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UCGAPS Overview of GAPs and CSGs 6/15/2011

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Microbial Food SafetyMicrobial Food Safetyyyof Edible Horticultural Cropsof Edible Horticultural Crops

Trevor SuslowTrevor SuslowDepartment of Plant Sciences Department of Plant Sciences Center for Produce Safety Advisory Center for Produce Safety Advisory Board & Technical Committee Board & Technical Committee [email protected] [email protected] 530‐‐754754‐‐83138313

1. Evolution of GAPs and GHPs2. Moving from CSG’s to Regulations3 T GAP M3. Top GAPs Messages

Microbial Food Safetyof Edible Horticultural Crops

http://ucgaps.ucdavis.edu http://ucgaps.ucdavis.edu 4

Industry 1996Industry 1996 FDA 1998FDA 1998 Academia 2000Academia 2000‐‐

1899 ‐Morse, Rept. Bd. Health Mass., p. 761salmonellosis – celery

1903 ‐Warry, The Lancet, p. 1671shigellosis – watercress & local vegetables

1912 ‐Creel, Public Health Rept., 27:187‐195Salmonella typhi – lettuce, other vegetables

Appreciation to L. Beuchat UGA for archival insights

WHERE WE HAVE COME FROM IN DEVELOP ING BEST PRACTICES


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E. coli O157:H7 1996

Gastrointestinal illness from consumption of fresh produce was only loosely acknowledged

by industry and most production‐oriented research and regulatory agencies until around 1990.

Early industry‐driven guidance document released 1996NOBODY CAREDNOBODY CARED

HIGH MEDIA ATTENTIONMead et.al., 1999, EIDAnnual Burden of Foodborne Illness in U.S.76 million illness / yr

ChickenChicken‐‐Little’s Little’s Ostriches Ostriches

Denial was a Prominent Food Safety Strategy

Come on people… there are more deaths from lighteningthan from Salmonella on our product

Outbreaks are not bad luckOutbreaks are not bad luck ––Outbreaks are not bad luck Outbreaks are not bad luck they’re bad managementthey’re bad management

Patrick Patrick Wall, Chief Executive of Wall, Chief Executive of Food Safety Authority of Ireland, Food Safety Authority of Ireland, 19971997

FDA, 1998 guidance documentFDA, 1998 guidance document“G id i i i i bi l d S f“G id i i i i bi l d S f“Guide to Minimize Microbial Food Safety “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables”Hazards for Fresh Fruits and Vegetables”

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Not Not a regulation a regulation ‐‐ guidelines onlyguidelines only Has Has been been a “de facto” a “de facto” minimal standardminimal standard Buyers are the enforcement branchBuyers are the enforcement branch CommodityCommodity‐‐specific and Regionspecific and Region‐‐specificspecific


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Food Safety Depends on Prevention Programs with Multiple Hurdles

PreharvestPreharvest Postharvest Postharvest

SeasonSeason Site SelectionSite Selection VarietyVariety

InIn season fieldseason field

PrePre--season field season field sanitation sanitation

PrePre har esthar est Crop ManagementCrop ManagementInIn--season field season field sanitation sanitation PrePre--harvest harvest sanitation sanitation

Harvest Harvest LogisticsLogistics

Process ControlProcess ControlHandling and TreatmentHandling and Treatment

Cold Chain and Cold Chain and Distribution ControlDistribution ControlCold Chain and Cold Chain and

Distribution ControlDistribution Control

6 Commodity groups make up > 85% of produce related outbreaks

Commodity % produce outbreaksLettuce/Leafy greens 31%Lettuce/Leafy greens 31%Tomatoes 17%Melons 12%Herbs (basil, parsley, cilantro) 11%Cane berries & strawberries 10%Green Onions 7%____________________________________Total % of 6 top commodities 88% Source: FDA CFSAN

Lettuce/Romaine 19Spinach 3Cabbage 1Tomatoes 15Cantaloupe 7

l

Basil 3Basil or mesclun 2Cilantro 2Celery 1Parsley 1

Melons 3Honeydew 2Squash 1Cucumber 1Raspberries/berries 7

yGreen onions 2Mango 2Table grapes 2Jalapeño/Serrano 1Snow Peas 1Snap Peas 1Unknown 2

