An agent Training Program in Safe Food Handling - Legal Liability

Development of Fresh Produce Safety Curriculum (Publication) & Resources
A peer-reviewed 9 module curriculum was developed that encompasses the Good Agricultural Practices (GAPs) and Good Handling Practices (GHPs) outlined in the FDA/USDA “Guide to Minimizing Microbial Hazards in Fresh Fruits and Vegetables.” It will also address recent needs surfacing from USDA GAPs/ GHPs audits, other third-party audits and the GAPs certification process. It is designed as a train-the-trainer resource with an emphasis on increasing an understanding of the microbial risks associated with producing, harvesting, washing, sorting, packing and distributing fresh fruits and vegetables and resources to train and support a network of North Carolina Extension Agents and other agricultural professionals in the implementation of Good Agricultural Practices (GAPs). The resources developed include a printed manual of the curriculum, with a corresponding jump drive containing electronic copies of PowerPoint slides, video clips (3) and a communications toolkit for the branded program. The curriculum is divided into nine modules, with each module encompassing 1 to 1.5 hour blocks of instruction. Each module provides a PowerPoint presentation, PDF files with more in-depth notes and references, learned experiences/exercises and handouts when appropriate, and pre-post evaluation tests (Modules 8 and 9 do not have pre-post tests).
In working with Tier 2, we realized that a main Powerpoint needed to be developed to address and tie together all of the risk management practices that were addressed within the proposed legislation.

Brand Name
A brand name has been developed for this curriculum to both protect the integrity of the contents and to create market recognition for participants. The brand name is “N.C. MarketReady Fresh Produce Safety – Field to Family Good Agricultural Practices (GAPs) Training Initiative”.

Tiered Educational Approach
A tiered educational program has been developed, upon the recommendation by N.C. Cooperative Extension faculty and North Carolina growers, to encompass the wide range of growers’ needs reflecting farm size, markets and associated commodity-specific risks. It is designed to give producers a proactive, educational and incentive based program for their individual needs. As such, the modules within this curriculum serve as the basis for a progression of training tiers that will have three tiers developed in totality. The curriculum with modules detailed is as follows:

Introduction - The introduction provides background on the curriculum development, information about the program design and guidelines for using the N.C. MarketReady brand.

Tier 1- Module 1 to 6. This represents the basic level of fresh produce safety training for a total of seven hours of instruction.
Content Covered: fresh produce-safety basics, pathogen introduction, GAPs for field practices, GHPs for packing facilities, proper health and hygiene, water quality, site selection and manure management. Agents will deliver content of these modules and collect evaluations from participants. Certificate of Attendance will be issued to participants.
Module 1: Fresh Produce Safety Introduction (PPT)
Supplementary notes and references (PDF)
There are numerous points throughout the supply chain where fresh produce can be exposed to contaminants which can be passed on to consumers. N.C. MarketReady Fresh Produce Safety Module 1 establishes a foundational knowledge of the microbes and chemicals associated with produce contamination as well as how those agents might be introduced throughout the food supply chain. Producers can utilize Good Agricultural Practices (GAPs) to reduce the potential for contamination in fresh produce.
Module 2: GAPs Field Practices (PPT)
Supplementary notes and references (PDF)
Good Agricultural Practices (GAPs) start in the field. This N.C. MarketReady Fresh Produce Safety module identifies potential areas of pathogen contamination during the growth and harvest of fresh produce. Water use, fertilization, animal hazards, worker hygiene and harvest operations are the five areas addressed, including specific examples and recommendations to avoid contamination.
Module 3: Packing Facility Sanitation (PPT)
Supplementary notes and references (PDF)
Maintaining sanitation at the produce packing facility is detailed through the food safety guidelines known as Good Handling Practices (GHPs). GHPs address environmental controls to minimize risk of pathogen contamination at the stages of postharvest handling and packaging. The primary areas of concern for constant monitoring are packing house water, pest management, worker hygiene and facility sanitation.
Module 4: Health and Hygiene (PPT)
Supplementary notes and references (PDF)
There is a direct link between poor personal hygiene and food-borne illnesses. Ensuring proper hygiene as part of Good Agricultural Practices (GAPs) helps reduce the transfer of pathogens from person to person and from person to produce. Several laws and regulations exist to encourage hygiene practices that will help keep North Carolina produce clean and safe. This N.C. MarketReady Fresh Produce Safety module includes a review of common food-borne pathogens and diseases as well as discussing the importance of supervising farm worker health and providing appropriate first aid in the event of accident or injury. Effective hand washing and guidelines for restroom availability and sanitation are an essential aspect of reducing potential contamination throughout the food supply chain.
Module 5: Animals, Animal Byproducts, Biosolids and Site Selection (PPT)
Supplementary notes and references (PDF)
Though fresh produce can become microbiologically contaminated at any point from field to table, contamination associated with animal or human waste represents the greatest health hazard to humans. Fortunately, when points of contamination are identified, remedies can be implemented to eliminate or reduce microbial contamination of produce. This N.C. MarketReady Fresh Produce Safety module covers Good Agricultural Practices (GAPs) as they relate to domestic and wild animals in or near production areas, the use of animal byproducts and biosolids for nutrient enrichment of produce fields, and evaluation of a site prior to produce cultivation.
Module 6: Water Quality (PPT)
Supplementary notes and references (PDF)
Fresh produce is exposed to water throughout its life cycle, from field irrigation to postharvest handling. It is important to keep the water supply safe from pathogen contamination, to continually monitor water quality and to treat any contaminated water. By recognizing the potential sites of produce contamination via water, producers can implement Good Agricultural Practices (GAPs) that will keep produce clean and safe.

