Romaine Calm: Breaking Down the Produce Safety Rule Harvest Tools & Equipment

03 April 2019

By Dominique Giroux, Vermont Agency of Agriculture and Andy Chamberlin, University of Vermont, Extension This is the sixth article in our series “Romaine Calm: Breaking Down the Produce Safety Rule.”

Ah, the fall harvest. A rewarding time of year when all the planning, planting, and maintaining that takes place throughout the growing season comes to fruition. While this is perhaps one of the busiest times of the year for produce growers, it’s important to keep in mind how you are handling, and cleaning, your harvest tools and equipment. With a rush of visitors on farms to get the last of their farm visits in before winter, it can be easy to overlook routine cleanings of tools and equipment. However, by staying organized and keeping track of cleaning and sanitizing procedures, you can efficiently execute your fall harvest, all while maintaining a clean working environment. Later in this article, we will share one growers’ farm-hack – an innovative solution or tool that anyone can use – that she and her crew used to remain organized and food-safe in the field. 

To start, let’s look at what produce farm equipment and tools are subject to the requirements of the Food Safety Modernization Act (FSMA) Produce Safety Rule (PSR). Bear in mind that the PSR only applies to farms that are covered under the rule. The PSR states:

  • Equipment and tools subject to the requirements of this subpart [Subpart L] are those that are intended to, or likely to, contact covered produce; and those instruments or controls used to measure, regulate, or record conditions to control or prevent the growth of microorganisms of public health significance (see 21 CFR §112.121).

So, what does this mean? Examples of equipment and tools likely to contact covered produce include knives, mechanical harvesters, cooling equipment, grading belts, harvest containers and bins, food-packing material, and vehicles – just to name a few. Think of any tool or equipment that contacts produce on your farm, and it’s likely something you’ll want to routinely clean, and when necessary, and/or appropriate, sanitize.   

Once you have identified tools and equipment that contact produce, take a look at the general requirements that apply to them as required by the PSR (all of the following requirements apply regarding equipment and tools subject to this subpart; see 21 CFR §112.123):

  1. You must use equipment and tools that are of adequate design, construction, and workmanship to enable them to be adequately cleaned and properly maintained; and
  2. Equipment and tools must be:
    1. Installed and maintained as to facilitate cleaning of the equipment and of all adjacent spaces; and
    2. Stored and maintained to protect covered produce from being contaminated with known or reasonably foreseeable hazards and to prevent the equipment and tools from attracting and harboring pests.
  3. Seams on food contact surfaces of equipment and tools that you use must be either smoothly bonded, or maintained to minimize accumulation of dirt, filth, food particles, and organic material and thus minimize the opportunity for harborage or growth of microorganisms.
  4. (1) You must inspect, maintain, and clean and, when necessary and appropriate, sanitize all food contact surfaces of equipment and tools used in covered activities as frequently as reasonably necessary to protect against contamination of covered produce.
    (2) You must maintain and clean all non-food-contact surfaces of equipment and tools subject to this subpart used during harvesting, packing, and holding as frequently as reasonably necessary to protect against contamination of covered produce.
  5. If you use equipment such as pallets, forklifts, tractors, and vehicles such that they are intended to, or likely to, contact covered produce, you must do so in a manner that minimizes the potential for contamination of covered produce or food contact surfaces with known or reasonably foreseeable hazards.

As noted in previous series articles, the language in the PSR is relatively flexible, giving you the freedom to meet the requirements through routines that best suit your farm. For example, in (d)(1), listed above, the PSR notes “you must inspect, maintain, and clean … as frequently as reasonably necessary to protect against contamination of covered produce.” In full-swing harvest season, perhaps this means you are cleaning tools every day, maybe twice a week, or every Friday – again, it’s up to you to determine a frequency appropriate for your farm.

Lisa MacDougall of Mighty Food Farm in Shaftsbury, VT came up with a creative solution to keeping tools clean and organized, aiding to efficiency in the field and in cleaning procedures. She has a new-found love for a little blue box she calls the “Harvest Tote” which holds all the essentials needed for daily harvesting out in the field.

What does the Harvest Tote include?

  • Harvest knives
  • Snippers
  • Scissors
  • Sharpening Stone
  • Rubber Bands
  • Harvest Log
  • Pens, pencils, markers

Every morning the Harvest Tote gets placed in the truck. These essential tools are always kept together in one place, minimizing time needed to look for tools, or to take trips back to the packshed because the rubber bands were forgotten. Reducing downtime and saving wasted steps can lead to increased efficiencies in your operation. “We always have what we need, when we need it,” says MacDougall. “I wanted an organized method for keeping all harvest supplies on hand and clean.”

And of course, this kit has food safety benefits too! With all the tools stored together, the crew is able to efficiently clean, sanitize, and record cleanings, usually on a weekly basis. You no longer need to wonder which knives are clean and which are dirty – storing all the tools in this handy tote and cleaning them at the same time is a great solution to being proactive about food safety. These routine weekly cleanings are also an opportunity for a weekly sharpening, so all tools are in good shape for the week ahead. Keeping the tools in a tote keeps the knives from getting used for other activities outside of harvest, further preventing contamination. Keeping the knives in a tote also ensures that they are not stored in a hard-to-wash sheath, tossed onto the dash of the truck, or into a cup holder.

Implementing this standard has many benefits and could be a great tech-tip to consider on your farm. It’s a prime example of how food safety and farm efficiency go hand-in-hand. Consider taking some time to brainstorm areas on your farm where developing standard-operating procedures (SOPs) can assist with tool and equipment organization and cleaning.

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. Email AGR.FSMA@vermont.gov or call (802) 828-2433 to connect with someone today. Visit http://agriculture.vermont.gov/produceprogram to learn more about the Vermont Produce Program.

 
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