Source: FDA CFSAN

Sprouts Sprouts 3030

SignatureSignatureAnimal* Reservoir Animal* Reservoir # # Human Human Source Source ##EE. coli. coliO157:H7 O157:H7 2121 ShigellaShigella 22SalmonellaSalmonella 3030 Hepatitis A Hepatitis A 33

CyclosporaCyclospora 1616

Implicated SourceImplicated SourceDomesticDomestic 2727ImportedImported 88Unknown Unknown 1515

TotalTotal 4949

Implicated SourceImplicated SourceDomesticDomestic 11ImportedImported 1212Unknown Unknown 88

TotalTotal 2121Source FDA 2008Source FDA 2008

* Zoonotic

Year Outbreaks Illnesses1999 0 02000 0 02001 0 02002 3 2302003 3 1252003 3 1252004 3 5322005 4 255

2006 4 4362007 0 02008 3 602009 0 0Total 20 1638

* Fresh‐cut produce: fresh produce that has been processed by peeling, slicing, chopping, shredding, coring, trimming, or mashing, with or without washing or other treatment, prior to being packaged for consumption.

Source Credit FDA/CFSAN 2010


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However… However… Ill t T t l S i Y ti i t i l ll Ill t T t l S i Y ti i t i l ll •• Illness to Total Servings per Year ratio is staggeringly small Illness to Total Servings per Year ratio is staggeringly small

••Consuming fresh produce remains the right messageConsuming fresh produce remains the right message•• Prevention across the supplyPrevention across the supply‐‐chain is needed chain is needed

Melon Tomato Stone fruit Mushroom Lettuce & Leafy Greens Culinary Herbs

FOOD SAFETY PROGRAMGood Agricultural Practices: Growing the World’s Safest Strawberries

Culinary Herbs Green Onions Sprouts Almond Citrus Strawberry Watermelon Blueberries Asparagus

HHazard azard AAnalysis nalysis and and CCritical ritical CControl ontrol PPointsoints

2222

A point, step or procedure at which control can be applied and is essential to prevent or eliminate a hazard or

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to prevent or eliminate a hazard or reduce it to an acceptable level

Systematic and Comprehensive AnalysisHazard Identification & AnalysisWritten Procedures and Programs

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Written ResponsibilitiesTraining –Awareness and ProcessVerificationCorrective Action & Re‐evaluationDocumentation & Record‐Keeping Positive Lot Trace‐back System


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Overview of Produce Outbreaks Biology of Pathogens Food Safety Prerequisites Manure and Compost Soil survival and transferWork Hygiene Training P h t W t

Typical GAP and GHP Training Typical GAP and GHP Training

Preharvest Water Postharvest WaterCleaning and SanitationDocuments and Record‐keeping Preparing for AuditsMicrobial Testing Pathogen TestingTest and Hold / Test to ReleaseTraceability and TracebackCrisis Management Planning…….and more

Knowledge of Details Knowledge of Details makes the Differencemakes the Difference

If you didn’t write it downIf you didn’t write it down

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If you didn t write it down…If you didn t write it down…It didn’t happenIt didn’t happen

Human Readable

GS‐128 Barcode

PTI Case LabelProduce Traceability Initiative

Regulated by GS1

Voice Pick Code

Global Item Identification Number (GTIN)

Lot Code

GS 128 Barcode

Option Data (eg. Date)References: http://www.gs1.org/barcodes/technical/genspecshttp://www.gs1.org/docs/barcodes/GS1_Bar_Code_Verification.pdf

GS1‐128 Carton Bar Codes

PTI SSCC Pallet TagCreates a new code for co‐mingles lots

SSCC‐18PalletBar Code

Grower, Ranch, BlockDate of harvest LotHarvest crew f Approx $26 00/stampApprox $26 00/stampDate of packing Packing line Product Code etc.

