Apr 6, 2009

Getting Started with a Food Safety Audit

Before you decide to pay $92 an hour or more to have an auditor visit your farm or packing facility, you need to lay a lot of groundwork.

Ninety-two dollars per hour is what the Michigan Department of Agriculture (MDA) charges to send a person to your farm and spend perhaps half a day looking over your operation and the paperwork that describes it.

Colleen Bess heads the program in MDA’s Pest Management Division. MDA is the designated agent in Michigan for the USDA audit. Bess stresses that this isn’t some government program being forced on farm people. From its inception in 1999, the Agricultural Marketing Service has said: “AMS, in partnership with state departments of agriculture, offers a voluntary, audit-based program that verifies adherence to the recommendations made in the Food and Drug Administration’s Guide.”

Bess was a presenter at several workshops, starting with EXPO in December. At the MIFFS workshop in February, she got help from Warren King, president of Wellspring Management, Oak Park, Ill.

They said the procedure growers should follow is this:

-Make an assessment of your farm or facility – a self-audit. Farmers who have been through Farm*A*Syst programs or the Michigan Agricultural Environmental Assurance Program or other industry programs designed to identify environmental hazards have a leg up because the food safety assessment is similar.

-Create your “manual” that lists the Good Agricultural Practices or Good Handling Practices you will use on your farm or facility and the Standard Operating Procedures you follow.

-When you’re ready, make an appointment with the state department of agriculture (or whoever is to be your certifier) to have an audit.

Writing the manual

The key part is the manual. It’s not like writing a novel; it’s more like doing an open-book essay assignment. That “book” is FDA’s “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables.” It can be downloaded from the FDA Web site, www.foodsafety.gov. All the “answers” are in this document.

The “questions” are on the audit verification checklist on the USDA AMS Web site, www.ams.usda.gov/gapghp. What you write must satisfy the auditors, who will examine your farm or facility as you carry your manual and show them your answers to the audit checklist questions.

To pass the audit you need an 80 percent score, but there are some things that will cause an immediate failing grade.

If the auditors see 1) an immediate food safety risk, 2) evidence of rodents in the facility or excessive amounts of insects or other pests in the produce in the facility, 3) employee hygienic practices that jeopardize the safety of produce, 4) falsification of records or 5) nobody in charge. Your operation must have someone designated as being in charge of the food safety program.

The USDA audit verification checklist is broken into sections. Only the general section applies to everybody. It has 15 points in it. Here are some:

G-3: Potable water is available to all workers. It’s worth 10 points and there’s the letter D in the last column. D stands for document. You need to write a document describing how your workers access fresh water and tell how you know it’s potable. Annual water quality tests are a good way.

G-12: Workers with diarrheal disease or symptoms of other infectious diseases are prohibited from handling fresh produce. This, worth 15 points, is also labeled with a D, meaning you have to describe your procedures. Who decides when to send a worker home?

G-14: Workers are instructed to seek prompt treatment for clean first aid supplies for cuts, abrasions and other injuries. Again, for 5 points, write a document that tells how they do that on your farm.

In other sections, you’ll address water usage, sewage treatment, proximity of livestock, wildlife and pets, manure storages and how you use raw or composted manure in your growing operation.

If you use raw manure, you’ll document how you store it, apply it, till it in and observe time limits between application, planting and harvest.

If part of your production land gets flooded, how do you assure there’s no microbial hazard?

There’s a section on field sanitation and hygiene, the location and placement of “field sanitation units” – toilets with hand-washing facilities, water and towels.

There’s a section on harvesting and transportation – how bins are cleaned, knives disinfected, damaged containers fixed, what you do if light bulbs break and contaminate product, how stones and other foreign objects are inspected for and removed, how wash water is sanitized and tested for potability.

As you move through the 27 pages, the GAPs sections for farm operations give way to GHPs sections for packing houses. A big part of GHPs is related to traceback – how do you handle your part of the process that moves produce containers from farm to packer to distributor to retailer. How do you record and label date of harvest, farm identification and who handled the lot?

Once you’re ready for the auditor, you want your manual to be ready – because auditors are supposed to audit and not coach, Bess said. Not only should everything be in your manual, it should be findable by you or your designated farm safety person.

It should look like you live your manual, Bess said. If you can’t find it in the manual, it doesn’t look like its part of your SOP.

The USDA audit, done by MDA, costs $92 per hour – and you pay drive time as well. No audit has taken more than a full day, Bess said, and half a day might be in the ballpark for an ordinary producer.

By signing on, you agree to pay for the visit – each year – and for a possible once-a-year unannounced visit.

USDA is not the only auditor out there, and the fee schedule varies.

In addition to this program, AMS provides oversight for the Leafy Green Marketing Agreements in California and Arizona, along with the California Tomato Growers Cooperative, each with specific best practices criteria that members can be audited against.