Episode Transcripts


Episode 3 Transcript


Introduction: Hello and welcome to the Agrifood Safety Produce Bites podcast, where we discuss all things produce safety and dive into the rules and regulations surrounding the Food Safety Modernization Act Produce Safety Rule.

Emily Hale: My name is Emily Hale. I am a Produce Safety technician with the Blue Water Conservation District and I assist produce growers in Southeast Michigan.

Chris Callahan: I'm Chris Callahan with the University of Vermont Extension. I run the Agricultural Engineering Program within Extension here. My work has focused on post-harvest handling, washing storage, with a focus on equipment and hygienic design most recently. And my role in the produce safety world, in addition to the post-harvest side of things and hygienic design, is I am the director of the Northeast Center to Advance Food Safety, which is one of four FDA and USDA supported regional centers focused on training and outreach related to the FSMA Produce Safety Rule and Preventive Controls for Human Foods Rules, and I am a PSA lead trainer.

Alison Work: And I am Alison Work. I am the Digital Media Designer with Michigan State University Extension for the Produce Safety team. Today we are going to be talking a little bit about cleaning, sanitizing and disinfecting-- why it's important, and when and where you should do it on your farm. The first question here is what is the difference between cleaning, sanitizing and disinfecting?

Emily: So cleaning is the physical removal of dirt from a surface, and usually this includes using a detergent and clean water, usually like scrubbing.

Chris Callahan: Yeah, and then sanitizing is really, you know, I tend to lean on the CDC definitions for these things, and then also the PSA curriculum. So when we think about sanitizing, we're actually talking about going beyond cleaning, beyond the physical removal of germs, dirt, impurities, and actually getting into chemically lowering the number of germs on a surface, or on objects to a safe level, and that's judged by public health standards or requirements.

Emily Hale: And then we have disinfecting, which is the treatment of a clean surface to destroy pathogens on that surface. And this is really done to non-food contact surfaces.

Alison Work: And so what areas on the farm should you clean, sanitize and disinfect? And are there any areas that often get missed or overlooked when it comes to cleaning sanitizing and disinfecting?

Chris Callahan: In terms of areas on the farm that should be cleaned and different ones that might be sanitized, and other ones that might be disinfected, I think of it in terms of, getting back to those different zones, zone one through four, with a primary focus on food contact surfaces. So zone one surfaces, surfaces that we know in normal practice will come into contact with food and making sure that we have an appropriate cleaning plan and schedule for those surfaces. And in my experience, even surprisingly, many of those surfaces do get missed. And sometimes it's just an accessibility or a visibility issue, and one of the things we've been working on a lot is bringing hygiene design principles increasingly to produce operations. And that's a key part of it, is making sure with these food contact surfaces that we can actually see and reach them so that we can at least get them effectively cleaned. And, by and large, they should also be getting sanitized. So again, going back to Emily's introduction to cleaning, we want to first remove any, physically remove germs, dirt, soil, other things, and then follow up with sanitizer to lower the number of germs on the surface, and pathogens on the surface, using some sort of chemical sanitizer or antimicrobial solution. So, zone one for sure. Zone two is definitely considered a best practice to do the same sort of thing with, and maybe on a slightly different schedule depending on the operation. And then I think, you know, going beyond that, zones three and four will likely have a different schedule and different approach but also are very, very important for being maintained with cleaning and at times sanitizing. Emily, do you want to add anything to that before we get into disinfecting?

Emily Hale: Yeah, so I would say when I first start working with a grower who's looking to develop food safety on their farm, I often like to sit down and kind of go through their food contact surfaces, and list those and then how they’re going to clean them and what's the frequency? How often do they plan on cleaning those? And it's definitely going to change depending on what the surface is and how frequently it's going to be used. So that's something I've also found.

