Romaine Calm: Worker Health & Hygiene
By Tucker Diego & Dominique Giroux, Agency of Agriculture
Now is the time of year when things really start gearing up for the produce growing season. Many farms will welcome back returning seasonal employees and invite new employees to join their crews. This makes it the perfect time to reinforce the produce safety culture on your farm by making sure workers are fully trained on the principles of health and hygiene for produce production and handling.
This is the first article in a new series, Breaking Down the Produce Safety Rule, where we will introduce the national produce safety standards in the Food Safety Modernization Act (FSMA) Produce Safety Rule (PSR). \While the PSR may appear daunting at first glance, the rule itself is divided into sections, or “subparts,” that focus on specific areas, such as health and hygiene, domesticated and wild animals, or recordkeeping. In each article we will break down a specific area of the rule with a focus on one or two subparts.
This month we discuss worker health and hygiene best practices, with an emphasis on worker training (PSR subparts C—Personnel Qualifications and Training and D—Health and Hygiene). Specific PSR standards are referenced by their citation number. (See How to Reference the Produce Safety Rule below to learn more).
When the U.S. Food & Drug Administration (FDA) conducted a comprehensive assessment of public health risks on produce farms, they found that workers who fail to follow basic hygienic practices, such as routine hand washing, were one of the leading causes of contamination in produce-related outbreaks between 2014–2016. It’s crucial that workers understand how to identify produce safety risks, reduce risks while they work, and become active participants in your farm’s produce safety policies. The good news is that effective worker training can not only reduce produce safety risks but can also lead to improved worker satisfaction and productivity.
With this in mind, what should you consider when designing worker training?
Planning Your Training
Dedicate specific times for training within the first few days of employees starting work. Training should be required for all workers, including new and returning employees, and a record should be kept of the topics covered, the date, and who attended the training (21 CFR 112.30).
Training material should always be delivered in a way that is easily understandable. If workers don’t speak English as their first language, make sure training materials are provided in a language they can understand (21 CFR 112.21(c)).
Health and hygiene training can be combined with other farm training, but at a minimum the following topics should be covered:
- the importance of produce safety and hygiene
- the proper way to wash hands
- when workers are required to wash their hands
- where to access handwashing and toilet facilities
- how to report an illness or injury and where to access first aid kits (21 CFR 112.22(a))
Ensure workers are aware of what is expected for personal cleanliness and hygienic practices. In particular, workers should:
- not eat, chew gum, or use tobacco products in areas where produce is grown or handled,
- remove hand jewelry that cannot be adequately cleaned when handling produce,
- avoid contact with animals other than working animals, and
- if gloves are used, they should be maintained in an intact and sanitary condition and replaced as needed (21 CFR 112.32).
Employees that harvest or directly handle produce should also be trained on how to recognize contaminated produce (e.g., from animal fecal matter in the field), how to maintain the cleanliness of harvest containers and equipment, and who to report potential contamination issues to. Contamination issues should be followed up by a supervisor or produce safety manager (21 CFR 112.22(b)).
Training should emphasize that when workers are not in control of their own bodily fluids, they are a potential risk to produce safety on the farm and should remove themselves from production areas and immediately notify their supervisor (21 CFR 112.31). For instance, workers who are sick should not handle produce or any related equipment or surfaces; workers with abrasions, cuts, or lesions should also avoid contact with produce and equipment until the wound is adequately controlled or healed.
Review potential sources of contamination on the farm (manure piles, livestock areas, etc.) and encourage workers to be aware of practices that could cause cross-contamination. For example, if the farm has a mixed livestock and produce operation, workers should avoid cross-contaminating clothing, footwear, and equipment when moving between livestock and produce production areas.
Lastly, if you need to comply with the Produce Safety Rule, be sure to keep records of all trainings that take place. The PSR requires all employees to be trained at least once annually, and that a record is kept documenting the date of training, topics covered, and the persons trained (21 CFR 112.30). Make sure to retrain any workers who fail to follow your farm’s health and hygiene policies.
With effective training, you can be confident your employees are equipped with the knowledge and skills to reduce produce safety risks on your farm and provide quality, safe fruits and vegetables to your customers. Stay tuned for our next series installment, Agricultural Water and Produce Safety!
What employee training resources have worked well on your farm? Are there additional training resources or information you would find helpful? We’d love to hear from you. Please share your thoughts, questions, or concerns with our Produce Program team at (802) 522-3132 and AGR.FSMA@vermont.gov.
How to Reference the Produce Safety Rule
The most up-to-date version of the PSR can be found in the Code of Federal Regulations (CFR), Title 21, Part 112, at https://go.usa.gov/xneJa (case-sensitive). To find the PSR, under Year, select most recent; under Title, select 21; and under Part, enter 112. A citation refers to specific sections within the PSR; for example, 21 CFR 112.21(c) refers to section 112.21(c).
Find additional worker training resources at University of Vermont Extension’s Practical Produce Safety page at http://bit.ly/2BKrdBl (case-sensitive). The Produce Safety Alliance provides a worker training record template and other templates for records required by the FSMA Produce Safety Rule at http://bit.ly/2CLtbOV (case-sensitive).
U.S. Food & Drug Administration. (2015) Final Qualitative Assessment of Risk to Public Health from On-Farm Contamination of Produce. Available at https://go.usa.gov/xnMHw (case-sensitive).
When to Wash Your Hands
- Before starting work
- Before handling food
- Before putting on gloves
- After blowing your nose, sneezing, or coughing
- After smoking
- After using the bathroom
- After returning to work
- After touching animals or animal waste
Receive additional produce safety resources by enrolling in the
Vermont Produce Portal at: