Greenhouse and controlled environment agriculture growers who are participating in USDA’s GAP program are expected to have an easier time meeting Food Safety Modernization Act rules.
The burden of proving a grower is exempt from the Food and Drug Administration’s Food Safety Modernization Act’s rule falls squarely on the shoulders of the growers. Phil Tocco, food safety educator at Michigan State University Extension, said there are growers who will be exempt from meeting the Act’s rules.
Although greenhouse and controlled environment agriculture growers may be exempt from implementing Food Safety Modernization Act rules, produce buyers may make compliance mandatory.
U.S. Centers for Disease Control and Prevention estimates 48 million people are sickened each year by foodborne pathogens. Of those people about 128,000 are hospitalized and 3,000 die each year.
On Nov. 13, 2015, U.S. Food and Drug Administration finalized three rules of the Food Safety Modernization Act. The purpose of FSMA, according to a FDA press release is to prevent foodborne illness “that, for the first time, establish enforceable safety standards for produce farms and makes importers accountable for verifying that imported food meets U.S. safety standards.” FDA said FSMA’s “final rules will help produce farmers and food importers take steps to prevent problems before they occur.”
“The recent multistate outbreak of Salmonella in imported cucumbers that has killed four Americans, hospitalized 157 and sickened hundreds more, is exactly the kind of outbreak these rules can help prevent,” said Michael Taylor, FDA deputy commissioner for foods and veterinary medicine. “The FDA is working with partners across the government and industry to prevent foodborne outbreaks. The rules will help better protect consumers from foodborne illness and strengthen their confidence that modern preventive practices are in place, no matter where in the world the food is produced.”
The three final rules released by FDA in November are the Produce Safety rule, the Foreign Supplier Verification Programs rule and the Accredited Third-Party Certification rule. FDA has finalized five of the seven major rules that implement the core of FSMA. In September 2015, FDA released the Preventive Controls for Human Food rule, which mandates preventive practices in food processing and storage facilities.
Produce Safety rule
The Produce Safety rule is the one rule that should have the biggest impact on outdoor farmers, greenhouse growers and controlled environment agriculture (CEA) growers. FDA used public comments and input collected during farm visits, meetings and listening sessions to develop a rule it says aims at reducing contamination risk while providing flexibility for farmers and growers.
This rule “establishes science-based standards for growing, harvesting, packing and holding produce that are designed to work effectively for food safety across the wide diversity of produce farms.” The rule’s standards include “requirements for water quality, employee health and hygiene, wild and domesticated animals, biological soil amendments of animal origin such as compost and manure, equipment, tools and buildings.” The rule’s standards have been designed to “help minimize the risk of serious illness or death from consumption of contaminated produce.”
The Food Safety Modernization Act’s Produce Safety rule includes standards for water quality, employee health and hygiene, equipment, tools and buildings.
One crop that the rule specifically addresses is the production of sprouts, which have been frequently associated with illness outbreaks. FDA reports that between 1996 and 2014, there were 43 outbreaks, 2,405 illnesses, 171 hospitalizations and three deaths associated with sprouts. Among the outbreaks was the first documented case of Listeria monocytogenes associated with sprouts in the United States. This crop is particularly vulnerable to microbial contamination because of the warm, moist conditions in which they are produced.
Exemptions to the Produce Safety rule
The earliest compliance date for the Produce Safety rule for some farms is two year after the effective date of the final rule. There are exemptions to the rule for some producers. These include farms that have an average annual value of produce sold during the previous three-year period of $25,000 or less. Also to be eligible for a qualified exemption, the farm must meet two requirements:
1. The farm must have food sales averaging less than $500,000 per year during the previous three years.
2. The farm’s sales to qualified end-users must exceed sales to all others combined during the previous three years. A qualified end-user is either (a) the consumer of the food or (b) a restaurant or retail food establishment that is located in the same state or the same Indian reservation as the farm or not more than 275 miles away.
Buyers driving food safety regulations
Dr. Elizabeth Bihn, director of the Produce Safety Alliance at Cornell University, said prior to FSMA, buyer demand has been the primary driver for implementation of food safety practices. “Consumers are buyers, but they are not protecting a name brand like Kroger or Wegmans or Wal-Mart,” Bihn said. “These companies are protecting their brands. They are going to have much higher stipulations for food safety then the consumers at farmers markets. There is some consumer demand for increased accountability for food safety, but it’s not as big a driver as the retail buyers’ demand. This includes most large food retailers.”
Even if greenhouse and controlled environment agriculture growers of food crops are exempt from the Food Safety Modernization Act, they may be pressured by buyers to adhere to the Act’s rules.
Bihn said greenhouse vegetable growers and CEA growers may receive added pressure from buyers to follow FSMA whether or not they are exempt from it.
“If a buyer tells a grower, “I’m not buying your produce unless you have a third party audit,” and the grower wants that company’s account, then the grower is going to do the audit,” Bihn said. “Legally a grower may be exempt from the regulation, but a buyer may say it doesn’t matter, the grower will still have to meet the regulation. There are still going to be markets that don’t require growers to meet the regulation if their operations are exempt from it. If you are a greenhouse grower who sells to a market that’s not requiring compliance with FSMA and you are exempt from the regulation, you may not have to do anything related to the regulation. Also, I can see third party audits, like the Harmonized GAPs audit, being updated to align with the rules to make sure that growers who have audits done meet the federal regulations as well.”
Increased interest in food safety
Even before the final rules were released, Bihn said she is receiving increased inquiries from greenhouse growers about food safety. “Greenhouse growers are trying to decide if they are subject to FSMA rules and how the required practices might fit with what they do with their greenhouses,” she said. “They are trying to figure out if they need to be concerned with meeting food safety regulations. They are going to be in the same situation as field farmers and asking the same questions. Are buyers asking the growers to meet the regulations? Greenhouse growers not subject to the regulations could easily get pushed into following the regulations if their buyers tell them in order to do business with them, the growers must follow the regulations.”
Bihn said her job is to help guide produce growers, whether they are field farmers, urban farmers, greenhouse growers or CEA growers, toward implementing food safety practices.
“Initially there may be frustration, hostility and denial,” she said. “All of those things will occur when growers first hear what they have to do. When they finally sit down and start to learn something about food safety and start to ask how can I fix this, then they start to make progress really fast.
“I love farmers who question everything. They don’t understand why doing something is a risk. They tell me I’ve never killed anyone so what’s the problem. That’s the engagement that I need to get them to think about it. They need to get to where they understand all farms can have produce safety risks and admit that they need to learn something about food safety so that they can make adjustments within their operations and put practices in place to reduce the risks.”
Industry job opportunities
Bihn said she has been encouraging Cornell students majoring in horticulture to get a minor in food science. She has also been encouraging students majoring in food science who are interested in produce safety to get a minor in horticultural production.
“There are food science students who have no idea how farms operate,” she said. “Unfortunately this sometimes results in food science professionals offering ideas for problem solving that may not be doable.”
Bihn said that food safety has traditionally been housed with the food science departments and crop production has been housed with the horticulture department.
“It’s time for there to be some cross pollination between these two departments,” she said. “It has been slow to happen. We now have a Masters of Professional Studies degree at Cornell that merges horticulture and food science. There are jobs out there, but they are difficult to fill because there are people who know production or there are people who know food pathogens, but there are very few people who know both.”
Bihn said she has received requests from her horticulture colleagues at Cornell to give guest lectures on food safety and to collaborate on publications about incorporating food safety guidelines into field publications.
“The fruit and vegetable industry as a whole is certainly saying food safety is something that we need to be incorporating,” she said.
University researchers, extension specialists, industry
representatives and USDA officials are working together to improve how research
is conducted in controlled environment structures, including greenhouses.
By David Kuack
North Central Extension & Research Activity–101
(NCERA-101) is a committee of the USDA
organized to help plant scientists understand how to use controlled environment
technology. The committee initially began in 1969 when plant scientists in the
American Society for Horticultural Science began to discuss how to effectively
use growth chambers to ensure consistent and comparable growth data. When the
committee was organized in 1976 as the North Central Research-101 (NCR-101)
committee, the group expanded to include all plant science researchers and
began encouraging private industry groups to participate.
NCERA-101 was organized to help plant scientists understand
how to use controlled environment technology. Photo courtesy of University of Alaska
NCERA-101 now has
over 160 members from 102 institutions and industries. There are even members
from outside the United States.
“NCERA-101 is a project with USDA,” said University of
Alaska horticulture professor Meriam Karlsson, who is the chairperson of the
committee. “USDA has several of these working groups or committees that work on
special topics. This committee is particularly large compared to some of the
others because of the involvement of industry members along with researchers.”
Poster child for
cooperation
Karlsson said the NCERA committee has to apply for
renewal every five years to keep operating and to keep receiving funding from
USDA. The USDA funding is distributed to land grant universities and their
experiment stations.
“The committee is open to industry and non-university
persons working with controlled environment technology appropriate for plant
research and production,” said Karlsson. “That is part of the reason the
committee has become so large. Industry members provide input and support the
work the university and extension personnel are doing. We can also communicate directly
to the industry members what kind of technology is needed in both greenhouses
and growth chambers in order to control the environment.”
Karlsson said USDA officials are very happy with the way NCERA-101
has been operating with the communication and cooperation that is occurring
between university scientists and industry members.
