[dominiquer60]

NEW FOOD SAFETY REGULATIONS PROPOSED FOR FRESH PRODUCE GROWERS
By Dr. Luke LaBorde, Department of Food Science, Penn State University

On January 4, 2013, the U.S. Food and Drug Administration (FDA) released
a draft Produce Safety Rule as required under the Food Safety
Modernization Act (FSMA) of 2011. This proposed regulation would
establish mandatory practices that farmers must take to prevent
microbial contamination of fresh produce. Below are highlights of
requirements FDA would issue in the final regulation.

Worker Health and Hygiene ‐ Farm and packing house workers who harvest
or handle fresh produce, and their supervisors, must receive training on
personnel hygiene and health conditions that can increase the risk for
food contamination. Growers are required to show proof of training by
keeping written records. Toilet facilities have to be readily
accessible, kept reasonably clean, and supplied with toilet paper.
Hand‐washing stations must be close to toilet facilities and supplied
with potable running water, hand soap, and clean single use towels.

Agricultural Water ‐ Growers must be able to demonstrate that the water
they use for rrigation, pesticide preparation, cooling and washing, etc.
is safe for its intended use. Maximum average E. coli levels of 126
cells per 100 milliliters have been proposed for irrigation water that
can contact the edible part of the crop. Water used for post‐harvest
operations face more stringent standards; no detectable levels of E.
coli are allowed.

Biological Soil Amendments ‐ At least a 9 month interval (270 days)
would be required between application of raw animal manure to produce
fields and harvesting if there is a possibility that the manure may
contact the produce. Composted animal manures can be applied from 0 to
45 days before harvest depending on whether or not it can contact the
crop. Growers, or commercial compost suppliers, must provide proof
through laboratory testing that the composting process was adequate to
make it safe to use. No human waste is allowed on fields except in the
case of sewage sludge biosolids that are treated according to already
existing regulations.

Domesticated Animals ‐ Working animals, such as mules and horses, are
allowed in produce fields as long as the grower can demonstrate that
they have taken adequate measures to prevent contamination. If animals
are allowed to graze in areas intended for produce growing, the waiting
period specified for application of raw manure (270 days) would apply.

Wild Animals ‐ FDA recognizes that it is impossible to keep all wild
animals away from produce fields. If the situation is out of control and
there is a reasonable probability that wild animals can contaminate
produce, growers would be required to monitor their fields for signs of
animals and take some kind of preventative measure to keep them out or
discourage them from entering.

Equipment, Tools, and Buildings ‐ Equipment and tools need to be kept
reasonably clean. Sanitation standards for packing buildings requires
good water drainage, control of dripping condensation, a pest control
program, and regular clean‐up of trash. Partially‐enclosed packing
buildings are acceptable if the grower or packer takes precautions to
prevent birds and other pests from becoming established in the buildings.

Here are some important points that need to be made about the proposed
rule. The proposed rule covers only fresh produce that is sold
commercially. It does not apply to produce used for personal
consumption, such as home gardens. The focus of the new regulation is on
fruits, vegetable, nuts, herbs, mushrooms, and sprouts that are
typically eaten raw, not commodities that are generally cooked or
further processed. For example, potatoes, eggplant, winter squash,
beets, and beans for drying are exempt.

Not all farms that grow fresh produce are required to comply with the
rule. Farms with gross food sales under $25,000 are exempt. Farms with
gross food sales over $500,000 are generally required to comply. Those
with total sales of between $25,000 and $500,000 may or may not receive
exemptions, depending on what kind of marketing channels are used. For
instance, if a farmer sells than more than half of his/her strawberry
crop directly to consumers, such as at a farmers market, farm stand, as
a CSA, or if he/she delivers it directly to a grocery store or
restaurant, they are exempt from the regulation. However, to receive
this exemption, these kinds of direct sales must be to buyers in the
same state as the farm, or if out of state, no farther than 275 miles
from the farm. If a crop is mostly sold through wholesale outlets, such
as through distributors, warehouses, or fresh‐cut processors, the farm
is not exempt and is covered under the rule. Exemptions can be cancelled
if FDA determines that a farm may be a source of contaminated produce.
And finally, keep in mind that growers of any size who sell at least
some of their crop through wholesale marketing channels, even if
technically not covered by the federal regulation, have been facing and
will to continue to face standards at least as stringent as anything in
the final FDA regulations.

Remember, this is a proposed rule. It is not a final regulation. This
means that growers have an opportunity to comment on any part of the
rule they do not understand or object to. The draft ruling is available
for viewing at http://www.fda.gov/Food/FoodSafety/FSMA/ucm304045.htm.
The public will have the opportunity to submit comment on the draft rule
until May 16, 2013. Before this date, FDA will be holding public
meetings to explain the proposal and to provide additional opportunity
for input. There are two ways to send comments. You may submit comments
through the internet at http://www.regulations.gov. Once you are on the
site, follow the instructions for submitting comments. For written
comments, you may fax them to FDA at 301‐827‐6870 or mail them to:
Division of Dockets Management (HFA‐305), Food and Drug Administration,
5630 Fishers Lane, rm. 1061, Rockville, MD 20852. All written
submissions received must include the Docket No. (FDA‐2011‐N‐0921).

