Wildlife, Domesticated Animals, and Land Use

Managing wildlife does not mean eradication of all wildlife from your farm or that you should clear all of your land, fill in streams, ponds, or wetlands. On the contrary, destroying wildlife habitat and vegetation around field edges frequently exacerbates food safety risks. Farms covered by FSMA are only required to monitor for animal presence in their fields and take measures to prevent the harvest of contaminated produce; FSMA does not override any county, state, and federal laws, including the Endangered Species Act, that protect certain animals and habitat (§112.84). Contact the USDA Wildlife Services for help managing wildlife safely and legally.

Massachusetts Wildlife Services
463 West St.
Amherst, MA 01002
(413) 253-2403

Co-management is the best way to mitigate food safety risks posed by wildlife while limiting the environmental impacts of your actions. It is important, for example, to fully understand the potential wildlife carriers of food-borne pathogens in your area and the relative risks that each of those animals pose to your farm, so that you can take targeted action to control the animals that pose the biggest food safety threats. Lots of research has been done on what animal species carry which human pathogens and what wildlife management techniques are effective for different species. Two excellent resources, from the Wild Farm Alliance, that outline the importance of co-management and how to effectively deter wildlife from your fields are below.

• Farming with Food Safety and Conservation in Mind
• A Farmer’s Guide to Food Safety and Conservation: Facts, Tips, & Frequently Asked Questions

Monitor your fields throughout the growing season but especially immediately before harvest for evidence of animal intrusion—animal poop, feeding damage, animal tracks, etc. The frequency with which you monitor should be based on the crop in that field, your growing practices, the field conditions, and your past experiences with wildlife in that field. For example, it is less important to monitor a pepper field before the plants begin to fruit, and more important once the fruit has set. Farms covered by FSMA must monitor their fields throughout the season at self-determined frequencies and immediately before harvesting from any field (§112.83(b)(1)). Such farms should keep records of field inspections and any actions taken. See the “Pre-Harvest Assessment” section below for more information, including what to do if you find evidence of animal intrusion in your field. 

It's also important to monitor agricultural water sources on your farm for animal intrusion. Surface water sources are the most likely to become contaminated, and you should monitor the water for spikes in E. coli numbers. Check well heads regularly to ensure that they’re installed correctly. See our Agricultural Water page for more general information and FSMA regulations regarding water safety, including water testing and water system inspection recordkeeping templates.

If there is unusually high wildlife presence in a field, you may want to take action to deter them. See the Vertebrate Pest Management section of the New England Vegetable Management Guide for recommendations for different animals.

 

Livestock

The key tactics for managing worker-livestock interactions are frequent handwashing and designated barn boots and/or clothing that do not leave the animal barn. Workers in direct contact with animals should wash their hands after handling animals or animal waste, before leaving any animal enclosure, and before beginning any task involving produce.

Draft Animals

If you use draft animals you should minimize the risk of having them in your produce fields by not allowing them in fields when the harvestable portion of the crop is present. If working animals need to be present in a field when the harvestable portion of a crop is present, do the following to minimize the risk of contaminated produce being harvested:

• Use a route that minimizes contact.
• Have a plan for if the animal poops. The best plan is to establish no-harvest zones around the contaminated produce. See the “Pre-Harvest Assessment” section below for more information about no-harvest zones and suggestions for what to do with the poop.
• Train all employees to understand food safety risks of having working animals in the field, and what to do if an animal poops.
• Develop written SOPs for all practices

Pets

Pets should be kept out of produce fields and wash/pack buildings. Barn cats used for rodent control are included in this—you should implement other rodent control programs. Farm visitors should be clearly advised through signage or other communication to keep their pets at home. If you do have pets on the farm, make a plan for if they poop in a produce field or building, and make sure all farm employees are trained on what to do if that happens. See the “Pre-Harvest Assessment” for potential options.

When deciding whether to allow any animals (livestock, draft animals, service dogs, etc.) into a field, first assess the following:

• Role of animals in field: Is it necessary for animals to be in the field?
• Will the crop be present when the animals are in the field? It is less risky if no.
• Will the harvestable portion of the crop be present when the animals are in field? It is less risky if no.

FSMA and Domesticated Animals

The FSMA Produce Rule regulations for domesticated animals apply to pets, working animals, and livestock.

Workers must wash their hands “as soon as practical” after touching animals or animal waste (§112.32(b)).

