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Contents of a Good HACCP Plan & Manual

Written by Safe Food Alliance Team
Originally Published in FOOD SAFETY, HACCP, STARTER SERIES

In today’s food manufacturing environment, basic food safety principles are no longer enough to meet customer and regulatory requirements. The rules have changed, in large part due to the Food Safety Modernization Act (FSMA). In addition to new laws from legislators, the standards and demands of customers now far surpass regulatory requirements. What this means is there is now an expectation to not only master Hazard Analysis Critical Control Points (HACCP) but to go one step further and become Global Food Safety Initiative (GFSI) certified. To gain certification with any of these programs, you need to start in the same place. You start with a HACCP plan.

12 Steps to a Good HACCP Plan

When building out your HACCP plan, follow this specific methodology involving 12 steps. If you are having trouble, just reach out to your friendly neighborhood Safe Food Alliance team.

One thing to remember as you build out your plan – a HACCP Plan is a living document, and as such, should be revisited often as your processes change, your company grows, and you discover better ways to produce your product. Now that we have that covered, let’s begin.

1. Assemble the HACCP Team

Your plan will typically include a table where all the names of the HACCP Team members are written and signed, and the team leader is clearly designated. The team functions best when it’s highly cross-functional and includes members of various departments such as sanitation, maintenance, production, and quality. It’s essential to have these varied perspectives and background knowledge. 

In this section, you should include a brief description of each member’s current position, background, and experience. You’ll also need to have a copy of a HACCP formal training certificate for the HACCP coordinator, from an accredited two-day HACCP course.  There should be some sort of documented HACCP training for the rest of the team as well, whether conducted internally or by someone like us. The more knowledgeable the team, the better the plan will be.

2. Describe the Product

This section should include a full description of each product or family of products within the scope of the plan. Product descriptions should consist of details that impact the food safety of the product, including (as applicable):

  • the recipe or formulation
  • the packing materials and any other information such as the modified atmosphere
  • the conditions in which the product is to be stored (e.g., temperature, light, humidity)
  • the shelf life
  • distribution conditions
  • any potential for abuse in the distribution chain or by consumers, which may put the product at risk.

The better you define the product before starting the hazard analysis, the more thorough the review will be.

3. Identify the Intended Use

The intended use is based on the usual consumption of the commodity by the final consumer or user. Again, defining intended use helps ensure a more thorough hazard analysis later. This section includes both your company’s intended purpose based on product design, as well as potential other applications. The more you know your consumers, the better you can take care of them. A classic example, in this case, is cookie dough: it’s a product you typically cook before consumption, but in some cases, it’s eaten raw. For this reason, several companies have had recalls on their cookie dough due to consumer illness.

4. Construct the Flow Diagram

The process flow diagram must be clear and detailed to describe all process steps. Use this diagram to help ensure the hazard analysis is thorough and as a visual reference as your team considers potential hazards to the consumer. The flow diagram must include every process step that occurs on-site, from the very beginning (e.g., receiving and preparing ingredients, storing packing materials, etc.) to the very end (shipping, warehousing, etc.) The clearer the diagram is to the viewer, the easier to understand the process. Others may also use the table during site visits (e.g., customers, auditors, consultants, regulatory officials). Hence, it’s wise to design it in a way that it’s relatively clear to others who don’t know the process as well as you do.

5. On-Site Verification of the Flow Diagram

On-site verification of the diagram helps ensure its accuracy.  Again, the purpose of this is primarily to ensure a thorough hazard analysis. The site will need to provide proof that the HACCP Team has verified the flow diagram.  Some companies like to keep the first version of the diagram with hand-written notes on it, indicating changes made and initialed and dated by the participants. Ultimately, however, proof of the verification is best done with a final, updated copy that is signed; or meeting minutes indicating approval of the final version and signatures of participants.

6. Conduct a Hazard Analysis

The hazard analysis is part of the plan that typically takes the most time to review and update. Here the team collects and examines all relevant data to the product’s safety, including process performance, product defects, customer complaints, results of internal and third-party audits, and various other relevant information.  The team must take the proper time to conduct a thorough analysis.

A Hazard analysis can vary in format, but needs to include these common elements:

  • List of all process steps and ingredients
  • Identification of potential hazards
  • Assessment of each hazard, with consideration of both severity and likelihood
  • Identification of ‘significant’ hazards
  • Justification of the assessment (detailed explanation as to the team’s reasoning)
  • Identification of appropriate controls for each hazard
  • Now, under FSMA, the identification of any Preventive Controls as well. For more information on this subject, take a look at this article. For training, refer to the PCQI course.

