloupes that just arrived at the facility from a nearby field. Hand washing and other hygienic protocol are all part of Westside Produce’s food safety program.
Photo/Steve Adler

Editor's note: This is Part 4 of a series of stories about how proposed federal food-safety rules could affect California farmers and ranchers.

When it comes to worker health and hygiene and to keeping work surfaces clean and sanitized, proposed food-safety rules released in January by the U.S. Food and Drug Administration coincide closely with what is already being done at California farms and packinghouses.

The proposed rules reflect how the FDA plans to enforce the Food Safety Modernization Act, which covers fresh fruits and vegetables. The FDA is seeking public comment for proposed rules governing the growing, harvesting, packing and holding of produce, and governing food processing facilities.

Two parts of the proposed produce-safety rule include: Personnel Qualifications, Training, and Health and Hygiene; and Equipment, Tools, Buildings, and Sanitation.

Bryan Little, California Farm Bureau Federation director of labor affairs, said that his analysis of the proposal showed it "didn't seem to require anything beyond what employers are already required to do for field sanitation."

This includes such things as providing appropriate toilet facilities—either fixed or mobile—hand-washing facilities, and the ability to dispose properly of the gray water and paper towels.

"Those are the basic things that employers are required to do with field sanitation," Little said.

Cantaloupe grower Garrett Patricio of Westside Produce in Firebaugh agreed, noting that stringent food safety requirements were adopted last year by the California Cantaloupe Advisory Board and are mandatory for all cantaloupe producers in the state. The 156-point cantaloupe checklist covers everything from worker health and hygiene to maintaining clean and sanitized work surfaces.

"Sanitation has become one of the most important things that we do," Patricio said. "With regard to workers and their health and hygiene, we are much more on top of this every day. We are asking, 'Are you sick? Have you been sick? Have you come into contact with anyone who is sick? Have you washed your hands? Please wash your hands.'"

Patricio said that if employees are to wear gloves during the course of the harvest, those gloves must be distributed by or under the control of the employer. They must be collected at the end of the day and must be cleaned and sanitized every day.

"It is our belief that based on environmental conditions, an outbreak is very unlikely; not to mention the way we handle the product. One hand is touching the melon, one hand is putting it onto the contact surface that is cleaned and sanitized daily, and one hand is stacking it in a box. So the likelihood of any pathogenic spread is pretty remote," he said.

Scott Horsfall, chief executive officer of the Leafy Greens Marketing Agreement, said proposed rules under FSMA are similar to those required under the leafy-greens agreement, and said he supports the federal rules' focus on training and education.

"We believe that worker training is extremely important. In our industry, we are building a commodity-specific training program to go along with our requirements. So this is one thing that we think is really good in the rule," he said.

Horsfall said he recommends that training be done through a "train-the-trainer" concept, where qualified individuals who have gone through training themselves—whether on-the-job training or in some kind of formal setting—would then be in charge of training foremen and their crews.

Patricio said training has taken on a wider scope at Western Produce, as well.

"Our training program has gone from virtually one training session a year on food safety and refresher training once a week to one training at the start of the year with all employees and supervisors, every Monday training and a visit from a food safety inspector from our company with each crew every day. We are asking the crew questions to make sure the policies and good agricultural practices are being followed," he said.

In evaluating the FSMA proposed rules, Horsfall said one area of concern relates to documentation.

"A lot of food safety practices have been in place for a long time and growers and packers are doing them routinely, but they may not have been documenting them," he said. "Documentation can be a real challenge and when we started our program, that was one of the biggest areas of concern that people had. What would be the cost? What would be involved in maintaining those documents and having them where you can get your hands on them when you are being audited?"

Horsfall said another concern relates to verification of compliance to FSMA provisions.

"We want FDA to look to programs that already exist—like the LGMA or the Cantaloupe Advisory Board or the tomato farmers—that already have food safety programs in place. We want to be in a position to do the verification along with FDA, so we don't get more audits and inspections on top of what people already have," he said.

The proposed FSMA rules require personnel who handle produce, or their supervisors, to receive training; require measures to prevent people with communicable illnesses from contaminating produce; require use of hygienic practices to protect against such contamination; and require measures to ensure that visitors are aware of food-safety procedures.

Rules for buildings, tools and equipment include requirements that equipment and tools be adequately constructed, cleaned and maintained; that equipment and tools be stored and maintained in ways that prevent produce from being contaminated; that all surfaces of equipment that contact produce be inspected, maintained, cleaned and sanitized; and that instruments or controls used to regulate and monitor temperature and other factors be accurate and precise.

The public comment period for the proposed food-safety rules continues until mid-November.

(Steve Adler is associate editor of Ag Alert. He may be contacted at

Next week: How proposed food-safety rules would affect food processors.

Permission for use is granted, however, credit must be made to the California Farm Bureau Federation when reprinting this item.

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