On-farm food safety documentation: How much is enough?

Knowing how much documentation is necessary to prove practices were done can be difficult to figure out. Here are considerations when trying to determine how much is enough.

A big reason to have a food safety plan is to provide a proof of commitment to food safety on the farm. So when an auditor or inspector asks that something be documented, the follow-up question from a grower is usually, “How much is enough?”

The best answer is it depends. The level of documentation you need depends on the size of your operation, the requirements of your audit scheme and how critical the particular activity is to ensure the safety of the product.

A larger operation that uses flume tanks to process product may need to keep a record of the water changing schedule of the flume, an hourly concentration of the sanitizer in the flume water, results of a frequent pH test and water testing records, in addition to standard operating procedures (SOPs) for each of these activities. A smaller operation may only use water once per batch of washing, necessitating one record of when water was changed.

Different audits require different levels of recordkeeping. In one situation, including the monitoring of toilets for adequate supplies into a pre-harvest checklist may be adequate for the particular audit. Other audits specify growers must have a separate record for stocking the toilet or sanitation units. Including this information in a pre-harvest checklist likely will not be acceptable under those audit schemes. Even within a particular audit scheme, there may be differences among auditors that can prompt a more aggressive recordkeeping need.

If a particular activity is critical to ensuring the safety of the fresh produce you are growing, expect that it will require more intensive recordkeeping. Worker health and hygiene is critical to ensuring produce is not contaminated. As such, training logs, blood and bodily fluids logs, worker policies, disciplinary policies and records of their activity as well as traceability as to who harvested what product are all essential components to ensuring workers are not serving as a source or route of contamination. By contrast, a simple log of cleaning and sanitizing totes or buckets and a pre-harvest check to verify they are clean at the commencement of filling may be all that is required to address the relatively small risk of sanitary food contact surfaces pre-harvest.

If you have specific questions about documentation or have difficulty tailoring GAPs to your farm, contact Michigan State University Extension’s Agrifood Safety Work Group at gaps@msu.edu or 517-788-4292.

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