Tools For Farmers: Biological Soil Amendments of Animal Origin

Find BSAAOs Produce Safety Rule standards here.

Identifying the risks

Biological soil amendments of animal origin (including manure, non-fecal animal byproducts such as table waste or animal carcasses; does not include human waste) can be the source of human pathogens, including bacteria (E. coli, Salmonella, Listeria), viruses (HepatitisA and Enterovirus), and parasites (Giardia, Cryptosporidium). Good management of BSAAOs can reduce the risks that these pathogens will impact the safety of your produce. In addition to direct contact with produce, good management will reduce the chances that BSAAOs will contaminate irrigation water sources and the soil in your production fields. Because it is not always possible to remove these pathogens from contaminated fruits and vegetables, prevention is the key. Reduce risks by adopting BSAAOs management practices that eliminate or minimize contamination.

To assess your farm for risks from BSAAO's answer the following questions:

		Yes	I need to work on this
	The risks of all types of soil amendments should be considered whether it is table waste, fish emulsion, or blood meal (all considered a BSAAO); vegetative waste or compost; or of chemical origin, through the Rule focuses on BSAAO's.
	Raw manure
1.	Is raw manure stored in a way that minimizes contamination (by leaching, drift, or wildlife) of water sources, composted manure, produce fields, and equipment?
2.	When employees work with raw manure; do they minimize cross contamination by changing clothes, shoes, washing hands prior to working in produce fields or packing facilities?
3.	Is raw manure applied at least 120 days prior to harvest of produce crops? 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?
4.	Is raw manure applied so that it does not come into contact with covered produce during application or during production or harvest? (i.e. no side dressing)
	Composted manure
1.	If composted manure or biosolids are used, is the product treated using a scientifically validated, controlled process?
2.	Do you use human sourced biosolids? If so, do they meet the requirements of EPA? Are they Class A biosolids?
3.	Are records kept and produced regarding treatment of soil amendments to render the treatment safe for use on produce?
4.	Is composted manure stored so that it is not at risk for contamination by raw manure, wildlife or domestic animals?
	Agricultural teas
1.	Is agricultural tea made from treated soil amendments and using water that contains no detectable generic E. Coliin order to be considered “treated”?
2.	If you are using agricultural tea that contains untreated soil amendments and/or surface water, are you treating it as untreated?
	Additional procedures
1.	Are tools and equipment designated for use with soil amendments; or, if used with produce, are cleaned/sanitized to prevent cross-contamination?
2.	Are records kept to document application of soil amendments?

If you answer any of these questions with “I need to work on this,” then you should consider ways to reduce food safety risks by working towards a “YES” answer.

What the Rule requires

Training and practice

Workers who handle and apply soil amendments receive training regarding food safety risks of BSAAOs, cross-contamination concerns with raw manure, including use of equipment and tools, and safe application of soil amendments to covered produce.
The responsible person must train workers regarding BSAAOs and food safety.

Farmers must minimize the risk of contamination of fresh produce by holding, transporting, storing, treating, applying biological soil amendments of animal origin (BSAAOs) according to PSR standards.

Untreated BSAAOs can only be applied 120 days prior to harvest or in a way that does not come into contact with edible product.
Farms can use BSAAOs treated to the most rigorous PSR standard directly on the edible (or soon to be edible) parts of produce.
Keep records regarding treatment of soil amendments of animal origin to show the method of treatment. If using raw manure you must keep records that show that the manure is not a source of contamination for covered produce, food contact surfaces, areas used for covered activity, water sources, water distribution systems and other soil amendments.

Go to the Training Page for more information specifically about worker training, including BSAAOs and other food safety related training.

What you might want to do 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 proper storage, treatment, handling and application of BSAAOs, including prevention of cross contamination. Writing the policies and procedures down ensures standardization of practices and provides a tool for employee education.
UConn Extension resource to help with questions regarding handling/storing/composting animal manures:
Rich Meinert; richard.meinert@uconn.edu ; 860.626.6240

Sample record keeping forms for BSAAOs

Compost Treatment Record (Produce Safety Alliance)

Soil Amendment Application Log (Missouri Department of Agriculture)

Agricultural Inputs (On Farm Food Safety)

Tools for reducing risks from BSAAOs

General information

FDA Fact Sheet: Produce Safety Rule (21 CFR 112)

Biological Soil Amendments of Animal Origin

FSMA Compliant On-Farm Thermophilic Composting: A Safe Way to Enrich the Soil

Iowa State University Extension and Outreach

North Central Region Center for FSMA Training, Extension, and Technical Assistance

Manure Management for Small and Hobby Farms