EAST LANSING, Mich. — If you grow fresh fruits and vegetables, you likely know that different types of produce crops have lots of different attributes. Any recommendation for pest management, fertility or cropping system needs to be framed in how a crop grows and how a particular farm operates.
With respect to produce safety risk, this is also true. Certain crops have very particular produce safety risks. These can be due to the crop’s proximity to the ground, whether it is typically eaten raw or even the tenderness of the outside skin. The industry that grows and processes a particular produce item can come up with industry guidelines that amount to a tailored produce safety audit for that crop.
In the case of the commercial production of lettuces and other leafy greens, the Leafy Greens Marketing Agreement (LGMA) created a guideline for the growing of greens that is very particular to the industry practices of lettuces. A group of industry professionals and scientists review the standards set forth in the guidelines regularly. Where changes are needed based on new science, they update the checklist.
An overwhelming number of fresh fruit and vegetable crops do not have industry guidelines similar to the Leafy Greens Marketing Agreement. Despite this, many of these crops are being audited under other audit schemes. This idea of industry standards has become something of a concern for those fruit and vegetable growers seeking a Primus GFS v3.0 audit.
The checklist’s point 1.01.06 reads, “Where specific industry guidelines or best practices exist for the crop and/or product, does the operation have a current copy of the document? Total compliance (3 points). There is a current copy of any specific industry guidelines for the crop and/or product available for review. Some examples include the Leafy Green Marketing Agreement (LGMA), California Cantaloupe Program, Tomato Good Agricultural Practices (T-GAP), Commodity Specific Food Safety Guidelines for the Production, Harvest, Post-Harvest, and Processing Unit Operations of Herbs, etc. Not applicable if no specific industry guidelines or best practices exist for the crop and/or product.”
A number of currently circulated industry-specific guidelines as listed by the U.S. Food and Drug Administration (FDA) in “Produce & Plant Products Guidance Documents & Regulatory Information” include the following.
Industry guidance in collaboration with FDA
- How to Work with FDA on Food Guidance Documents (Jan. 31, 2017)
- Commodity Specific Food Safety Guidelines for the Production, Harvest, Storage, and Packing of Potatoes (June 17, 2013) (PDF – 7325KB)
- Commodity-Specific Food Safety Guidelines for Cantaloupes and Netted Melons (March 29, 2013) (PDF – 4.77MB)
- Commodity Specific Food Safety Guidelines for the Production, Harvest, Post-Harvest, and Processing Unit Operations of Fresh Culinary Herbs (Jan. 24, 2013) (PDF – 7.34MB)
- Commodity Specific Food Safety Guidelines for the Production, Harvest, Post-Harvest, and Valued-Added Unit Operations of Green Onions (Feb. 26, 2010)
- Commodity Specific Food Safety Guidelines for the Melon Supply Chain, 1st Edition (Nov. 7, 2005)
- Commodity Specific Food Safety Guidelines for the Fresh Tomato Supply Chain, 2nd Edition (July 2008)
- Commodity Specific Food Safety Guidelines for the Lettuce and Leafy Greens Supply Chain, 1st Edition (April 25, 2006)
FDA letters to industry
- Letter to Firms that Grow, Harvest, Sort, Pack, Process, or Ship Fresh Cantaloupe(November 2011)
- Letter to Firms that Grow, Harvest, Sort, Pack, or Ship Fresh Cilantro (March 2011)
- Letter to Seed Suppliers, Distributors, and Sprouters (May 2009)
- Letter to California Firms that Grow, Pack, Process, or Ship Fresh and Fresh-cut Lettuce (Nov. 4, 2005)
- Letter to Firms that Grow, Pack, or Ship Fresh Lettuce and Fresh Tomatoes (Feb. 5, 2004)
The list presented in the citation above may not be exhaustive, so check with your local state produce or trade association to ensure something isn’t missed. If no guidelines exist, growers are expected to answer 1.01.06 “N.A.” or “Not Applicable.”
If you have difficulty tailoring good agricultural practices (GAPs) to your farm or have questions about this audit question or others, contact the Agrifood Safety Work Group at firstname.lastname@example.org or 517-788-4292.
Funding for this article was made possible, in part, by the Food and Drug Administration through grant PAR-16-137. The views expressed in the written materials do not necessarily reflect the official policies if the Department of Health and Human Services; nor does any mention of trade names, commercial practices or organization imply endorsement by the United States Government.
— Phillip Tocco, Michigan State University Extension
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