Why is Worker Hygiene Critical to Ensure Produce Safety?
Pathogens, or disease-causing agents, are commonly transmitted through the food we eat. Consumers can grow sick resulting from poor food packing or sanitary conditions in factories. Consumers are uniquely vulnerable to food safety risks from produce more so than other foods, because produce is often consumed raw. One of the largest risks posed to food safety is from the workers themselves. Those who handle produce are a key cog in the process of putting food on the table. That large role poses a large pathogen risk in many ways, such as:
- Poor bathroom hygiene, where human fecal matter can contaminate produce.
- Hand contact with saliva, mucus, or other unsanitary surfaces.
- Clothing contamination, often with manure.
- Direct sewage leaks/defecation in fields.
- Blood or fluid contact.
- Contamination of tools, which in turn affects produce.
These conditions can directly lead to major disease outbreaks, as they did in 2003, when worker-based contamination led to the spread of hepatitis A in green onions. To prevent these outbreaks, and maintain safety standards, farm owners, managers, and supervisors must create an environment conducive to safety through training and through keeping a safe and sanitary workplace.
What Do Agricultural Employers Need to Do to Create Sanitary Conditions?
Keeping supplies of sanitary goods such as soap and paper towels is one critical way to keep workers in the habit of hygiene. Under FSMA § 112.129(a), toilets must be readily accessible and kept suitable for use so that workers prevent human contamination and may appropriately dispose of waste. Additionally, FSMA § 112.130(b) requires that handwashing facilities have soap, running water, and drying devices to reduce the risk of touch-based contamination. The Occupational Safety and Health Act (OSHA) requires one toilet and one handwashing facility per every 20 workers within a ¼ mile (or a 5 minute drive). State and local regulations may also have additional requirements on top of OSHA. It is recommended that stations are monitored and logged through well-kept records to determine when it is necessary to clean and restock facilities. Workers also need to be provided with drinking water to avoid dehydration and exhaustion. State and local regulations may have additional requirements. FSMA § 112.32(b)(6) requires that workers not eat, chew gum, or use tobacco in activities with covered produce, although drinking beverages is permitted in designated areas.
It is also critical to ensure that workers are not sick on the job. Workers should stay home if they feel ill and have a risk of communicating pathogens, but often times, workers will not want to report an illness and be sent home. Because of this tendency, employers need strict policies on sickness in the workplace. Managers should know how to identify when workers are sick so that they can intervene. Also, to prevent sickness in the workplace, employers need to prevent heat stroke and other stressors. Under FSMA § 112.31, growers must take steps to prevent contamination from sick workers, especially by excluding sick workers from taking potentially risky tasks and telling workers to report illness.
In the case of injury, employers need to make sure that the worker receives medical attention, and if necessary, call 911. First-aid kits should be located conveniently to treat such accidents. Minor wounds should be bandaged, and hand wounds should be double-covered to prevent contamination. Any blood or body fluids from such wounds should be promptly cleaned.
Developing a monitoring program for illness, injury, and hygiene is useful to see how effective food safety plans are in supporting sanitary behavior in the workplace. Recordkeeping plays a special role in this to create accountability. These programs can indicate potential areas where action is required to fix continued suboptimal practices. Plans can include negative incentives for worker failures to follow safe practices, positive motivation for doing the right thing, or both. Contingency plans in case of emergencies allow workers to better take swift and appropriate actions to prevent contagious spread of pathogens.
Under FSMA § 122.30, worker-related records must be kept according to rigorous standards. Facility-based records, especially for restrooms, and worker illness/injury reporting also requires well-kept records. All records should include:
- Name of log or task.
- Date of task completion.
- Who completed the task.
- What the task entailed.
- Any materials specific to the task.
- Signature of the person responsible for the food safety plan.
- The name and location of the farm.
- Data and observations of monitoring.
- Description of produce, if applicable.
- Location of growing area.
- When the activity was documented.
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Who Needs Training Under the FSMA Produce Rule?
Safety from pathogens is only as strong as its weakest link, so it requires comprehensive measures. Under FSMA § 112.22(a), every worker, whether full- or part-time, who handles or contacts covered produce must be trained to understand food safety policies. But training must extend beyond workers to truly achieve full safety. Anyone on the farm, from workers to volunteers to interns to landscapers to family members, may contaminate food, contact surfaces, or commonly touched surfaces such as doorknobs. Owners, managers, and supervisors also have a special responsibility to lead by example when it comes to food safety. Under FSMA § 112.33, visitors to the farm must be made aware of farm policies on food safety, and must have access to toilet and hand-washing facilities. Visitors are defined as any person, other than personnel, who enters the farm with permission. To make these visitors aware of policies, it is recommended to use posters, handouts, similar materials, or verbal warnings. FSMA § 112.22(c) requires that at least one supervisor from a given farm completes training at least equivalent to the FDA’s recognized curriculum. While this guide is meant to encourage farmers to focus on food safety, it must be noted that it is not officially recognized to satisfy that requirement.