Chris Callahan: Great idea, walk through it together and identify all the food contact surfaces. I also think in terms of, when deciding between cleaning, sanitizing and disinfecting, I think it really comes down to what's your intent and what's the trigger for doing this activity? So, you know, cleaning can be triggered by just some visible impurity that needs to be removed. It can also be triggered by a schedule or the need for a clean break between lots or between crops that are being handled. Sanitizing much the same way. I think I may differ with some people on where I'm going next, so I welcome a conversation on this but I do think there are times when we should be considering disinfecting food contact surfaces. And I think the difference between the two for me is if you have a known hazard, we should be considering disinfection. So, if there's something that is clearly a human pathogenic hazard you know, we may want to be looking into disinfection doses and times and application details going beyond sanitizing. And I'm happy to talk more about that but I do think there's another level that may be important beyond just sanitizing, and that's disinfection.

Emily Hale: So if you were to go to the next level from sanitizing to disinfecting food contact surfaces, are you just following a label on that, as far as your steps to disinfecting that food contact surface? And are you finding labels that are addressing disinfection of food contact surfaces?

Chris Callahan: Yeah, I recently went through the labels for common antimicrobial solutions that are used in our area. Everything from sodium hypochlorite-based solutions to peroxyacetic acid and hydrogen peroxide based products. And they, with the exception of one common brand, they all include labeled applications and labeled uses for both sanitizing surfaces but also disinfecting food contact surfaces. And the differences that I noted are the level of the concentration of the product used when mixed for use, and then the amount of time, the amount of contact time. And products also differ, of course, based on what the final step is. You know, some indicate draining, some indicate air drying and some indicate rinsing. But yeah, there are definitely labeled applications that provide for that.

Emily Hale: And what if you were advising a grower to choose disinfection? When would it be better to use a disinfecting step than a sanitizing step?

Chris Callahan: So for me it comes down to the difference between… I mean, what we're trying to address here are the risks of hazards being present. And so to me, what it comes down to is the probability that you have a hazard, and so I think of it in terms of if it's a possibility of a hazard, you know, so for example, we grow in an open environment. And so, there are human pathogens in the open environment. We don't necessarily know that we have a human pathogen on the produce. But there's a possibility of it. And so that points to the need for sanitizing. If we have a known or probable hazard, for example, maybe we have a worker who is diagnosed with a communicable disease, and they have been in contact with a food contact surface in a way that might transmit that. That, to me, is a known hazard. And that really calls for disinfection. So, to me, it's the likelihood of the hazard, and that would determine what approach to take.

Emily Hale: Is this something that you've kind of moved towards recently based off the current climate or is this something you've always advised people to maybe choose disinfection?

Chris Callahan: So my current thinking on this came about as a result of growers asking about what to do in the face of increasingly likely hazards. So, hazards that we haven't been dealing with using traditional training curricula necessarily, and hazards primarily involving labor and work crews. And so yeah, it definitely has introduced a new level of consideration for farms and for growers and as a result for educators like myself, so trying to provide some guidance that will help people decide, you know, when to do either of these things so that on the one hand, we're not, you know, overdosing food contact surfaces unnecessarily, but at the same time, the growers have some peace of mind that they're addressing what could be a known hazard.

Emily Hale: Interesting. Yeah, I guess they hadn't really discussed disinfection like they are now. And then just with the last few, or the amount of information I've gotten, it's always been for non-food contact surfaces. So that's interesting. I've never heard them talk about disinfecting food contact surfaces.

Chris Callahan: Yeah, it is. It's interesting. And I think, you know, I think what we're seeing is a blending of medical practice, or hospital practice with commercial practice, farm practice and home practice. And you know, including to the point where the CDC recommendations for using germicidal bleach isn't even on the label for germicidal bleach for disinfection, so, you know, it's, it's interesting to me, we're kind of in a in a new land.

Alison Work: So then how should a grower decide what detergent sanitizer or disinfectant to use?

Emily Hale: So mostly when I'm talking to growers about using sanitizers, I'm focusing on making sure they have EPA labels for their sanitizers, and they know what the label says and that they're using it how the label directs. That's mostly what I discussed with growers when choosing a sanitizer or determining if the sanitizer they're currently using is safe to be used.

