By Dominique Giroux, VT Agency of Agriculture, Food & Markets
This is the fifth article in our series Romaine Calm: Breaking Down the Produce Safety Rule.
The season for agritourism is among us! With pick-your-owns, farm tours, and on-site workshops in full swing on Vermont farms, it’s important that visitors are well-informed about your farm’s food safety policies. Visitors are excited to be on farms but may not realize that their actions, and those of their children or pets, can lead to unintentional food safety risks. Set your farm up for success this season by ensuring you have clear policies in place for visitors and their furry friends.
The Food Safety Modernization Act (FSMA) Produce Safety Rule (PSR) requires farms that are covered under the rule to:
- Make visitors aware of policies and procedures to protect covered produce and food contact surfaces from contamination by people and take all steps reasonably necessary to ensure that visitors comply with such policies and procedures, and;
- Make toilet and hand-washing facilities accessible to visitors (see 21 CFR §112.33).
In addition to human visitors, the PSR also includes requirements relating to domesticated and wild animals. While there is nothing in the rule that prohibits pets on farms, it is important to note that covered farms must:
- Assess areas for evidence of potential contamination of covered produce as needed during the growing season, and;
- If significant evidence of potential contamination is found (such as observation of animals, animal excreta, or crop destruction) you must evaluate whether the covered produce is reasonably likely to be contaminated with a known or reasonably foreseeable hazard and should not be harvested (see 21 CFR §112.83).
You will notice the language in the PSR is relatively generic, which gives you the freedom to meet the requirements through procedures and practices that best suit your farm. Ultimately, it’s up to you to determine how to communicate your produce safety policies to visitors.
The Basics: What Visitors Should Know
Once you open your farm to guests, you are introducing a new set of risks. Let’s face it, not everyone understands the amount of time and effort that goes into ensuring produce is grown and handled with safety and care. When folks visit your farm, they are likely not thinking about the impact they can have on food safety. Consider reviewing the following topics with visitors, either verbally or visually through the use of posters, handouts, or policy summaries:
- Remind visitors not to visit the farm if they are sick or have symptoms of a communicable illness. Does your farm have a website or main entry point? You can utilize these central locations to advertise sickness policies as they relate to your farm. Farms using a visitor’s sign-in sheet may wish to include a sickness policy reminder on the sign-in sheet itself.
- Remind visitors to keep their pets at home. Domesticated animals can pose as many produce safety risks as wild animals, and when possible, it’s important that visitors keep pets off the farm. For example, let’s say a visitor brings Fluffy to your farm. As you walk around children and adults see the dog and go to pet its long, luscious fur. Now, they go to pick their own apples. You see where we are going with this. You can avoid unnecessary produce safety risks by kindly asking your guests to reunite with their pets after their visit to your farm. If you do have animals on your farm, (visiting, working, domestic, or wild) be sure to assess areas for animal intrusion and take the necessary actions to mitigate potential contamination.
- Clearly communicate to visitors what areas of the farm are off limits. For example, unless there is a good reason for visitors to enter the wash/pack and storage areas, or to walk in production fields, consider marking these areas off limits with posters or through verbal communication.
- Help visitors understand why, when, where, and how to wash their hands. Do you have a pick-your-own and an animal petting zoo? Consider placing a sign or an employee at the exit/entry points of these two locations indicating where visitors can wash their hands and when to do so, (for example, before and after touching animals). Also consider adding a “How-To Wash Your Hands” sign in toilet facilities. While we love to believe everyone is a master hand-washer, it’s not always the case. Having a few simple reminders such as using soap and thoroughly cleaning hands for at least 20 seconds are important reminders that can go a long way.
It is important to note that the Americans with Disabilities Act (ADA) and Vermont public accommodation statutes makes provisions for service animals. Service animals are trained to perform specific jobs or tasks for individuals, and in general, therapy, emotional, and comfort animals that have not been specifically trained are not considered service animals. Under the ADA, in situations where it is not obvious that the dog is a service animal, staff may ask only two specific questions: (1) is the dog a service animal required because of a disability? and (2) what work or task has the dog been trained to perform? Staff are not allowed to request any documentation for the dog, require that the dog demonstrate its task, or inquire about the nature of the person’s disability. For further details, see the U.S. Department of Justice’s document “Frequently Asked Questions about Service Animals and the ADA” and the Vermont public accommodation statutes.
Communication is Key
As mentioned above, it’s up to you how you make visitors aware of policies and procedures that prevent produce safety risks. Consider the logistics of your farm flow – do you have a centralized location for visitor check-in? A central entry point can be a great location to either verbally or visually communicate your farm’s produce safety polices and let guests know where toilet and hand-washing facilities are located. For example, you could:
- Create a sign that outlines visitor policies and display it at the point of entry to your farm.
- Allow visitors to easily locate restrooms by placing arrows pointing to where the toilet and hand-washing facilities are located.
Develop communications that work well for your farm – the examples above are just suggestions to get you thinking but may not be appropriate for every operation.
Taking the time to educate visitors about your produce safety policies will not only help reduce risks but also shows your customers that you take produce safety seriously. Many of us strive to eat healthier and doing so means we need to trust that the produce we eat is safe. We all have a part to play, and it’s important to remind visitors to do their part to minimize the risk of potential contamination when they enjoy a visit at your farm.
Do you have questions about the Food Safety Modernization Act Produce Safety Rule or produce safety in general? Contact the Vermont Produce Program team at the Vermont Agency of Agriculture, Food, & Markets. They can help you determine whether your farm is covered under the rule and provide you with resources and next steps.