Food Protection Trends - November/December 2023 - 468

Subpart K: Growing, Harvesting, Packing, and Holding
Activities
Subpart K establishes standards for growing, harvesting,
packing, and holding activities. Topics covered in Subpart K
include the following:
* Measures to take for farms that grow, harvest, pack,
or hold both covered produce and produce that is
not covered, including the transition points between
those produce items and separation of covered and not
covered produce;
* Identifying and not harvesting contaminated
covered produce;
* Handling harvested covered produce;
* Dropped covered produce;
* Packaging covered produce; and
* Food packaging material.
Generally, Subpart K had low numbers of non-compliance
issues (n = 13) based on the data collected from 69 farms.
Non-compliance issues under this subpart pertained to
section 112.113 that requires covered produce be handled
in a manner that protects from contamination against
known or foreseeable hazards. Qualitative data showed
that harvested covered produce encountered soil and nonfood-contact
surfaces. In addition, there was at least one
non-compliance issue under section 112.114 that requires
produce growers not to harvest dropped covered produce.
Qualitative observational data from the assessment showed
the harvesting of covered produce that made contact with the
ground before harvesting activity.
According to the FDA, microbial contamination of fresh
produce during pre-harvest and harvest activities may
result from contact with soils, fertilizers, water, workers,
and harvesting equipment (33). Foodborne pathogens may
persist on the uninjured surface of fresh produce, but growth
is not common because of the protective outer barriers
found on most produce; however, once the protective
epidermal barrier has been broken by physical damage, the
nutrients and moisture released by the produce significantly
enhance the survival of foodborne pathogens (15). This is
an important factor to consider when assessing the risks
associated with reusing soiled tools and equipment because
punctures and bruising of fresh produce are common
occurrences during various stages of harvesting (15).
Furthermore, the guidance document identifies tables,
baskets, and containers as fomites that can easily spread
microorganisms through cross-contamination to fresh
produce and recommends that they be cleaned and sanitized
before hauling fresh produce and reuse (33). A previous
study demonstrated the persistence of key foodborne
pathogens (E. coli O157:H7, Listeria monocytogenes,
Salmonella, Staphylococcus aureus, and MS2 bacteriophage)
on cardboard, plastic, tablecloth, molded pulp fiber,
and wicker baskets commonly used on the farm and for
transporting produce (5). The results of this previous study
468 Food Protection Trends November/December
showed that molded pulp fiber, plastic, and wicker surface
materials supported the persistence of Salmonella and S.
aureus for up to 59 days (5); hence, it is critical to limit the
potential of containers as a vector for cross-contamination.
Subpart L: Equipment, Tools, Buildings, and Sanitation
Subpart L establishes requirements for preventing
equipment, tools, buildings, and inadequate sanitation
from contaminating covered produce. This part includes
requirements for toilet and handwashing facilities, as well
as the appropriate storage, maintenance, and cleaning of
equipment and tools. Subpart L had the second highest
non-compliance issues (n = 37) from the data collected
in this study. This subpart of the PSR targets various
equipment and tools that are likely to come in contact with
covered produce, building structures and functionality, and
sanitation requirements for all items covered under this
subpart. The most frequent non-compliance issue reported
was section 112.140 (n = 19) that requires that records
be maintained that satisfy Subpart O of the PSR, record
keeping. The most prominent non-compliance issues stem
from the documentation of the date and method used
to clean and sanitize equipment; specifically, regarding
covered harvesting, packing, or holding activities. Another
noteworthy non-compliance area under this subpart is
section 112.130, handwashing facilities where a total of
10 non-compliance issues were observed across 69 farms.
The data collected identify the provision of handwashing
facilities, and significantly, proper waste disposal for these
facilities as areas that require attention by farming operations.
Other areas where non-compliance issues occurred relate to
the inspection, maintenance, and cleaning of food-contact
surfaces; the storage of equipment and tools to prevent
contamination; equipment used to transport covered
produce; and the provision of toilet facilities and measures
to prevent toilet facilities from becoming a possible source
of contamination on the farm. Qualitative data showed that
a handwashing facility close to the fields did not contain a
catch bucket for wastewater leading to the field and possibly
contributing to the contamination of covered produce.
One of the non-compliance issues of this subpart observed
was under 112.130(a), the failure to provide adequate and
readily accessible handwashing facilities during growing,
harvesting, packing, and holding activities. According to
several studies, lack of properly equipped handwashing
facilities and tools addressing proper handwashing practices
are the two main reasons for employees' contravention of
handwashing as well as the two most common obstacles
to public health, because poor handwashing by personnel
who work in the food industry has been a crucial risk factor
associated with foodborne illnesses (2, 4, 19, 24). From this
perspective, a key to improving handwashing practices is
to ensure the installation, inspection, and maintenance of
adequate physical sanitary facilities.
Food Protection Trends - November/December 2023

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