“USDA officials tell us this is how they would like other
committees to work together on multi-state projects,” she said. “USDA works
with a sizable list of working groups,
including animal sciences, forage, insects and diseases. There is no limit in
regards to the number of members the committee can have, although to keep
focused the group needs to remain manageable. NCERA-101 also collaborates with
similar working groups in Europe and Australia. In two years the meeting will
be international and held in Australia.”
Information sharing
As chairperson, Karlsson prepares an annual report and
the committee holds an annual meeting, which occurred in Alaska earlier this
year.
“During the meeting there is information sharing among
the members,” she said. “Everybody is asked to give station reports and talk
about what they are working on. It primarily has to do with how the researchers
are using controlled environment technology. It could be greenhouses, but much
of the research is being done in growth chambers, phytotrons and biotrons. The
discussions are very specific about how to run the growth chambers and what
kind of variables to measure.”
Karlsson said one of the hot topics of discussion among
the members is lighting and LEDs.
“Right now it’s very confusing as to how to evaluate LEDs,”
she said. “This is one of the committee’s areas of focus—light measurement, how
to provide sufficient light and how to use light. When using artificial lamps
there isn’t a natural spectrum.”
Another topic of discussion has been about humidity and
its effect on plants.
“How do you measure humidity and provide it
consistently?” Karlsson said. “Much of the discussion is related to how to
characterize the environment. The same types of discussions also occur
regarding the instrumentation that is used to measure these variables. The
committee works on developing guidelines for measuring these essential
variables.”
The guidelines developed by the committee can then be
used by scientists worldwide to consistently measure environmental conditions
regardless of where the research is conducted.
“Industry members also discuss the challenges they face
in regards to developing the measuring instrumentation that the scientists are
telling them is needed,” she said. “The scientists want the equipment to
measure a variable with limited influence of other factors.”
New greenhouse
open house
During this year’s NCERA-101 annual meeting, which was hosted
by the University of Alaska Fairbanks, Karlsson had the opportunity to show off
the new teaching and research greenhouse that was recently completed. The
4,500-square-foot Nexus greenhouse consists of an upper and lower level. The
upper level, which was completed in 2012, is used for teaching and
instructional purposes. The lower level, which was finished earlier this year, will
be used for research.
The new greenhouses at the University of Alaska
are equipped with high pressure sodium lamps. Photo courtesy of University of Alaska
The greenhouses are equipped with both blackout and
shade/energy curtains. There is also a Mee fog system which is used to cool the
greenhouses and to increase the humidity.
“During the winter the natural humidity is really low,”
Karlsson said. “During the summer when the temperatures can reach into the 80s,
the fog system keeps the greenhouses cool.”
Karlsson said when the greenhouses were being planned
during 2010-2011 the decision was made to install high pressure sodium lamps.
“At the time the technology for the LEDs was not
developed enough for us to choose them,” she said. “We are doing research with
LEDs because the cost of electricity here is very expensive and LEDs are anticipated
to be more efficient. I expect LEDs will make a big difference for the
commercial greenhouse industry in the state. We are looking at how we can get
enough light from LEDs to substitute for high pressure sodium to promote the
kind of growth we want to have. And we need to determine how plants respond to
different light qualities under our growing conditions.”
Interest in food
crops
Karlsson said there is a lot of interest in many
communities in Alaska about hydroponics and the production of food crops.
University of Alaska researchers are studying the
feasibility of growing a variety of edible crops.
“Alaska is at the end of the supply line so there is a
lot of interest in extending the growing season and even possibly growing
during the winter months,” she said. “We are looking at growing hydroponically and what is the
easiest way to produce leafy greens, lettuce, tomatoes and cucumbers. Even
though Alaska is known for having major natural gas and oil reserves, having an
affordable energy source is one of the obstacles that has to be addressed. Some
communities have access to natural gas, which is almost an unlimited resource.”
Karlsson said because of Alaska’s cold, dark winters,
there is interest in growing hydroponically with vertical shelf systems.
“There is also a lot of interest in greenhouses and high
tunnels,” she said. “Alaska is a big state. South of Anchorage on the Kenai
peninsula, high tunnels are used to start the season earlier in the spring and
to extend fall production. The climate is more moderate there. As you go
further north, it doesn’t make sense to put up a high tunnel. Greenhouses would
be a better choice. Even during the summer when there is plenty of light, some
heat would be needed in the greenhouses to maintain the warmer temperatures the
crops would need.”
For more:
Meriam Karlsson, University of Alaska Fairbanks, (907) 474-7005; mgkarlsson@alaska.edu.
David Kuack is a freelance technical writer in Fort Worth, Texas; dkuack@gmail.com.
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