7. Determine Critical Control Points (CCP’s)

This one is a simple concept. Based on the hazard analysis described above, you can quickly identify all significant hazards and CCPs. Critical Control Points are those essential steps designed to control a specific hazard so that the product will be safe to consume. The team should use a decision tree like this one when determining CCPs.

8. Establish Critical Limits for Each CCP

A critical limit is a critical control point’s “go/no go” or “acceptable/unacceptable” criteria.  For some processes, such as metal detection, it is as simple as testing with certified metal test pieces to ensure proper function. For other types of CCPs, it can be much more complex and include parameters such as temperature, humidity, product viscosity, or chemical concentration. All these variables and values have to be clearly defined, including both lower and upper limits, as applicable.

Documents related to the process and relevant sources used to establish the critical limits must be available to support the limits. These documents could be regulatory standards, guidelines, internal or third-party validation, experimental results, literature surveys, and expert guidance. The stricter the validated limits, the higher the potential efficacy.

9. Establish a Monitoring System

This step is where we define the monitoring method for each CCP.  Monitoring is how we ensure the process has met the critical limit, so the product is safe.  The monitoring procedure should contain the following:

  • What will you monitor?
  • How often shall it be monitored?
  • Who is responsible for performing the task?
  • What instruments will you use?
  • How will you monitor? (method)

The clearer the instructions, the fewer chances of failure.

10. Establish Corrective Actions

Each CCP is required to have predetermined and documented corrective actions for deviations that may occur. The corrective actions plan should comprise at least the following elements: the responsibility for each action, disposition of the non-complying product, the correction of the cause of failure, and recording the event. Keep records of activities readily available. If you need help with conducting root cause analysis for your corrective actions, check out our quick root cause analysis course.

11. Establish Verification Procedures

Much of the discussion in our HACCP courses end up centering around how to conduct verification in the context of HACCP properly.  Verification procedures should be activities designed to confirm that the plan is: 1) being followed; 2) effective for its intended use, and 3) adequately maintained. We are looking for defined procedures here, indicating how we conduct routine verification activities like the sign-off of the CCP monitoring records, as well as how you complete the less-frequent validation. The more exhaustive the verification is, the more confident we can be of the plan.  For more on verification, take a look at our article “The 6th Principle of HACCP: Verification”.

12. Establish Documentation and Record-keeping

This final step includes establishing both record-keeping processes and the company’s documentation system (establishing defined procedures, the company’s methods of document control, etc.). Consider:

  • How will you document your system?
  • What should you include?
  • Who is responsible for doing it?
  • How long are you keeping records? Where are you saving them?
  • Who needs to have access to what documents and how are documents controlled?

A better-documented plan helps ensure better execution.

As you may realize by now, developing and documenting an effective HACCP plan is not an easy task. Training on the methodology, experience, and technical elements are essential aspects of effective HACCP Plan implementation. If you need guidance with training or consultation, Safe Food Alliance is here to help.

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CBD in Food and Dietary Supplements: What is the legal status?

Written by Natalie Rainer
Counsel, Keller and Heckman LLP

Interview with Natalie Rainer of Keller and Heckman LLP as a webinar.
Interview with Natalie Rainer of Keller and Heckman LLP as a podcast.
Open in Spotify to listen to the full episode.

Since the Farm Bill of 2018 changed the definition and regulatory status of hemp from an agricultural perspective, confusion and misinformation has been rife on the U.S. Food and Drug Administration (FDA) regulatory status of hemp and its products—including cannabidiol (CBD), a non-psychoactive cannabinoid.  Despite there not being a clear basis for concluding that CBD has an appropriate FDA regulatory status for use in food, CBD has gained mass popularity, and it is not uncommon to see CBD sold in chocolate, oils, and even pet treats in your local stores.  In this article we have summarized the current status of CBD in food and dietary supplements and the hurdles that lie in the path of supporting a suitable FDA status for such uses.

Impact of 2018 Farm Bill

When Congress passed the 2018 Farm Bill (formally known as the Agriculture Improvement Act of 2018), there was widespread misunderstanding that the law legalized substances derived from the Cannabis sativa L. plant, including CBD, for use in food and dietary supplements.  In fact, the relevant provisions of the Farm Bill merely removed hemp from the Controlled Substances Act definition of marijuana.  The 2018 Farm Bill defined “hemp” as Cannabis sativa L. with less than 0.3% tetrahydrocannabinol (THC, a psychoactive component of cannabis) on a dry weight basis (1) and affected the Drug Enforcement Administration’s authority over hemp farming.  The change granted more authority to states to regulate the growth, production, and distribution of hemp products.

