Salad Greens and HACCP

Food safety is on the local farm radar as proposed legislation that might have wide-ranging impacts on small farms that do basic packing and processing on-farm. CISA’s feasibility research on HACCP for salad greens can be helpful on several fronts as Massachusetts farmers navigate the continued evolution of food safety requirements. While the focus of our research has been on the market as a driver – large chain stores interested in buying local but requiring third party HACCP audits for salad greens after the spinach E. coli outbreaks of 2006 – the lessons we learned can help farmers prepare for voluntary market programs and regulatory changes and advocate for practical approaches to food safety.

One thing we’ve learned since the spinach outbreaks is that food safety is a moving target, and one of the biggest challenges is finding the program that works for farmers, meets buyers’ expectations, and can be adaptable for future regulations.

Feasibility Report
Is it possible for local farms to meet emerging industry standards for packed salad greens? CISA’s research focused on determining if it is worthwhile for local greens growers to pursue third party audited HACCP for the markets that require it. What are the benefits and the barriers farmers will find along the way?

Audits for On-Farm Processing: Intro to GAPs, GMPs, HACCP
CISA worked with Vermont Food Venture Center’s Brian Norder to develop an introduction to food safety programs and audit requirements.

Self-Assessment and Cost-Benefit
Is HACCP right for you? What are the biggest questions or barriers that arise when you’re working on improving food safety on the farm? This simple cost and benefit analysis and farmer self-assessment will help you start to identify next steps.

Wholesale Salad Greens Market Study
What does the wholesale market for salad greens look like from the perspective of western MA buyers and what are food safety requirements? Read CISA’s survey results to determine the wholesale market potential for locally grown and packed salad greens, and buyers’ evolving preferences for food safety practices.

Cash Flow Template – Salad Greens & Food Safety Upgrades
What are the financial considerations related to pursuing third party HACCP audits? CISA’s cash flow template provides farmers with a simple tool to chart different scenarios for their salad greens enterprise, calculate the financial implications of pursuing HACCP, and understand the impact of volume, target market, and capital and operating costs on the overall viability of their business.

Food Safety Programs for Farmers

The following programs are optional at this point, meaning they are not currently required of farms through regulation, but may be required for marketing purposes, whether through USDA commodity programs or chain stores interested in selling local products.

GAPs:
Good Agricultural Practices are a manageable first step for farms looking to upgrade their food safety practices, and is a prerequisite for any farm considering HACCP plans or audits for their finished product. The lessons and record-keeping established as part of GAPs and a self-audit can be applied throughout the farm enterprise, and will prepare the farm operator with more background data as a foundation for a HACCP plan.

Farmers can find detailed GAPs resources here:

GMPs:
Post-harvest protocols like Good Manufacturing Practices (GMPs) are most commonly applied to food processing facilities and often exclude raw agricultural commodities (including salad greens). However, these protocols are now being applied to salad greens by retailers part and parcel with HACCP audit requirements. GMPs are a particularly challenging prospect for small farms because they require facilities for “processing”, like commercial kitchens with washable surfaces, food contact approved equipment, and extensive documentation.

Quality Assurance outline– designed with Brian Norder
CISA developed a Good Manufacturing Practices example index for farms that may be engaged in processing activities and/or intend to pursue HACCP audits. Additional template forms and logs are available by request.

Equipment & Facility Recommendations
We found that there are limited equipment options for small-medium scale producers, and compliance with GMPs may require substantial investments to bring packing sheds into line with the commercial kitchen standards designed for food processing activities. However, some basic upgrades can reduce the chances of pathogen problems and should be considered by all farmers. Equipment doesn’t solve the HACCP conundrum, but it can be a good first step. Having the right equipment and facilities can improve a farmer’s chances of implementing SSOPs correctly by being designed for easy cleaning, and bringing a professional confidence to the overall operation. Investments should be prioritized in terms of items that can serve other needs (such as efficiency or worker health) at the same time.

Case Studies – Salad Greens Packing: On-farm vs. Off-farm
This document walks through the possibility of using an established commercial kitchen for the packing of greens to meet HACCP prerequisites (namely GMPs) and auditor requirements. We used the example of our local incubator kitchen, the Franklin County CDC’s Food Processing Center, to think through the pros and cons of on-farm and off-site packing. While working with a food processing incubator may be an efficient partnership for some producers, salad greens harvested in warm temperatures have the distinction of needing immediate on-farm hydrocooling for quality assurance – often making it redundant to rinse and pack at two separate locations.

HACCP
HACCP for raw agricultural products like salad greens is unique – and controversial – in that it can help reduce or prevent risks, but will not eliminate them (like a cooking step would for processed products). The incremental benefits provided by HACCP for raw agricultural products like salad greens has been debated, when prerequisite programs like GAPs and GMPs have been used as the controls in HACCP plans. One argument suggests that a HACCP approach requires a more conscientious review and monitoring of the results of prerequisite programs.

HACCP Plan
CISA developed a HACCP plan template in collaboration with a nationally-recognized food safety firm. While the prerequisite programs are a good starting place for everyone, reviewing this HACCP plan example is useful to see what kind of activities and documentation a third party auditor might expect from you. This example plan is available by request.

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