Find Worker Post-Harvest handling of Produce Safety Rule standards here.
Identifying the risks:
Post-harvest contamination of fresh produce primarily takes place during washing and packing of the product. An assessment of risks involved can help reduce contamination. The main pathogens identified as risk factors in produce are Listeria spp., Salmonella spp., and E.coli (primarily E.coli O157:H7). Recent outbreaks in fresh produce from these bacteria have led to increased focus on cleaning and sanitation practices to eliminate food safety risks in post-harvest operations.
Formation of sturdy biofilms (bacterial film that is attached to a surface and protects the microorganism), such as formed by Listeria and the harborage site of bacteria are additional risks that can cause continuous contamination of the washing and packing areas. Biofilms can occur on any surface such as metal, flooring material, fabric, rubber and wood especially if the material is porous or pitted. Problems associated with these areas are that they are infrequently or inadequately cleaned, which can cause pieces to break off and enter food contact surfaces and food without worker’s knowledge. Sites that are hard to clean, but provide food, water, ideal temperatures to the bacteria, include hollow rollers, boots/shoes, forklifts, cracked walls or ceilings, equipment such as conveyors, bins, blenders, slicers etc. These are hard to get to and are often overlooked. Therefore, increased precautions should be taken during cleaning and sanitation of these sites.
Areas within the packing and handling area can be broken into zones to help determine the likelihood of direct contact with the produce you are handling:
Zone 1: Direct food contact surfaces such as conveyors, belts, brushes, rollers, sorting tables, racks, utensils, harvest/storage bins, and worker hands. This zone is the biggest concern because it has direct contact with the produce and if contaminated, could result in contamination of the entire crop.
Zone 2: Non-food contact surfaces that are in close proximity to the product, such as internal and external parts of washing or processing equipment such as sidewalls, housing, framework, or spray nozzles.
Zone 3: Areas inside of the packing area such as trash cans, cull piles, floors, drains, restrooms, forklifts, phones, and catwalks or storage areas above packing areas.
Zone 4: Areas outside of or adjacent to the packing area such as loading docks, warehouses, manure or compost piles, and livestock operations
To assess your farm for post-harvest contamination risks answer the following questions:
| Yes | I need to work on this |
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| 1. |
a. Do you harvest and handle both covered and non-covered produce?
b. If you answered yes for the above, do you separate covered and non-covered produce? |
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| 2. | a. Do you clean and sanitize equipment used in washing and packaging of produce? b. If you answered yes for the above, are there records of cleaning and sanitation of food contact surfaces/containers or equipment? |
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| 3. | Is the produce that contacts the ground, packing house floor, or other non-food contact surface discarded? | ||
| 4. | Is there an absence of standing water in the washing of fresh produce after cleaning and sanitation? | ||
| 5. | Are you using any monitoring equipment (temperature recorders, pH meters etc.) to check the accuracy of all appliances? | ||
| 6. | Do you ensure vehicles used to transport produce are cleanable, clean or sanitary? | ||
| 7. |
a. Are building drains, walls, ceilings and floors checked for leaks or other sources of contamination?
b. Are buildings adequate in size and construction (including adequate partitions and drainage)? |
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| 8. | Do you have a pest control program in place for your facility? |
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
- If you grow both covered produce and produce that is not covered—you must keep them separate. Wash, pack and handle them in a separate space or by handling the covered produce first thing in the day and the non-covered produce after that. Be sure to adequately clean and sanitize food contact surfaces after handling non-covered produce, before using the surface for covered produce. The best approach might be to treat all produce you grow as if it were covered produce.
- Workers must use clean hands/utensils/tools for harvest. Keep product off the ground during harvest, do not harvest dropped produce.
- All tools, equipment, and buildings must be constructed of materials that can be cleaned and will not contribute to the contamination of produce.
- All buildings used for covered activities and/or for storing equipment or packaging that might come into direct contact with covered produce are included; as are vehicles used for transportation of covered produce.
- All tools or equipment that might come into contact with covered produce, including any that are used to measure (I.e. pH meters or thermometers), regulate or record conditions to control or prevent growth of pathogens must be used in a way that prevents contamination with pathogens.
- Farms must consider drainage, condensate and drip (from water pipes, compressors), and other characteristics of the post-harvest environment, including shielded light fixtures.
What you might want to do in addition to the Rule
The rule does NOT specify if you must have a certain building, tools and equipment that is constructed in a certain way. It doesn’t say you can’t use wood or that you must use stainless steel. Only that surfaces should be cleanable and, if needed, you should be able to effectively sanitize in a way that prevents contamination. The Produce Safety Rule provides the requirements necessary for handling harvested produce in the packing shed. In addition to these requirements, 21 CFR Part 117 Subpart B provides a list of Good Manufacturing Practices that are applicable to ensure product is compliant with the Food, Drug, and Cosmetic Act.
It will benefit to keep records of sanitizing the equipment, transport vehicles, carts, forklifts etc. Also, its good to use monitoring equipment such as temperature and pH meters and record the adequate administration of sanitizers or cleaning solutions.
Consider writing a food safety plan and/or standard operating procedures (SOPs) to adopt proper cleaning and sanitizing practices. In addition, although not required, frequent testing of various cleaning surfaces and equipment is recommended. In addition, a pest control and management program would greatly reduce potential contamination of fresh produce.
Sample record keeping forms and SOPs for post harvest sanitation
https://gaps.cornell.edu/educational-materials/decision-trees/sanitation-and-postharvest-handling/
http://blog.uvm.edu/cwcallah/2015/06/15/farm-building-plans/
https://www.fda.gov/media/107298/download
Tools for reducing risks post harvest contamination:
SOPs
- Cleaning and Sanitizing Surfaces, Tools, and Equipment
- Pest Monitoring, Management, and Corrective Actions Program to Minimize Food Safety Risks in Packing and Postharvest Handling Areas
Log Sheets
- Pest/Rodent Control Log
- Food Contact Surface Sanitation Log
- Tools and Equipment Cleaning and Sanitizing Log
- Produce Storage Area Inspection and Cleaning Log
- Cooler Temperature Log
*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.