The 2018 Farm Bill had no effect on FDA’s authority to regulate CBD or other hemp products; it also did not change the regulatory definitions of “food additive” and “dietary ingredient” to facilitate the use of ingredients like CBD in food and dietary supplements. (2)  FDA continues to have authority to regulate products containing cannabis and cannabis-derived compounds, including those classified as hemp. (3)  Therefore, CBD is subject to the same regulatory requirements under the Federal Food, Drug, and Cosmetic Act (FFDCA) as other food additives and new dietary ingredients.  

Current FDA Position on CBD

FDA has consistently taken the position that it is unlawful to sell a food or dietary supplement containing CBD in interstate commerce because CBD is not eligible for use in those products under the FFDCA, as CBD had been studied for possible “drug” uses before it was marketed in foods or dietary supplements.  These clinical studies led to FDA’s 2018 approval of Epidiolex, which contains a purified form of CBD, as a drug for use in the treatment of seizures associated with Lennox-Gastaut syndrome (LGS) or Dravet syndrome.  Pursuant to Section 301(ll) of the FFDCA, FDA is taking the position that it is unlawful to market foods that contain an added “drug” that has been approved by FDA or “for which substantial clinical investigations have been instituted and for which the existence of such investigations has been made public.”   (While there are exceptions for substances that were in foods before they were approved or studied as drugs, such as caffeine or baking soda, FDA has determined that CBD does not fall under such exceptions.) (4) Likewise, FDA has cited Section 201(ff)(3)(B)(i) of the FFDCA, which explicitly excludes approved drugs or those substances that are the subject of publicly-disclosed clinical studies, from the definition of “dietary ingredients,” as being the basis for CBD not being permitted for use in dietary supplements.  Thus, FDA’s current position is that marketing foods or supplements containing CBD violates the FFDCA and, because of this, that such products are adulterated.  

That said, FDA thus far has taken enforcement action only against foods and supplements containing CBD when such products make drug claims concerning the prevention, diagnosis, mitigation, treatment, or cure of disease.  Specifically, FDA has sent warning letters to a number of companies making claims that CBD can treat conditions such as cancer, Alzheimer’s disease, opioid withdrawal, pain, pet anxiety, arthritis, and other conditions. (5)

In early March 2020, FDA released a Congressionally requested report (6) on the agency’s progress toward developing a regulatory framework to allow CBD in conventional foods and dietary supplements.  To the frustration of many, however, it appears that little actual progress has been made.  The most significant revelation from the report is that FDA is considering developing a risk-based enforcement policy that could clarify FDA’s enforcement priorities.  Given the widespread availability of such products, however, an informal policy of enforcement discretion has essentially been in place for some time.  

Congress Tries to Intervene

FDA has received considerable pressure from Congress, particularly members like Senate Majority Leader Mitch McConnell of Kentucky whose states have invested in hemp agriculture, (7) to permit CBD to be legally sold in foods and supplements.  In September 2019, bipartisan Congress members sent a letter to FDA urging the Agency to provide legal clarity and establish a regulatory pathway for food products containing hemp-derived CBD. (8)  They expressed concern with FDA’s estimate that rulemaking on this topic could take between 3 to 5 years and asked for more expeditious measures, like announcing a policy of enforcement discretion and using an interim rule to establish a regulatory framework.  Several bills have been introduced to create a legislative fix for this issue.  One proposed solution, outlined in a H.R. 5587 introduced by Representative Collin Peterson of Minnesota, would amend Section 201(ff)(3)(B)(i) of the FFDCA (discussed above) to exempt “cannabidiol or a hemp-derived cannabidiol containing substance” from the prohibition on marketing approved drugs as dietary supplements.

Lack of Safety Data

As of yet, there have been no proposed Congressional fixes that address the second hurdle to an appropriate FDA status for CBD:  the definitions of “food additive,” “new dietary ingredient,” and related definitions of adulteration in the FFDCA.  These aspects of the law require FDA to evaluate CBD based on a robust safety data set and do not provide FDA with the authority to authorize CBD for use in food and dietary supplements in the absence of such information.  

