Farm Food Safety Plans & Traceability
Farm Food Safety Plans
Why Develop a Farm Food Safety Plan?
Compiling food safety documents such as risk assessments, SOPs, and recordkeeping logs into an easily accessible place can help you develop a comprehensive food safety plan on your farm. Not only can a farm food safety plan help you organize your records, it can also help you identify the practices or areas on your farm that pose the biggest food safety risks so that you can focus your limited time and resources on reducing the biggest risks first. An easily accessible, organized food safety plan will help prepare you for buyer questions or requirements, third party audits, and current and future food safety regulations. (See the “FSMA and Farm Food Safety Plans” section below for more information about regulations.) Additionally, creating a farm food safety plan will compel you to think through your processes and likely lead to improved systems and labor efficiency, which ultimately can increase profits.
Food Safety Personnel
While all employees on your farm should be trained to identify and mitigate food safety risks in their daily work, there should be one person—often the farm owner or a long-term manager—who is ultimately responsible for developing the food safety plan and overseeing food safety related activities on the farm, including ensuring that all records are completed correctly. The food safety point person should receive appropriate training and have awareness of all of the farm’s practices and the authority to make changes and delegate tasks as necessary to ensure that the food safety plan is adhered to. This person might meet with auditors or inspectors, deliver trainings to employees, and be the first contact in case of a food safety incident. It is also a good idea to have at least one back-up contact person who can support and fill in for the food safety point person.
What Should You Include in Your Farm Food Safety Plan?
A food safety plan does not need to be extensive and complicated—short and concise is better, in fact. Start small, and add to it as the season progresses or over a few years. A farm food safety plan is a living document that should be revised and added to over time. Similarly, you should remove outdated information and practices from your plan.
Set realistic goals for your operation. Develop practices and schedules you know you can follow. Don’t include practices in your plan that you wish you were doing—only include those that you actually are doing. It is much better to have a few practices outlined in your plan, with recordkeeping to show that the practices have been implemented and followed, than to have a stack of empty recordkeeping logs showing wishful thinking. Make sure that your employees have the appropriate time, tools, and training to follow the practices that you lay out in your plan.
Here are some things you should include in your farm food safety plan:
- Farm name and address
- Farm description (commodities grown, farm size, years in operation)
- Name and contact info for farm food safety manager
- Food safety risk assessment: see below for more information
- Corresponding practices to reduce risks: Standard Operating Procedures (SOPs) are an excellent way to write out instructions for risk reduction practices or any other procedure that has to be done the same way more than once on your farm. See our SOP Fact Sheet for more information.
- Records that document practices
Additional information that could also be included in a food safety plan:
- Farm maps
- Emergency contact information
- Supplier and buyer information
- Traceability and recall plans
- Contact info for contracted services
A 3-ring binder (or binders) can help you organize all of the parts of your plan, but you can use any filing system that work for you.
How to Develop a Farm Food Safety Plan
Step 1: Assess risks
Systematically think through farm practices and environmental conditions that could impact food safety. This can seem overwhelming—you can start by considering each of the five food safety areas that we have on our website: Agricultural water, Worker health, hygiene, & training, Post-harvest handling & sanitation, and Wildlife, domesticated animals, & land use. Each of the food safety topic pages includes more specific information about the hazards associated with these areas and assessing the particular risks these hazards might pose on your own farm. Think about each discrete location on your farm—fields, wash and pack facilities, irrigation sources, roads, etc. Write down all the food safety risks you can think of, then review and identify the biggest risks:
- Risks that are the most likely to occur, risks that could contaminate an entire crop
- Risks that are linked to previous outbreaks (not just on your farm)
- New or modified farm practices that may increase risks (like new employees, retrofitted equipment, or new suppliers)
Step 2: Develop practices to reduce risks
Again, start small, and focus on the biggest risks that you identified in step 1. Create a list of steps or tasks that need to be completed in order to reduce risk or establish new practices. Make sure you consider the resources you’ll need to successfully implement new practices (time, people, equipment/infrastructure, disposable supplies like soap, paper towels, etc.). Write SOPs as needed.
Develop a system for archiving records. Build recordkeeping into the daily flow of your farm so that it’s not forgotten and it doesn’t require extra time. If your farm food safety plan is electronic, one tactic can be to take a picture of a recordkeeping log daily, weekly, or on another regular schedule. Remember to back up the photos regularly if you do this.