So my question is if you apply raw manure, and work it in, say with a plow, or a harrow, is there a risk of it coming into contact with the produce, after such procedures?

Also
“as long as the grower can demonstrate that
they have taken adequate measures to prevent contamination.”
How does a teamster take adequate measures to prevent contamination when working in a vegetable field?
Personally I don’t harvest where I stopped the horses and one made a deposit, it didn’t make sense to even before this bill, but is it “adequate?”

[dominiquer60]

I am with you Kevin in regards to both the low tech sprouting and the aquaponics. I imagine somewhere on this earth there is a good justification for such an intense system, but I really prefer to eat vegetables grown in soil, I feel that the nutrients are more complete and the system more harmonious with my lifestyle.

[dominiquer60]

Small horses can do work, I helped a friend in college do farm work with draft ponies and we got a lot done, but Morgans, Quarter Horses and other types can be very hand on a farmstead. Here is a good example, http://www.nealperryfarm.com/ben.html. Sounds like you should start reading some of the old horse threads 🙂

[dominiquer60]

Thanks Kevin.

I am considering doing this when I get my flock of layers (dominiques someday). For now we have been soaking spelt for the horses for 24 hours (weather permitting). I know that 4 days is better but we are not disciplined enough for that yet, but the 24 hours is a step in the right direction because we see less spelt in the manure. I hope to have some indoor space to do 4 days in the future.

This article was written by someone trying to sell something, but I know the power of green feed so there is some truth to it. http://www.progressivedairy.com/index.php?option=com_content&view=article&id=3082:yummy-sprouts-for-dairy-cows&catid=48:new-technology&Itemid=74

[dominiquer60]

Thanks for the up dates, I am imagine they were all beaming and exhausted last night. Good job Team DAPNet!

[dominiquer60]

Good example Jim. Sam started logging with horses off the home farm as a way to harvest material for timber frame structures that he was building. This allowed him to get the kind of material that he wanted cut the way he wanted and at a better price for the home/land owners. A couple customers even had him harvest off of their own land, the one couple tells the story of how their house was built to any that will listen, they are extremely happy with the results. It makes so much sense and provides good opportunities for local economies.

[dominiquer60]

Rick,

Yes, they are connected to forests in NH and they own some around Keene. We planted the seed we will see if they want to act on it. The suggestion was made to have a part of their forest managed strictly with draft animals so that they had something to compare with their usual harvest methods. There is a grad student that may be interested in taking this on for research. We will see where it goes.

Andy,

Some of the focus was on how a land owner may make use of precision harvest and woodlot improvement with draft animals and the other part was hiring a woodmill to get the most value out of your timber, especially if you have use for the wood. It worked because one man who walked away with a card wants his small property managed with the intentions of some of his harvest used for firewood and lumber to make improvements to his camp. His lot is too small to really make use of a machine and the value of the lumber not worth the machine loggers time, but it still has value to him and so does improving his lot. This is what we focused on but yes there are many more questions that can spring from this idea, I am not the person to answer most of them.

“Does someone set up the wood-mizer at portable sites in the woods so as to minimize haul distance, or at one site (perhaps further away) where the wood can be handed easier, and boards can stacked and sold without moving it twice?”

We were asked this same question, and given our terrain that day, it made much more sense to bring the logs to the landing. In this case it was the parking lot where there was plenty of room for both team, sawmill, lumber and a pile of logs. Bringing the saw mill into the woods was not an option, there was not enough room for everyone to work safely and the footing was poor, it was not even a consideration when we were setting up for the workshop.

[dominiquer60]

NB,

Mulch is a huge help with crops that get to large to cultivate. Once the tomatoes are too tall to drive over with a hiller or a cultivator, give them a good hoeing and then use straw, hay, pine needles or whatever you have available. Put a good layer on so that the weeds are not likely to grow through. The more weed free your mulch is (hay tends to have weed seeds) the less weeds you introduce to your garden. If you use combined straw avoid rye, it will sprout and produce a growth inhibitor that can have negative effects on your crop. Mulches are good for the garden because they conserve moisture and soil, plus they are good soil builders by adding organic matter.

If you get the Small Farmers Journal, the Nordell’s have written about mulches, or you can find some info on there work online, just Google Anne and Eric Nordell, Beech Grove Farm. Here is a lecture that they gave at a conference, it is audio only http://www.youtube.com/watch?v=JJ6GcsStfks

Here is a discussion and some good pictures http://www.backwoodshome.com/forum/vb/showthread.php?t=4179

[dominiquer60]

Glad she got over that quick. It was good of the sled to catch you so gracefully 🙂

Many of us have had our little mishaps, luckily you were able to maintain some control and get her back rather quick. She is a pretty little mare, there should be more crossed like her out there.

