Module 7:
How to Develop A
Farm Food Safety Plan
Learning Objectives
• Name the essential parts of a Farm Food Safety Plan
• Describe why one qualified person should be
designated as the person responsible for the Farm
Food Safety Plan on every farm
• Conduct a risk assessment of the farm’s practices
and environment
• Describe management steps and practices
to reduce risks
• List key steps involved in developing a traceability
system including establishing lots and clean breaks
• Identify resources available to assist in developing
a Farm Food Safety Plan
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Farm Food Safety Plans
• The FSMA Produce Safety Rule does NOT require a
written Farm Food Safety Plan
• However, writing a Farm Food Safety Plan was
identified by PSA Working Committees as a critical
component to implementing produce safety
practices effectively
• This module will outline considerations when writing
a Farm Food Safety Plan by incorporating both GAPs
and FSMA Produce Safety Rule requirements
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Reasons for a Farm Food Safety Plan
1. Gets you organized and focused on food safety
• Describes risks you have identified and actions to
address those risks
• Defines your practices, policies, and SOPs
• Efficient and effective use of your time and resources
by prioritizing most important risk reduction steps
2. Best way to be prepared!
• Buyer questions/requirements
• Third party audits
• Food safety regulations
Food Safety Plan
▪Policies: What to do
▪Procedures: How
▪Records: Proof of what
and when
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YOU Can Identify and Reduce Risks!
• Each farm is unique
– Practices to reduce risks
will be specific to your farm
– Best done by someone who knows
the farm and how it operates
• Each commodity is different
– Grows on the ground or in trees
– Harvest by hand or by machine
– Single vs. multiple harvests
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Who Is YOUR Food Safety Person?
• Each farm should have one person to lead
the development of the Farm Food Safety Plan
– Will be supported by others on the farm
– May need a back-up in case the person is unavailable
• Should have food safety training and experience
to know how to assess risks and develop a plan
• Should have the authority to make necessary changes and
invest in resources to reduce risks
• Must make sure the plan is implemented
• Should be willing to be the farm food safety contact
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Knowledge Is Your Friend!
• Writing a plan can be difficult –
begin with information you know
– Start with your general farm
information and what you do
• Some basic food safety knowledge is key!
– Assessing risks requires understanding risks and this
requires knowledge and information
– For many growers, preparing a detailed, written Farm
Food Safety Plan may be a new practice
• There are many resources available to help
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Farm Food Safety Plan Parts
• Farm name and address
• Farm description
– Commodities grown, farm size, etc.
• Name and contact information for
farm food safety manager
• Risk assessment of practices and environmental
conditions on your farm that impact food safety
• Practices to reduce food safety risks
• Records that document practices
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• Farm maps
• Farm policies
• SOPs
• Training records
• Agricultural water test results
• Emergency contact information
• Supplier and buyer information
• Traceability and recall plans
• Contact info for contracted services
Other Items to Include In Your
Farm Food Safety Plan
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Farm Mapping
Main farm site and one for each non-contiguous field site
Be sure to locate and identify on the map:
• production areas (labeled according to traceback scheme)
• field packing, and staging areas
• field sanitation units
• active wells
• surface water sources
• regular or recent flooding areas
• manure or compost or chemical fertilizer storage sites
• septic systems
• any important residential/commercial/
other facilities adjacent to farm, such as sewage treatment
sites, landfills, dairy or animal farms, etc.
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Step 1: Assessing Risks
• Identify risks that are most likely to occur, noting the
ones that could happen often
– Because time and money are limited, prioritize which risks
to address first
• Review all farm operations to
identify practices that contribute
to or increase produce safety risks
• Review the farm environment and adjacent land
• Focus on microbial, chemical, and physical risks
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Ranking Your Risks
• Risks that can lead to whole crop contamination
• Risks that have caused previous outbreaks
– e.g., Contamination from postharvest water, wildlife fecal
contamination
• New or modified farm production practices that may
increase risks
– e.g., Hiring new people, changing processes, retrofitting
equipment, changing suppliers
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Step 2: Develop Practices to
Reduce Risks
• Develop practices that will reduce identified risks
– Use resources and ask for help if you are not sure!
• Know what resources are required to successfully
implement practices
– Human resources (time and/or people)
– Equipment or infrastructure (may require changes/upgrades)
– Disposables (hand soap, paper towels, etc.)
• Create a list of tasks/steps that need to be done
• Designate a person(s) to be in charge of each task
Risk Assessment
Map out your process
Field
Production
Harvest Packing Storage
Adjacent Land
Irrigation water –
source and type
Animals
Soil inputs
People
Animals
Equipment –
cleaning
sanitation
Containers
Workers
Equipment
Facility
Pests
Water
Packaging
Temperature
Facility
Sanitation
Worker
Other
products?