“Food additive” is defined under Section 201(s) of the FFDCA as substances that are intended, or may reasonably be expected to result, directly or indirectly, in its becoming a component or otherwise affecting the characteristics of any food.  While food additives require FDA premarket clearance so as not to be found to adulterate food, there is an exemption from the definition of “food additive” for substances that are “generally recognized as safe” (GRAS) for their intended use.  GRAS status can be supported by either common use in food prior to 1958 (which is not relevant to CBD) or general recognition of safety through scientific procedures—generally requiring the availability of published safety studies in peer-reviewed journals.  Similarly, supplements containing new dietary ingredients are considered adulterated unless they contain only ingredients “present in the food supply as an article used for food in a form in which the food has not been chemically altered” or if, 75 days before marketing, the company submits to FDA evidence to show the dietary ingredient “will reasonably be expected to be safe” for human consumption under labeled conditions of use.  In any case (i.e., to obtain premarket clearance or to support a GRAS position), there must be a robust data set supporting the safety of CBD for use in food.  While FDA has had no questions concerning the use of hulled hemp seeds, hemp seed protein, and hemp seed oil as ingredients for use in human food based on existing safety data (9), to FDA’s knowledge, there are not adequate safety data for CBD.(10)

Setting aside the lack of safety data, FDA is aware of potentially adverse safety data regarding CBD.  FDA has noted that taking CBD may increase or decrease the effects of other medications, as well as the risk of liver injury (a side effect observed in its review of Epidiolex). (11)  Studies performed on laboratory animals found potential male reproductive toxicity concerns (e.g., a decrease in testicular size, inhibition of sperm development, and decreased testosterone). (12) Any safety data developed to support CBD’s safety would also need to adequately address these adverse data to satisfy FDA’s requirements for the safety of food additives and new dietary ingredients.  

The current regulatory framework under the FFDCA does not allow FDA to affirmatively evaluate the safety of CBD for use in foods and supplements, nor does FDA have funding to sponsor the necessary studies to support the safety of CBD.  Rather, FDA is waiting for the necessary safety data to be developed to evaluate CBD’s safety.  While FDA held a public hearing on cannabis in May 2019 and opened a public docket to gather comments and data for FDA review (through which the Agency received approximately 4,500 comments), FDA has yet to receive the necessary safety information to allow it to agree that CBD has a suitable status for use in food and dietary supplements. (13)

What about the States?

For the foreseeable future, it does not appear that CBD will have a suitable FDA status for use in food and supplements, and cannabis containing more than 0.3% THC remains an illegal narcotic under the Controlled Substances Act. (14) But how are states handling this issue?

The legality of cannabis state regulation is varied.  Some states, like California and Colorado, have completely legalized recreational cannabis, which includes CBD products.  Other jurisdictions, such as Vermont and Washington, DC, have legalized marijuana but do not allow sales.  Others have decriminalized it or only allow medical use. (15) A number of states, like Texas and Wisconsin, continue to regulate marijuana as an illegal drug.  Individual states handle issues such as age restrictions, dosage, labelling, testing, and licensing of marijuana differently.  Further complicating matters, individual cities and counties can impose different rules, with some completely banning the growing, manufacturing, and selling of cannabis.  As a result, in many jurisdictions, there is a conflict between the federal government and states that permit the marketing of CBD products.

* * *

Regulations concerning CBD remain in flux.  It remains to be seen how Congress and FDA will address the legality of CBD in food and dietary supplements under the FFDCA.  However, the CBD industry should be aware that robust safety data will most likely be required to ultimately convince FDA to permit CBD in food and dietary supplements.  This endeavor will take a considerable amount of time and financial resources and will need to overcome existing data on adverse health effects.    Despite these issues, we expect to continue to see CBD readily available in food and dietary supplements, provided that such products do not bear drug claims.

The author gratefully acknowledges the assistance of Paula Pastuskovas in the preparation of this article.

1.What You Need to Know (And What We’re Working to Find Out) About Products Containing Cannabis or Cannabis-derived Compounds, Including CBD; FDA (March 5, 2020), available at: https://www.fda.gov/consumers/consumer-updates/what-you-need-know-and-what-were-working-find-out-about-products-containing-cannabis-or-cannabis 

2. Contrary to Popular Reports, Farm Bill Will Not Affect FDA Status of CBD; Daily Intake, Keller and Heckman (December 13, 2018), available at: https://www.dailyintakeblog.com/2018/12/contrary-to-popular-reports-farm-bill-will-not-affect-fda-status-of-cbd/

3. Remarks at the National Industrial Hemp Council 2019 Hemp Business Summit; FDA (August 12, 2019), available at:  https://www.fda.gov/news-events/speeches-fda-officials/remarks-national-industrial-hemp-council-2019-hemp-business-summit-08132019 

