Bulletin #4282, Food Safety Best Management Practices for Wild Blueberry Producers in Maine
This is a living document. These best management practices are subject to change based on future decisions made by DCAF and FDA.
Developed by Lily Calderwood, Ph.D. University of Maine Cooperative Extension Wild Blueberry Specialist, Robson Machado, Ph.D. University of Maine Cooperative Extension Food Science Specialist, Chris Howard, University of Maine Cooperative Extension Produce Safety Professional, and Reviewed by Leah Cook, Food Inspection Supervisor, Maine Department of Agriculture, Conservation & Forestry
Table of Contents
- Processing Exemption
- Best Practices to Meet the Produce Safety Rule Requirements
The goal of this factsheet is to help wild blueberry growers with the requirements of the Produce Safety Rule, as well as to describe some best management practices.
The overarching goal of food safety is to identify the risk of contamination and then reduce that risk. The University of Maine Cooperative Extension has identified the following best management practices to assist growers and processors in producing safe wild blueberries for human consumption. This document is a list of best management practices based on the Produce Safety Rule (PSR) under the Food Safety Modernization Act (FSMA). This fact-sheet is not a regulatory document, and the activities listed are not the legal language from the Produce Safety Law. In creating this document, UMaine Extension worked with wild blueberry growers and processors, the Maine Department of Agriculture, Conservation and Forestry (DACF), and the National Food and Drug Administration (FDA).
Starting on January 27, 2020, the Produce Safety Rule applies to businesses that earn more than $27,500 (average produce sales from 2016, 2017, and 2018; when compliance comes in 2020, these must be calculated with the average sales from 2017, 2018, and 2019) from all produce, including blueberries that are not made into jam or another processed product. If your business sells more than $550,000 (average sales from 2016, 2017, and 2018) from all foods, you are fully covered by the rule and will be inspected starting in 2019 (see table below). If you are between those two values, you may be partially covered and claim a qualified exemption. For covered farms, compliance dates for inspections are staggered based on total produce sales. For more information on exemptions to the rule, please check this factsheet at Bulletin #4281, Food Safety Modernization Act (FSMA) Produce Safety Rule Exemptions and referenced links at the bottom of this factsheet.
|Business Size (Values must be adjusted by inflation)||Compliance Dates for Covered Produce||Water Regulation Compliance Dates||Compliance Inspections to begin|
|Large (>$500K)||1/26/18||1/26/22||Spring 2019|
|Small (<$250K-500K)||1/28/19||1/26/23||Spring 2020|
|Very Small (>$25K-250K)||1/27/20||1/26/24||Spring 2021|
|Not covered (<$25K)||–||–||–|
Berries that will be sold fresh or frozen do not qualify for this exemption. The Produce Safety Rule has a “commercial processing exemption” for covered produce that is processed to “adequately reduce the presence of microorganisms of public health significance.” This exemption applies to covered produce that will be used to make final products that have a regulated kill-step that has been scientifically proven to reduce pathogens (such as pasteurized juice or acidified jam making). Another example of exempt produce would be tomatoes that are pasteurized when made into ketchup. Freezing, sanitizer application, or any combination of the two is not currently considered a kill step.
In cases where the farmer ships or transports produce from the farm to a processor that uses a kill step to make the end product, the farmer must include the following disclaimer with the produce: ‘‘not processed to adequately reduce the presence of microorganisms of public health significance.” This statement should accompany the produce on the bulk packaging or on your shipping/invoice paperwork. The goal of this practice is to clearly identify produce that was not handled according to the PSR due to a processing exemption from produce that will be sold fresh. The farmer will need written assurances* from the commercial processor that they, or their later customers, will be using a kill step to commercially process your produce.
*There is currently a hold on the requirement that processors must provide growers with a written assurance. Right now, any form of confirmation from the processor that they are processing in a manner that ensures safety is enough. This requirement is under evaluation and may become mandatory in the future. Nonetheless, if a grower claims the processing exemption, all the berries sold under this exemption must have the disclaimer with the berries (on containers) or on the invoice.
- Processing facilities are responsible for the fruit and other products that they sell. At this point, it is up to the processor to guarantee the safety of their products as they see fit.
- Processing facilities may require growers to follow the Produce Safety Rule, even if the growers are not covered under the federal regulation. Talk with your processing buyers and ask them what they expect for food safety measures going forward.
Best Practices for Pre-Harvest
1) Train all workers (outsourced, on-farm, and volunteers) in:
- The parts of the PSR that affect their responsibilities, in an easily understandable way.
- Worker health and hygiene.
- How to recognize people with foodborne illnesses related symptoms (vomiting, diarrhea, fever, jaundice, open wounds).
