Worker Health, Hygiene, and Training

At least one person from your farm is required to receive comprehensive food safety training and to be responsible for rolling out and enforcing FSMA compliance on your farm. This person will be responsible for training the rest of your employees in general food safety principles and specific practices that reduce food safety risks on your farm. This food safety training follows the person, not the farm, so if the employee who is trained leaves your farm, another employee will need to be trained in their place.

The Produce Safety Alliance Grower Training is one way to satisfy this requirement. Food safety trainings will be held annually in Massachusetts. Upcoming Massachusetts trainings will be posted on the UMass Vegetable Extension Upcoming Events page. Produce Safety Alliance trainings outside of Massachusetts are listed on the Produce Safety Alliance website.

As stated above, all other farm employees (anyone who handles covered produce or supervise others handling covered produce) must be trained by someone who has attended a comprehensive food safety training (for example, the Produce Safety Alliance Grower Training). All of the information below applies to training farm employees on general food safety principles and specific food safety practices on your farm.

Worker trainings must be:

1. Customized to each employee’s job. For example, an employee who works solely in the wash/packroom will need different training than someone who is principally a tractor operator.
2. Conducted upon hiring, and then repeated at least annually, or if a problem arises.
3. Easily understood. Trainings must be given in a language that the employee can fully understand. When creating training material, remember that people have various levels of literacy; if you don’t know the literacy levels of your employees, create training material that relies on verbal and graphic communication rather than written.

Training content must include:

1. Principles of food hygiene and food safety. This should include the basic microbiology of food safety – what kinds of microorganisms are involved and under what conditions does each survive, and reproduce – how contamination spreads, and how it relates to your farm. The Worker Health, Hygiene, and Training section of the Produce Safety Alliance (PSA) Grower Manual outlines these principles and can be used for employee training. All PSA training attendees receive this manual. It is also available on the PSA website, but remember that if your farm has to comply with FSMA, at least one person from your farm needs to attend a food safety training.
   Other resources:
   The Bad Bug Book
2. Symptoms of foodborne illness, including fever, vomiting, diarrhea.  Jaundice--the yellowing of skin or eyes--is a common symptom of hepatitis A. If employees observe any of these symptoms in themselves or a coworker, the affected person should stop handling produce immediately and notify their supervisor.
3. The importance of personal hygiene for all personnel and visitors. The better employees understand the importance of hygiene for the sake of food safety, the easier it will be for them to adhere to farm policies regarding personal hygiene.
4. Any other food safety topics that are relevant to any given employee. For example, wash/packroom workers should be trained on postharvest water procedures and rules, and tractor operators should be trained on how to safely apply raw manure fertilizer.

Workers who harvest produce must receive training that includes:

1. Recognizing un-harvestable produce. Produce that should never be harvested includes visibly contaminated (don’t harvest the fruit with the poop on it, folks!) and dropped produce. Dropped produce does not include root crops, crops that grow on the ground (e.g. cantaloupes), or produce that is intentionally dropped to the ground as part of harvest (e.g. almonds, ground cherries).
2. Inspecting harvest containers. Before harvesting into any container, workers should ensure that they are functional, clean, and haven’t been contaminated.
3. Protocol for dealing with problems with harvest equipment. All harvesters should know what needs to happen if there is a problem with harvest containers, tractors, implements, or vehicles. This can be as detailed as training all harvesters on how to fix relevant equipment, or as simple as requiring workers to report problems to a supervisor who knows how to fix it.

Recordkeeping

You must keep documentation of the date, the topics covered, and the individuals trained for any trainings conducted on your farm. Use the template provided below to record the following for each training:

Worker Training Log

Where can I find this information within the FSMA Produce Rule?

Subpart C – Personnel Qualifications and Training

All workers must:

• Maintain personal cleanliness. 
• Avoid contact with non-working animals.
• Notify their supervisor if they are sick. In this case, alerting workers of this rule is only half of the job. Make sure that you, and any supervisors that workers report to, are accessible and understanding so that workers feel comfortable letting you know if they are sick and need to be reassigned or stay home. FSMA does not require sick workers to go home, but they cannot work directly in contact with covered produce.

Remember that labor laws also apply to worker health. Employees must be allowed to earn up to 40 hours of sick time each year, under Massachusetts state law. Employees earn sick time at a rate of 1 hour for every 30 hours worked. If a farm has an average of 11 or more employees per pay period over the course of the year (including seasonal, part-time, and temporary employees), sick time must be paid. For other farms, sick time may be unpaid.