Tier 2 Modules 7 to 9, represents the continuing level of fresh produce safety training that involves:
Content Covered: transportation, traceability and recalls, liability and insurance options, crisis strategy and risk management. Specialists will deliver content of these modules and collect evaluations from participants. Certificate of Attendance will be issued to participants and participants will be listed on www.ncmarketready.org for end markets to view.
Module 7: The 3 Ts: Transportation, Traceback and Traceforward (PPT)
Supplementary notes and references (PDF)
Even after fresh produce has been picked, processed and packaged, follow-through with transportation and traceability requires adequate attention to ensure the highest quality product is delivered to the end consumer. Transportation issues related to fresh produce safety include cleanliness of the transporter, load compatibility and maintaining the cold chain. Government regulations require that “everybody in the supply chain must be able to trace one step back and one step forward.” Key components of traceability include maintaining lot integrity, labeling premises identification, product identification and electronically tracking the movement of the product through the food chain.
Module 8: Managing Liability and Risk (PPT)
Supplementary notes and references (PDF)
Good Agricultural Practices (GAPs) are currently being implemented on a voluntary basis. Market data demonstrate that producers with GAPs certification rebound faster than those who are not certified after an outbreak of food-borne illness and an associated product recall. There are some costs to becoming GAPs certified, including first year expenses typically associated with changes in procedures, paperwork and record-keeping, as well as an annual fee for each crop certified. Each farm must consider the value certification offers by means of reducing economic risks and improving market-access opportunities. This N.C. MarketReady Fresh Produce Safety module also provides an overview of liability and insurance options to manage risk exposure.
Due to the legal and technical nature of this module, a video presentation by two of the contributing authors is available to download and play during the training and to ensure trainers are familiar and comfortable with this information.
Module 9-B: Dealing with Controversies and Crises: Working with the News Media (PPT)
Supplementary notes and references (PDF)
In the event of an agricultural related controversy or crisis, such as an outbreak of a food-borne illness, it is important to be prepared to communicate with the news media. Fostering good media relations is an ongoing responsibility, not just in times of crisis. Knowing when, why and how to talk to the media is part of the crisis management strategy. Plan and prepare now to better handle controversies and crises in the future.
Module 9-B was developed for agents to use in trainings for growers. This provides media basics and how to deal with a crisis, including how to develop key messages and supporting points. Depending on the crisis, it may be advisable for a farmer to seek legal counsel. In the event they decide to grant interviews regarding an outbreak, for which the source has yet to be determined, this module includes videos on how best to respond to the news media and what not to do. Preparation is the key.
Video: Food-borne Illness Outbreak Scenario 1: What NOT to Say (2:15)
http://www.ncsu.edu/fvsi/value-added/agents/index.php?section=fresh-produce-safety&page=educational-curriculum&subpage=university-of-minnesota-scenario-1
This training video from the University of Minnesota demonstrates how growers should NOT handle the media during a food-borne illness outbreak. A mock media interview with two growers (actors) shows how poor handling of this situation can damage credibility, business and even the industry. The video provides great examples of questions that media ask in real-life scenarios.
Video: Food-borne Illness Outbreak Scenario 2: What ToSay (3:53)
http://www.ncsu.edu/fvsi/value-added/agents/index.php?section=fresh-produce-safety&page=educational-curriculum&subpage=university-of-minnesota-scenario-2
This training video from the University of Minnesota demonstrates how growers SHOULD handle the media during a food-borne illness outbreak. A mock media interview with two growers (actors) shows how effective handling of this situation can bolster credibility and instill confidence in consumers and the industry. The video provides great examples of questions that media ask in real-life scenarios.

