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Training Scenarios for USDA and Third Party Auditors on the Co-management of Food Safety and Conservation as well as Small and Mid-Size Farm Concerns

Co-management means farm system management approaches that respond to site-specific conditions by integrating cultural, biological, and mechanical practices that promote ecological balance and public health by conserving biodiversity, soil, water, air, energy and other natural resources, while also reducing pathogen hazards associated with food production” (definition from National Sustainable Agriculture Coalition).

Co-published by Wild Farm Alliance and Community Alliance with Family Farmers

Auditors who are knowledgeable about
conservation and small farm concerns have a well-rounded understanding of how to inspect for food safety. They know how to recognize situations
where farmers use conservation practices that
make food safe, when beneficial actions support natural safety processes, and when improvement
is needed. Fully trained auditors also understand small farm issues of friends and family, pets, multiple crops, and mixed operations of produce and livestock. Auditors who work for, or are accredited by USDA, can receive continuing education units. Download a Certificate of Completion for your records after reviewing scenarios.

The following training scenarios were created to be used alongside Produce GAPs Harmonized Food Safety Standards. Many of the co-management of food safety and conservation concepts described in detail here are also addressed somewhat in the Produce Safety Alliance's materials, On Farm Food Safety Project website, the Leafy Green Marketing Agreement (LGMA), and FDA's proposed produce standards. All conservation and small farm scenarios present examples followed by statements of compliance or corrective actions, so that the auditor learns the appropriate response.

The Produce GAPs Harmonized Food Safety Standards: Requirement, Procedure, Verification and Current Training Scenarios, are in tan boxes.

Co-management training scenarios are in blue boxes.

Small- and mid-size farm training scenarios are in green boxes.

Co-management Training Scenarios

Small- and Mid-Size Farm Training Scenarios

 

Field History and Assessment Requirement

Produce GAPs Harmonized Food Safety Standards
2.1.1 Field History and Assessment Requirement
The food safety plan shall, initially and at least annually thereafter, evaluate and document the risks associated with land use history and adjacent land use including equipment and structures.
Procedure
When land use history or adjacent land use indicates a possibility of physical, chemical or biological contamination, preventive controls shall be performed and documented to mitigate food safety risk. The assessment is re-performed, and documented, at least annually for environmental conditions or risk awareness that has changed since the last assessment. The assessment shall include indoor growing facilities and structures such as green houses and hydroponics.
Verification
Auditor reviews food safety plan to verify that risks associated with field history, adjacent land use and indoor growing facilities have been evaluated at least annually and preventive controls implemented for identified risks.
Current Training Scenarios

  • Does the assessment have to be written? [yes]
  • The field has been in fresh produce production for more than 20 years; the assessment does not include how the field was used before that. [compliant]
  • The assessment concludes that there are no biological risks because they've never had a recall. [not compliant]
  • The assessment only includes on-site risks and does not consider risks from adjacent land use. [not compliant]
  • The assessment includes adjacent land use but does not consider risks from a dairy 12 mile away [if you can see it, note it]
  • The most recent annual reassessment of risks only says “no change.” [compliant]

WFA/CAFF
2.1.1 Co-management Training Scenarios

a) The food safety plan describes how a crop field is adjacent to land with a compost windrow operation, and wind and water may cause the crop to be contaminated.

  • The crop is located downwind of the compost windrows. A windbreak* that follows NRCS' or other conservation professionals' recommendations  is situated between the two to reduce dust that may contaminate the crop. The windbreak has not been written down in the food safety plan [corrective action needed - compliant once windbreak is included in the plan].
  • The crop is located down slope from the compost where runoff is possible. The farmer has worked with NRCS or other conservation professionals to determine that a vegetated diversion ditch or conveyance system would effectively mitigate potential pathogens in runoff. This is written down in the food safety plan [compliant].
Photo courtesy NRCS

 

