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- From: KAKerby AT aol.com
- To: market-farming AT lists.ibiblio.org
- Subject: [Market-farming] GAP summary (long)
- Date: Mon, 15 Mar 2010 12:31:09 EDT
Good morning all. I've held off writing up my GAP thoughts because I
wanted to talk to a variety of other growers first, to see what their
impressions were in addition to my own. What I found was that grower
impressions were all over the map. Before I get into those reactions, here
is a very general summary of what I learned:
Top Bad Guys: E coli, salmonella and listeria. But Campylobacter is in there too. If growers have a program that adequately control E coli and listeria, the other two are probably adequately controlled as well. E coli has become something of the poster child for this whole thing because it is so pervasive in the environment, is so adaptable to various conditions, and its toxicity is so variable, ranging from beneficial to deadly. Any warm-blooded animal can produce any of the variants, from beneficial to deadly, simultaneously, and without showing outward signs of illness. So the presence of one form of E coli is sufficient to be concerned about the presence of more toxic forms. Salmonella is the most common form of mild to moderate sicknesses by number, but listeria is the biggest single killer. Campylobacter is a distant fourth, but is still significant from both a public health and economic impact standpoint. Manuring/Harvest separation times: The standing 90 day separation for
above-ground crops and 120 day separation for root crops stands, for now.
But strong research results are coming in that indicate that separation time
should be increased to 200 days where possible because E coli continues to live
in soil for much longer than anyone expected. This seems to be the case
regardless of how the soil is managed. The vast majority of manuring
issues with E coli can be dealt with by manuring the beds or fields in fall
rather than springtime. One of the specific things I asked during that
second workshop was whether E coli survival rates had been tested in certified
organic ground; those results are being compiled now but seem to be fairly
consistent with previous results that E coli can remain viable in soil up to 200
days after application. Also, the carrot/onion study I cited before
was only one of a whole body of research, all of which show that E coli (and the
others) are very persistent in a wide variety of environments, and very potent
once ingested.
Irrigation: overhead irrigation is being strongly discouraged wherever possible, because one of the greatest contamination risks comes from contaminated water being sprayed on crops. Drip irrigation is the hands-down recommendation for most applications where scale allows, but any form of irrigation which keeps water on the ground is recommended over irrigation wheel, pivot systems and similar. In terms of sheer contamination potential, irrigation water is the greater threat than actual manure application, simply because water can carry contamination to untreated fields where manures are not otherwise present. Employees: employee movements in the field remains the #1 source of
contamination. Of those movements, failure to wash hands is the single
most common form of employee-caused contamination. Many farms face greater
GAP challenges on the employee front than they do on the manuring front, because
all levels of the operation - pre-planting cultivation, planting, in-row
weeding, harvesting, processing and packing - can involve the potential for
contamination to spread from where it is to where it shouldn't be, particularly
from the restroom to the fields.
Equipment management: the general rule of thumb is that existing cleaning
methods for equipment is fine IF that cleaning addresses any pockets, crevices,
nooks/crannies and other corners where dirt or contamination can otherwise build
up. Harvest crates were a huge topic, because they are handled so
often, commonly stored fairly dirty, and come into direct contact with
ready-to-eat fresh produce. Ventilation was also important because any
contamination there spreads aerosolized bacteria throughout the rest of the
operation.
Composting: the recommended method for composting remains the certified
organic protocols, which are not expected to change.
Documentation: there are no universal documentation requirements, but the
more specific the documentation is already in place (or can be put into place)
the less impact the grower will suffer during any particular contamination
issue. For instance, one recent contamination issue found contamination
occurred from one grower whose produce went to two wholesalers. One
wholesaler kept impeccable records and was able to identify the boxes containing
that grower's produce from the suspect date range, and pull just those boxes out
of circulation. The other wholesaler didn't keep such good records and
that produce had been mixed in with other growers' product. Everything
that had come in during that date range was therefore suspect and had to be
pulled out of distribution. Growers were told during the session that if
they couldn't make any other changes to their practices, invest time in their
recordkkeeping to help minimize the impact if a contamination event ever did
occur. Records like "this field manured on this day, planted or cultivated
or harvested with X crop by Y employee, packed in box #x to #y by Z employee,
shipped such-and-such date" is the type of documentation they're looking
for. In most instances, records kept for certified organic operations are
sufficient with very little tweaking.