[dominiquer60]

I paid $2k for my 5′ Schipshe, that includes the articulating from roller, pole and seat. I actually got it for a little less because I bought it at Horse Progress Days and it was in the field demos both days. I highly recommend the articulating front roller, it still takes a lot of sideways pressure for the horses to move it around on my tight headlands, but much less than the non-articulating version, and makes a much tighter turn as well.

[dominiquer60]

“I see some value of this organization being a part of a larger organization. I think there would be a long term benefit, both saving overhead costs and gaining greater exposure, to actually being a part of and integrated into a larger type of community. Because for me, though draft power is a huge part of my vision for the future, it is in fact only a single arrow in the quiver… I wonder if the DAP organization would lose some control, but gain a much broader influence in the sustainable farming/logging community.”

Part of what the website change is going to do is to clarify the fact that DAP.com (this website) IS already part of a larger organization. Draft Animal-Power Network (DAPNet) is a larger organization in the sense that we maintain this site, create events in the northeast of the US, print a newsletter, maintain a data base all while educating others and providing resource connections. The couple hundred members and a few sponsors of DAPNet has allowed us enough keep this site going. With thousands of registered members on DAP.com there is such huge potential to take this good site and and make it a great one, keep all that we have an build on and add to it in a big way.

Any one who is not aware of DAPNet, please scroll to the top and click on “Draft Animal Network” button to learn about the rest of our organization. When combined the information from both sights will be blended together so that it will be one bigger happier easily accessible family of draft folk in one place not 2 or 3 (we also own a site for our large event Draft Animal-Power Field Days).

I am really excited by all of your support.

[dominiquer60]

Friends of mine raise beef, pork, lamb, goat, chicken, turkey and duck. They keep everything in various coolers behind the table in the shade, each cooler is labeled with what it contains and how many cuts of each, in hot weather the coolers are covered with insulating blankets. They keep track of every cut sold so they know what is in there without shuffling thru everything. On hot days they use ice packs, some commercially made and some just ziplocks with frozen water in them. They have a couple black trays from home depot, I think that they are for mixing mortar, many meat vendors use these. Some freeze water in the bottom (easier with a walk in cooler) others use crushed or cubed ice. They all put these trays on an blanket for insulation and have an insulated display box with a plexyglass or better yet lexan cover, generally on hinges. My favorite ones have angled tops and hinges in the front so that the vendor can open it easily and reach in for products, this also vents the warmest air at the top of the display. The vendors I know will keep a sampling of what they have that day in the display box and rotate frequently either from selling the products or swapping them for one in the coolers in back. Some other subtleties are having a squeegee to wipe condensation off the clear display top, keep the display box deep enough to corral the cold air when you open the top, bring an extra insulating blanket to cover the display when it is really hot or business is slow.

Letting customers handle the product opens you up to possible damage to your meat packaging which leads to possible freezer burn and unsaleable product.

[dominiquer60]

Andy, Just to clarify that would be $1 donation to register to post, not $1 per post? This may not be clear to all.

[dominiquer60]

I should not have assumed that you don’t farm, my apologies I have a hard time remembering what everyone does on this site. It sounds to me that you are a size they they would probably like to hear about.

My friend just got back to me and said that if you have anything that resembles Ag they would love to hear from you, especially about animals. With the NAIS 2.0 rearing its head they are looking for every animal owner so that they can get you in the system, hobbyist or not. I have a “please don’t ask me, I don’t want to tell” mentality when it comes to things like this. Although I think small farms are very very important, I don’t want to be part of big brother system, I want to be part of the local solution for food sovereignty.

A side note on how ridiculous the USDA is with our tax dollars:
A few years ago the family that I was with returned the Census, it triggered 2 visits by men hired by the USDA to go to farms and ask two questions: How many acres of oats did you plant? What is your expected yield? During the second trip they asked: How many acres of oats did you harvest? and what where your yields? The next farm on their list was 40 minutes from us, and was not the next closest farm that grew oats.

All of this (2 trips in a gas guzzling Durango, 2 men, and handouts of gloves and rain gauge) just to ask 4 questions about 5 acres of oats that are used on farm for feed. A ridiculous use of resources if you ask me, it would have been entirely more efficient to use the phone in this case.

[dominiquer60]

We got the Census too, rather my partner did, and he owns 4 horses that don’t live on the property. I don’t see it as a personal attack against farmers but rather, like Sam they somehow found your name associated with a farm name. In Sam’s case his name is associated with his fathers farm name and we are assuming that is how he got on the list. He helps his father farm and proudly displays the name on his hame covers and the USDA caught wind and wants to double check that he does or does not farm. They are trying to avoid wasting time money on someone that doesn’t make money for the IRS is how I see it. On the flip side, if they catch someone that has not been include in the census before and should, then they have their additional info that they are seeking.

I am going to ask a friend who ought to know more about this than either of us.

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