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The pre-harvest agricultural water requirements under the Produce Safety Rule kick in this year for small farms, producing $250,000 to $500,000 annually. Rules begin next year for the smallest operations.
At the California Walnut Conference, California Department of Food and Agriculture environmental scientist Trevor Goldsberry explained PSR compliance and inspections for tree nut growers, particularly walnut growers.
Water quality requirements have been updated. Agricultural water is defined as water intended or likely to come into contact with produce or food contact surfaces during processing. The department places water into two categories: pre-harvest, which includes irrigation and water used in spray operations, and harvest and post-harvest water used for processing, cleaning equipment or worker hygiene.
The new requirement for pre-harvest water replaces prior mandatory testing. Growers are asked to evaluate five key factors that could impact the safety of their crop for human consumption. This assessment must be done annually or if any significant change in water occurs. The assessment must also be documented.
The pre-harvest ag water assessment factors are:
1. Water source, distribution system and degree of protection from possible contamination sources.
2. Application method, contact or no contact with produce.
3. Type of crop and potential risk factors.
4. Weather events that may impact exposure to contamination.
5. Other relevant factors.
The Produce Safety Rule does not allow use of untreated surface water for harvest or post harvest. The water used for these activities must be non-detectable for generic E. coli. Prior to a PSR inspection, the water source and system must be inspected and findings documented. If groundwater is to be used, it may not be stored in a reservoir. If using municipal water, an annual water quality test report from the water source is needed.
Goldsberry noted some exemptions: if pre-harvest water meets requirements, there is an exemption from Ag Water Assessment.
In his presentation, Goldsberry covered what growers can expect with PSR inspections and how to prepare for them. He emphasized that CDFAās Produce Safety Program is intended to first educate growers about food safety to help growers implement the required practices. The PSR is now mandatory, Goldsberry said, and producers found to be out of compliance may face regulatory action.
The PSR impacts walnut growers, Goldsberry explained, because walnuts are often eaten raw and not immune to contamination or outbreaks.
Inspection Goals
Farm and processing facility inspections, he noted, are made with the goals of preventing foodborne illness and improving public health. Inspections are mandatory and carried out by credentialed FDA or state inspectors who will evaluate the farm or processorās compliance with minimum federal produce safety standards of the PSR. There are no fees.
Audits are not the same process, he said. Audits of farms and processing facilities are voluntary and done by second- or third-party auditors. These are consumer-driven and auditors are looking to confirm company-defined standards. There are fees for audits.
Inspections by the state are random and risk-based. All covered farms receive an initial inspection, which are conducted on the farm and areas where covered activities take place. Inspections include a records review and walking inspection of the farm or processing facility.
In addition to water testing, growers should prepare for inspections by noting animals, domestic and wild, accessing production areas, human activity in the field, soil conditions, and equipment, buildings and tools.
Risk Assessment
Growers must assess risk and evidence of potential contamination of produce from animals. Monitoring during the growing season and immediately prior to harvest is required. If there is evidence of potential contamination, growers must prevent harvest if contamination has occurred. Written records of the monitoring are not mandatory.
Workers who come into contact with produce or food contact surfaces must be trained at hire and at least once annually. Principles of food hygiene and food safety and the importance of health and personal hygiene are topics that must be covered. Workers who are harvesting the crop must be able to recognize when crop is contaminated.
Goldsberry said each farm is required to have at least one supervisor who has completed food safety training. The required records of training must include date and time, topics covered and the persons trained.
If labor is outsourced to a farm labor contractor, they must verify they are aware of and following the PSR requirements.
Visitors to the areas where the crop is grown need to be made aware of the procedures in place to protect the harvestable crop and food contact surfaces from contamination. Handwashing and restroom facilities must be accessible.
During the farm inspection, inspectors will be looking at soil amendments applied in the orchard. These include compost, poultry litter, manure, fish emulsion or table waste. Biological soil amendments of animal origin must be applied, handled and stored to prevent direct contact with the crop to be harvested. Untreated raw manure must not be applied to the harvestable part of the crop.
The required records for compost use include a certificate from the supplier that the produce meets the microbial standards in the PSR. This also applies to compost made on site.
Food contact surfaces, including equipment, tools and containers used in harvest or processing must be of adequate design for cleaning and sanitation to prevent contamination of the product. There are cleaning and sanitizing required records for any food contact surfaces used during harvest, packing or holding. They include method of cleaning and sanitizing, date and time.
Goldsberry noted CDFA services offered to growers to help them understand and comply with the PSR.
CDFAās Produce Safety Program offers free, voluntary and confidential on-farm readiness reviews to assist growers preparing for Produce Safety Rule inspections. These reviews include a farm walk-around and consultations with staff to identify compliance gaps, providing resources including a produce safety manual and records templates.
The Technical Assistance program is aimed at ensuring small-scale growers can become compliant with the PSR. The program is managed by CDFA and staffed by UCCE specialists who have expertise in on-farm food safety and production practices.
The Produce Safety Alliance offers free and reduced-cost grower training. For information and scheduling visit: www.cdfa.ca.gov/producesafety
Cecilia Parsons | Associate Editor
Cecilia Parsons has lived in the Central Valley community of Ducor since 1976, covering agriculture for numerous agricultural publications over the years. She has found and nurtured many wonderful and helpful contacts in the ag community, including the UCCE advisors, allowing for news coverage that focuses on the basics of food production.
She is always on the search for new ag topics that can help growers and processors in the San Joaquin Valley improve their bottom line.
In her free time, Cecilia rides her horse, Holly in ranch versatility shows and raises registered Shetland sheep which she exhibits at county and state fairs during the summer.
