The Michigan On-Farm Produce Safety team frequently emphasizes the importance of best practices as outlined in the Food Safety Modernization Act (FSMA) Produce Safety Rule. Our newsletters, infographics, and podcasts focus on identifying risks across different areas of the farm and provide actionable strategies to mitigate those risks. Whether we’re offering technical assistance, on-farm education, or working alongside regulatory inspectors, our goal is the same: to help farms strengthen their produce safety culture.
However, a recurring concern from growers is that compliance with FSMA standards often feels overwhelming, particularly in terms of financial investment and time commitment. The language of the rule—filled with terms like “minimum,” “necessary,” “adequate,” and “appropriate”—can be overwhelming and unclear. What do these terms really mean for growers striving to meet FSMA requirements?
The Produce Safety Ladder
One of the best ways to think about produce safety is as a ladder—a metaphor often used by our Upper Peninsula Technician, Landen. Imagine that ladder represents your farm’s food safety culture. Each rung of the ladder is a step toward achieving excellence, with the top rung representing the "gold standard" in produce safety.
The first rung—the foundational step—is acknowledging that on-farm food safety is critical for the farm’s success. From there, the key is to approach the process with a "Good, Better, Best" mindset, allowing you to gradually implement practices that enhance safety without feeling overwhelmed.
Applying Good, Better, Best
Let’s explore how this concept works using an example from FSMA’s Subpart K §112.116(a), which states that food-packing materials must be "adequate for their intended use."
Good: Use clean containers, free of visible filth, and consider adding a liner if you're reusing single-use containers. This is a basic step, but it's crucial for preventing contamination.
Better: Invest in reusable harvest containers designed for cleaning and sanitizing. Establish a schedule for cleaning these containers and create a Standard Operating Procedure (SOP) that outlines how and when they are sanitized.
Best: Take it a step further by cleaning reusable harvest bins daily or using single-use containers in the field. These upgrades make it easier to consistently ensure food safety.
Improving Packing Lines
Another area where the Good, Better, Best ladder is helpful is with produce packing lines. Older equipment can still be used safely if it is cleanable, though it may be more challenging.
Good: Perform daily visual inspections before using the packing line. Check for visible dirt and inspect areas like foam padding or rollers for wear and tear, which can harbor bacteria. Cleaning dirty surfaces and repairing damage before using the line is a good first step.
Better: Implement a daily cleaning and sanitizing schedule, which includes disassembling the machine, removing soft surfaces like rollers and brushes, and allowing them to dry for 24 hours. This step reduces the risk of contamination from moisture-retaining materials.
Best: Invest in modern equipment with non-porous food contact surfaces that can be easily cleaned and sanitized. Newer machines are designed to make daily cleaning simpler and more effective, reducing the risk of contamination and making it easier to maintain a high level of food safety.
Creating a Produce Safety Culture
Building a strong food safety culture on the farm can seem like a daunting task, but breaking the process down into smaller, manageable steps can make it more achievable. By adopting the Good, Better, Best approach, you can continuously improve your practices, no matter where your farm currently stands on the produce safety ladder.
For growers interested in assessing their current practices, On-Farm Readiness Reviews and Produce Safety Technicians are available to help you evaluate your farm’s position on the ladder and identify steps to improve. Visit miofps.org for more information.
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Article by Micah Hutchison, Produce Safety Technician
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