Approx. $26.00/stampApprox. $26.00/stamp

Grower RanchLot

GW23C4209gtJulian Date

Grape tomato


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DATE:

EST. HARVEST DATE:

GROWER:

RANCH:

LOT:

PRODUCT:

YES or NO

PRE-HARVEST FOOD SAFETY ENVIRONMENTAL FIELD INSPECTION

Evaluation of Potential Contamination Risks: YES or NO

4. Is there any evidence of foreign material contamination?(ie. glass, plastic, paper, metal, leaves, roots, wood etc.)

Evaluation of Potential Contamination Risks:1. Is there evidence of wildlife or livestock intrusion in the block?(ie. fecal matter, tracks etc. of: deer, pigs, sheep, cattle, domestic animals, rodents, reptiles, rabbits, horses, birds, snails, slugs etc.)2. Is there evidence of flooding?

3. Are potentially contaminating materials (e.g. compost, manure, etc.) present in such manner as to pose a likely contamination risk to the fields to be harvested?

Person assessing Evaluation/Verification:

unless appropriate remedial action has been taken.*If the answer to questions 1 through 7 is "YES", then the planting block should not be harvested

5. Is there any evidence that the irrigation delivery system being managed may potentially be compromised?6. Is there any evidence that field workers have not complied with employee hygiene and sanitary facility rules as outlined in the company food safety programs?

7. Are there any other potential contamination risks present?(ie. leaking equipment or unexpected adjacent land activity.)

Equipment condition Health of Employees Are all employees in good health? Are employees wearing appropriate apparel?Are employees wearing appropriate apparel? Are employees following GAP’s?

Evidence of any food safety issues Animal intrusion Injuries during harvest ‐ Blood Feces Equipment condition and sanitation


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Harvester:_____________________ Crew #:__________ Ranch:_____________________ Lot:________ Date:______________

Crew Forman:__________________________________ Harvester Supervisor (full name):_______________________________Machine #__________

ALL ITEMS MUST BE CHECKED ON A DAILY BASISNote: Supervisor is responsible for conducting pre harvest risk assessment of the lot described above. YES NO

123456789

10 Are the knives dip station with adecuate PH level (6.5-7.5)?1112131415

Are employees wearing or using jewerly, hair pins, cell phones, headphones, fake eyelashes, or fake nails?

Is there evidence of domestic or wild animals, fecal material or blood found in or near field (if seen, DO NOT harvest unitl a Taylor Farms representative is notified to perform a visual inspection of the field)?

Are field employees washing their hands with soap and water before starting to harvest, after breaks, and lunches and after visiting sanitary facilities?Are field employees wearing required protective equipment (hairnets, beardnets, clean gloves and aprons, sleeves)?

Are field employees sanitizing their gloves, after using sanitary facilities, sneezing or going on break?

Are there any employees eating, drinking, smoking, or chewing gum in or around harvesting machines or production areas?Are there any personal items hanged or stored on harvesting machines or in product containers?

Are there any employees who are using the sanitary facilities excessively?Are there any employees with indications of a hacking cough, discharge of bodily fluids (eyes, nose), fever or outward signs of a contagious illness?

Are knives being sanitized and washed with chlorinated water?Do knife dip stations have adequate levels of total chlorine (50 ppm to 100 ppm of Chlorine)?

Are mix tanks and machine tanks clean and have no mineral and debris buildup?

Are knife dip stations being emptied and refilled with clean, chlorinated water after breaks or when needed throughout the shift?Are all harvesting machines clean and sanitized before harvesting begins?

15161718192021222324

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Foreman must supervise and log chlorine information every hour and harvesting Supervisor will verify that this is being done correctlyTimeSpray nozzles chlorine level (50-100 ppm).

Spray nozzles PH Level (range 6.5-7.5) Check every hour

Dwell Time*Foreman Initials

*The contact time of the chlorine must be a minimum of 3 seconds. 12.22.10 V.1

Harvesting Supervisor Check Time___________________________

INDICATE ISSUES OR COMMENTS ON CORRECTIVE ACTIONS BEHIND THIS SHEET

Have any foreign materials been found on the product, product containers, packaging material or pallets? (If yes, stop harvesting machine, take proper corrective action and document)PH and Chlorine monitoring method:Material used: PH/Chlorinte test stripsProcedure: Submerge the testing strip inside the liquid for a few seconds. Take out the strip and compare and match the color that shows with the printed colors available in the testing tube. Record the chlorine or PH level.

Are all overhead hydraulic hoses and fittings protected with drip pans ?Is there any indication of new leaks on hydraulic hoses, motors and fittings?

