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Produce Safety Educators Call #40 September 30, 2019

Total Attendees: 76
Audio recording
Presenters: Sara Runkel, Assistant Professor of Practice, Horticulture, Oregon State University Extension and Tucker Diego, Agricultural Production Specialist, Vermont Agency of Agriculture, Food & Markets
Organizer: Dr. Don Stoeckel, Midwest Extension Associate
Topic: Module 3 – Soil Amendments

I. Meeting Notes:
The presenters alternated delivery of informational slides for this presentation, highlighting key components of the module and challenging concepts throughout the presentation.

  • Structure of Module 3 – flow of slides covers risk assessment, implementation of practices, monitoring and recordkeeping, corrective actions
  • Recent meeting at the FSMA North Central Region BSAAO Workshop - Sept. 11-12, Altoona & Ames, IA
    • Discussion included highlights from Iowa compost facility – even larger and well-run operations have challenges keeping feed stock and finished product clearly separated. Some concerns with storage & re-contamination; equipment used were not cleaned at all or infrequently; commercial composting facilities may struggle to meet PSR standards, but are not regulated by PSR. This emphasized the challenge for farms that are covered by PSR standards.
    • Reminder that untreated BSAAOs, or treated BSAAOs that do not meet 112.54(a), cannot be used on covered root crops (see draft guidance p 68); this may be a difficult and sensitive issue to broach with course attendees.
  • Concepts and approaches for engagement – Oregon hands out GMP mini handbook. It is very helpful to identify which soil amendments the audience uses to tailor examples and not belabor requirements that do not apply to them; use humor; use real world examples (e.g., draft guidance).
  • 3 Key Questions to cover at the beginning of the module:
  • Is it a BSAAO?
  • Is it treated?
  • How is it applied?
  • Key to Module is Being Familiar with Definitions as outlined in PSR
    • Can incorporate activities such as Bingo or reading definitions out loud during training to familiarize participants.
  • Less common soil amendments – examples discussed during the presentation included agricultural teas and its specific definition, foliar application vs. soil drench (foliar applied is water, soil drench is BSAAO), use of amendments in potting mix for plant starts rather than in the field. Presenters also note for trainers that worm castings are considered a BSAAO.
  • Inspectional Approach – from draft guidance, steps 2 & 3. This order does not flow the same when you are on the farm. Alternative flow that might be used by an inspector while observing the farm activities - check definition; when, where, how, and on what crops is the amendment applied to; what restrictions apply, based on use; should it be treated; is it practical for the grower; storage & handling practices. By using this flow, the emphasis is on how the BSAAO is used rather than on what level of treatment was achieved.  Many farms use treated and untreated BSAAO the same, within PSR requirements for untreated, so the inspector (and farmer) doesn’t even have to worry about whether the treatment conditions were met and documented.  Reference table from the PSR 112.56 for treatment options and application intervals.
    • Note: The standard of treatment under 112.54(a) is no detect of the three pathogens.  The standard of 112.54(b) is no detect Salmonella, less than 1000 fecal coliforms per gram.  Typical composting meets the standard of 112.54(b) but not 112.54(a).
  • Worker training & reducing risk – no specific training requirements for handling BSAAOs, but there are general training requirements for anyone who handles covered produce or is in contact with food contact surfaces. Workers also must be trained on the duties required for their job.
  • Application, handling, and storage – need to think about potential risks and how to mitigate them. There are many options to manage application, handling, and storage depending on the farm’s resources, composting system, and type of soil amendment.
  • Where should I go with questions? State’s Inspection Agency, PSA, Local Food Safety Collaborative, Indigenous Food and Agriculture Initiative (IFAI), FSMA Regional Centers, FDA Produce Safety Network. It is important to know what the regulatory perspective may be within your state.
    • Use the draft guidance as a resource – helps to describe what FDA means by ‘minimize the potential for contact’.  
    • Ask around for resources on specific topics (validation studies for composted mushroom substrate, fish hydrolysate/emulsion, validation of vermicomposting).
    • Connect with regional commercial BSAAO suppliers.

Question & Answer

Q: For argument’s sake, what risk is attributed to a grower adding raw manure to a potting mix for vegetable transplants. One scenario is with tomato and the other is lettuce (45 day maturity). How do you address a grower questioning the risk potential?
A: Reference the table in the PSR. With tomato, fruit will not likely come into contact.  Lettuce, if it does not contact covered produce during application and minimizes contact after application the application interval is reserved.  Likely to be lower risk, but may depend on type of lettuce, harvest practices (multiple harvests vs. head lettuce). Gray area, depends on situation.

Q: Can someone discuss whey, which is from an animal, but doesn't contain any of the pathogens that are of concern, to my knowledge? Does anyone know the logic or science behind risk assumption?
Follow up: Is the whey pasteurized? Yes, comes directly from dairy plant and onto truck for field and foliar application.
A: Concern might be storage or handling of whey. FDA has not yet provided guidance saying pasteurization (under the right operating conditions) is a 112.54(a) treatment but someone may be able to dredge up the data or studies showing that it is.

Q: If agricultural teas are applied to foliage, then is it not considered a soil amendment?
A: If it is not applied to the soil, then it is not considered a soil amendment. This was discussed at the workshop in Iowa. Dave Ingram – spoke extensively at workshop; ag teas don’t have enough nutrient for feeding as a soil amendment, but often used as pest control through direct foliar application. Enforcement discretion on ag water (Subpart E) until 2022. Whey may fall under Subpart F as a BSAAO. Documentation would be needed to demonstrate that the whey was a treated BSAAO (e.g., document that pasteurization is a scientifically validated, controlled process that meets a set of standards in 112.55).

Clarification on BSAAOs and root crops:
With how the regulation is currently written, if you use raw manure, you can never grow root crops in that manure-amended field. FDA recognizes that this is untenable and is working to address this in guidance. The risk assessment that FDA is conducting may help address some of these issues. A publication is in the pipelines (to be released in the next few months) that will describe a model and fate of pathogens in the soil. The risk assessment hinges on first 10-15 days after incorporation of a BSAAO.

Comment: As someone who teaches lots of smaller growers who use compost, I’m wondering if there are techniques or strategies for not letting this derail or really alienate compost growers. This used to be a fairly easy conversation when we were just saying that well-made compost had a 0 day application interval, but now that we see that using farm made compost would be impossible on root crops… and that it will be difficult for even large compost operations to comply.
Response: This is, indeed, is tricky territory to navigate during Grower Training Courses and we look forward to the guidance to be updated by FDA so we can address it more effectively.


Next Call: Two Part Series!

Tribal Culture
November 4, 2019 - 2-3:30 PM Eastern, Call #41
Speaker: Roylene Comes-At-Night, Washington State Conservationist and Deputy Equal Opportunity Officer

Eight Fascinating Cases Impacting Indians and Tribes
November 25, 2019 - 2-3:30 PM Eastern, Call #42
Speaker: Stephen Pevar, Senior Staff Counsel - American Civil Liberties Union

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