Worker Health/Hygiene Requirement

Produce GAPs Harmonized Food Safety Standards
2.2.2 Worker Health/Hygiene Requirement
Employees and visitors shall follow all personal hygiene practices as designated by the operation.
Procedure
Operation’s hygiene policies shall apply to all employees, contractors, visitors, buyers, product inspectors, auditors, and other personnel in the field. The operation shall designate competent supervisory personnel to ensure compliance by all workers, visitors, and field personnel with the requirements in this section.
Verification
Auditor observes personnel in field for evidence of compliance.
Current Training Scenarios

  • Auditor observes a customer leaving toilet facility without washing hands. Supervisor re-instructs customer on hand washing requirements [compliant].
  • Rain event has prevented harvest activity from taking place on the day of the audit. Hence, no observations are possible [N/A].
  • Operation has designated competent supervisory personnel to ensure compliance. Operation can demonstrate competency of designated supervisory personnel. However, designated person is not on-site/available on day of audit and harvest/agronomic activity is taking place.
  • Operation has posted the field with “all visitors must check in at the office prior to coming onto property, where visitors are instructed in safe practices. Utility workers are demanding the right to come onto property without notifying the operation, so the operation has no opportunity to instruct or monitor the workers in the field.

WFA/CAFF
2.2.2 Small Farm Training Scenarios

a) Farmer lives on the farm.

  • Family friends visit on the weekend and are treated as other farm visitors, as specified in the food safety plan [compliant].
  • CSA (Community Supported Agriculture) members and other customers visit the farm and walk the fields after they sign-in on a sheet and agree to farm hygiene practices [compliant].
  • Family members, interns, and CSA members who work on the farm are included in the farm employee guidelines of the food safety plan [compliant].
  • Middle school children come to the farm to learn about agriculture. They are also instructed about food safety, and are required to wash their hands before they pick strawberries. Gardens used for education are located in a designated area separate from the commercial crop [compliant, if it is consistent with the farm's written policy].
  • The farm hosts events such as wedding receptions and does not keep visitors in designated area away from the production field [corrective action needed-create a designated area for visitors that is separate from the crop field. If visitors are allowed to walk the production area, they follow health and hygiene practices addressed in the farm's food safety plan].

 

Water System Risk Assessment Requirement

Produce GAPs Harmonized Food Safety Standards
2.4.2.1 Water System Risk Assessment Requirement

An initial risk assessment shall be performed and documented that takes into consideration the historical testing results of the water source, the characteristics of the crop, the stage of the crop, and the method of application.
Procedure
A review or new assessment shall be conducted seasonally and any time there is a change made to the system or a situation occurs that could introduce an opportunity to contaminate the system. The risk assessment shall address potential physical, chemical, and biological hazards and hazard control procedures for the water distribution system.
Verification
Auditor reviews the risk assessment for completeness of consideration of potential hazards.
Current Training Scenarios

  • Row crop operation is sourcing water from an open pond on-site for overhead spray irrigation.
    • The operation has no testing data but claims there are no risks because their children swim in it. [corrective action required]
    • The operation had the water tested once last season for Salmonella and none were detected. [corrective action required]
    • Operation performed a Sanitary Survey of the pond, installed berms and fencing and pruned overhanging branches on trees to protect the pond. Indicator (E. coli) and Salmonella tests are taken bimonthly during the season. None have been detected in last 3 tests. [compliant]
    • Salmonella were detected, but water was used anyway because “this is all we have.” [immediate corrective action required]

WFA/CAFF
2.4.2.1 Co-management Training Scenarios

  • A tree crop operation is sourcing water from an open pond and feral pig prints were found once on the banks. The water was immediately tested for indicator E. coli and Salmonella, and seasonally thereafter, and none have been detected [compliant].
  • An initial risk assessment shows on the farm's map that an irrigation wellhead is near a stockpile of raw manure.
    • The distance of 10 feet between the wellhead and the raw manure is recorded in the risk assessment [corrective action needed -This is too small a distance. The actual requirement varies by locale. For instance, the State of Virginia requires at least 50-100 feet away depending on well type. Check with local or state government entity for actual distance required.]

