Bulletin #4283, Starting a Produce Safety Worker Training Program on Your Farm

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woman farmer in the field with a tray of fresh-picked lettuce

Developed by Christina Howard, Produce Safety Professional, University of Maine Cooperative Extension, and Robson Machado, Assistant Extension Professor and Food Science Specialist, University of Maine Cooperative Extension.

Reviewed by Linda Titus, AgMatters LLC.

Do you need to start a produce safety worker training on your farm to comply with the Food Safety Modernization Act (FSMA) Produce Safety Rule (PSR)? Worker training that is specific to produce safety is required for farms that fall under the FSMA Produce Safety Rule. The Center for Disease Control (CDC) estimates that each year, 48 million people get sick from a foodborne illness, 128,000 are hospitalized, and 3,000 die. Also, plant-based foods were responsible for 37% of the outbreaks between 2009–2015. Training workers about produce safety helps to mitigate foodborne disease outbreaks, and often workers will be more apt to comply with the rules if they know the potential risks.

Which farms must implement a Produce Safety Worker Training Program?

If your farm is a “covered farm,” you must have a produce safety training for your workers. If you are unsure if your farm is covered under the PSR, please refer to the U.S. Food and Drug Administration’s (FDA) FSMA flowchart (PDF) and University of Maine Cooperative Extension bulletin 4281, Food Safety Modernization Act (FSMA) Produce Safety Rule Exemptions. All covered farms must have at least one person from the farm complete a food safety training that is at least equivalent to that received under the standardized curriculum recognized by the FDA (112.22(c)). The only training that satisfies this requirement currently is the PSA Grower Training. UMaine Cooperative Extension offers the PSA Grower Training. For more information and for upcoming dates visit the Produce Safety Alliance Grower Training page.

Who needs to be trained?

  1. Workers performing duties subject to the PSR: those working with covered produce and covered food contact surfaces.
    1. The term covered produce is produce that falls within the conditions of the Produce Safety Rule. The PSR only regulates produce that is still in its raw or natural state, including all produce that is washed, colored, frozen or otherwise treated in their unpeeled, natural form. See FSMA Produce Safety Rule Defining “Covered” Produce.
    2. The term covered food contact surface is a surface that “covered produce” will touch after harvest and before the sale of that produce.
  2. Those who supervise these workers.

This includes workers who are: full-time, permanent, temporary, part-time, seasonal, volunteers, contracted, and all other relevant personnel.

When must workers be trained in produce safety?

Produce safety training must be done upon hiring/contracting the workers and before the workers start handling covered produce. Training must be offered for each employee when hired and at least annually after that. To make sure workers are qualified for their assigned duties, separate trainings can be held for preharvest, harvest, and post-harvest jobs if those jobs will be performed by separate workers. Also, training can be staggered, so you don’t have to train workers on everything they need to know on the same day. For example, new hires can be trained on the required basics (see below) and what they need to know for the activities on that day or week and continue the rest of their training on other days as it makes sense for your farm.

What subjects need to be covered in the trainings?

Workers must be trained on specific duties as they pertain to produce safety and working with covered produce, covered food contact surfaces, and supervision of these tasks. Introduce workers to the procedures and requirements of the PSR. Make sure they are aware of the relevant sources of foodborne pathogens, routes of contamination (e.g. from people or animals to produce) and introduce the preventative and corrective measures you decide should be used on your farm.

Specifically, your workers who handle covered produce during covered activities or supervise those workers need to be trained on:

  1. The principles of food hygiene and food safety. View the video Basics of Worker Training (YouTube).
  2. The workers’ health and hygiene practices and how workers can lower their risk of contaminating covered produce or covered food contact surfaces, including:
    1. Recognizing symptoms of a health condition that is reasonably likely to result in contamination of covered produce or food contact surfaces with microorganisms of public health significance.
      1. Symptoms include fever, vomiting, diarrhea, and jaundice.
    2. Notifying the supervisor if the worker is ill or hurt.
      1. Supervisors and workers should be on the lookout for sick workers. The sick workers should not work with fresh produce until their symptoms clear up.
    3. Knowing how and when to wash their hands.
      1. Workers are required to wash their hands with soap and water before beginning or returning to handling produce, before putting on gloves, after using the toilet, as soon as practical after touching animals or animal waste.
      2. Workers should sneeze or cough away from the produce, preferably into their shirt. If they cough or sneeze into their hands, they must wash them before handling produce.
    4. Wearing clean clothes and footwear.
      1. Clothing must be reasonably clean and intact to protect food from bodily sources of contamination.
      2. Workers must be careful about where they go with their footwear before entering produce fields and produce packing facilities. If the footwear has been exposed to animal waste (for example, if the worker has collected eggs in the chicken house), the footwear should be changed or cleaned and sanitized before entering a produce field.
    5. Following glove, hairnet, and jewelry policies.
      1. If using gloves, workers must wash their hands before they put them on. Gloves must be maintained in an intact and sanitary manner, and workers must get new gloves when necessary. Gloves are not required under the rule, but if used, gloves must be maintained appropriately.
      2. The rule doesn’t require the use of hairnets, beard nets, aprons, or other PPE that will prevent contamination of the produce. If using those PPE, it is best to have a policy of best practice.
      3. The PSR requires a jewelry policy: Workers must remove or cover hand jewelry that cannot be cleaned and sanitized before handling produce.
      4. Workers must promptly treat cuts, abrasions, and other injuries and report them. DO NOT handle produce with an open wound. Use a glove to cover a bandage on your hands.
      5. If blood or other bodily fluids touch produce, it must be immediately culled, and any food contact surfaces involved need to be cleaned AND sanitized (including equipment).
    6. Learning the importance of using worker break areas, handwashing stations, and restrooms.
      1. Workers must be shown the location of the toilet facilities and the proper use of them.
      2. Workers must not smoke or eat in areas designated for produce. Worker break areas must be shown to workers and workers must understand the importance of always use break areas when eating, chewing gum and smoking (or using tobacco).
      3. Workers must be told where handwashing stations are and when it’s appropriate and mandatory to wash their hands (see letter c.).
      4. Workers’ drinks may be allowed in the produce areas if they are in unbreakable containers.
      5. Workers must be notified that potable water is available for all employees.
    7. Avoiding contact with animals other than working animals.
    8. Maintaining personal cleanliness.