4.  FDA warns 15 companies for illegally selling various products containing cannabidiol as agency details safety concerns; FDA (November 25, 2019), available at:  https://www.fda.gov/news-events/press-announcements/fda-warns-15-companies-illegally-selling-various-products-containing-cannabidiol-agency-details

5. Id.  See also FDA warns company marketing unapproved cannabidiol products with unsubstantiated claims to treat cancer, Alzheimer’s disease, opioid withdrawal, pain and pet anxiety (July 23, 2019), available at:  https://www.fda.gov/news-events/press-announcements/fda-warns-company-marketing-unapproved-cannabidiol-products-unsubstantiated-claims-treat-cancer.

6. Report to the U.S. House Committee On Appropriations and the U.S. Senate Committee on Appropriations – Cannabidiol (CBD) – Report in Response to Further Consolidated Appropriations Act, 2020 – U.S. Food and Drug Administration (undated) (public existence disclosed on March 5, 2020), available at: https://hempsupporter.com/assets/uploads/FDA-CBD-Report.pdf.

7. Senator Mitch McConnell, Leader McConnell Discusses Tobacco 21 Legislation, Hemp and CBD with FDA Commissioner Nominee (November 20, 2019), available at:  https://www.republicanleader.senate.gov/newsroom/press-releases/leader-mcconnell-discusses-tobacco-21-legislation-hemp-and-cbd-with-fda-commissioner-nominee.

8. Congress Continues to Seek Regulatory Clarity on CBD from FDA; Daily Intake, Keller and Heckman (September 24, 2019), available at: https://www.dailyintakeblog.com/2019/09/congress-continues-to-seek-regulatory-clarity-on-cbd-from-fda/

9. Remarks at the National Industrial Hemp Council 2019 Hemp Business Summit; FDA (August 12, 2019), available at:   https://www.fda.gov/news-events/speeches-fda-officials/remarks-national-industrial-hemp-council-2019-hemp-business-summit-08132019 

10. FDA, FDA Regulation of Cannabis and Cannabis-Derived Products, Including Cannabidiol (CBD) (March 11, 2020), at https://www.fda.gov/news-events/public-health-focus/fda-regulation-cannabis-and-cannabis-derived-products-including-cannabidiol-cbd. 

11. What You Need to Know (And What We’re Working to Find Out) About Products Containing Cannabis or Cannabis-derived Compounds, Including CBD; FDA (March 5, 2020), available at:https://www.fda.gov/consumers/consumer-updates/what-you-need-know-and-what-were-working-find-out-about-products-containing-cannabis-or-cannabis 

12. Id.

13. Id.

14. Cannabis remains a Schedule 1 drug under the Controlled Substances Act. This means that it cannot be used on federal lands within the states as it remains unlawful under federal law.  Let’s Talk Cannabis; California Department of Public Health (November 17, 2017), available at: https://www.cdph.ca.gov/Programs/DO/letstalkcannabis/Pages/legal.aspx.  This is because of the Cole memorandum that was issued in 2013. The memorandum was sent to all United States Attorneys that the Justice Department would not enforce the federal marijuana prohibition on states that legalized marijuana in some form and implemented effective enforcement systems.  Cole Memorandum; U.S. Department of Justice (August 29, 2013), available at: https://www.justice.gov/iso/opa/resources/3052013829132756857467.pdf.  After a brief rescission of the Cole Memorandum by Attorney General Jeff Sessions in 2018, current U.S Attorney General William Barr made a pledge not to go after companies growing or manufacturing marijuana that was in compliance with state laws and with the Cole Memorandum. Cannabis Quick Hits; Daily Intake, Keller and Heckman (February 1, 2019), available at: https://www.dailyintakeblog.com/2019/02/cannabis-quick-hits/.

15. About Marijuana; NORML (last accessed March 11, 2020), available at:  https://norml.org/marijuana 

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Innovating Dairy Digester Research

Author: Chris M Brunner
Originally Published on UCANR Food Blog

This episode of Food & Facilities, our host is joined by Chris Brunner and Heather Johnson of Western Institute for Food Safety and Security, and Dr. Pramod Pandey of UC Davis’ School of Veterinary Medicine to discuss innovating dairy digester research.
Open in Spotify to listen.
Dr. Pandey checking samples of biogas collected at UC Davis School of Veterinary Medicine’s lab.
Samples of biogas collected at Dr. Pandey’s lab at the UC Davis School of Veterinary Medicine.