GAP recommendations versus certified organic standards: any grower who is
already certified organic is already 95% of the way to meeting GAP
standards. A review and refinement of cleaning practices and employee
habits would probably provide the other 5%. Certified growers are also
already meeting the bulk of the record-keeping recommendations as noted
above.
Now, for grower/market manager/public reactions: Some growers I know got
disgusted very quickly, and didn't attend the second session. Several of
the growers I talked to considered GAP just one more thing they knew was
coming down the pike. One attendee was the farm manager for one of
our larger operations in the area, and she had worked at other on-farm
processing facilities, one of which suffered a listeria contamination
that had shut down the operation. She seemed eager to get her
employees started on these new guidelines. Her biggest worry was trying to
make management understand this was not optional for liability reasons, even
though they were still only guidelines. Other growers didn't fret too much
about these changes either because their procedures were already very close to
what was being recommended, and/or they operated without manures and/or
employees. Oddly, the certified organic growers were the most annoyed even
though they were already the closest to meeting the new recommendations.
And finally, a number of growers I have spoken to expressed concerns that this
was just another piece of the "Monsanto taking over the world" machinery.
While I am not privy to Monsanto's diabolical plans, I came away from these
sessions feeling like that particular response was an over-reaction, and perhaps
even an unfortunate and damaging over-simplification, for what is a much
more complicated and very-long-running topic.
Perhaps the most telling part for me came a few days ago, when an
email was sent to area growers from a local farmer's market manager. She
said that she had already been contacted by an number of market customers,
asking if it was still safe to buy from vendors at the market, because of food
safety concerns. Some of those customers specifically asked if the market
had a GAP requirement in place for the vendors who sold there. That
particular market manager has asked for a special vendors meeting where that
topic will be discussed, and hopefully a strategy formulated that everyone can
buy into (literally or figuratively), to help reassure buyers that the market is
selling safe produce. As was predicted in class, any sort of regulatory
legislation is probably secondary to the buying public's demands for some kind
of food safety accounting system.
My own farming system relies very little on employees so I only have myself
to train in that regard, but we rely heavily on manure and compost. I
asked myself several times if, having learned what I learned in class, I would
consider making these recommended changes on my own without any outside
pressures from regulatory bodies or customers. I have to say that, given
what I've learned, I would already be putting these changes in place
anywhere/everywhere they apply to my operation.
Also, from a historical perspective, there is a lot of precedent for any
new set of guidelines or recommendations to be met with much gnashing of teeth
and predictions of "the end of things as we know them". Yet that doom
never materializes. The meat and dairy sectors have already gone through
this process, and small scale producers have weathered that transition in both
sectors. Some would argue that small scale processors were given a leg up
if they could meet the initial costs, because they were then able to compete
more effectively in the more lucrative retail marketplace. I firmly
believe this is going to be the same result for GAP produce
recommendations.
Bottom line, the marketplace will continue to demand tighter growing,
processing and packing conditions of produce growers, whether those demands are
justified or not. When I got that email from the farmers market manager, I
realized two things - first, if there is some diabolical plot, that's now a moot
point because the public has already reached a point of deciding they need this
for their own protection. As a grower, I can either meet that requirement,
or not sell to them. And that pool of "buyers who don't care" is shrinking
every day. Secondly, if I am angered or frustrated or further taxed as a
result of all this, it would seem the best application of my limited energies
would be to first meet the requirements so I can at least continue to sell, but
then also ramp up my educational efforts to help demystify this magical thing we
do called growing. Only when people are well educated about the real
risks, and real benefits, will they collectively decide that our methods are
better than any other approach. So, at the end of the day, that's what I'm
going to do.
Kathryn Kerby
Frog Chorus Farm
Snohomish, WA
|
-
[Market-farming] GAP summary (long),
KAKerby, 03/15/2010
- Re: [Market-farming] GAP summary (long), Road's End Farm, 03/15/2010
-
[Market-farming] GAP summary (short),
Richard Stewart, 03/16/2010
- Re: [Market-farming] GAP summary (short), BarbaraJ, 03/16/2010
- <Possible follow-up(s)>
- Re: [Market-farming] GAP summary (long), Debbie Moore, 03/16/2010
-
Re: [Market-farming] GAP summary (long),
KAKerby, 03/16/2010
- Re: [Market-farming] GAP summary (long), Todd Lister, 03/16/2010
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