If you’re not sure how to reduce a risk, ask for help!Lisa McKeag
UMass Extension Educator
Contact the MDAR Food Safety Team
Step 3: Document & revise
Document the steps you take or practices that you develop to reduce risk. Revise your plan if something isn’t working, or when practices change. At least annually, or anytime practices change, new employees are hired, or you obtain new equipment, review the entire plan with any relevant employees.
- Electronic or hard copy: Create your food safety plan in whatever format works best for your farm.
- Templates: Many different food safety plan templates exist. It can be helpful to have an existing document to work off of instead of starting from scratch. If you choose to work from a template, remember to make them your own – only include information that is applicable to your operation. Each farm’s food safety plan should be unique to that farm. The Produce Safety Alliance has a list of farm food safety plan writing resources with links to templates.
FSMA and Farm Food Safety Plans
While written farm food safety plans are not required by FSMA, in most states, the law will be enforced at the state level and each state may develop different mechanisms for enforcement. In Massachusetts, a farm food safety plan will be required for farms who must comply with FSMA or for any farm wishing to participate in the state’s voluntary audit program, CQP. Whether or not you are required to maintain one, a farm food safety plan can help show inspectors that you are complying with FSMA’s Produce Rule. If you choose to develop a food safety plan to facilitate your FSMA compliance, make sure that your plan includes what you are doing not what you wish you were doing. It is better to have a simple, truthful plan with records showing that you follow the plan than to have lots of empty recordkeeping logs.
Know your plan. If you are familiar with all of the parts of the plan and confident that your records are complete, you will be better able to answer an inspector or auditor’s questions and the process of going over the plan may take less time.
Traceability is the ability to track your produce one step forward and one step back—where did a specific case of produce come from on your farm, and to whom did you sell it? Traceability is very important for minimizing the impacts of contaminated produce, but is also useful for tracking produce quality after a buyer complaint or tracking sales from different market types.
Food distribution systems can be very simple, like CSAs, or very complex, with multiple steps between growers and consumers. Creating a traceability plan for your farm does not mean you need to be prepared to track produce all the way to the individual consumer. You are not responsible for the entire food distribution system that they are a part of, but you should be able to trace your product one step back and one step forward and at least know into which market the food was sold.
Developing a Traceability Program
- Define a “Lot”
Tracking produce requires the definition of a “lot”, or a distinct and limited portion of a crop. You can determine the exact definition and size of a lot on your farm—it may vary by crop or by field. A common example of a lot is all of the same commodity harvested on the same day from the same field. Lots can be defined more or less broadly, resulting in larger or smaller lot sizes. Bigger lots may be more difficult to recall, as parts of one big lot may be distributed to many buyers; bigger lots may also result in recalling more produce if you can’t pinpoint which produce was contaminated. Smaller lots require more specific recordkeeping but may allow for smaller, more specific recalls. If different commodities or produce from different fields are being washed and packed using common equipment, you should establish “clean breaks”, or breaks in activity for tools and equipment to be cleaned and sanitized so that you can be confident that a new lot is likely to be contacting pathogen-free equipment.
- Establish Lot Codes
Once a “lot” is defined, you need to develop a system for lot coding. Lot codes should be a unique code for the identifying characteristics of a lot—for example, the crop and variety name, field or block of origin, and the harvest and packing date. Codes can be a series of numbers, letters, and can even include a color code. Many growers prefer to use Julian dates (day 1, being January 1, through day 365), which allow for a 3-digit date code that is not easily recognized by consumers. Buyers sometimes request specific lot code formats. Lot codes should be attached to their appropriate lot, for example with a sticker or stamp, and should be on any accompanying documentation.
Information that could be included in a lot code:
- Farm name
- Field/block of origin
- Inputs applied
- Harvest date
- Harvest crew
- Packinghouse used
- Packing date
- Packing crew
- Conduct a Mock Recall
Once you have a product tracing system in place, you should test your system by conducting a mock recall. Mock recalls are required by the Commonwealth Quality Program and USDA-GAP and can also be initiated by buyers. To conduct a mock recall:
- Select a lot code for produce that has been sold.
- Call a buyer that received some or all of the lot.
- Tell them that you’re conducting a MOCK recall.
- Ask how much of the product is in stock and how much has been sold. Document the response.
- Trace the lot in your records (field of origin, harvest/packing crew, spray records, soil amendment applications, etc.)
- Can you trace the lot backwards and forwards? If you can, good. If you can’t, figure out what’s missing and fix it. Document the results of the mock recall either way.
Traceability and FSMA
Traceability plans are not required by the FSMA Produce Rule, but may be included in future versions of the law. Additionally, mock recalls can be initiated by buyers and you may lose business if you can’t track your produce backwards.