PSA Working Committee 4: Core Curriculum. Hazards and Preventive Control – Production

8/5/11 Minutes

Attendance: See Excel Spreadsheet of Membership and Roll.

Logistics: It was noted that in a few instances background noise during a call has been a challenge. Participants who are participating in an active or windy environment can use *6 using conference call system to mute and activate their phone as needed or utilize the mute function associated with their phone.

Fred and Karen thanked the committee for their participation through email submissions over the previous weeks. The amount of information and level of participation was very useful in developing committee notes and organizing topics for the call. Taking the time to submit comments and information is greatly appreciated.

Chemicals: The following topic areas were discussed, as outlined in the meeting’s agenda: preparation of chemical compounds and additives, calibration of spraying equipment, potential for drift, storage, disposal, personnel and training and recordkeeping. Committee discussion for chemicals for the 6/24/11, 7/15/11, and 8/5/11 meetings is captured below under “Notes”. The initial discussion of challenges associated with chemicals was concluded. The committee will revisit this topic and our notes as we move forward with setting goals and objectives later in the process.

Topics for the next call:

1) Animals: Wildlife and Domestic (Pets, Animals used in Production and Livestock). An outline of topics related to animals was developed.

Proposed Next Call: August 26 at 4:00pm ESTEmail alternative suggestions if this doesn’t work

For the next call, please submit the following by August 23:

  • additions/corrections to the 8/5/11 minutes
  • topics and discussion points for next call(Animals-wildlife and domestic)
  • Educational materials, relevant websites or links, etc. related to next call

Fred Finney: aren Killinger:

Please send topics you’d like to discuss on the next call to Karen and Fred so they can be included on the agenda. It will really help ensure that everyone’s topics of interest are discussed on the call.

PSA Working Committee 4. Core Curriculum. Hazards and Preventive Control – Production

Agenda: 8/26/11 4:00pm EST

Dial In Information 1) Dial: Toll free 1-800-566-2245 Toll/International 1-913-312-9372
2) Enter Passcode: 602351

  • Roll Call and Logistics

Animals : Domestic (Pets, Animals used in Production and Livestock) and Wildlife

Definitions

What terms need to be defined?

Animals used in production (used as a source of power)

Animal Risk Assessment

Documentation of pets, animals used in production and livestock

Observation of domestic animals and wildlife

Livestock

Rotational Grazing Schemes

Animals used in Production (used as a source of power)

Ag Tourism Animals – Petting Zoos

Domestic Pets

dogs, cats, etc. (A lot of people are not aware cats can be attracted to garden areas)

‘How to” keep animals out of fruit and vegetable production

Use of Animals for Pest Management

Pollinators

Preventive Measures and Mitigation

Types: Vegetative Filter strips, other buffers, Fencing, Physical Exclusion, Trapping, Noise/Sound

How much exclusion is “enough”

Corrective Actions

Buffer zones around animal droppings

Documentation

Federal, State, Local Laws on Wildlife Control

Pathogens associated with Wildlife – Risk Assessment

Type of animal and association with pathogen

E. coli O157:H7, Salmonella,

Wild pigs, elk, deer mice, crows, deer

Leafy Greens lists pigs (wild and domestic), deer, goats, sheep and cows

Need to classify types of wildlife

PSA Working Committee 4. Core Curriculum. Hazards and Preventive Control – Production

Notes 4.1.3 Chemicals

Definition of Terms: The committee felt that a list of terms and definitions would be useful to help clarify terminology, especially to identify terms for compounds that can crossover between conventional and organic methods. A point was made that overall, it may be important to emphasize in definitions the intended use of a particular compound in order to develop definitions that can be utilized for both organic and conventional management systems. The National Organic Standards has a list of definitions that may be useful.

The following words were recommended to be defined in a GAPs food safety curriculum:

Chemicals – the group discussed that most compounds are chemicals (water, salt, etc). There is a need for some sort of broad statement that the chemicals are related to the production of crops. Perhaps defining that this segment of the curriculum is referring to chemicals for disease and pest control, including pesticides (for weeds, insects, etc.), fumigants, herbicides, fungicides, insecticides, and fertilizers.

Compost Tea – A question arose as to whether compost tea would qualify as a compound used for crop protection. Discussion items included: the need for labeling requirements, MSDS information, and the amount of supporting documentation for compost teas as a pesticide. The group agreed to table this discussion until soil amendments are discussed.

Crop

Crop Protection Materials/Inputs

Fertilizers

Food Product – in terms of a food product that might be used for crop protection (vinegar, Mt. Dew)

Pest Control

Pesticide

Plant Food Product– in terms of an organic compound that is utilized as a fertilizer

Primary Container

Secondary Container

Sanitizers* - topic covered by WC #6. This topic will be addressed in the final curriculum but will not be covered in our committee.

