Food Safety Modernization Act: Produce Safety Rule: Worker Health and Hygiene
Identifying the Risks
People can be a source of produce contamination in the field, during harvest or during post-harvest activities. They can carry the pathogens that cause illness on their hands, skin, and in their gastrointestinal and respiratory tracts. Hands (or gloves), when contaminated with dirt, dirty water, poop or bodily fluids, or bacteria, or manure from animals, can spread the pathogens that cause foodborne illness. If workers are sick, they can be the source of those same pathogens—especially if they have an infection, are vomiting, or have diarrhea.
Note: “Workers” includes employees, family members, volunteers or CSA workers who are involved in pre-harvest, harvest and post-harvest activities.
To assess your farm for worker health and hygiene risks answer the following questions:
- Do you have clean, stocked, and accessible bathroom facilities for workers and visitors?
- Do you have clean, stocked, and accessible handwashing facilities (including in proximity to the bathroom facilities) for workers and visitors?
- Do you have policies in place that do not allow workers/visitors to eat, smoke, or chew gum in production, harvest and post-harvest areas when these areas are in operation?
- Do your workers know how to address injuries, cuts, illnesses, etc. and the presence of blood or bodily fluids that may occur on the job?
- Are workers who apply pesticides, sanitizers or other chemicals in food production, harvest or processing areas, trained and aware of the food safety risks?
- Is appropriate training provided to all workers and visitors at least annually or when they are first on the farm? This includes:
- Understanding the relationship of safe food handling practices and foodborne illness.
- Appropriate personal hygiene and illness practices.
If you answered NO to any of these questions then you should consider ways to reduce food safety risks.
What the Rule Requires:
Training and Practice
Handwashing, personal cleanliness, wearing clean clothes, not smoking or eating on the job, proper glove use, etc. are all practices and policies farm workers must know, understand, and follow. The responsible person must train workers regarding health, hygiene, and food safety.
Employee Health
- The supervisor must have policies, procedures and training in place to prevent ill or infected persons from contaminating produce.
- You must exclude any person from working if they have an applicable health condition. What are applicable health conditions? Communicable illnesses that present a risk: infection, open lesion, vomiting, and diarrhea.
- Personnel must be trained to tell their supervisor if they have, or if there is a reasonable possibility that they have these health conditions.
- Restrooms and handwashing stations must be available to workers. Workers need to be able to get to restrooms easily so they are not tempted to go on/near the field.
- Visitors, including those attending a pick your own operation, taking a tour or conducting business need to be made aware of food safety practices and must have access to toilet and hand washing facilities.
In Addition to the Rule
It is always good to write things down. Consider writing a food safety plan or at least standard operating procedures (SOPs) or policies that address worker health and hygiene. Writing the policies and procedures down ensures standardization of practices and provides a tool for employee education.
- Sample Worker/Visitor Food Safety Policies and Procedures
- Sample list of employee health and hygiene rules
- Video describing FDA Guidance regarding worker health and hygiene standards compliance
- Visitor Policy Language for food safety manuals (Michigan State University)
- Worker health and hygiene (Penn State University)
- Bodily fluid clean-up on the farm (North Central Region)
Tools for Worker Health and Hygiene
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Sources for hand washing sinks*
- Portable Handwashing Station/Unit - Multiple Plans/sources
- Or, search “hand wash stations to buy”.
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Sources for portable toilets and hand wash sinks to rent*
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- Use your favorite search engine, type in portable toilets or hand wash stations, Connecticut or portable toilets for sale.
- If considering purchase of a portable toilet, think about how you will have the facility serviced. You may still need to hire a sanitation company to empty and/or service the toilet.
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Sources for hand wash signage*
- Cornell National GAPs program plastic laminated signage
- Centers for Disease Control (CDC) downloadable posters (print and laminate yourself)
- You may also find signage options at commercial outlets such as Uline, Amazon, and ComplianceSigns.com and others.
- *Trade, brand names, and commercial product examples are used only for information and to illustrate source options for farmers. UConn Extension does not endorse, guarantee or warrant any product mentioned; neither does the use of a trade or brand name or commercial website imply approval of any product to the exclusion of others which may also be suitable.