WFA/CAFF
2.4.2.1 Small Farm Training Scenarios

  • The farmer is growing cherries and is using an above-ground drip system, and not testing the water [corrective action needed - must conduct water testing since drip system could be punctured causing water to spray on the crop].
  • The farmer is growing lettuce and broccoli using sprinkler irrigation and is testing the water for generic E. coli (126 MPN/100ml) for all crops on an ongoing basis [compliant].

 

Animal Control Risk Assessment Requirement

Produce GAPs Harmonized Food Safety Standards
2.5.1 Animal Control Risk Assessment Requirement

The operation has a written risk assessment on animal activity in and around the production area.
Procedure
There shall be a written assessment of the growing fields and adjacent land, prior to each growing season, focusing on domestic and wild animal activity including grazing and feeding operations, noting crop characteristics, type and approximate number of animals, proximity to the growing field, water sources, and other relevant factors.
Auditor reviews the written assessment to ensure it has been performed for this season and is complete.
Verification
Auditor reviews the written assessment to ensure it has been performed for this season and is complete.
Current Training Scenarios

  • Row crop operation states in their food safety plan that there are no contamination risks from animals.
    • There are no animals present during the audit, and no records of animal intrusion. [compliant, unless the auditor has evidence of contamination risk from animals, and the food safety plan explains why there are no contamination risks from animals.]
    • The auditor notices one horse in the backyard of an adjacent property.  The operation says that it is the only horse in the area. [Compliant, as long as the risk assessment acknowledges the horse and there are adequate barriers to prevent and detect intrusion of the horse onto the property]
    • The food safety plan makes no mention of a dairy one half mile away. [Compliant, unless there is a reason to believe that contamination from the dairy is reasonably likely to reach the operation.  Some customers may have more stringent requirements.]

WFA/CAFF
2.5.1 Co-management Training Scenarios

a) A diversified produce grower has documented his assessment of risk from a nearby cow pasture.

  • The grower explains that he is implementing strategies that support co-management. He says he has reduced the risk of the cow pasture that is located a thousand yards away by restoring a wetland* that now intercepts the pasture's runoff [compliant].
  • The food safety plan describes the nearby fenced pasture with five cattle in the risk assessment, noting that a hedgerow* was installed in between the produce fields and the pasture to reduce the airborne hazards, because winds sometimes blow from the cattle's loafing area under a tree where manure is ground into dust [compliant].
  • The auditor observes evidence of runoff from the pasture that occurred during a rainstorm, which may be contaminating the crop [corrective action needed].
  • The farmer has made special effort in the food safety plan to note and assess bird movement between cattle and the crop at different stages of crop growth and especially near and during harvest [compliant].

b) In an initial risk assessment for a broccoli crop, a large number of birds were noted roosting on windbreaks*/hedgerows* or telephone lines at the edge of the field.

  • It was noted how far the bird droppings could extend into the field, and then the crop was planted a specific distance away that was determined safe. Monitoring ensures that this distance is effective [compliant].
  • The crop had already been planted when the bird roost was noticed, so the farmer has marked off a specific safe distance from the bird droppings that won't be harvested, and monitors to ensure no contamination is taking place [compliant].
  • Windbreak*/hedgerows* are noted as a potential roosting site for birds. Standard procedures include preharvest surveys to create non-harvested buffers between any identified areas of feces contamination and crop [compliant].

c) The initial risk assessment for a carrot crop mentions the presence of a few gopher holes and that the crop is adjacent to a wildlife corridor. During the weekly monitoring, one coyote was seen hunting around the gopher holes and then disappearing in the wildlife corridor, and no feces, dead gophers or crop damage was found [compliant].

 

Photo courtesy NRCS

 

 

 

 

 

 

Photo courtesy dnr.maryland.gov

WFA/CAFF
2.5.1 Small Farm Training Scenarios

a) The initial risk assessment points out how produce and pastured chickens are raised on the same farm. The farmer mitigates the risk of waterborne pathogens by keeping the chicken tractors/movable coops a safe distance below the crop fields so that runoff from the chicken pasture drains below the crop and does not contaminate it. He mitigates windborne pathogens by situating chickens so that the crop is never downwind of the birds [compliant].