Communication Toolkit
To aid Cooperative Extension Agent in marketing the Curriculum several resources were developed and placed on an “Agent Resource” page of the website. These editable resources include summary excerpts, news releases and fliers that can filled in with pertinent data on location and dates that will help agent to market consistently and saves time.

On-line Curriculum Participant Tracking, Certificate Issuance, and Searchable database for Grower’s Marketing Tool
Within two weeks of participants completing the training requirements for each tier, agents use this Web form to generate a “Certificate of Attendance” and to submit grower information that will be included in a public database for farmers to be able to market their food safety efforts and to provide produce buyers an on-line reference when seeking suppliers of specific commodities with food safety knowledge. Entering the grower information will automatically generate a personalized certificate for the grower. The searchable database is by commodity and includes the farm name, growers’ name, location, contact information and additional crops grown.

Fresh Produce Safety Plan Template (Publication)
Each grower’s conditions are different. This instructional template, “Good Agricultural Practices Fresh Produce Safety Plan for Field Practices” was developed in workshops with North Carolina growers to provide a framework that would help producers shape their own food safety plans. The plan template follows the guidance from the Food and Drug Administration’s Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables and incorporates the U.S. Department of Agriculture’s Good Agricultural Practices & Good Handling Practices Audit Verification Matrix. The plan is available electronically as a printable guide (pdf) or an editable document (MS Word). http://ncsu.edu/enterprises/ncfreshproducesafety/good-agricultural-practices-gaps/audits-plans/food-safety-plans/

Educational Mock Audits
Two educational mock audits were conducted during the summer of 2009. Two 3rd-Party Auditors (USDA/NCDA and Primus) conducted these educational audits, providing insight on documentation needed and answering questions. The educational audits took place over two days at different locations across NC; day one (July 17) encompasses the field audit (4 to 5 hours) at Premier Produce LLC in Wilson, NC and the second day (July 22) encompasses the packing facilities audit with traceability (6 to 7 hours) at Patterson’s Farm Inc., in China Grove, NC. These events were well attended and served as an effective tool in helping growers to understand what GAPs certification means. A mock audit slideshow was created from these events to better enable growers unable to attend to understand the process of GAPs certification.
Direct Market Display Risk Checklist (Publication)
Working with local farmers markets, a checklist for assessing risk factors and best management practices was developed and given to agents. Agents can use this tool to work with markets vendors attending trainings. For each question, market vendors would indicate their particular risk level in the right-hand column. Although some choices may not correspond exactly to situation, vendors are instructed to choose the response that best fits. In this way, markets begin to look at the chain of conditions that might represent risks for the entire food chain before it gets to consumers.

Growers Toolkit
A grower’s toolkit has been developed and purchased for distribution to agents and association meetings. The grower’s kit is a resource developed to aid growers in starting their food safety programs. Fifty grower’s toolkits were created and handed out to NC farmers. The kit includes :
Fingernail brush , GlowGerm , Blacklight, Chlorine Strips Kit, pH Test Strips, Nitrile Gloves, Waterproof Thermometer, Handwashing Posters and Toilet Use Posters, Bilingual First Aid Kit and Blood Pathogen Kit.

Website
A website (www.ncfreshproducesafety.org) was developed that brings together comprehensive resources for fresh produce safety. This project is responsible for compiling valuable resources and materials including information on traceability, postharvest quality, cost share opportunities, Good Agricultural Practices (GAPs) and more.

Blog
A New Blog was launched (http://ncfreshproducesafety.wordpress.com) the second week of January to better enable the rapid and regular entries of commentary, descriptions of events, or other materials such as graphics or video.