- The basic principles of food safety (vulnerable people get sick from pathogens, pathogens come from feces, pathogens get on food via people, water, tools, and equipment).
2) Train all harvest workers (outsourced, on-farm, and volunteers) to:
- Not harvest any blueberries visibly contaminated with feces.
- Inspect harvest containers before using them to make sure they’re clean, working, and in good shape.
- Not use harvest containers or report the problem to someone if they’re dirty, not functioning, or damaged.
3) In crop fields only, flag locations of mammal and bird droppings (feces) beginning at the green fruit stage. If removing feces will decrease the risk of contamination, remove them. If moving feces could spread contamination, do not remove it. Clean and sanitize any equipment used during removal. When sanitation is required by the PSR, like in this example, you MUST document the sanitation step (e.g., using a sanitation log). Other activities to reduce contamination risk that are best practices, but not a requirement (e.g., cleaning and/or sanitizing bins just before harvest even if they were already visibly clean), can be documented, but that is NOT a requirement.
4) The day before or day of harvest, scout field for animal droppings. Flag as necessary so that the harvester can easily avoid flagged areas. There is no specific clearance distance; use your best judgment.
5) Inspect, maintain, and clean harvesting bins before harvesting. If you believe that they had contact with animal droppings, bodily fluids, or other produce not covered by the PSR, you must clean and then sanitize them. For the Produce Safety Rule, ‘clean’ means free of visible accumulations. Blueberry stains aren’t a problem as long as the harvest container is clean. You must document sanitation when required, like in this example. Best practice actions to reduce contamination risk are encouraged, but not required; documentation of such practices is optional.
6) Inspect, maintain, and clean transport trucks as needed during the harvest season.
7) Start thinking about testing your agricultural water source(s). As defined in the PSR, agricultural water includes any water that is directly applied on covered produce or food contact surfaces, including water used for frost protection, irrigation, pesticide, and fertilizer application.
The water testing specifics are still being worked out by the FDA, so there is no requirement to test right now. That said, we recommend that you do test your agricultural water to understand the level of E. coli in your water sources. Farmers must start taking water samples two years after the date that they must comply with the Produce Safety Rule (see Table 1).
8) Practice good record keeping. Depending on your exemptions, required records may include:
- Qualified exemption review: the information needed to claim an exemption
- Worker training: to show that workers were trained to do their jobs safely
- Compost Treatment Record: the information about compost treatment, if you do it yourself
- Cleaning and Sanitizing Record: information about your sanitizing procedures
- Water System Inspection: annual visual check of the conditions of the water source(s)
- Water Treatment Monitoring (if applicable): the information about water treatment, if you treat your water
- Water Die-off Corrective Measures (if applicable): how many days of die-off you used
*For more information about these records we encourage taking the FSMA PSR training. You can find more information about the training at Produce Safety Alliance Grower Training.
DACF compiled a list of the required records; check the link in the references.
Best Practices During Harvest
- Check to make sure that harvest bins are clear of any soil before harvesting.
- Do not harvest berries that have animal droppings on the skin. If droppings are discovered in a bin, discard the berries and clean and sanitize the bin. You must document sanitation when required, like in this example. Best practice actions to reduce contamination risk are encouraged, but not required; documentation of such practices is optional.
- Do not eat or use tobacco in the field. Drivers can eat inside a harvester cab if the cab is enclosed and the driver doesn’t have contact with berries after eating and before washing their hands. The best practice is for everyone to take lunch breaks at pre-established break areas outside the field. Do NOT eat blueberries in the field while harvesting.
- Handwashing stations and bathrooms should be available for workers to wash their hands before starting to work, after breaks, and after using the toilet. Materials needed for proper handwashing include clean water, soap, single-use towels, and a trash bin. Water for handwashing does not need to be heated, but it does need to be sanitary (zero generic E. coli).
- Under normal conditions, there is no need to cover berries in transport. However, if an event occurs or circumstances change, the risk of contamination could increase. For example, if street sweeping or construction is occurring on your route to the processing facility, it would be best to cover the berries.
- Rakers should avoid raking animal droppings.
- Clear rakes of blueberry “gunk” and debris, when necessary.
- The driver should look ahead and avoid animal droppings.
- Check conveyor belt and harvester rakes to make sure droppings are not present. Clean out the harvester when necessary.
- Drivers should be trained to look ahead for previously flagged areas to avoid harvesting animal droppings.
- The ground crew should watch the back end of the harvester to make sure droppings are not present. Clean out harvester back end when necessary.
We (growers, processors, and Extension) continue to work with the DCAF and FDA to understand how bins can function in wild blueberry fields. This document will be updated when information becomes available.