Workers should be trained on the following if applicable to their job duties:

  1. Introduce the term “agricultural water” and explain the importance of using water free of generic E. coli when it contacts produce covered by the PSR. See Safe Uses of Agricultural Water.
  2. How to inspect covered produce fields for visible evidence of domestic or wild animal intrusions during the growing season.
    1. Know how to identify and report (and/or stop) sources of contamination, including workers’ footwear and farm vehicles going from field to field.
  3. Workers who conduct harvest activities for covered produce must receive training that includes:
    1. How to safely handle, apply, and store biological soil amendments of animal origin (e.g., compost, manure) to reduce the risk of contamination of covered produce (see Reducing Risks from Animals and Manure);
    2. How to do a pre-harvest field assessment for evidence of contaminated crops due to animal intrusion.
    3. To examine the harvest containers for cracks, dirt, feces, etc.
      1. Culling or fixing broken harvest containers;
      2. Not using harvest containers that are being used for non-produce uses.
    4. How to recognize and not harvest contaminated produce. See Reducing Food Safety Risks During Harvest.
    5. To wash their hands if there is any contact with animal feces.
  4. Post-Harvest: How to assess produce safety risks in the packing areas, coolers, and vehicles that hold covered produce. See Reducing Food Safety Risks in the Packhouse.
    1. Show workers how to clean the harvested produce and prep for sale. Farms will have many different cleaning procedures depending on the crop, and those procedures will vary from farm to farm. Here is an example of a video SOP “How to triple rinse greens (YouTube video).”
      1. Make sure workers know how and when to monitor for bleach concentration as well as turbidity of the wash water. The Triple Rinse Greens video (above) explains both.
    2. Pest management in farm buildings and vehicles that hold covered produce.
      1. This may include using traps to monitor pest levels, checking the traps regularly, and using that data to make sure pests aren’t in the packing area and vehicles.
    3. Cleaning and sanitizing food contact surfaces.
      1. Workers must inspect and maintain harvest containers and equipment to ensure they are functioning properly, clean, and not a source of contamination. Workers should know where the cleaners and sanitizers are and know how to use them correctly.
      2. How to keep records of cleaning and sanitizing
    4. Introduce your farm’s packing house SOPs including:
      1. How to wash and pack the produce
      2. How to mix and when to use sanitizers
      3. How to clean the packing equipment, transportation, and storage areas
      4. What to keep records of and how to do this. (This will vary from farm to farm.)

Who should train the farm workers/supervisors?

The farmer, supervisor, produce safety specialist on your farm or whoever is overseeing the produce safety duties, or a third party should train the workers. The person on your farm who took PSA Grower Training Course doesn’t have to be the trainer.

How should the trainer present the training to employees?

The trainer must use an easily understandable format. The most effective trainings are hands-on, but there are no requirements as to how the training needs to be set up. There are also no standard time requirements, and the training doesn’t need to be done all at once. You can use:

  1. Pre-made videos (for example, this cute video about handwashing (YouTube video).)
  2. A written training sheet with important bullet points of the procedures about your farm operation of covered produce and covered food contact surfaces.
  3. An in-person demonstration of correct practices and procedures specific to your operation.

To supplement and support your training, you can pinpoint the most important produce safety practices and put up posters or other visuals around the farm promoting practices presented in your trainings. Examples of this would be:

  1. How to wash your hands effectively (PDF)” hung near the handwashing station.
  2. How to wash-rinse-sanitize, a three-step procedure” hung near your bin washing station.

How must I document the trainings my workers take?

The required components for documenting your worker trainings are:

  1. Date(s) of training
  2. Topics covered (Many farms have this in a written form that they use during the training and have added to their Food Safety Plan if they have one.)
  3. Name of person trained.

It’s a good idea to also add the name of the trainer in case it needs to be referenced later.

You should keep these records for at least two years. Inspectors may ask for them when they come to your farm for a FSMA PSR inspection.

And all records required in the PSR must also include the following:

  1. The name and location of the farm.
  2. Accurate values, dates, and observations recorded at the time of the training (e.g., accurate description of the topics covered.)
  3. Location of the record being kept (e.g., If the training was being presented about how to safely mix sanitizer for use on covered produce in the packing house, note that the training took place in the packing house.)
  4. The record must be signed or initialed by the person who performed the activity (e.g., in the case of worker training record-keeping: the person conducting the training could be the one to sign or initial the records.)

Where must the trainings take place?

There is no specific place to hold the trainings. You should train people where it makes sense for them to learn their duties and the relevant produce safety concepts. If a third party is training the workers (whether they are contracted workers or farm employees) you must obtain training documentation from them that includes the date of the training, the topics covered, and the name of person trained.

What to do if the worker(s) are not following the produce safety protocols?

Have a clear discipline policy for workers who don’t follow the produce safety protocols. Example: After the worker makes the first mistake: notify them about the importance of produce safety and retrain them in the specific duty that was not done correctly. After the worker makes a second mistake: more retraining and provide extra supervision when the worker is handling fresh produce. After the worker makes a third mistake: reassign the worker to a task that doesn’t involve handling fresh produce.

References and Resources:

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.

© 2019

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