Adapted from presentation by Jim
Gormy 3/2014 workshop: ”Local
Grower Food Safety”
Risk Assessment: Lay out a plan
▪ Questions to ask:
⚫ Are there potential sources of pathogens?
⚫ Could they get on or in your fruits or
vegetables?
⚫ What can you do to help manage or prevent
these risks?
▪ Good risk assessment leads to
good risk management!
Adapted from presentation by Jim Gormy 3/2014 workshop:
”Local Grower Food Safety”
Risk Assessment:
What should you be considering?
▪ Risk/Hazard
▪ Type of Contamination (e.g. bacteria type)
▪ Significance – Is it high or low?
▪ Risk Management Practices – what are you
going to do to minimize risk
▪ How are you going to measure the practice and
how often?
▪ Verify and record
▪ Anything new? Field? Commodity? Equipment?
Adapted from presentation by Jim Gormy 3/2014 workshop: ”Local Grower Food Safety
Risk Management Scheme:
Soil amendment Use
Risk/Hazard: Compost Use
Contamination: E. coli 0157:H7, Salmonella
Significance: High
Practice: 1) Purchase from vendors with
validated process
2) Validate own process if on-farm
(turns, temperature etc.)
3) Storage so no recontamination
What needed? 1) Certificate of Analysis each lot and log
2a) Temperature/Time over process and log
2b) Pathogen testing and log
3) Inspect piles and log
Adapted from presentation by
Jim Gormy 3/2014 workshop:
”Local Grower Food Safety
Risk Management Scheme:
Domestic Animals
Risk/Hazard:
Contamination:
Significance:
Practice:
What needed?
Domestic animals
E.Coli 0157:H7, Salmonella
High
1) Fences
2) Location down from produce
3) Ditch to prevent run off
4) Buffer zones
5) Do they have to be there
Visual inspection – weekly and log
Testing when needed
Risk Management Scheme:
Workers and Hygiene
Risk/Hazard:
Contamination:
Significance:
Practice:
What needed?
Restroom
Cross-contamination with E.Coli
0157:H7, Salmonella, viruses
High
1) Worker Training
2) Sanitation procedures
3) Location
4) Paper towels/toilet paper
5) Soap, water
Visual inspection – daily, 3 times a
day, logs
Adapted from presentation by Jim Gormy 3/2014 workshop: ”Local Grower Food
Safety
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Step 3: Document and Revise
• Write a plan to guide implementation of practices
• SOPs and policies will outline what needs to be done
for those who are responsible for completing the task
• Build recordkeeping into the logical flow of activities
• Revise your plan if it is not working or when practices
change
• Review and update your plan at least annually, or
whenever practices, personnel, or equipment changes
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Educational Resources
• There are many educational resources available to
help you write a Farm Food Safety Plan
• Resources are available through:
– Land grant institutions and extension programs
– Industry or commodity specific guidance
– Produce trade associations
– Federal guidance
– Independent organizations
• A list of educational resources are provided in your
training materials
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Food Safety Plan Writing Resources:
Be sure to make them your own!
• There are many available resources, including
templates – pick which one works best for you
• Tailor templates to meet YOUR needs
• Template plans, recordkeeping logs, and SOPs give
you someplace to start and are easier than building
the plan from scratch
• Be sure to make it your own, so you know what is
in the plan and that it will work for you
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A Few Thoughts About Your Plan…
• Only include practices you are doing on YOUR farm
• Do NOT include things you wish you were doing
• Does not need to be long or complicated
• Pick practices and schedules you know you can do
• Focus on risk reduction!
Food Safety Plan
▪ Your grower information
⚫ Who are you?
⚫ Crops you grown, and site location
⚫ Person(s) responsible at your farm
⚫ Water source for your farm
⚫ Type of soil
amendments/handling/storage that you
use
⚫ Facilities available for your operation
Food Safety Plan
▪ What are you going to do? What is
your policy?
▪ How are you going to do it?
⚫ Analysis
⚫ Training
⚫ Treatments
▪ How often are you going to do it?
▪ What records are you keeping?
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You have written your plan, your
practices are in place, records
are being kept, and delicious,
high quality, safe produce is
being grown and packed.
So now what?
TRACEABILITY
Final Steps
Farm
Buyer
Consumer
PRODUCT IDENTIFICATION
Traceability
Who am I?
Where do I belong?
Where have I been?
Where have I gone?
