April 20, 2021
In this issue:
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Breakfast with the Food Safety Group
What is the National Organic Program 90/120 Day Rule?
We know that animal manure can be a source of human pathogens. Animal manure is also a good source of organic matter and nutrients. It is usually an inexpensive and readily available fertilizer and soil amendment.
When farmers consider their choices of nutrient sources, manure or a composted product often comes to mind. These sources are referred to as biological soil amendments of animal origin (BSAAO). We know from many studies that care must be taken to avoid cross contamination between the possible human pathogens in these sources and the edible portion of the crop they are fertilizing.
How are BSAAOs Considered Under the PSR and GAPs?
Photo credit, Carol Allen
Currently the FSMA Produce Safety Rule (PSR) does not have specific guidance on the application interval between untreated manure or compost application and the harvesting of the crop. The FDA is still examining risk assessments and in-depth research. While farmers wait for FDA guidance, the National Organic Program (NOP) guidelines are the standards to follow and will satisfy compliance. That guidance is found here: https://www.law.cornell.edu/cfr/text/7/205.203.
The guidance is detail-specific and should be read in its entirety. The part governing the untreated manure application interval is summed up here:
ii) Incorporated into the soil not less than 120 days prior to the harvest of a product whose edible portion has direct contact with the soil surface or soil particles; or
(iii) Incorporated into the soil not less than 90 days prior to the harvest of a product whose edible portion does not have direct contact with the soil surface or soil particles
Photo credit, Angela Ferelli
What is Compost and What is Untreated Manure?
The Produce Safety Rule considers untreated pre and post-consumer vegetative waste, non-manure animal based soil amendments (like bone meal), as well as raw animal manures to be untreated soil amendments of animal origin. Also included are ‘aged’ or ‘stacked’ manure, untreated manure slurries, untreated manure teas, agricultural teas with supplemental microbial nutrients, and any soil amendment mixed with raw manure.
MDA Good Agricultural Practices audit requires farmers to adhere to the 90/120 day rule when applying any of the above products.
Harmonized GAP requires that records be maintained detailing the processing and application of compost. The standard states “it shall be used in a manner so as not to serve as a source of contamination of produce”. (F7.2) The 90/120 day NOP guidelines will assure farmers of compliance.
Considering Making Your Own Compost?
Proper composting is an exacting science. More information can be found here: https://enst.umd.edu/extension/composting and on this YouTube video here: youtube.com/watch?v=5CtlMfpin-g
The Plant Science Food Safety Group YouTube Page!
There are signs available through the MDA Food Quality Assurance Program to encourage good consumer practices while in the market and on the farm. Contact the Food Safety Group for availability.
This 12" x 18" poster comes either as a corrugated poster board or as a magnetic sign and is perfect for Pick-Your-Own operations.
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Breakfast with the Food Safety Group from 7:00 - 10:00 am
We are offering virtual office hours from 7:00 - 10:00 am.
Carol Allen can be reached at 240-994-5043 on Monday, Wednesday & Friday mornings.
Angela Ferelli can be reached at 302-353-7159 Tuesday and Thursday mornings.
Call in with your questions about food safety for fresh produce.
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Housekeeping: Notice there are Subscribe and Unsubscribe links at the bottom of the page. Please subscribe and pass this newsletter on! We want to serve your needs and the needs of all Maryland farmers big and small no matter your food crop. If something bugs you, please contact me! …but we want to stay in touch so don’t unsubscribe, reach out!
Carol D. Allen, Agent Associate and Editor
Chris Walsh, Professor Emeritus and Co-PI
University of Maryland
Plant Science Food Safety Group
callen12@umd.edu
Questions for MDA Food Quality Assurance Program:
Deanna Baldwin, Program Manager
Food Quality Assurance Program
Maryland Department of Agriculture
produce.safety@maryland.gov
Funding for this publication was made possible, in part, by the Food and Drug Administration through grant PAR-16-137. The views expressed in written materials or publications and by speakers and moderators do not necessarily reflect the official policies of the Department of Health & Human Services; nor does any mention of trade names, commercial practices, or organization imply endorsement by the United States Government. University programs, activities, and facilities are available to all without regard to race, color, sex, gender identity or expression, sexual orientation, marital status, age, national origin, political affiliation, physical or mental disability, religion, protected veteran status, genetic information, personal appearance, or any other legally protected class
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