Chris Callahan: Yeah, for a lot of the growers I work with it, it comes down to issues of things like access and availability. So, there are a handful of sanitizers in particular that are readily available through supply chains that they’re accustomed to. We also have a significant number of new or emerging farms, and they've learned what they know working on other farms and so a lot of it comes down to what they've been exposed to and what other folks have used. So there's a lot of sort of peer learning that happens. But absolutely, regardless of all that, I completely agree with Emily's point about being grounded in the label, and understanding why the product is being used, what is the intent, and making sure that intended application is a labeled use and is being carried out in accordance with the label. They can be incredibly confusing with labels. And so I think starting with a very clear idea of why am I using this and to what end and then making sure you ground that application with the label.

Alison Work:So then lastly, what are the Food Safety Modernization Act requirements when it comes to cleaning, sanitizing and disinfecting? For example, what is required versus what is recommended?

Chris Callahan: So, under the FSMA Produce Safety Rule, cleaning and sanitizing are covered primarily under 112.123 and that section asks what general requirements apply regarding equipment and tools subject to this subpart. And in D 1 under that section, sort of the framing requirement is as follows: “you must inspect, maintain and clean and when necessary and appropriate. sanitize all food contact surfaces of equipment tools used in covered activities as frequently as reasonably necessary to protect against contamination of covered produce.” That's a mouthful. But a couple of key things, there's a “must” in there. So, you must do something and that something is inspect, maintain and clean and when necessary and appropriate, sanitize. And then what they're talking about are food contact surfaces of equipment and tools, specifically those used in covered activities. How frequently? As frequently as reasonably necessary to protect against contamination uncovered produce. So this this is a very, very flexible statement in and so as a result, it's also a somewhat vague statement, but it does provide for a consideration of risk at the farm level and the development of not only sop’s, standard operating procedures, but also schedules that makes sense for that farm based on the specific risks. That's how I summarize. That's how I would summarize this. And the rest of it, I think depends incredibly on the individual operation, and the specific line or piece of equipment. But Emily, how do you how do you approach this?

Emily Hale: Yeah, so I usually approach it as you're required to clean and then that line that says, sanitizing is required when necessary and appropriate. So that, we kind of talked about this earlier, is developing those schedules of when you'll be cleaning and then sanitizing is going to help you either move to a different commodity, or maybe establish your clean breaks. And that might be the “when necessary and appropriate”. But it's all, like you said, going to be based off your operation.

Alison Work: Awesome. Well, thank you guys so much for your time today and for coming out and doing this podcast.

Chris Callahan: Yeah, you're welcome. I do have one resource that may be helpful. That's go.uvm.edu/clean-sanitize-disinfect. And one of things that's there is a label comparison between four common products used in our in our area. So that provides a, you know, a summary of the CDC definitions of the different things, but also the labels may be helpful to folks.

Conclusion: Links or definitions to anything referenced in this episode are provided in our show notes, which can be accessed on the website at canr.msu.edu/agrifood_safety. You may also visit the Agrifood Safety website for additional produce safety resources, trainings, and assistance offered by MSU Extension. Thank you to everyone for listening, and don't forget to tune in next month for another episode of our Produce Bites podcast.


Episode 2 Transcript


Introduction: Hello and welcome to the Agrifood Safety Produce Bites podcast, where we discuss all things produce safety and dive into the rules and regulations surrounding the Food Safety Modernization Act Produce Safety Rule.

Phil Tocco: My name is Phil Tocco with Michigan State Extension, based in Jackson County but covering the entire state with on farm produce safety.

Shane Mart: My name's Shane Mart and I'm with H&A farms, a blueberry packinghouse. A number of our growers have U-picks and I have my own U-pick as well. So, we're in Mt. Dora, Florida, so we're just a little bit north of Orlando. So we do blueberries and I've got blackberries that I do myself.