Videos
The Produce Lady was made discussing Good Agricultural Practices (GAPs) and how N.C. Cooperative Extension is training farmers across the state in GAPs in order to minimize risks throughout the food supply chain. She introduces different aspects of GAPs and provides information on sanitary methods of food handling, storage and transportation for growers and consumers. (http://www.ncmarketready.org/the-produce-lady/videos.php)

Video of Module 8 – Risk and liability - Due to the legal and technical nature of Module 8, a video presentation by two of the contributing authors is available to download and play during the training and to ensure trainers are familiar and comfortable with this information. Video presentations of Module 8 materials by Rod Rejesus and Ted Fietshans can be viewed on website (http://www.ncsu.edu/fvsi/value-added/agents/index.php?section=fresh-produce-safety&page=educational-curriculum&subpage=gaps-certification)

Mock Audit Resource Slideshow - The N.C. MarketReady Fresh Produce Safety – Field to Family program offered a mock third-party audit to educate N.C. Cooperative Extension agents and growers on the requirements for GAPs certification. Video Full Text: As concerns about food safety increase, farmers are experiencing more pressure than ever to minimize risks when it comes to fruit and vegetable production. As a result, they are encouraged to become GAPs certified. GAPs stands for Good Agricultural Practices and is a key component of food safety measures required by some produce buyers, such as grocery stores. Buyers consider GAPs certification an important step to help minimize the risk of pathogen contamination in the food supply chain.
North Carolina Cooperative Extension is working with growers across the state to help them learn more about third-party audits required for GAPs certification. In late July, Cooperative Extension presented a mock third-party audit at Premier Produce in Wilson. The mock audit was conducted by Michael Fagan and Brooke Stephenson of the North Carolina Department of Agriculture and Consumer Services. Throughout the audit, growers and Extension agents engaged in open dialogue with the auditors about the process.
Premier Produce was in the midst of cantaloupe harvest at the time of the mock audit. David Harrell, field manager, and Sarah Lancaster, office and packing house manager, were on-hand to discuss the operation, answer questions and participate in the educational audit. Premier Produce has been audited in the past as required by their contract buyer and is currently GAPs certified. This year the company anticipates yields of 1.2 to 1.4 million melons from 180 acres.
The audit process begins when a grower contacts a 3rd party auditor, like the North Carolina Department of Agriculture, to request GAPs certification. This mock audit used the USDA GAPs audit matrix and the NCDA auditor’s criteria. An audit may change depending on which matrix and third party auditor the grower works with. When initiating an audit, the grower will be asked to send the auditor records, such as an aerial map that shows fields and facilities. These maps may help identify potential sources of contamination in proximity to the production area. An auditor works with the grower to schedule a visit when the produce is being harvested. It’s up to the grower to specify which commodities and which fields or packing facilities he or she wants certified.
On the day of the auditor’s visit, the auditor will review the grower’s food safety plan before the inspection begins. The auditor will assess whether the grower has implemented all items outlined in the food safety plan. The auditor then uses a “matrix” where areas of potential concern are assigned a value and points are awarded for compliance. GAPs certification requires that 80 percent of the possible points are awarded. The inspection includes the physical assessment of each field or facility being considered for certification. The auditor will observe harvesting operations and may question the harvest crew to ensure that they have a working knowledge of the food safety plan.
The auditor is not a regulator; rather, the auditor assesses the grower’s food safety plan content, implementation and supporting documentation. For example, at Premier Produce, the food safety plan requires each field worker to wear gloves, apron and a hat or hairnet. The auditors observe that all field workers are following the policy, but they do not stipulate what the policy should or should not entail.
The field assessment also includes an evaluation of field equipment. Tractors should be clean with no fluid leaks and all light covers in good repair to avoid glass breakage in the packing bins or anywhere in the product flow zone. The product flow zone is anywhere the produce travels from field to end transport. The auditors also do a visual inspection for bin cleanliness. Nothing should be in the bin except produce; however, it is common practice to designate one bin for trash. A trash bin should be clearly marked with bi-lingual signage.
While it may be common practice to throw cull fruit in field aisles, it is never acceptable—and may result in an automatic audit failure—if partially eaten fruit is observed in the field or anywhere in the product flow zone. Visual inspections can easily identify bite marks in partially eaten fruit. Additionally, no outside food should be allowed in the product flow zone, with the exception of drinking water. Premier Produce uses municipal water in the packing house and for drinking water in the field. Annual documentation from the municipality asserting the water quality is required for the audit. At Premier, irrigation water is supplied from a pond that is on-site. The pond water is tested monthly during the growing season for a variety of pathogens including generic E. coli. Given the open source nature of the pond, it is difficult to deter domestic animals and wildlife. Since Premier has made no efforts to prohibit wildlife from the pond, due to cost considerations, the company would not receive the points associated with that item on the matrix.
According to current North Carolina Department of Labor regulations, one toilet and hand-washing facility should be available for every 20 workers, no more than one-quarter mile from the field. Auditors carefully examine the portable toilets for cleanliness, including a schedule of cleaning and maintenance. A hand-washing station must also be near the toilet, where the auditor will check the availability of water, soap and paper towels. Signage, in appropriate languages, reminding employees of hand washing is a must. Auditors will also be interested in a response plan for spills or leaks for the sanitary facilities to ensure waste does not flow into the field or the irrigation pond.
There are several reasons an audit can automatically fail. Examples include: the presence of an immediate food safety risk, evidence of pests, unsanitary conditions and falsification of records. At the point when an automatic failure is observed, the audit will stop and the grower will be issued a corrective action form. The grower will determine which measures must be taken to correct the problem and reschedule the audit. GAPs certification is valid for 365 days from the date of certification. During that time, the grower agrees that the auditor can make one unannounced visit.
Premier also shared information about their traceability system. For example, harvest bins in the field are tagged with a card that identifies the variety, block number, crew identification and harvest date. As the melons move through the packinghouse a coded sticker is applied to: each cantaloupe, the case and the pallet.
In keeping with their food safety plan, Premier representatives asked everyone who entered the packing house to wear a hairnet.
The mock audit was coordinated by Diane Ducharme, GAPs Program Coordinator and Extension Associate in Horticulture & Food Safety with the Program for Value-Added & Alternative Agriculture. For more information about fresh produce safety and GAPs certification, visit other sections of this Web site. http://ncsu.edu/enterprises/ncfreshproducesafety/2010/05/11/mock-third-party-audit-for-gaps-certification/

