SAFEGUARDS

have to inspect all the canals that are going to come to our ranch.”

“Prior to that first plant,” Sierra said, “we already have to be pulling water samples so we can be a month ahead of the water we’re going to use for planting. So right around the middle of August is when we’re pulling our samples. And we have to have five samples of water prior to that first harvest.”

They send the water samples to a certified lab to test for total coliforms and generic E. coli, since both bacteria indicate contamination from fecal material. Growers’ records must show that employees taking the samples are trained and certified in proper procedures to collect and send the samples.

If the bacteria count is too high or if there is any E. coli, more samples must be submitted for testing. Positive tests, if consistently high coming from the main canal, must be reported to the authorized water district, and growers will be unable to use that water until levels meet FSMA specifications for safety. If the water is from the farm’s canals, those can be drained, cleaned thoroughly and re-evaluated.

Also, a month before the first planting, growers or food safety directors must inspect the ranch and its surroundings where they will grow the produce — leafy greens especially — for any buildings, cattle or concentrated feedlots, neighboring houses, trees or anything close that can risk field contamination.

Sierra explained that they also look for animal tracks and bird populations.

“If we happen to find (those) prior to the planting, then that’s when we would make our corrections. Like make our buffers a little bit bigger from say an adjacent wild brush or canal or a river or a house.” A lot of animal activity at that ranch will probably need adding fencing. “We’ll put up some rodent fencing, some rodent traps. So we’re taking preventive measures before we start. If all that is in place, we’re good to go.”

Before seeds or transplants are put into the soil, growers must also obtain seed or transplant providers’ documentation, assuring growers that suppliers are not using anything that is contaminated in their processing procedures.

During the summer prior to planting, tractors, planting machines and other equipment are set up and serviced. During the harvest season, equipment that is in contact with produce, such as those that use conveyor belts to send produce to waiting bins upon trucks, are thoroughly washed and sanitized at the end of each harvest day and cleaned again as needed.

“By the time of planting, employees that are going to be transplanting are already trained in hand washing and good agricultural practices,” said Sierra.

The growers’ food safety directors or specialists, like Sierra, train them. Or other agencies may. LGMA partners with state and grant-funded Campesinos Sin Fronteras, a non-profit agency that — among other things — helps train employees in safety precautions, even going into the fields upon request to do so. Part of the training includes proper hand washing and sanitizing at the field restroom station. And the restrooms are inspected as well.

Trained field foremen observe and document employee safety procedures, whose requirements may vary with the company that is purchasing the produce. These requirements may include but are not limited to empty shirt pockets to prevent things falling into fields. They also include “not to come sick to work, no jewelry, no eating in the field, no spitting, nothing in your mouth — things like that,” said Sierra.

“Some companies require you to wear beard nets; some, hair nets,” Sierra said. “Those are a food safety protection. Men wear bandanas for the sweat.”

Some companies provide reusable gloves; others, disposable gloves, which cost less and do not have to be sanitized after their use.

“It’s a requirement now for us to have training logs,” Sierra added.

Once the plants are in the soil, safety practices are ongoing. Weekly producegrowing ranch inspections are conducted to determine whether the mitigations that were done at the beginning of the season are working.

“Like our fencing,” Sierra said. “Any downed fencing or anything new — like maybe a coyote came and dug under a fence or we have some raccoons that are climbing the fence, deer jumping the fence.”

Keeping animals away from the fields is necessary to food safety. Their feces may contain E.coli that could contaminate a crop. Applied research by Paula Rivadeneira, Ph.D., of the University of Arizona Cooperative Extension helps growers with pressing issues related to wildlife and food safety.

“To protect public health, fecal material is always treated as if it is contaminated with a foodborne pathogen, regardless if it has been tested or not,” said Rivadeneira, UofA food safety and wildlife extension specialist. “As a result, farmers always buffer a minimum of 5 feet around it, meaning they will not harvest anything within 5 feet of fecal material.”

“If we’re finding deer tracks, then we know that we’d have to make a taller fence (or) use electric fence for the raccoons,” Sierra explains. “The raccoons can climb anything no matter what size those fences are. Coyotes, too — we’d probably run one string of electric fence to the bottom because they’ll dig. And that will kind of shock them. It’s not a powerful shock. It’s just a little scare so that it doesn’t hurt the animals or anything like that.”

When birds come in trying to eat the seeds, growers may tie little Mylar tapes to twigs. Some growers use bird bombs or cannon as noise makers to keep birds out of a field. Sierra said that if bird activities are really heavy, an employee may use a shotgun (without pellets) as a noisemaker to scare them off.

Animal activity is unpredictable, making food safety even more challenging.

“One season we can have a perfectly good ranch, and then the next season we’re just attacked by all these birds,” Sierra said. “We’re always trying to be one step ahead of the activity out there. Same thing with deer and coyotes — we know that they’re coming in from the desert to feed and to drink water. So right around irrigation time, we’re telling our irrigation guys, ‘Don’t just stay around the pump. Take a ride around in your car; make sure everything is okay. If you see anything, honk your horn, scare them away, and things like that.’”

When it comes to local farm safety, three factors benefit the growers: the spirit of cooperation, the weather and clean water.

“A good thing about the farmers (and food safety team members) here in Yuma is that a lot of us are friends,” said Sierra. They share information. “Our neighbor could have a good water result, and yours could be bad. So we’re calling each other, working together to figure out what it was.”

As for weather, Sierra said that bacteria counts are “pretty low because it’s cool. We’ve got a lot of sun — a lot of UV light — so the concentration of bacteria is really low. When we do get those high spikes, it’s either at the beginning of the season because it’s still warm or at the tail end of the season because it starts warming up. So the bacteria rises a little bit, but it still never passes our limit. In November, December, January when it’s still cold and we get little spikes, we still look, do assessments and see what’s going on.”

Farm safety expenses, yet to be computed, are high. There are no shortcuts either. Farmers must comply with FDA regulations.

“And you don’t get the returns back like you would on everything else,” Sierra said. “Every part of the section in growing — whether it is pesticide, equipment operations, buying seed, leasing ground — you can always figure out a way to work it to make your money back,” said Sierra. “But when it comes to food safety, you can’t go around it. You have to continuously do this every single year all the time. No matter how you do it, it’s still costly.”

Large-scale growers are apprehensive about one of the exemptions to FSMA regulations. Farms that don’t sell more than 50 percent of their products are exempt from the law.

“That’s a scary deal for us because a lot of these small businesses don’t have to do all of this stuff,” said Sierra. “They don’t get audited. They don’t get checked. So who knows if they’re doing the practices? In order for them to sell to these big shippers, they would have to (comply) as a requirement from the shipper. But say I’m growing 10 acres in the back of my house, five different commodities, and I’m just selling three, four or five boxes to a local grocer or a restaurant. If something was to happen, they’re not the ones who are going to get blamed — it’s the industry.”

Sierra said that Yuma-area growers do their best to implement measures over which they have control.

“It’s a lot of work,” he admits. “People don’t realize what we do — the time and the money that’s being spent on making sure that the produce is getting to the overall client. It’s time consuming, it’s costly, but we have to do it to our best. It’s not 100 percent, but we’re minimizing the risk the best we can. That’s all we can do.”