Best Practices for Post-Harvest (Fresh Pack Cleaning Lines)
- Wash/clean picking belt at the beginning of the day with water and a detergent/soap. Sanitize when needed.
- At the beginning of the day check to make sure berry shoot is clear of visible soil and blueberry gunk. Surfaces must be clean (clear of any visible soil) before the operation starts.
- Workers must NOT eat berries or other food while sorting.
- Hand washing stations should be available for workers to wash their hands. Materials that must be available include clean water, soap, single-use towels, and a trash can. Water for handwashing does not need to be heated, but it does need to be sanitary (zero generic E. coli).
- Store and transport berries in a way that minimizes contamination.
Best Practices for Toilet Availability
The rule requires one toilet and one handwashing facility per every 20 workers within a ¼ mile of the working area, regardless of the work being done, or within a 5-minute drive if the farm provides transportation (e.g., a truck is always available for workers when they are in the fields). If you receive visitors at your farm, a toilet and handwashing facility must be available for them to use as well. Toilets must be maintained and stocked.
Best Practices for Health and Hygiene
All workers on the farm should be trained to follow the farm food safety plan if you have one. Workers should stay home if they are sick and report to a supervisor any illnesses or injuries that occur while working. Workers should use clean clothes and wash their hands before handling produce, after using the restroom, before starting or returning to work, before and after eating or smoking, and whenever their hands are dirty.
Developing a Farm Food Safety Plan
Having a formal farm food safety plan is not a requirement of the Produce Safety Rule, but UMaine Extension recommends that you have one. A food safety plan gives you the chance to think through your entire operation and where there may be food safety risks to your customers. The food safety controls you put in the plan help to protect your customers and your business and can make training your workers to the same standards a lot easier.
The Produce Safety Alliance (PSA) Grower Training offered by UMaine Extension provides the necessary knowledge and tools to create a farm food safety plan. The Produce Safety Rule requires that at least one person per each covered farm take the PSA training.
Ultimately, writing a farm food safety plan is the farmer’s responsibility. For liability reasons, UMaine Extension can’t write a food safety plan for you. Additionally, you know your farm better than anyone else and writing the plan is an essential part of the process to improve the safety on your farm.
Food Safety Modernization Act (FSMA) document:
- Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption
- FSMA FACTS: What You Need to Know About the Produce Safety Rule (PDF)
Draft Guidance document:
- Draft Guidance for Industry: Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption: This document discusses how the PSR should be interpreted and gives multiple examples of how it could affect you.
Procedure for water sampling:
- FSMA water sampling 101: Tips for sampling irrigation canal water (YouTube)
- FSMA water sampling 101: Tips for sampling piped water (YouTube)
- Water Sampling Done Simply
*Ask the laboratory where you will send the water samples if they can perform any of the tests approved by FDA. You can find a list of the methods at Equivalent Testing Methodology for Agricultural Water (PDF)
PSA Grower Training:
For more information about the PSR and how it will affect your farm, we encourage taking the FSMA PSR training. You can find more information at Produce Safety Alliance Grower Training.
Clean surface: For the FSMA Produce Safety Rule, the minimum requirement for a clean surface is simply a surface that is free of any visible soils (dirt, leaves, stems, etc.). This level of “clean” can be achieved just by rinsing with water in most cases. Best practices for a cleaning step ask for initial removal of debris, a rinse, a brushing step with detergent (soap), followed by a final rinse to remove the suds. Whenever a sanitizing step is required, a full cleaning step must be done before. Sanitizing means the application of a sanitizer (chemical) to a clean surface to reduce the microbial load to acceptable levels.
Kill step: Traditionally a “kill step” has been understood by food safety professionals, and inspecting agencies, as a processing step that consistently guarantees at least a 5-log (99.999%) reduction of known pathogens of concern for the specific food. This treatment also must be effective in any portion of the food (i.e., both on the surface and inside when the food is solid or throughout the treated amount of liquid food). Although the term “kill step” was not used in the rule, the definition mentioned above has been what the food safety professionals across the country understand when the rule mentions “commercial processing that adequately reduces the presence of microorganisms of public health significance.” That interpretation is corroborated by the examples that the rule provides of acceptable commercial processing: thermally processed low-acid foods (21 CFR 113), acidified foods (21 CFR 114), and juices under a HACCP system (21 CFR 120). Nonetheless, FDA is reviewing such understanding and, for now, growers can claim the commercial processing exemption based solely on the processors’ claim that they are processing the berries to adequately reduce the presence of microorganisms of public health significance, without the need of guarantees by the processors.
Information in this publication is provided purely for educational purposes. No responsibility is assumed for any problems associated with the use of products or services mentioned. No endorsement of products or companies is intended, nor is criticism of unnamed products or companies implied.
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