Fully Cooked Compost: How FSMA Defines Treated vs Untreated BSAAO

Hello! My name is Charles Gould and I’m with Michigan
State University Extension. In this video, I am going to discuss how the
Food Safety Modernization Act Produce Safety Rule approaches and regulates treated versus
untreated biological soil amendments of animal origin. We will cover the difference between treated
and untreated animal-based soil amendments and how should they be handled and stored
to minimize food safety risks. Here is how the Produce Safety Rule defines
treated soil amendments of animal origin. According to the FSMA Produce Safety Rule,
a biological soil amendment of animal origin is considered treated if it has gone through
a complete process to adequately reduce microorganisms of concern. As you’ll notice, the definition refers
to section 112.54 of the rule. In this section, the law outlines two acceptable
compost production methods that have been scientifically validated. The video entitled “Safe and Successful
Composting Under FSMA” takes a detailed look at both of these scientifically valid
composting options. If you choose to use a different treatment
method, you’ll have to collect documentation to prove that it is a scientifically-valid
method. Untreated soil amendments, such as raw manure,
have not gone through an appropriate process to kill any potential pathogens such as Salmonella
or E.coli. Due to this, untreated soil amendments can
pose a significant food safety hazard to fresh produce. The Produce Safety Rule states that growers
must handle, convey, and store soil amendments so that they do not become a potential source
of contamination to harvestable portions of the produce. Treated soil amendments should be handled
and stored in a way that minimizes risk of recontamination from untreated soil amendments. This may look like designating different equipment,
clothing, gloves and boots for handling treated versus untreated amendments or washing and
sanitizing equipment and changing clothing, boots and gloves between uses. It also involves storing treated amendments
in an area where they will not be re-contaminated by foot traffic, wind or other factors. However, if treated soil amendments come into
contact with untreated soil amendments, such as raw manure, agricultural tea made with
raw manure, or an amendment of unknown treatment status, they must be handled as if they were
untreated or raw. This means maximizing the amount of time between
application of the soil amendment and harvest; cleaning and sanitizing equipment or using
designated equipment; changing clothing, boots and gloves before moving onto another task;
and washing hands. Essentially if it’s a problem, we’ll just
treat it as a raw product and do fall application. If there’s any question on any of the piles
that we have we just do fall application, which allows us to have, at least currently,
the timeline that we need for raw materials. And so yeah, if they get into this side and
this pile is exposed, if they get over there than any of those too, but it’s at least
contained to one section. Static and turned composting are two validated
treatment options for soil amendments, covered in section 112.54, and detailed in the video
entitled “Safe and Successful Composting Under FSMA.” Other treatment methods are allowed, as long
as they are scientifically valid, controlled processes that achieve the microbial standards
outlined in 112.55. To
ensure the adequate treatment of soil amendments, process monitoring and record keeping must
be documented, according to section 112.60. If there is no record of treatment, a soil
amendment must be considered untreated and managed as if it were contaminated. You can refer to the video entitled “FSMA
Recordkeeping Requirements for Biological Soil Amendments of Animal Origin” to learn
more about which records you need to keep in order to be in compliance with the FSMA
Produce Safety Rule. In summary, the use of biological soil amendments
of animal origin can be risky. However, if the amendments are treated properly,
as well as handled and stored in a way to reduce cross contamination, the risk of a
foodborne illness can be minimized, and soil amendments can be extremely valuable to soil

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