Phil Tocco: So I'm here with Shane Mart, and he's getting the tail end of his blueberry picking season. And so we thought it would be interesting to talk with him a little bit with regards to what he does and what he's done this season different. So I'm curious. You know, every state has really responded differently to this crisis. The responses had various impacts on produce growers. I'm curious. How did Florida respond, and was there any particular impact on your operation?

Shane Mart: I think there was a big impact. Working in the packing house, as well as having my own U-pick and dealing with some of our other growers that have U-picks as well, I've kind of seen multiple viewpoints from our industry, the blueberry industry. The food service market is essentially dried up with the closings of schools, restaurants, cruise ships and everything, and our blueberry season really coincides with spring break, so a lot of people are traveling to Florida to do U-picks and that’s just something families enjoy doing, so I feel like that's really impacted sales. And just not having these big social gatherings… I think that people want to come out in groups or families and pick blueberries and other produce. So yeah, it's been a huge impact on our operations, and we kind of had to get creative as to what we were doing to really bring people still to the U-picks through a variety of different ways, to expand on that.

Phil Tocco: So everyone seems to have various levels of anxiety about our current situation. From a business perspective, was there anything that kept you up at night during the season about the crisis?

Shane Mart: Being the food safety director for H&A, employee safety is definitely a huge concern when it comes to delivering everyone with a safe, wholesome product. So employee health, I mean, that's been the big one. That's worried the heck out of me. You know, you see some of these headlines that we've seen recently with Smithfield, some of their port facilities and everything having to shut down because of the virus. And so that’s really hit home close to us, because we do have a lot of people that work in the packing house, and so we kind of do our best to social distance everybody. We’ve had extended trainings to reiterate the importance of GMP’s and good hygiene practices. But, in some some situations in the packing house, especially, it's really hard to maintain that six-foot distance. So we’ve had to get creative in that regard too. We take temperatures, we’ve got thermal scanners and everything, so before they come into work we make sure they don’t have a fever. Anyone that has a fever or has any symptoms of sickness is not allowed to come into the packing house to work. So that’s been a preventative measure or step that we’ve taken. And then we've got hand sanitizer and soap and hand wash stations about everywhere you can imagine, so we definitely can’t hit home enough with washing your hands. We've added additional people to our staff where all they're doing is going around and cleaning door handles, around the sink areas, anywhere where that virus may live momentarily until it gets on another person. So we really are just trying to step up our sanitation to try to prevent this as best we can.

Phil Tocco: It sounds like you guys really did a pretty comprehensive program with regards to taking care of the employee base. I'm curious about... there's some folks that are walking around, probably with some anxiety that might be your customers. So I was kind of curious if there were any differences in how you advertised to your perspective clientele to address any anxiety they might have about coming out and doing U-pick?

Shane Mart: Surprisingly, there has been a lot of anxiety, but it's also been quite the opposite too in some regard, at least for Floridians. I can't speak for Michiganders or anything, but I know we're not used to being cooped up for long periods of time, so a lot of the families around here kind of have cabin fever, and they want to venture out and do any outdoor activities that they're allowed to do. So what we've done, and I think what a lot of our growers have done with U-picks, we’ve done a great job keeping the customers up to date with some of the practices that were doing to keep them safe. We've got some of the U picks that are doing a curbside pickup where you can call ahead or on their website you can sign up for what products you’re looking for and everything. And you can even pre-pay online, so you don't have to exchange any kind of money. I think that’s really put some of those customers at ease, so they’re not even getting out of their vehicle, they’re rolling the window down. It’s a person coming up to him that just washed and sanitized their hands, handed them their product, and they can be along their way, and they feel good supporting local agriculture. And then I’ve got other ones that are right down the road for me, a friend of mine, they’ve got a U-pick peaches, and they’ve got a sign-up genius. It’s a free program you can get online, and they used that, and they had different time slots that you can sign up for, and they won’t let more than 10 people into that field of that block. So they’ve done everything they can to social distance individuals, so families can still go out and do that outdoor activity and still stay safe and abide by the guidelines set forth.

