November/December 2024 - 10

SUSTAINABILITY
matter, and determines whether corrective or mitigation
measures are needed to reduce the potential for
contamination of covered crops.
" The AgWA looks for ways to mitigate identified risks, "
Stoeckel said. " Where is the fecal matter on the
landscape and how could it get on the crop? If the risk
profile is extensive, what can you do about it? "
The preharvest water section of the Produce Safety
Alliance Grower Training has been revised to include the
new water rule. It's a good starting point for those who
haven't taken the training or want a refresher. The FDA
also has fact sheets that are good sources of information.
ENHANCED TRACEABILITY
Traceability applies to a broad range of foods other
than the whole fresh produce items that are on the Food
Traceability List, like pre-packaged salads and certain
types of fish.
Traceability will be dependent on farms establishing clean
breaks based on their cleaning and sanitizing programs.
" Traceability will rely on solid records for clean breaks
between lots and all of the records that go along with it, "
Simmons said.
Processors or packers who have a problem will rely on
those records to understand where the problem occurred.
" Instead of testing for generic E. coli to
make definitive conclusions, the new
rule has you looking around the farm
for risks. "
- DON STOECKEL, CORNELL UNIVERSITY
Good records could limit a potential recall to just a day's
production and not a year's worth.
Finding a way to identify lots is going to be an important step.
" How do growers partition their production into lots
and how do they identify those unique lots? " Stoeckel
said. " How do they organize their production into
segments and how do they identify them? Do they use
stickers or mechanical label guns? "
Simmons said traceability will bring expanded
responsibility for growers, but a contamination event with
a loss of consumer confidence could destroy an entire
commodity market.
" Traceability should help protect the crop that leaves
an individual farm, " Simmons said. " This will help
protect the business and ultimately help protect the
entire market. "
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November/December 2024

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