Photo courtesy NRCS

 

Animal Control Monitoring Requirement

Produce GAPs Harmonized Food Safety Standards
2.5.2 Animal Control Monitoring Requirement

The operation routinely monitors for animal activity in and around the growing area during the growing season.
Procedure
There shall be scheduled monitoring of growing fields and adjacent land for evidence of animal activity. A frequency of monitoring and assessment shall be established based on production factors, such as the crop, geography, and other conditions.
Verification
Auditor reviews monitoring records to ensure the frequency of monitoring is consistent with the schedule.
Current Training Scenarios

  • The tree crop operation has no records of monitoring for animals because their food safety plan says that there are no risks of contamination from animals. [Corrective action needed.  The standard requires that there “shall be scheduled monitoring of growing fields and adjacent land for evidence of animal activity”
  • The blueberry operation has no established frequency for monitoring for animal activity in the field, but procedures require animal activity to be recorded when observed. There are three records of animal activity in the past two months.  [Corrective Action Needed, if only to establish a schedule (e.g., “daily, when personnel are in the field”).  Monitoring records are required, but there is no requirement to record when the monitoring is performed.  For example, recording only when activity is observed would be compliant.]
  • The Florida green pepper operation has procedures to inspect fields each morning for deer and large animal activity.  There are no procedures to inspect for rodent, bird or amphibian activity.  [Compliant if the risk assessment concludes, and observations support, that rodents, birds and amphibians do not pose a contamination risk. Otherwise, the risk assessment is incomplete and Corrective Action Needed because monitoring is insufficient.]

WFA/CAFF
2.5.2 Co-management Training Scenarios

a) The crop is cherries and there is bird and ground squirrel activity.

  • Once the fruit is present, the farmer monitors the bird activity daily and notes when a flock is present, or when a few are there for a long time. When necessary, the farmer uses bird netting to reduce the presence of pest birds [compliant].
  • The auditor sees that recent ground squirrel activity in the crop, near equipment, food contact surfaces, and packing materials, and the farmers says monitoring is only done when there is time [corrective action needed to monitor for ground squirrels, record monitoring, and use strategies to reduce the population].

b) An orange crop for fresh market is grown next to a wetland*.

  • Prior to each irrigation, the crop is monitored for damage and animal feces [compliant].
  • The crop is monitored weekly for animal activity. Feral pig prints and feeding of fallen oranges were noted in the pre-harvest assessment.  The food safety plan does not allow fruit to be picked up off the ground [compliant].
  • The monitoring occurs only once right before harvest [corrective action needed].

c) An organically managed cherry tomato field adjacent to a hedgerow* is monitored for animals.

  • The farmer conducts a weekly food safety assessment at the same time s/he is conducting an Integrated Pest Management (IPM) assessment for the period. It is noted in the log that beneficial and pest insects and birds, are located in, or in proximity to, the hedgerow,* and it was deemed that they caused minimal risk [compliant since the birds were attracted to the hedgerow and not the crop].
  • The farmer monitors daily for ground squirrels, finding a few associated with the weedy areas. Short, silt fencing is used to reduce the rodents and all animal presence is noted as part of their food safety plan [compliant].

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WFA/CAFF
2.5.2 Small Farm Training Scenarios

a) Farmer lives on the farm.

  • Feral cats are periodically seen on the farm's perimeter hunting mice, but not in the crop fields. Weekly monitoring of the crop field near where the cats were seen is performed. If evidence of cats is found in the production area, steps are taken to discourage them, including removing food sources and shelter, and trapping [compliant].
  • Farm dogs and other visitor pets are allowed to run around on the farm [corrective action needed –dogs are only allowed in production fields that will not be harvested for 120 days. When harvest is less than 120 days, the animals are not allowed].