Phil Tocco: Well, it sounds like you mentioned that Floridians don't like to be cooped up, so I'm curious if there were any differences in maybe the number of the demographics of the customers that showed up this year as opposed to maybe previous years in the past.

Shane Mart: That’s a tough one, because I’ve seen both ends of the spectrum. You see a lot of families with young children and everything that they want to get them out of the house and they want them running around or outside doing something. And you also see some of the older couples that want to get out, and I think their thing is they really want to support American local agriculture. So that’s been a big one. You’ll see a lot of face masks, and we’re doing our part to keep those people that are most at risk safe. So, it’s honestly been refreshing, I guess, to see the pride in which these customers have for taking part and really wanting to get out there and purchase local American produce.

Phil Tocco: Sweet. Sweet. Well, so I heard you talk a little bit about this, but I'm wondering, apart from just signage, were there are other ways that you communicated the changes to customers that you made, or the employees on the farm, how did you reinforce? Because it sounded like you did a lot of things to help make sure that your employees stayed healthy and tried to make sure that there wasn't a lot of spread among your customer base. Were there any special ways this year different than previous years in terms of talking about food safety or talking about just general health and hygiene of workers?

Shane Mart: Well, like I said before, a lot of the growers have closed the U-pick portion of the business and they’ve been doing scheduled pickup hours, which is something normally they wouldn’t be doing, after hours for the people that were on the front lines or different people that still have to work, you know, the essential employees, just doing after hour pick up. Pre-picked produce has been a big thing or new thing I guess. Essentially, the reason they’re coming out to this U-pick is they want to pick their own produce, but they understand that it could be a bit more dangerous at this time, so they’ve been more accepting of buying the pre-picked stuff that’s coming from the farm and having scheduled appointments. Facebook itself has been kind of a blessing and a curse. It definitely helps get the word out, and I’m able to talk to all of my customers that want to come out and say hey, if you’re coming out, this is what I need you to do for me, and if you’re sick, find someone else that can go get the produce for you, and just reiterate the importance of washing your hands. I’ve got plenty of hand wash stations, we’ve got plenty of hand sanitizer when you come out. So really just informing the public ahead of time to what to expect when you come out to the U-pick. So, you know, Facebook, Instagram. Some of the other growers that we have have their own website, were they able to post some of those instructions? And then I’ve gone as far as poster board making, you know, handmade signs as well when they get to the facility. So, I think it really depends on how the operation is set up, and how comfortable that you feel that you’ll be able to follow the rules and limit the spread of that virus. So, all the growers, myself, everyone at H&A and Atwood Family Farms and Southern Hill are ones around our area that we work with, they’ve done an excellent job really doing everything they can to inform the public, preventing the spread of this virus. I’ve seen other ones eliminate cash transactions, so everything is done through PayPal or Venmo, just some of those online cash transactions and so you don’t have the exchanging of money or anything like that, where you could possibly contaminate that person. So that’s been the biggest challenges and different changes to the U-picks.

Phil Tocco: Sweet. One last question, I'm curious, if you could change one thing about this season, what would it be in terms of the way things went and the practices that you put in place? What one thing would you change having to go through it again?

Shane Mart: I think preparedness has been the biggest thing because, really, this has really changed the dynamic of U-picks and a lot of us were not prepared for something like this and having to change on the fly. I think everyone has done an excellent job doing that, but it’s really been a challenge. I think just kind of adapting that situation and really preparing ourselves for the future if something like this were to happen, you know, knock on wood, hopefully we don’t have to deal with something like this in the future. I think larger stock of supplies—I mean, I kind of scrambled trying to find sanitizer, which was difficult to find, so you know, I wish I had a little bit more paper towels. Paper goods are still, I don’t know how it is up there, but it’s definitely difficult to get your hands on paper towels. So, I wish we had a little bit better stock of those kinds of things. We were able to find it and provide the employees and anyone that comes out to our farms with hand sanitizer, but it’s definitely been a struggle to try to find some of those goods. So, I think in the future I will definitely have a larger supply of that, so I don’t have to scramble around finding it.

