A food safety plan is a necessity for anyone who grows food for sale. This is true whether you grow in a field, a greenhouse, an indoor farm, hydroponically or aquaponically. Contamination sources are not limited to animal manure. Pathogens can travel in water and be transferred by hands and tools. Fruit, vegetables and herbs can come in contact with them while growing, during harvest and during packaging. Pathogens are not the only sources of contamination, though. Chemicals used as pesticides or cleaning agents are contaminants as well.
Prevention can be as simple or complex as your operation. It requires pre-planning, implementation, and follow-through. Over the course of the next few months, I will cover a variety of issues relating to food safety and greenhouse production. We’ll start simple and head towards the complex. The journey of a thousand miles begins with the first step!
Who’s Exempt
Legally, not all growers are required to have a food safety plan. The new FSMA Final Rule “Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption states “Farms that have an average annual value of produce sold during the previous three-year period of $25,000 or less” and that grow produce that FDA has identified as rarely consumed raw are exempt from this rule. These are farms that also do not grow “produce that receives commercial processing that adequately reduces the presence of microorganisms of public health significance, under certain conditions.” Farms in this category have different exemptions. Keep in mind, what you may be exempted from is paperwork, not the consequences of an outbreak of e coli or salmonella.
Therefore, even if your growing operation is exempt from this rule, having a food safety plan is still very important. It is not difficult to create and implement one and the costs (both ethical and financial) can be so high. Moreover, buyers such as Wal-Mart and Whole Foods require them as well as third party audits to ensure compliance. So think of a food safety plan not as an onerous task but as an opportunity to set your business apart from your competitors, to market your produce in a way that will really connect with buyers and consumers.
Public Demands What Feds Suggest: Traceability Via Food Labels
4 Stages of Food Safety Plan Development 
The creation of a food safety plan consists of 4 steps: risk assessment, creation of a plan, implementation and review.
Risk Assessment
The first step in creating a food safety plan is analyzing the areas where there is a potential for risk and determining how high the risk level is. Questions to ask yourself include:
- What are the potential sources of human pathogens?
- Is the potential high or low?
- What can you do to mitigate that potential?
The standard risk sources for greenhouse growers are:
- Water
- Soil Amendments
- Personal Hygiene
- Chemicals
- Inputs
- Storage & Handling of Materials
- Post-Harvest Handling & Sanitation
- Traceability
Let’s take water, for example. As was mentioned in Quick Plug North America’s last blog on clean water, there are a number of points of access for pathogens in an irrigation system. First is the source. Is your water runoff that’s stored in a pond or does it come from a municipal supply? Do you recirculate your irrigation water? Is it filtered? Answering these questions will help you determine what the risk for contamination is, how high that risk is and how you can mitigate it. Cornell University has published a document, Farm Food Safety Decision Tree, that will guide you through the process of identifying food safety risks and prioritizing which practices to use on your farm to reduce food safety risks.
Creating a Food Safety Plan
Once you have done your risk analysis, the next step is to come up with a plan for addressing, preventing or mitigating the risks you’ve identified. The plan, when it’s complete, should tell you:
- What needs doing
- How you are going to do it
- When and how often it will be done
- Who is responsible for what
- How you will follow-up/assess successful implementation
This plan should contain documents that detail protocol for managing and mitigating potential risks in the areas mentioned above.
If you do not feel comfortable writing up a food safety plan on your own, there are a variety of templates on-line. The On-Farm Food Safety Project has developed an on-line tool that allows farmers/growers to create an individualized food safety plan by answering questions presented in the form of a decision tree. This tool is free. Or try the these: 
Implementation & Review
Be mindful that once the plan is created, the job is only half done. The next step is to implement your new protocols. Having written protocols for employee hand-washing, for example, is not helpful if staff have not been trained, hand-washing stations are not accessible or well-stocked and signs to help people remember have not been posted or if there is no follow-through for non-compliance. A plan is worth only the paper it’s written on unless it is put to use. Therefore, part of your plan should include measures for evaluating its effectiveness.
One method of review is to stage a mock recall of your product. Were you able to identify the appropriate lot and batch number and in an acceptable amount of time? Another form of review is, if you have employees, watch them as break time ends. How many washed their hands following protocol? How many washed their hands but not effectively? Speaking of handwashing, Phil Tocco of Michigan State University has stated that it “can reduce foodborne illness by as much as 80 percent, and germs in general by as much as 50 percent”. If your first food safety plan includes nothing else but proper hand washing, you are off to a good start.
Conclusion
A working food safety plan is a must for any fruit and vegetable grower, big or small. There are many supports out there for small growers. Check with your local cooperative extension office or look through the resources below. There is no getting around the work that is involved in crafting and implementing a plan. It requires organization, attention to detail, systems thinking and commitment. But so did building your business. A food safety plan can go a long way towards safe-guarding that business and your customers. That’s worth some time, wouldn’t you say?
Resources
Produce Safety Alliance Resources-links for educational materials
FSMA Final Rule on Produce Safety
Certified Greenhouse Certification Standard
Leafy Green Marketing Agreement Food Safety Practices– for field grown operations
Michigan State University Online Training-Choose your learning style- audio, text, slides, presentations
Whole Foods Small Supplier Support
Wal-Mart Food Safety Requirements for Produce Supplier
Produce Safety Alliance Curriculum Learning Objectives and Critical Concepts