If you have domesticated animals on your farm you must:

• Have an effective method of controlling animal excreta and litter that is implemented systemically across the farm. Your methods for controlling animal excrement must allow for proper disposal of the waste and prevent the contamination of harvested or growing produce, and all relevant workers should know how to safely dispose of the waste (what tools/equipment/vehicles to use, how to clean and sanitize tools afterwards, handwashing requirements, etc.) If you compost animal waste on your farm, you must ensure that the compost pile is maintained properly (§112.134(a)).
• Keep domesticated animals out of fully enclosed buildings where produce, food contact surfaces, or food-packing material is exposed, or separate the animals from the aforementioned produce/surfaces/materials by location, time, or partition (§112.127(a)).
• Guide and service dogs are allowed in fully-enclosed buildings if it is unlikely that they’ll contaminate produce, food contact surfaces, or food-packing material. This needs to be determined on a case-by-case basis, depending on many factors including how big the space is, how big the dog is, how likely it is that the dog is carrying contamination on its feet/fur/etc., and how well-behaved the dog is (§112.127(b)).
   

It is important to assess fields before you harvest out of them, to determine if the produce has been contaminated and to establish a plan to prevent the harvest of any contaminated produce. If your farm must comply with FSMA, you must do this (§112.112).

During each pre-harvest assessment, you should determine whether:

1. Fecal contamination is present, or if other signs of animal presence indicate risk. Contamination is not limited to feces from an animal in the field – it also includes runoff from manure on adjacent land, a spilled porta-potty, and other sources. Signs that indicate risk other than feces itself include animal tracks, trampling of produce, rooting, and feeding damage.
2. Produce has been contaminated and therefore cannot be harvested.
3. Steps are necessary to prevent the harvesting of contaminated food.
4. Harvest can safely proceed.

If you find contamination in your field, take these steps to prevent the harvest of any produce that may be contaminated.

1. Determine if no-harvest buffer zones around the contamination are sufficient to reduce the risk to allow harvest of the uncontaminated produce. Establishing no-harvest buffer zones around contamination is not required by FSMA but is an easy way to isolate contaminated produce and allow for the harvest of safe produce in the same field. Suggested no-harvest buffer zones vary from 0-25 foot radius, depending on the factors listed below, among others.

• Crop: is the edible portion of the plant touching the ground (e.g. lettuce)? Is it protected from above by foliage that will not be eaten (e.g. peppers)
• Weather: splashing rain, high wind and dry conditions
• Extensiveness: isolated area or spread throughout field?
• Consistency of poop: potential for runoff?
• Harvest equipment: hand tools can easily be maneuvered around a small buffer zone, but larger mechanized harvesting equipment may require a larger buffer zone 

2. Consider other solutions, for example, harvesting questionable produce for markets that include a processing step that will kill any harmful pathogens.
3. Decide what to do with the contamination. You can choose to remove or leave the feces in the field—both options have benefits and risks outlined below.

• Remove: Removing the contamination can be complicated because as people move the feces, there’s risk of people contacting the feces, and risk of spreading it further throughout the field. If you choose to do this, think about the path you use, and make sure you have washing and sanitation procedures in place for any equipment used and any people involved. It’s best to have separate tools designated for this.
• Leave: Flag the area and don’t harvest from that area for the rest of the season. This can be risky if you use overhead irrigation, because of splashing water. This is the best option if the crop will not be harvested again that season.

4. Document any notable actions taken. It’s not important to document every time you see a groundhog in your field, but if you see a flock of Canada geese in your field and have to flag off that section of the field and not harvest from it, keep a record of that.
    

It is important to assess food safety risks in fields when you are making land use decisions and before you plant crops into fields. Think about the following things and how they could pose contamination threats to produce in that field:

• Topography, wind patterns, water movement
• Previous uses of that land (grazing, landfills, manure applications)
• Impact of domesticated animals, other than above (e.g. do neighbors walk their dogs through the field, is the field in between a livestock barn and a pasture meaning that animals will be passing through?)
• Sewage systems or septic tanks: All sewage systems and septic tanks must be maintained in a way that prevents contamination of produce, food contact surfaces, buildings used to wash, store, or pack produce, and agricultural water sources and distribution systems. This specific point is included in the FSMA Produce Rule here: §112.131(b). 
• Relative locations of produce fields/packing areas and pastures and livestock barns (taking into consideration manure/urine runoff, your ability to control where the livestock graze)

Workers should be trained as needed on how to conduct pre-harvest assessments. Any worker who will be harvesting should be trained on farm policies around what to do if contamination is found in a field during harvest.

Recordkeeping for FSMA

To comply with FSMA, you must keep records of worker trainings (date, topics covered, and persons trained). See the Worker Health, Hygiene, and Training section for more information.

You should also keep records of:

• Pre-plant land assessments
• Monitoring for animal activity – log any major events
• Actions taken to reduce the risks related to animal intrusion into a crop
• Results of pre-harvest risk assessments: It is up to you to decide whether your farm should record every pre-harvest assessment or only if something major is discovered in a field during an assessment. If you harvest under relatively more risky conditions – for example with a rotating crew or with new crew members every other week – you may want to record the results of every assessment even if the field is clean, to help mitigate that risk.
• All actions taken to avoid harvesting contaminated produce

Animal Monitoring Log

Land Use Log