The birds and the… bats?
- 4 days ago
- 3 min read
There are many ways to increase wildlife and pollinator habitat on your farm. But what does that mean for food safety?
I appreciate bats, but I like to keep a distance. That’s because I grew up in an old farmhouse. The worst is when they’re there, and then you never find them again. Where are they hiding? Are they still inside? So much paranoia!
But lately, when it comes to conservation and regenerative agriculture, folks are discussing ways to close that distance.
When it comes to birds and bats, they are a crucial part of the ecosystem. Not only are bats an important pollinator, but both creatures serve as biological pest management by eating harmful insects. You can provide habitat for these lil’ guys by enhancing forests on your land, establishing plants that attract insects (which create a big ‘ol serving platter for bats & birds), or by building houses (Source).
Not only is the conservation-regenerative-agriculture conversation shedding light on these practices, but so are some audits. Specifically, the newest IPM chapter (Module 9) of PRIMUSGFS, which some buyers are inquiring about.
So, what does this mean for food safety?
When it comes to the FSMA Produce Safety Rule (PSR), which is the minimum set of food safety standards for folks who grow, harvest, pack, and hold fresh produce, it depends! The FDA does not have the authority to authorize the taking, killing, etc. of endangered species, even if such animals are causing harm to the product or present food safety risks.
Instead, your responsibility is to acknowledge the risk of creating wildlife habitat and that you must take steps 1) immediately prior 2) during harvest and 3) as needed during the growing season to identify and not harvest produce that is likely to be contaminated” (CFR §112.112 + §112.83(b)(1)). If there are any related or additional issues, your team must also know who to notify about it.
This means that worker training is essential— which includes initial training and monitoring to make sure pre-harvest assessments are properly executed, and that any corrective actions are taken as needed. Personally, I think monitoring is the highest bang-for-your-buck part of training. As someone who has worked on produce farms, as well as shadowed during inspections, it’s a waste of time (and $) to train folks but then not make sure your policies are being followed, as risky practices tend to follow.
For example, I was once on a farm that stacked carrots in their cold room, which was wet since they don’t want the carrots to shrink. They stacked the carrots right underneath the condenser, which had the largest condensation droplets I’ve ever seen hanging right above the product. The farm manager was made aware of the importance of immediately fixing this issue, especially since they have an inspection the following week.
The day of the inspection, there were no changes to how the carrots were stored in this cold room. The inspector walks in and is immediately alarmed by the condensation, as it is a major Listeria concern (Listeria is nasty, folks). So, either the farm manager did not re-train their employees, or the person stacking the cold room that day was not monitored during or after the task to make sure it was done properly (especially on inspection day). There was a potential seizure of produce due to the severe Listeria risk.
Lessons learned: lack of monitoring = high risk practices = produce is disposed or people get sick = time and $ is lost. Invest in your team! They are your front lines of defense.
Worker training and related records are also an essential part of other food safety programs. But when it comes to bird and bat habitat within a USDA GAP program, the standard is that bird + bat houses can be on the outsides of the orchard, but not directly in the tree rows within the orchard. For PRIMUSGFS, they are not as specific in location, but you must acknowledge your practices in the risk assessment, and all the mitigation procedures you have in place to reduce those risks.
Ultimately, if you’re thinking about establishing bird or bat houses or habitat on your operation, there is nothing telling you that you can’t do it. However, if you do, there are some management practices that come with it (like everything else). You can absolutely establish wildlife habitat on your produce farm, but doing so requires some intention and follow-through— especially when it comes to pre-harvest assessments and worker training.