• Not eat, chew gum, or use tobacco products in harvest or wash/pack areas. OSHA requires that potable water be provided to and be readily accessible to workers, and drinking is allowed in harvest or wash/pack areas. Break areas for eating must be a designated area – this doesn’t need to be a separate room or building, but can be as simple as an area under a tree or one corner of a barn.
• Remove or cover hand jewelry that can’t be sanitized.
• Wash their hands, even if they are using gloves or hand sanitizer,
  • After using the toilet
  • Before starting/returning to work
  • Before and after eating or smoking
  • Before putting on gloves
  • After touching animals or animal waste
  • After any other time contamination is possible

Farm employees are not required to use gloves (fabric or plastic), but if they do, they must change them regularly to keep them clean and intact. In general, you should make sure that the gloves are not potential sources of contamination. Farm workers may use gloves for two main reasons: to protect their hands, or to protect produce. It’s easy to get into the mindset that gloved hands are always clean hands, but gloves that have been used to protect your hands (from dirt, pesticides, tractor grease, tomato residue, etc.) can contaminate produce if those dirty gloves are then used to handle clean produce. If workers are using gloves to help protect produce from potential contaminants on their hands, it is important that they only touch clean surfaces with their gloved hands while handling produce – otherwise the gloves are obsolete. Plastic and cloth gloves are difficult to clean, so make sure that employees change their gloves frequently, especially when switching between tasks. Fabric gloves used to polish produce should be washed regularly, or, if that is not possible, they should not be used.

One of the simplest ways to enforce hygiene rules is by example. If your employees regularly see you following the rules you set for the farm, they will be more likely to follow the rules themselves, and vice versa!

Toilets & Handwashing Station Requirements

Both FSMA and OSHA contain toilet and handwashing station requirements for farms. Peeing and pooping is never allowed in the field, so make sure your employees have close, easy access to restrooms whenever they may need it. You must have one toilet and handwashing facility per 20 workers within a ¼ mile or 5 minutes of the workers at all times. The facility must be your own and not belong to another business (for example, a coffee shop restroom does not count), as you need to be sure that the facility is available at all times and that you have cleaning and maintenance authority over it.

Toilet facilities must:

• Be readily accessible to workers during harvest
• Be placed in an area where they don’t pose potential risks to crops, packing areas, water sources or distribution systems, or any other food-contact surfaces. There is no minimum distance from crops, but keep in mind worst-case scenerios when placing toilet facilities – remember, portapotties can tip over and spill!
• Be kept clean and stocked, either by you or by a company. If you have a company clean and stock your toilet facilities, remember that you can always contact them to request more frequent maintenance if needed.
• Provide for the sanitary disposal of waste and toilet paper
• Be located close enough to a handwashing facility so that visitors and employees who use the toilet can was their hands

Consider using the posters below to ensure that all employees understand toilet sanitary practices:

Toilet Use Poster
Toilet Paper Use Poster

Handwashing facilities must:

• Have soap, running water, and drying capacity (single-use paper towels, electric dryers, sanitary towel service). Hand sanitizer cannot replace a handwashing station.
• Provide for appropriate disposal of waste water and dirty towels

Workers must wash their hands, even if using gloves or using hand sanitizer,

• After using the toilet
• Before starting/returning to work
• Before and after eating or smoking
• Before putting on gloves
• After touching animals or animal waste
• After any other time contamination is possible

Resources:

• Toilet and Handwashing Facilities Maintenance Log
• Handwashing Units: An Overview of Units for Small- to Large-Scale Agricultural Operations
• How to build a field handwashing station in 10 easy steps for under $20
• Washing Away Misconceptions About Gloves and Handwashing
• Food Safety - It's In Your Hands
• Handwashing Poster

 

Where can I find this information within the FSMA Produce Rule?

• Worker hygiene requirements: §112.32(b)
• Notifying supervisor if sick: §112.31(b)(2)
• Where can employees work if they are sick? §112.31(b)(1)
• When do workers need to wash their hands? §112.32(b)(3)
• Toilet Requirements: §112.129
• Handwashing Station Requirements: §112.130

Visitors to your farm are often overlooked as potential food safety hazards, as they may not be aware of the way your farm operates or how to protect themselves and your produce. Any visitor to your farm, whether they are a farm stand customer, a potential wholesale buyer, someone coming to do you-pick, or a neighbor who wants to walk their dog through your fields, need to be made aware of your farm’s food safety policies. FSMA requires that you make visitors aware of your food safety policies, for example:

• Where people are allowed to eat and drink
• What parts of the farm visitors are allowed to visit
• Not visiting the farm if they are sick
• Proper handwashing practices (when and how)
• Keeping pets at home
• Any other relevant food safety policies

Visitors must also have access to toilet and handwashing facilities on the farm.

Where can I find this information in the FSMA Produce Rule?

§112.33

The only records you are required to keep regarding workers health, hygiene, and training is a worker training log, which must include the date of each training, the topics covered, and the individuals trained.

Worker Training Log

We also recommend keeping the following records:

• Toilet and Handwashing Facilities Maintenance Log
• Worker illness and injury reporting