 

Animal Control Requirement

Produce GAPs Harmonized Food Safety Standards
2.5.3 Animal Control Requirement

Based on the risk assessment, there shall be measures to prevent or minimize the potential for contamination from animals, including domestic animals used in farming operations.
Procedure
The operation shall have risk-appropriate actions to prevent or minimize the potential for contamination of produce with pathogens from animal feces, including from domestic animals used in farming operations. There shall be a written record of any mitigation or corrective actions. Preventive measures and corrective actions shall comply with all local, state and federal regulations concerning animal control and natural resource conservation.
Verification
Auditor reviews preventive measures and corrective action plans.
Current Training Scenarios

  • The blueberry operation has records indicating that deer are periodically observed in the fields.  There are no subsequent actions recorded.  The operation says that they chase the deer away when they see them. [Corrective action needed. The standard requires that “there shall be a written record of any mitigation or corrective actions”]
  • The operation uses horses for cultivating fields.  The operation’s procedures require that horses walk on a lane parallel and separate from the growing rows, and that horse feces are collected and removed from the field. Auditor does not observe any contamination from the horses on the growing rows.  [compliant]

WFA/CAFF
2.5.3 Co-management Training Scenarios

a) The spinach farmer has seen wildlife twice in the fields.

  • Loud noises, sprinklers activated by motion sensors, and scare balloons are used to discourage wildlife and written down in the records [compliant].
  • Management of poorly drained areas is done and this written down [compliant].

b) The asparagus farmer finds mice damage was occurring in one corner of the crop.

  • The farmer puts out mouse traps to reduce the population, and keeps traps out after that to ensure that they do not come back, but does not it write down [corrective action of keeping written record is needed].
  • A control program for the rodents is written down, including live trapping, and the use of raptor perches to encourage hawks to hunt the rodents [compliant].

c) The fruit and vegetable farmer sees mice tracks coming from an adjacent riparian area into the crop fields.

  • In order to discourage the mice, the farmer planted native grasses along the riparian edge after consulting with appropriate natural resource agencies. The grasses are kept mowed so that they do not provide the mice with food or with cover from predators. Grass was chosen over bare dirt since it is better at filtering pollutants before they reach the waterway [compliant].

d) The crop is strawberries for fresh consumption.

  • Animal feces, presumably from a small terrestrial wild animal, are found in one location in the crop field. After searching in the crop, no other feces were found. The feces are properly disposed of, and a small area around where the feces were is flagged and cordoned off so that it will not be harvested. A written record has been made of these events [compliant].

e) The crop is leafy greens that will be processed in water and bagged.

  • Cattle are grazing on adjacent land upslope from the leafy greens field. Corrective actions, including installations of a fence that contains the animals, a diversion ditch that redirects the runoff, and a windbreak* that intercepts dust-containing pathogens, have been made between the grazing land and the crop field. These actions were noted in the written record [compliant].

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Soil Amendments Requirement

Produce GAPs Harmonized Food Safety Standards
2.6.1 Soil Amendments Requirement

The food safety plan shall address soil amendment risk, preparation, use, and storage.
Procedure
If animal-based soil amendments or biosolids are used, records of composition, dates of treatment, methods utilized and application dates must be documented. Evidence of processing adequate to eliminate pathogens of human concern, such as letter of guarantee, certificate of analysis (COA) or any test results or verification data (e.g., time and temperature) demonstrating compliance with process or microbial standards, shall be documented. Such soil amendments must be produced and applied in accordance with applicable federal, state, or local regulations.
Verification
Auditor reviews soil amendment records for completeness and evidence of compliance with prevailing regulations. If biosolids are used, it shall be noted.
Current Training Scenarios

  • Under what conditions are biosolids permitted [operator is responsible to know the rules].
  • The operation has no COAs for soil amendments because they do not use animal-based compost. Records of compost sources indicate that this is accurate [compliant].
  • The operation obtains its compost from the municipality, which compost lawn litter. The municipality offers no guarantees of test results for the compost. The operation does not test the compost [corrective action required].

WFA/CAFF
2.6.1 Small Farm Training Scenarios

a) Farmer uses manure-based compost.

