Considerations When Working with Animals

Continue reading to determine what steps you can take to reduce the risk of contaminating produce when working with animals on the farm.

Background:

The FSMA Produce Safety Rule (PSR) does not prohibit animals from being on or near produce farms. Instead, it requires farms to minimize the risk of contamination of covered produce from both domesticated and wild animals. It is important to understand that animals are a food safety concern because animals can carry human pathogens in their feces and can spread contamination around fields as they move. In a 2007 study done by research scientists at UC Davis, it was found that domesticated animals, due to their close proximity to humans as well as other wildlife, are more likely to harbor human pathogens.

Assessing Risk

When assessing risks associated with domesticated animals, you can begin to ask yourself the following questions: Are the animals allowed in the field while the crop is present or, are animals controlled so that they do not have access to fields and packing areas? Are production fields rotated into grazing land? Is there a chance for manure and runoff to enter the growing area? Do your animals have access to the water source used in the growing area? The photo below is a great depiction of zooming out from just the field to the whole farm and adjacent land to see what hazards from animals could create a risk to where your covered activities are taking place.

Photo: Will Suckow

What does the rule say in regards to domestic and working animals?

The FSMA PSR §112.134(a) requires that if those subject to the rule have domesticated animals, to prevent contamination of covered produce, food contact surfaces, areas used for a covered activity, agricultural water sources, or agricultural water distribution systems with animal waste, they must: 1) Adequately control their excreta and litter; and 2) Maintain a system for control of animal excreta and litter.

In addition, §112.32(b)(2) requires that any workers in direct contact with working animals take appropriate steps to minimize the likelihood of contamination of covered produce, and §112.32(b)(3)(v) requires thoroughly washing hands as soon as practical after touching animals or any waste of animal origin.

There are also rule provisions that come into play for what needs to be done if buildings on the farm are used for both produce activities and animals. §112.127 states that: (a) You must take reasonable precautions to prevent contamination of covered produce, food contact surfaces, and food-packing materials in fully enclosed buildings with known or reasonably foreseeable hazards from domesticated animals by: (1) Excluding domesticated animals from fully-enclosed buildings where covered produce, food contact surfaces, or food-packing material is exposed; or (2) Separating domesticated animals in a fully enclosed building from an area where a covered activity is conducted on covered produce by location, time, or partition. Additionally guard or guide dogs may be allowed in some areas of a fully enclosed building if the presence of the dogs is unlikely to result in contamination of produce, food contact surfaces, or food-packing materials.

Worker Training Considerations and Checklist

All workers that handle or contact covered produce or supervise covered activities must be trained. Workers are the front line of defense and are the ones who can identify animal intrusion events and the presence of feces that can contaminate produce and equipment. Workers who handle domesticated animals must be trained on the cross-contamination risks from feces on hands, clothing, shoes, and/or other equipment after handling animals or manure. One common practice is to have separate tools and footwear designated for activities that involve animals such as mucking stalls or feeding animals. Wearing dirty boots or not cleaning tools between uses can introduce contamination from the animals into produce fields or packing areas.

Training Checklist for Farms Working with Animals & Produce

• Recognize signs of animal intrusion in the produce growing area (feces, feeding damage, tracks, etc.)

• Monitor growing area for evidence of animal intrusion (feces, feeding damage, tracks, etc.)

• Do not harvest produce that is contaminated or likely to be contaminated by feces or other contaminants

• Maintain personal cleanliness during produce activities

• Wash hands after handling animal feces or any time hands may be contaminated

• Take appropriate steps to minimize the likelihood of contamination of covered produce when in direct contact with working animals

• Keep tools and equipment and/or clothing used for animals separated from produce activities OR add and cleaning step (sanitizing as necessary) between uses.

References

Jay, M.T., Cooley, M., Carychao, D., Wiscomb, G.W., Sweitzer, R.A., Crawford‐Miksza, L., Farrar, J.A., Lau, D.K., O'Connell, J., Millington, A., Asmundson, R.V., Atwill, E.R., & Mandrell, R.E. (2007). Escherichia coli O157:H7 in Feral Swine near Spinach Fields and Cattle, Central California Coast. Emerg Infect Dis, 13(12), 1908–1911.