Soil Amendments

Soil Enhancement

Supplement

Overlap with other Committees:

It was discussed that land history and adjacent land use would be covered by Working Committee #3. Sanitizers and chemicals applied to crops post-harvest will be covered by Working Committee #6; however, overlap was identified regarding storage of chemicals. Wes Kline, WC #6 co-chair, was present and

Big Picture Discussion Points regarding Chemicals:

  • Requirements are similar across commodities
  • Recommended standard operating procedures
  • Short cuts are not recommended
  • Don’t do anything from memory
  • For beginning farmers, providing links to needed information on chemicals is useful
  • Educational materials should emphasize that the majority of chemicals are not lethal to human pathogens. The majority of insecticides, fungicides and fertilizers have not biological effect on human pathogens. It is possible that some can support pathogen growth. Ex. Elemental sulfur.

Gasoline and other chemicals that are not considered agricultural plant production materials

The group discussed that non-agricultural chemicals need to be mentioned as many items are relevant to this class of chemicals as well (spills and leaks, run-off, storage). Many of these chemicals can linger in the soil if spilled in fields.

Plant Foods and Fertilizers

Potential Challenges:

Would these compounds support pathogen growth or survival? See discussion under preparation of chemical compounds.

Do they contain toxic compounds that need to be identified?

Purchase, Registration and Use:

Discussion Points:

  • Compounds need to be EPA-approved and specifically labeled for that crop and intended use (same applies for sanitation chemicals).
  • Make sure all chemicals are registered
  • Need to know if compounds are labeled for general/home use or restricted use (require an applicator’s license to purchase and use)
  • Emphasizing to growers that they are responsible for documentation of the source and purity of chemicals purchased (esp. imported chemicals). Use of letters of guarantee, etc.

Purchase, Registration and Use:

Challenges:

Differences between states exist for purchase and use. A curriculum might need to mention that all compounds must be purchased and used in accordance with all federal, state and local jurisdiction regulations and all licensing requirements. Some states might benefit from more in-depth training on chemicals in a food safety curriculum (see examples below)

  • Participants from New Jersey and California shared that a pesticide license is required for all agricultural operations (including organic operations) to apply general/home use and/or restricted use chemicals
  • In contrast, participants from Ohio indicated that a license was only required for agricultural operations using restricted use chemicals.

Use of compounds not normally described as compounds for crop protection (food products, etc) as additives or stand-alone compounds.

  • Challenges were identified with off-label usages or addition of unapproved compounds
  • Example: Homemade vinegar or apple cider vinegar used as an acidifier, sugar to attract insects
  • Challenge – Additive into a spray to enhance results
  • Example: Mountain Dew added to standard insecticide – FDA would have problem with it
  • When is an additive to the spray an adulteration and when is it an enhancement? The simple farmer question is if we add something that is already edible, why is that an adulteration or is that OK? This is an area that probably will need to be explored, more so for the small grower who is trying to be as low impact and chemical free as possible.
  • Although an unapproved additive might appear to be beneficial, legal ramifications must be considered
  • Legal ramifications
  • Comment provided via email from committee member:

EPA's regulation,40 CFR §180.950 (), "Tolerance exemptions for minimal risk active and inert ingredients, Subpart D - Exemptions From Tolerances" paragraph (a), "Commonly consumed food commodities" as an item classthat is exempt from the requirement of a tolerance. Although yes, in the case described MtDew is a "pesticide" by definition, it is also exempt from tolerance by EPAso therefore would not be an adulterant per FDA.

  • Betsy has requested input from FDA on this item also.

Storage

  • Security of pesticide storages – locked storage
  • Do not store liquids above powders
  • Store like chemicals with like, herbicides should not touch insecticides, etc.
  • EPA information is available on cross-contamination
  • Maintain proper storage temperatures
  • Separate pesticide storage unit from packing of produce. Must be separate building.
  • Properly labeled containers – commonly neglected/overlooked
  • Maintain an inventory of chemicals

Preparation of Chemical Compounds and Additives

  • Mixing chemicals – awareness of hoses, potential for backflow
  • Sanitation of physical environment and equipment used to mix chemicals
  • Importance of maintaining a clean and sanitary environment

Calibration of Spraying Equipment

  • Some states require documentation of calibration for food safety plans
  • Resources available

Application

  • Bottom line: Read the label and follow label instructions
  • Time of Application
  • *Pre-harvest intervals are important to emphasize in education, follow labels
  • Prior to Planting - Fumigants –used in soil, prior to planting
  • During the Growing Season- Fungicides, insecticides, herbicides, and foliar plant foods.
  • Post Harvest–

Applications to produce prior to storage or packing shed (covered in WC #6)

Application to soil or plants (needs to be addressed by this group)

Might be the same applications

  • Awareness of Surroundings - Chemical Drift, Overspray,

Proximity of organic and conventional

  • Waiting periods (read label) Both pre-harvest intervals and crop rotations
  • Proper cleanup of equipment between usages (no cross-contamination of chemicals)
  • MRL’s - Maximum Residue Levels allowed on product. The group discussed that this is primarily a trade issue. Application according to the label should address this issue. Country (Codex MRLs, US MRLs, etc) and commodity differences exist.Label does not cover MRL. Country (Codex MRLs, US MRLs, etc) and commodity differences exist. Awareness of MRLs and working with buyers to identify correct levels. Foreign Ag Service has a database that will useful. (EPA and USDA). Change on a daily basis.