  • The compost is made on the farm, recording inputs, time and temperature, and the number of turnings during the composting process [compliant].
  • The compost is made on the farm and incorporated three weeks before the crop was planted, but no records were kept of the composting process [compliant even without composting records, because the time period instituted before planting is the same as is required for manure].

 

Soil Amendments Requirement

Produce GAPs Harmonized Food Safety Standards
2.6.2 Soil Amendments Requirement

If a soil amendment containing raw or incompletely treated manure is used, it shall be used in a manner so as not to serve as a source of contamination of produce.
Procedure
If such a product is used, there shall be documentation of the composition, and time and method of application. Such use will be consistent with current industry practices or regulatory restrictions for that commodity.
Verification
Auditor reviews records for any soil amendment use that may contain raw or incompletely treated manure.
Current Training Scenarios

  • Leafy green operation applies animal-based compost to the field after harvest, works it into the ground and plants alfalfa between seasons. They have no records whether compost was sufficiently treated to destroy pathogens [corrective action required].
  • Leafy green operation applies compost as side dressing during growing season. They have letter of guarantee and COA from the compost supplier [not allowed].
  • Carrot operation applies animal-based compost immediately prior to planting. They have documentation of the composition and composting procedures (consistent with current industry practices), and time and method of application [compliant].

WFA/CAFF
2.6.2 Small Farm Training Scenarios

a) Farmer uses raw manure from farm animals for a leek crop.

  • Organic farmer spreads raw goat manure with bedding straw on the field 120 days* before harvest [compliant - since this is the time required in the National Organic Program for crops in contact with the soil].
  • Farmer applies unfinished compost made with cow manure from the farm as a side dress 60 days before harvest [immediate action required].

b) Farmer allows animals to graze fields.

  • Organic farmer plants summer squash in a field that was grazed by sheep and times it so the harvest occurs 120 days after animal presence [compliant - since this is the time required in the National Organic Program for crops in contact with the soil].
  • Organic farmer uses geese trained to eat weeds* in apple orchard and times their presence so the harvest occurs 90 days after their removal [compliant - since this is the time required in the National Organic Program for crops not touching the soil].
  • California farmer allows sheep to graze under almonds and removes them from the orchard 120 days before the harvest [compliant - while the CA Almond GAPs do not specifically address grazing, they have the 120 day restriction for non-composted, non-treated manure, and they also require almonds to be pasteurized].

 

Certificate of Completion
Download a Certificate of Completion for your records now that you have reviewed these training scenarios.

*Endnotes

  • Hedgerows are lines or groups of trees, shrubs, perennial forbs, and grasses that are planted along roadways, fences, field edges or other non-cropped areas.
  • Wetlands are areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas (from US Army Corps of Engineers and US EPA).
  • Windbreaks are linear plantings of trees and shrubs designed to enhance crop production, protect people and livestock, and benefit soil and water conservation.
  • Clark, S., S. H. Gage (1996). "Effects of free-range chickens and geese on insect pests and weeds in an agroecosystem." American Journal of Alternative Agriculture 11(1).
  • USDA-AMS National Organic Program Regulations 7 CFR Part 205.

User's Note: These training scenarios provide suggestions for use by food safety auditors. They were supported by Columbia Foundation, Farm Aid, Gaia Fund, Newman's Own Foundation, Organic Farming Research Foundation, and the True North Foundation. The information provided herein is offered by Wild Farm Alliance and the Community Alliance with Family Farmers in good faith and believed to be reliable, but is made without warranty, express or implied, as to merchantability, fitness for a particular purpose, or any other matter. It is intended as an educational resource and not as technical advice or as a substitute for actual regulations and guidance from FDA or other regulatory agencies. It is also not intended as legal advice. We will not be responsible or liable, directly or indirectly, for any consequences resulting from use of these training scenarios or any resources identified in this web document.

Jo Ann Baumgartner of Wild Farm Alliance (WFA) wrote these scenarios with review and substantial technical input from Trevor Suslow of UC Davis, and editing by Community Alliance with Family Farmers (CAFF). WFA and CAFF co-published the final training scenarios in October 2013.

 



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