What Sanitary Practices Should Workers Follow?
- 112.32 of the Food Safety Modernization Act specifically requires several actions for farm workers to take. Though these actions might seem overbearing for workers at times, they should be taken in order to prevent potential contamination. They include:
- Maintaining appropriate levels of personal hygiene.
- Avoiding unnecessary contact with animals, and taking appropriate steps to reduce animal contamination when such contact is necessary.
- Washing hands. This is especially important, and the law goes into even further detail that workers must:
- Wash hands thoroughly by scrubbing with soap, or a similar surface cleaning agent, and running water and dry hands thoroughly using sanitary methods. This procedure must be done before starting work, before putting on gloves, after using the toilet, upon return to the work station after breaks, directly after touching animals or animal waste, and at any other time that hands might have become contaminated.
- Keeping gloves on, and in sanitary condition.
- Removing hand jewelry that cannot be cleaned or sanitized well.
- Refraining from eating, chewing gum, or using tobacco products in covered areas.
- Knowing what to do in the case of illness or injury. This includes knowing where first-aid kits are, how to treat injuries, and how to report an illness or injury.
- Understanding any other policies related to their job-specific tasks.
- Knowing points of contact for reporting food safety risks. While not listed by the law, it might be useful to also provide encouragement for reporting risks through small incentives.
Visitors also must be informed how to properly wash their hands under the same standards. In general, 20 seconds (or the “Happy Birthday” song) is the golden rule for the proper length of handwashing. Warm or cold water can be a personal preference, as long as the water meets standards of quality under FSMA § 114.22(a) and is not contaminated itself. To ensure that workers and visitors are aware of good handwashing practices, it might be useful to demonstrate through hands-on activities. Note that antibacterial hand sanitizers are not a true replacement for handwashing, and should not be treated as such. They can be an addition to handwashing, but because they do not effectively deal with dirt, they cannot be the only line of defense.
Not using proper toilets is a major, and unfortunately widespread, problem when it comes to sanitary conditions. Urinating or defecating should always be done in toilets, never in the field. Flushing toilet paper is often advisable to reduce contamination risk. To monitor handwashing practices, external sinks outside of portable toilets are one way to ensure that workers maintain sanitary conditions.
Workers should dress for success, and success means cleanliness. If animal work is done alongside produce work, workers should have separate boots for both activities to reduce cross-contamination. Gloves are not required, but if they are used, they need to be changed or cleaned well. If they are reusable, cleaning is especially important. Hands need to be washed no matter what, regardless of gloves. Clothing covers like aprons should be stored, cleaned, and removed at proper times. Jewelry is often a worker safety risk, and it is also a common food safety hazard because it often carries contaminants.
How Can Workers Be Trained to Ensure Produce Safety?
First, it is important to identify the potential barriers to open communication when it comes to training. Time taken for training, language barriers, differing literacy levels, new hires, variations in hygiene standards, and misconceptions surrounding hygiene are all potential reasons why food safety training is incomplete. To protect against these dangers, it is recommended to:
- Make a conscious investment of time to train workers upon hiring or maintain regular training sessions. Training is required upon hiring and at least annually.
- Provide training in workers’ native languages.
- Use visual or demonstrative cues for workers with low literacy levels.
- Ensure that all workers, no matter how new to the job, understand safety expectations.
- Develop Standard Operating Procedures to provide clear instructions.
- Create a unified standard of expectations to avert cultural differences or ambiguity.
- Reinforce the reasons behind why food safety should be central to the workplace environment.
- Provide opportunities for workers to practice skill development.
This training must involve basic principles of food hygiene, the importance of health on farms for everyone involved, and specific FDA standards related to job responsibilities. On-the-job training, while often meaningful, does not suffice for food safety. Also, under FSMA § 112.30(b), farms are obligated to document their training sessions with names, topics, and dates. Workers, too, have a responsibility in developing safety standards. Encouraging workers to keep their eyes open for what they think are unsanitary practices creates a stronger culture of trust in safety, and leads to added protections for consumers. To achieve this, farm managers need to be open to new ideas and ensure that workers feel comfortable airing concerns.
Additional training standards are required for harvesters: under FSMA § 112.22(b), those who harvest covered produce must be trained to recognize covered produce that must not be harvested because of contamination risk, to inspect harvest containers and equipment to ensure that they are properly clean, and to correct or report any problems with those containers or equipment should it be necessary. This is one specific area covered by the law, but many other individual concerns may arise since produce farming has many potential complications. Such individual areas require forethought and concern to address.
We hope this guide helped to train you for your future training needs!