Train-the-trainer activities
Three regional trainings were held across the state in 2008 and 2009 to facilitate a total of 46 counties and 152 agents being trained on this curriculum.
In addition, a Webinar Series (Elluminate) for Tier 1 was developed and given to agents and a select group of growers. This webinar series was recorded in November 2009 to serve as an on-line coursework/training tool for N.C. Cooperative Extension Agents. Agents are encouraged to review the presentations and new agents never attending these first training have a “live” presentation of resources available as they prepare for trainings to growers.

Needs Assessment & Evaluation Meetings
In early September 2008, an electronic need assessment was sent to NC Cooperative Extension with a 74% county response rate. The following responses allowed for prioritization of resource development within this project:
Websites are the primary source for food safety information. Agents feel that a one-stop website offering all pertinent food safety information would be helpful and web-based updates were most preferred (64%).
Fresh Fruits and Vegetables are the highest category for questions regarding food safety (76%)
Water issues are the main areas of concern/requests for information (51%)
Direct marketers are the primary audience contacting agents for information (67%)
A moderate level of knowledge (know about this topic but there are more things to learn) of Fresh Produce Safety was indicated (56%)
Less than 10% of growers in Counties test agricultural waters for food safety purposes (55%)
Agents rated Growers needs for fresh produce safety training as High (46%)

Project evaluation tools for measuring changes in knowledge, attitudes, skills and aspirations were developed and employed during the agent trainings. Statistics from these show effective advancements in several areas for this project including improvement in agent knowledge, confidence levels on subject matter, training expectations, and potential audience numbers.

Monthly NC Fresh Produce Safety Task Force meetings allowed for a continue flow of information and evaluations of needs from the representatives of the education, industry, regulatory areas and individual farmer and farming groups. In addition, the farmers and agents in the planning advisory group have met to reference and develop the necessary changes to the curriculum. It was members of this advisory group that recommended the branding and tiered educational approach that the curriculum has advanced in this direction.

Potential Contributions
The beginning of this project marked the advent of the fresh produce safety initiative for NC. This project served as the catalyst for a larger view of food safety from the state’s perspective. It brought many of the key players together as advisors for not only this project but assisted in a larger sense for the formation of the NC Fresh Produce Safety Task Force. The task force is a partnership that brings together members involved in education, public policy, the fresh produce industry and research. Partnering institutions and agencies include North Carolina State University and NC Cooperative Extension, North Carolina A&T State University North Carolina Department of Agriculture and Consumer Services, United States Food and Drug Administration (FDA), North Carolina Farm Bureau, Commodity Groups, Fresh Produce Brokers/Distributors, and most importantly individual growers. As this Task Force developed, communication linkage with key personnel from NCDA & CS, FDA and USDA ‘s involvement was initiated, with several listening sessions and visits from FDA/USDA being initiated due to this initiative’s efforts. As the potential regulations are formed for fresh produce safety, this project’s initiative have given voice to the needs of small, medium, and large farms in the area of fresh produce safety.