Are mix tanks and machine tanks clean and have no mineral and debris buildup?

Is there any loose or missing bolts and nuts on conveyor belts?Are all lights functional and shielded?

Are product container labels completed with correct information?Are sanitary facilities clean?

Are the tractors well maintained and clean of any oil/diesel leaks?Are sanitary facilities properly stocked with soap, disposable paper towels and clean water?

Are spray nozzles operating correctly (for example, no plugged,or broken nozzles, etc.)?

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Pre‐Farm Gate and Post Farm Gate

Reduce Audit fatigue

l d f d Retail and food service

Reverses commodity‐specific trend

Non‐prescriptive; highly generalized

More stringent audits still likely


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Is 100% prevention always possible? NO!

Is 100% prevention ever possible? Rarely

Goal is to minimize risk to lowest extent

Do we always know how to do this?o Nope

GameGame‐‐Changing Rules for Produce SupplyChanging Rules for Produce Supply‐‐Chain Chain S f ?S f ?Safety?Safety?

Water Workers Waste Wildlife Record‐keeping Traceability

Water: The Critical Control Point?Water: The Critical Control Point?

Wherever water comes into direct contact withWherever water comes into direct contact withfresh produce, its quality may directly determinefresh produce, its quality may directly determinethe potential for pathogen contamination and the potential for pathogen contamination and

its persistence.its persistence.

LivestockLivestockStorm water Storm water

RunoffRunoff

BirdsBirds

Manure effluentManure effluent

Multiple Risks Multiple Risks i i

Sources of Pathogens Sources of Pathogens In Surface Water WaysIn Surface Water Ways

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Irrigation Irrigation tailwatertailwater

PetsPets Urban CentersUrban Centers

Compost Facility Compost Facility RunRun‐‐offoff

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Booster PumpBooster Pump

require require Multiple Prevention HurdlesMultiple Prevention Hurdles


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Key Recommendations for Irrigation WaterKey Recommendations for Irrigation Water

1.1. Ensure wells and ground water are protected from surface eventsEnsure wells and ground water are protected from surface events2.2. Test wells for Total Coliform and Test wells for Total Coliform and E. coliE. coli at least once per yearat least once per year3.3. Shock and reShock and re‐‐test if needed test if needed

Wells and Ground WaterWells and Ground Water

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Casing Casing

GroutGrout

UC ANR UC ANR #8086#8086

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• Mixtec• Oaxaqueño• Zapoteco• Trique• Chatino• Nauhatl• Mayan

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• valuable resource• improves soil• can be handled safely• but has been implicated in outbreaks and illness

Photo taken March 15, 2011Photo taken March 15, 2011 Traceback investigations reach far back to the source of contamination

Run‐off to field Run‐off to water sources Particulate aerosols –wind Particulate aerosols‐ spreadingVermin mechanical transferTransfer to crop f kiTransfer to packing cartonsTransfer to harvest surfaces

3333ooCC

Measured at 1mAt least 55oC (131oF) for 3

daysNon‐regulated

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5959ooCC

4242ooCC

3333 CC

1 meter1 meter6464‐‐7474ooCC

Recontamination Recontamination is possibleis possible

g

Composts must meet management guidelines …



Would you source melons from this site?Would you source melons from this site?



Finger‐Bobs Cover Bandage

Metal Detection in Salad Plant

• Clean • Sanitize…..Store• Rinse



Welcome to Welcome to Produce Food Safety:Produce Food Safety:Roadmap to SuccessRoadmap to Success

Don’t be intimidated Don’t be intimidated

Data and Documentation is Worthless if not Used to Data and Documentation is Worthless if not Used to Identify Hazards and Improve Your Safety ProgramIdentify Hazards and Improve Your Safety Program

Don’t get so lost in the activity of collecting datathat you forget to use the information

#1 #1 Food Safety Must be PlannedFood Safety Must be PlannedFrom Seeding to EatingFrom Seeding to Eating

#2 Details Make the Difference#2 Details Make the Difference

#3 #3 Food Safety SolutionsFood Safety SolutionsDon’t Have to be Don’t Have to be

Complex or ExpensiveComplex or Expensive

• Food safety•Worker protection• Sustainability• Environmental stewardshipp