Traceability: ability to follow movement of food through
production, processing and distribution
Traceback
▪ Ability to track food through the food system
back to their source and forward to the next
destination
▪ DOES NOT prevent a foodborne outbreak
▪ CAN quickly identify the source of a product
and speed an investigation
▪ CAN limit damage to the consumer
▪ CAN prevent damage to the innocent grower
Penn State Extension 2012
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The Value of Traceability
• Following quality
– Identifying boxes that have quality issues
• Keeping track of amount sold
– Knowing what sold well and how much money you should
be making
• Minimizing foodborne illness impacts
– Recalling a contaminated load/lot/bin
– Knowing how much was sold and in the marketplace
– Knowing who may have purchased/consumed it
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Product Tracing:
One Step Forward, One Step Back
• Traceability means identifying where the produce
came from including inputs (one step back) and
where it went (one step forward)
• For growers, this means knowing the field where it
was grown (step back) and the buyer (step forward)
• This does not mean you are
responsible for the entire system,
especially if there are multiple
steps to the consumer
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Understanding a “Lot”
• Product tracing requires defining and following a
distinct portion of the crop. This is called a lot.
• A lot is a distinct and limited portion of a crop
– e.g., all of the same commodity harvested on the same day
from the same field
– It may require establishing a ‘clean break’
• Difficult issue: How big should the lot be?
– If there is a problem, the whole lot
will be recalled, so the bigger the lot,
the bigger the recall
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Developing a Lot Code
• Can be numbers or letters, or a combination of both
(alpha-numeric)
• Should identify specific details about the lot
– Farm, field of origin, harvest date, and more
• Should be unique to a specific lot
• Should follow the lot
– Attached with a label, stamp, or sticker
to the sellable container (such as a box)
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Steps to Developing a Lot Code
• To begin developing a lot code, growers should
identify:
– Field locations
– Commodities and varieties
grown
– A method for indicating
harvest and/or pack date
– Harvest/packing crews
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2
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How to make your products traceable
Step 1 - Map field production areas
Penn State Extension 2012
Field #1
Field #2
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A Lot Code Could Identify
• Commodity including type
(e.g., Empire apples)
• Farm/field/block of origin
• Agricultural inputs applied
• Harvest date
• Harvest crew
• Packinghouse used (if any)
• Packing date (if different from harvest date)
• Packing crew (if different from harvest crew)
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Traceability Example
Farm Location: 10
(Rose Farm)
Block: 01
Fruit Type: 01 (Apples)
Variety: 05 (Empire)
Harvest Date: 284
(Julian date)
Traceback: Finding the Source
▪ Traceback is the ability to identify the source
of a product—important if a foodborne
disease outbreak occurs and you need to find
out where the food came from
▪ A good traceback system can:
⚫ Protect you from false association with an
outbreak
⚫ Minimize consumer anxiety and bad
publicity
⚫ Give you a competitive advantage
Traceback: Summary
▪ At the minimum, you should identify your product with
• Date of harvest and/or date of packing
• Farm identification
▪ Document your handling chain from the farm to your
distributor/customer
▪ Document all aspects of your packinghouse
operations
▪ Get help from industry trade groups for
information on coding, labeling and tools
available to make the job easier
▪ Write an SOP
RECALL PROGRAM
BE PREPARED
Class I: Reasonable public health hazard for illness or death
Class II: Remote probability of adverse health consequences
Class III: Will not cause adverse health consequence
FDA Recalls are Mandatory
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• Each container/lot leaving the
farm should be identifiable
• Attaching the lot code to the lot
– Many ways to get it done
– Stickers, stamps, bar codes
– Boxes, clamshells, or individual pieces
• Determine the best system for your farm
– Size, markets, costs, infrastructure
– Electronic or paper
Labeling
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“Must prominently and conspicuously display, at the
point of purchase, the name and complete business
address of the farm where the produce was grown, on
a label, poster, sign, placard…”
Labeling: FSMA Modified Requirements
for Growers Who May Be Exempt
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Testing Your Traceability System:
Conducting a Mock Recall
• Steps in a mock recall
1. Select a lot code for produce that has been sold
2. Call a buyer that received some or all of the lot
3. Tell them you are conducting a MOCK recall
4. Ask how much of the product is in stock and how much
has been sold. Document the response.
5. Trace the lot in your records
(e.g., field of origin, harvest crew, spray records)
6. Can you trace it backward and forward? Yes, good!
No, figure out the problem. Either way, document it!
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Summary
• The best person to write the plan is someone who knows
the farm and has food safety knowledge
• Identify someone to be in charge of food safety
• Farm Food Safety Plans should include assessing risks, any
actions taken to reduce risks, and recordkeeping
• Simple is best: write what you do, not what you hope to do
• Traceability = one step forward and one step back,
as well as inputs to the crop throughout production
• Establishing lots, lot codes, and labeling are necessary for
developing a traceability system
• Finally, follow the plan and update as necessary
