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    Preventive Control Approaches for Small Growers

    PMA repeatedly emphasizes its commitment to bringing real-world solutions to our industry’s food safety needs. This applies to all industry members, large and small. We know local, smaller growers in particular can find it challenging to access the information and resources they need. But despite the challenges, it is important for operations of all sizes to have risk- and science-based food safety programs and preventive controls in place.

    From a food safety perspective, it doesn’t matter where the produce comes from; consumers do not expect to be injured in the consumption of a food product. In the eyes of the marketplace, small and local growers are expected to have effective and verifiable food safety programs. Retail and foodservice buyers are looking to support suppliers in their neighborhoods, yet these very same suppliers could find themselves at a market disadvantage if they do not have adequate risk and science based food safety programs.

    The good news is that food safety can be completely scalable to any size operation, large or small. It makes sense that a larger processor might have to expend proportionally more resources to manage a large, multi-production line processing plant with hundreds of employees manufacturing a half million pounds of product a day. Of course these expenses can be offset by proportionally larger pack-out volumes.  By way of contrast, a small processor with a handful of employees and who processes washes and packs a thousand pounds of cut fruit or vegetables in small operation could expect to spend considerably less than the large operation. However, the degree of sophistication employed may be much less which helps offset the costs.  Risk management practices and preventive controls can be designed to match the risk and the scale of the operation.
    Preventive control programs can seem overwhelming to someone who has not previously considered food safety as central part of their operations. Yet many preventive control approaches and practices, like wash water verification or supplier qualification controls, are practical for small and very small businesses to implement. My experience with smaller companies has been that once processors understand the concepts of hazard analysis and management, they come to see how simple practices that are not expensive to implement can be effective preventive controls.

    Often these controls are simply good operational or business practices. For example, a preventive control on wash water quality for a small processor’s wash system that uses single pass batch equipment might be as simple as a visual inspection of organic load through a portal in a flume tank, sanitizer and pH test strips, a tested water source and a verified sanitation program. These scale-appropriate preventive controls can be just as effective as more sophisticated continuous flow spectrophotometric methods for monitoring organic loads and state of the art electronic sanitizer probes that might be employed by a large processor to monitor multiple production lines in an automated system. The key factor is identifying the need for monitoring wash water quality and the importance of organic load as a risk factor, taking the responsibility to do so and having the freedom to develop preventive controls appropriate for the size of the operation to manage the risk.

    At the next level of preventive control, a microbial test to verify sanitation efficacy or a food safety audit to verify adherence to a food safety program is routine for many processors, yet many smaller processors not accustomed to applying these controls might fear the costs of these services. Again, to those not using these types of preventive controls, they can appear daunting, but they are rapidly becoming part of doing business. We have seen far too many instances where failures to provide adequate sanitation or adhere to a rigorous inspection program can lead to breakdowns in the safety of foods and cause illnesses among consumers.

    A company’s specific risk assessment/hazard analysis plan should serve as a guide as to which preventive controls should be employed to manage identified potential risks. No matter the size, basic measures such as providing training for worker hygiene, wash water sanitation, facility and equipment sanitation and supplier qualification apply to all operations and can help assure food safety. The liabilities associated with foodborne illnesses increasingly are requiring buyers to use only producers with risk-based food safety programs and verifiable preventive controls. Many buyers have worked with their smaller, local suppliers to explain their requirements, and several buyers offer specialized training and workshops in this area.

    PMA also offers training to help small growers understand how food safety programs can be incorporated into their operations, can be cost-effective, and can open or maintain market channels where buyers require effective food safety programs. PMA has conducted six local grower food safety worshops in 2011 to reach out to small growers and we already have several workshops planned for 2012. This local grower outreach is part of PMA’s overall food safety program, which also includes industry education, advocacy, knowledge generation and outreach.  

    For all of us in the industry it comes down to offering the consumer a healthy, safe product. Consumers want local food and our responsibility is to work together to ensure our entire supply chain can verifiably present effective food safety programs. If you would like to access any of PMA’s local grower food safety resources, please contact PMA’s Solution Center staff by telephone at (302) 738-7100, or by email at solutionctr@pma.com. As always, you can contact me via email at askdrbob@pma.com.

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