Food Protection Trends - November/December 2023 - 467

have successfully completed produce safety training at least
equivalent to that received under a standardized curriculum
recognized as adequate by the FDA.
The on-farm assessments indicated that the majority
(46%) of non-compliance issues fell under subsection
112.30(b), which requires that farming operations establish
and keep training records to ensure compliance with Subpart
O (record keeping) of the PSR. Although farming operations
did cover some of the necessary trainings required to
safely handle covered produce, observations in 12 separate
instances showed that specifics on dates and personnel
trained were lacking. The second most frequent (19%)
non-compliance issues were under subsection 112.21(a)
that requires that all personnel who handle covered produce
receive adequate training appropriate for their specific
duties and continued training periodically thereafter. During
on-farm assessments, observations in five independent
instances showed that field personnel were working with
covered produce, but were not trained. The remaining noncompliance
issues focus on the specifics of the training that
are required under the PSR. Under section 112.22, data
from the assessment suggests that farms may need to focus
training efforts on the principles of food hygiene and food
safety and personal hygiene for all personnel and visitors, and
have supervisors or other responsible personnel adequately
trained under a standardized curriculum that is recognized
by the FDA. In five instances, it was observed that a farm
supervisor or responsible party of the farm had not received
training based on the standardized curriculum.
The inherent assumption and design of training tools
are that practices will be improved because of enhanced
knowledge of the subject matter (17, 18). According to
the PSR, at a minimum, all personnel who handle covered
produce must receive training that includes (1) principles of
food hygiene and safety; (2) the importance of health and
personal hygiene for all personnel and visitors; (3) standards
established by the FDA in Subparts C-O of this part that are
applicable to the employees job responsibilities; (4) training
that covers harvesting activities such as recognizing produce
that must not be harvested, inspecting harvest containers to
ensure that they do not become a source of contamination
for covered produce, and correcting or reporting problems
with harvest containers; and (5) at least one supervisor or
responsible party must have completed a safety training
recognized as adequate by the FDA (29).
Subpart D: Health and Hygiene
Subpart D of the PSR addresses adequate measures
that are required to prevent ill or infected persons from
contaminating covered produce, hygienic practices, and
preventing visitors from contaminating covered produce.
In addition, it establishes minimum measures and practices
that farms must implement for personnel, supervisors, and
visitors to prevent contamination of covered produce and
food-contact surfaces. General non-compliance issues under
this subsection highlight the need to use hygienic practices
used by the personnel conducting covered activities to
the extent necessary to prevent possible contamination
of covered produce and food-contact surfaces. The noncompliance
issues reported by field specialists all fell under
section 112.32, hygienic practices (n = 10). Specifically,
non-compliance issues were centered around maintaining
personal cleanliness to prevent the contamination of covered
produce. An example of a specific non-compliance issue
observed in the field was that farm workers were wearing
defective vinyl or latex gloves (torn) during post-harvest
activities. Under 112.32(b)(4), if personnel choose to use
gloves in handling covered produce or food-contact surfaces,
the gloves must be intact, clean, or replaced as necessary.
The lack of handwashing after using the restroom and
before returning to work was reported among the noncompliance
issues under Subpart D. The Centers for Disease
Control and Prevention identify hand washing as an
important prevention method for limiting the transmission
of foodborne pathogens from hands to food and food-contact
surfaces and vice versa (11). Moreover, handwashing after
visiting the restroom is crucial because feces is a source of
pathogens such as Salmonella, Escherichia coli O157:H7, and
norovirus and could be transferred to food and food-contact
surfaces upon returning to work (11). Independent studies
suggested that hands are a storage of microorganisms and
are important carriers for transferring them to fresh produce
during manual production, harvesting, and packing (3, 14).
For example, a previous empirical study showed that when
E. coli was present on hands, the handled produce was up to
9 times more likely to be contaminated with the E. coli (3).
The results of the current study showed that the provision
of adequate handwashing facilities and proper waste
disposal were among the non-compliance issues reported
under Subpart L. A study by Bovay et al. (7) estimated that
farms with annual produce sales of between $500,000 and
$700,000 will incur an annual cost of compliance of 4.2%
of their produce sales. Based on the statistics retrieved
from the Regulatory Impact Analysis of Food and Drug
Administration, a large proportion of costs to comply
with the PSR are incurred by personnel qualifications and
training, health and hygiene, and equipment, tools, buildings,
and sanitation, with $68.44 million (29%), $69.74 million
(29.6%), and $63.33 million (26.9%), respectively (35).
Bovay et al. (7) also indicated that enhancements to
practices in areas include agricultural water quality, worker
health, and hygiene, and sanitary standards are anticipated
to be helpful to reduce microbial contamination by
restricting the exposure of produce to pathogens at the
farm level. Worker health and hygiene practices were the
most understood topic by produce growers; however, the
frequency of reported hygiene practices was inconsistent.
November/December Food Protection Trends 467
Food Protection Trends - November/December 2023

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