Phil Tocco: I think we all have learned the value of having an extra roll of toilet paper squirreled away somewhere, or the same thing with with paper towels. Shane, thanks so much for joining us today. I really appreciate it. I really, I think you bring a really good perspective because we're maybe a month or two months away from... a month and a half away from strawberry season and then blueberry season to follow. So, you know, we're still trying to learn and negotiate this stuff and I really appreciate your perspective because I think it'll bring a lot to the U-pick folks up up this way.

Shane Mart: Absolutely, any time.

Conclusion: Links or definitions to anything referenced in this episode are provided in our show notes, which can be accessed on the website at canr.msu.edu/agrifood_safety. You may also visit the Agrifood Safety website for additional produce safety resources, trainings, and assistance offered by MSU Extension. Thank you to everyone for listening, and don't forget to tune in next month for another episode of our Produce Bites podcast.



Episode 1 Transcript


Introduction: Hello, and welcome to the Agrifood Safety Produce Bites Podcast, where we discuss all things produce safety, and dive in to the rules and regulations surrounding the Food Safety Modernization Act Produce Safety Rule.

Marissa: My name is Marissa Schuh, and I'm a vegetable production educator with Michigan State University Extension.  

Mike: My name is Mike Snarski. I'm the manager of Summit Laboratory out of Grand Rapids, Michigan. 

Marissa: So the reason we wanted to get together and talk about water testing is because when it comes to doing FSMA compliant water testing it seems like growers speak one language, labs speak another language, and the FDA speaks a whole other language so it can be very tricky to figure out what you need from a lab, and how to find a lab that can give you the testing, the numbers, that you need to comply with the Food Safety Modernization Act. So we just wanted to have a conversation to help figure out how to get what you need from a lab. 

So, in our experience reaching out to labs and figuring out if they can do the testing that's required by the law, we found that you can really get ping ponged around by the people who answer the phones, the sanitarian, all kinds of people can be involved in trying to figure out if the lab can do the testing you need to do. So we want to get a little input from Mike here, who's been on the other side of the line and can do the testing, on how to help you navigate this system. 

So I want to run by a couple questions with you, Mike- things a grower might ask and how, what you as a lab, what you hear when a grower asks this question. 

A grower might call up and start the conversation with, "can I get a water test from your company?" What do you hear when you hear this kind of question?  

Mike: So when I receive a call from a farm that's doing the irrigation water testing, the main thing I need to know is what is the test for? Once they tell me it's irrigation water and they know that it's E. coli testing, then we know on our end what they need. They need the enumeration E. coli method on that water.

So, what it would transform into from there is I need to tell them there is a certain sample period time that they need to get that sample to us. There's paperwork that they need to fill out. We'd like them to fill out the paperwork ahead of time if they can. That paperwork should be available– if they don't have access to the website, we can email that to them. Otherwise, if they don't have that, we will fill that out when they bring the sample to the lab. 

Marissa: Yeah, so you mentioned timing. One of the key parts about all the different testing methods under the rule is that it has a hold time of 6 hours, so that means you as a grower have 6 hours from the time you dunk that bottle into the water, take it from your spigot, whatever, to get it to the lab for testing. So you have a really short turnaround time. So it's important that, even before you call the labs, you know they're local and they're somewhere you can get in a pretty short turnaround time.

Do you have any tips, Mike, for when you're transporting the sample from the farm to the lab? How do you keep that sample good? 

Mike: Key thing is that timing because you need to look at your scheduling, when you're going to collect that sample, do you have time to transport that sample to us pretty much promptly right after you collect it, how will that fit the schedule, making sure you're going to get to the lab within their normal business hour times. Our business hours are 8:30 to 5:00. Sometimes we can accommodate outside of those hours if you can't get to us in that time frame, but the main thing is, we have to receive that sample within that 6 hours. It has to be processed within that 6 hours.