Potential for Drift

When must a crop be abandoned?

Programs for drift are available. Some states have a pesticide sensitive registry available that is a free resource for producers within the state.

Spill Management

  • If spill in the field, how much of an area needs to be blocked off?
  • Would there be differences between harvest times and off-season?
  • Is this information provided by supplier?
  • If not, what resources are available to assist? Need to identify
  • LGMA – discusses spills for fecal materials (5 feet), no information on chemicals?
  • Each state might have own recommendations
  • MSDS - management for specific pesticides (don’t provide specific distances)

Disposal

  • Hazards associated with cross-connection in water systems (potential for chemicals to contaminate water used for other purposes)
  • Some Departments of Agriculture offer programs to drop off and dispose of chemicals
  • Useful for educational programs to provide examples of what can go wrong (farm or well becomes contaminated)

Personnel

Qualifications and Requirements to apply certain chemicals

Every state has requirements for training

Overlap with food safety training exists

Personal Protective Equipment – different than worker health and hygiene component

For small farms, need to consider changing from PPE toclean clothes for other activities

Many resources are available

Training

Education and Awareness of Consequences

Providing Examples of What can happen

Legal Ramifications

It is important to consider the audience and keep information simple to convey with clarity

What topics need to be included in food safety materials? Potential Challenges:

Ensuring that sufficient education and information is provided in the GAPs food safety training materials without duplicating pesticide education and training efforts.

Is there potential for information to “fall through the cracks”, information that we assume is covered in pesticide training that might not be covered.

Not all farmers may use pesticides and receive pesticide training, what information must be included about chemicals in GAPs training.

The following topics were suggested by a committee member as points that need to be addressed in training materials.

1.) Where to go for information

2.) Where to go for training

3.) Links for state and federal laws

4.) Training for usage of off-the-shelf garden supplies/pesticides (garden-farmers are making entry to direct-to-consumer sales

5.) Storage (secondary containers are required over certain threshold levels)

6.) Visual and descriptions of various applicator devices

7.) Recycling

*Important to note that since there are so many new production entries, I venture to say the majority of these folks have limited experience levels. Therefore, not only is it important to provide information, but also inform folks on where to obtain additional information from state and federal agencies.

Recordkeeping

  • Records must be kept and included in food safety plan
  • Water source needs to be documented
  • Anything put on the crop needs to be documented, no exceptions
  • General SOP and daily documentation
  • Records must be written in ink
  • Scientific documentation to support practices
  • Emphasizing to growers that they are responsible for documentation of the source and purity of chemicals purchased (esp. imported chemicals). Use of letters of guarantee, etc.

Challenge: Many growers don’t know what information to record and where to start

Solutions: Provide templates with specific information, emphasize that documents don’t need to be complicated or too time consuming

Resources on Chemicals

(Western Plant Health fertilizer handbook)

(container disposal)

residue database)

Office of Pesticide Programs)

UC Integrated Pest Management Program has commodity-specific management information for major pests and diseases as well as year round calendars for many crops that specify monitoring and control practices. The website link is

For instance, the year round IPM program for lettuce can be found at Management practices to reduce air and water contamination from pesticide applications can be found at Each of the specific pests includes management alternatives to pesticides. Worth taking a look for practices related to pesticides.

A portion of the UC-IPM Pesticide applicator Instructor’s Handbook, 3rd edition, UC-IPM Publication 14 (pdf) will be included on a shared website for the committee, once established.

Cornell GAPs Assessment

National Organic Standards

State or Regional Production Guides - many states produce their own but some such as Midwest produce a regional guide for tree fruits and small fruits.

Links for Illinois:

Illinois Driftwatch:

Producers with approved fields can order No Drift Zone signs.

General information regarding

Pesticide Use and Regulation

in Illinois

General information regarding the

Aerial Application of Pesticides

in Illinois


Resources on Animals

These documents will be uploaded onto a shared website for the committee, once established:

On-Farm Animal Risk Assessment Form from Wild Farm Alliance On-Farm Animal Risk Assessment and Best Practices documentfrom Wild Farm Alliance