What you want to do with that sample is, if you're holding it at any point in time you want to put that sample in a refrigerator or in a cooler with an ice pack. An ice pack is better than ice– we don't want ice melting and leaking and potentially contaminating the sample. What we would use is maybe a cooler box with an ice pack that you have designated for these types of samples. And keeping it on an ice pack, typically you're gonna be out in the field, so you probably have some type of carrying vessel for your containers, so a cooler box that's designed to hold temperatures, and then you can use that to transport that to the lab. The main thing is cooling it. After you collect it, keep it cool, don't let it get hot, don't let it get into direct sunlight. So if you're using some kind of carrying vessel it will protect it from that. 

Marissa: Yeah, and when you're transporting it, it's also important that when you're taking the sample, before you even take it at all, that you have the right kind of sample bottle. In our experience, most labs in Michigan will provide you with a sample bottle. Mike, do you want to talk about what to look for in those?

Mike: Yeah. The thing is, what we are held to is they would state it as an approved container, and ideally an approved container is sterile. Those are best. We typically have those containers on hand. If you need several, we can provide you with that. That's the main thing is the sterile container, because you know when you put the sample in that that is what's being represented is just that sample– not what was in the container.

So our lab times, you know we're open from a Monday through Friday, we will accept samples Monday through Friday from 8:30am to 5:00pm, but we do on those days, if you're running towards the end of the day, ideally we want to see that sample by like 4:30pm so we have time to process that sample. If it's gonna run towards the very end of the day, let us know ahead of time. We're always willing to stay a little bit after to get that sample process but ideally we want that sample process by 5:00pm. 

Marissa: Yeah. Another important question for a grower to ask is do you do the tests in-house? This comes back to that 6 hour hold time we discussed. If that lab is packaging up the sample and sending it out to the state lab in Lansing, you're gonna miss your 6 hour hold time and that sample's gonna be no good, so it's really important to understand that a lab is going to be able to do your tests in the 6 hour timeframe, which likely means being able to do it in-house. 

Mike: Yeah, most definitely. The lab would have to do that, and what I would anticipate is that you're seeking out a lab that is certified by the state for the enumeration of E. coli. That is offered to labs. I know it's a Michigan DEQ requirement.

Marissa: One thing that I've run into when trying to figure out if labs can do compliant testing is the language "surface water". This is something that we talk about a lot with the rule. There's different testing requirements for water that the FDA call "surface water". What do you guys hear as a lab when you hear surface water, and how do you... what kind of information can the grower have to help you figure out what they're actually trying to get done?

Mike: Yeah. The main thing, like I said earlier, is if they know that this is ultimately for irrigation. Whether it's surface water, a well, you know, either way, it's still going to be tested for the same enumeration of the E. coli. We know that the surface water obviously is gonna have more of an influence from the E. coli than a well, but still they're going to be held to that same requirement to test for that. 

Marissa: Under the rule, any water that touches the harvestable portion of the crop would be water that needs to be tested, so irrigation, even if it's, you know, water using for a fungicide spray that you need tested, irrigation might be a key word for a grower to use to help really break through with the lab at what you're trying to get done.

Another important thing I think to ask with surface water is if the lab can handle water that's cloudy or turbid. If you're taking the water sample from a stream or a pond, for example. 

Mike: Yeah. The turbidity will have an influence. It does make it harder for interpretation of the results. Ideally, the less turbid, the better. If the water has some turbidity to it, it's just a natural turbidity, that's fine, but if it's something that's stirred up because you're getting into the water and you're stirring up the sediment and it's more turbid than normal, that will have an influence. We don't want to... we want to see that turbidity as less as possible. If it's a stream and you have to get in there, you know, obviously when you're going in, you're collecting up stream. The sample is collected upstream of you instead of down stream because you're going to be stirring that up. If you have to get into a pond or surface water, same thing, you know, getting in there and getting that sample collected as soon as you can so you're not stirring up a lot of sediment that's gonna be in there that naturally isn't there. 

Marissa: So once you've figured out that the lab is able to test your surface water, it's really important to make sure you're using one of the EPA testing methods that has been approved by the FDA. So if you're calling a lab that's new, as a grower, it might be helpful to print out the list of approved methods. They're not easy to remember off the top of your head. They don't sound like regular English, so it can be helpful to have those printed off so that you can, if you're working with a new lab, kind of run through... "I'm looking for Quanti-Tray 2000... Colitert tests." Really know what you're asking for with the new labs so you can get what you want. 

Mike: Yes.

Marissa: As a lab personnel, is there anything you want growers to know as they bring you tests? Common mistakes you see in water testing?

Mike: The main thing is obviously the representation, making sure the sample just represents what you're collecting, making sure you're collecting it in what we would say is an aseptic way– you're not contaminating the inside of the container. The key thing is documenting the date and time that the sample is collected... identification of that sample, so when we report it that's what you want on the reports. The hold time that, you know, you're only allowed six hours, and the type of container, and how you're handling that sample from when you collect it to getting it to the lab. You don't want to go outside of that, and make sure that it's not a true representation of that sample. 

Marissa: Yes, there are all kinds of things that could artificially cause your E. coli numbers to go up or down. It could be you didn't handle that bottle right, maybe you didn't think it was clean so you rinsed it out. You know, e. Coli is in the environment all around us. We have pets, we have kids... so we can introduce E. coli artificially into our water samples if we're not handling it correctly.  

Mike: The other thing too is making sure you're collecting at least 100 milliliters of that sample. Most containers, they have an indicator around the container– if you're using an approved EPA container, it does have an EPA mark on there at the 100 milliliter mark. We want to make sure that you're collecting at least that. It can be more than that, bu tit needs to be at least 100 milliliters for representation.

Marissa: And if your lab is doing one of these approved methods and giving you a bottle, it should be the kind that's gonna give you the 100 milliliters you need to get one of these tests done. 

Thanks, Mike! I think this is really helpful. Lots of good information there that can help growers around the state figure out how to get the water testing they need done. 

So, let's talk a little bit about what the law wants to see in terms of your water testing. 

Depending on your farm's gross annual produce sales, sometime between 2022 and 2024, farms will need to start building a microbial water quality profile. The numbers used by this profile are taken from a series of water tests. The water tests are meant to be representative of use, meaning you take them at the times while you're using the water, so you'd use it in time with frost protection, when you start your crop sprays, when you start irrigating, that kind of stuff.

The number of tests you need to take to build and maintain the profile vary by your water source. For municipal water sources, no additional testing is required. Instead, growers need to get documentation about the monitoring and treating of the water from their local municipality.

For ground water sources like wells, in the initial year of testing, growers need to take 4 samples to the lab. These 4 samples will be the basis of the microbial water quality profile. The next year, 1 new test has to be done, and then you'll kick out one of the original tests in your profile, add in the new one, and do your math over again. From here on out, you'll just be taking one water test to the lab a year, adding that one to your profile, taking one of your old numbers out of your profile, and redoing your math. You'll be eventually working off a rolling 4 test average for your microbial water quality profile. 

Surface water sources like rivers, streams, canals, and holding ponds, are open to the environment. This means it is much harder to predict the quality of the water. Thus, these sources require more testing to build the initial profile. 20 samples have to be taken over the course of 2-4 years. Once you have these 20 samples, you generate your microbial water quality profile. The next year, you'll only need to take 5 tests to regenerate your profile. You'll kick 5 old tests out of the profile, add your new 5 tests in, and from there recalculate with your new 20 sample microbial water quality profile.

If you are currently testing, you don't need to do any radical changes yet. You're doing the right thing already. If you are a farm that has never tested your water before, it's good to start. As you can hear from this conversation, it can be really complex getting your water sampling regime in place and figuring out what labs can do the testing you need. So if you've never tested before, it's a good time to start talking to labs, taking some test samples, and figuring out how you're gonna work water testing into your farm's regular procedures. 



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