California leads the nation in agricultural production, producing nearly all the nation’s leafy green vegetables, most nut and fruit varieties, and is ranked first in egg and dairy production.

What that means is that California also produces a lot of agricultural waste materials, including lots of manure.

Historically these waste materials have been used as a rich source of compost. However, researchers at UC Cooperative Extension are researching innovative uses for this material. 

Dr. Pramod Pandey, a faculty member and Cooperative Extension specialist at the UC Davis School of Veterinary Medicine, focuses on better ways to manage waste material for both large and small farms. Dr. Pandey researches how to convert the organic matter in manure and other waste materials into a renewable energy source that can be used to power our state.

Converting manure to renewable energy

California gets over 27% of its energy from renewable resources like solar wind, and hydroelectric. Our goal is 50% renewable energy by 2030. California is taking steps towards this goal by building a network of dairy digesters which use bacteria to break down dairy manure and convert it into biogas. Clean burning fuels, such as biogas, are a sustainable source for generating energy because when they are burned, harmful by products are not produced.

California currently gets 27% of its renewable energy from solar, wind, and hydro-electric sources. California hopes to reach 50% renewable energy by the year 2030, and 100% by 2045.

Big bonus

Dr. Pandey holding dry manure material, ready for reuse as fertilizer.

A bonus is that the solid material left after the digesters have done their job is a fertilizer that can be used to grow the fruits, vegetables and nuts that our state is famous for. This type of fertilizer contains nutrients that are more readily available for plants because the digestion process breaks up organic materials more efficiently than traditional composting. The digestion process also helps reduce the number of harmful bacteria found in manure, making it much safer for use on plants grown for human food.

Dr. Pandey and Tim Van Beek (Van Beek Brothers’ Dairy) inspect the contents of a dairy digester together.

California leading in discovery and innovation

When we think about where agriculture has been and where it is going, innovation, efficiency and environmental sustainability are hallmarks of our approach in California. People like Dr. Pandey are driving forward research and technology to minimize the impact of agriculture production on the environment. When we think about where agriculture has been and where it is going, innovation, efficiency and environmental sustainability are hallmarks of our approach in California. His multidisciplinary approach to solving this complex problem of agricultural waste materials and water/air quality helps improve the economic wellbeing of farmers, and benefits Californians by providing nutrients for safe, healthy, and nutritious food.

While the importance of California’s agriculture might be huge, its footprint on the environment doesn’t have to be, and it is researchers like Dr. Pramod Pandey who are ensuring our state leads in discovery and innovation for many harvests to come.

Dr. Pandey and Tim Van Beek stand in front of dairy cows at the Van Beek Brothers’ Dairy.
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Hand Washing: Sanitation That Saves Lives

AnnMargaret Dwyer
Originally Published in Food Safety

We can all agree that handwashing is important. We know that washing your hands prevents you from getting sick, helps prevent the spread of germs, and helps keep our food safe. But time and time again we see people choose to not wash their hands, knowing full well they should be. Why does this happen? It is important to understand why people do not wash their hands, that way more effective techniques can be created to enhance your facility’s handwashing culture.

The Psychology of Not Washing Your Hands

Many people do not wash their hands after they go to the bathroom. But why? Pol Rodellar from VICE chose to ask people why exactly they don’t partake in this sanitary process in the article “People Explain Why They Don’t Wash Their Hands After Peeing”. A few responses to note were:

“People just wash their hands because that’s what they see in films. I sometimes do it in front of people who I saw just washed their hands-I suppose it’s out of respect for others. I guess I don’t do it for myself, but for them.”

Sara, 26

“It’s a fact that washing our hands is just something we do to fit into society. This morning, while I was using the urinal, a colleague who had just finished peeing started thoroughly washing his own hands. So when I finished, I had to do the same so that guy- who continued to wash and dry them as if he had just come out of a mine – didn’t think I was some filthy urchin. So here’s to wasting water and soap and a disposable paper towel just because I can’t be bothered to explain my toilet habits to my colleagues.”

Jordi, 30

“I normally wash my hands before I pee because they’re always dirty due to my job. I only wash my hands afterwards if I splash myself. And to be honest, I’ve stopped worrying about contracting things down there.”

Martin, 28

“I don’t have time to be constantly washing myself. I actually think we all clean ourselves too much – it can’t be good for our skin. Our society is too sterilized and it’s not natural.”

Lucia, 22

But Why?

In a study conducted by scientist Thomas Berry and his colleagues on a university campus, Berry wanted to analyze whether or not gender played a role in handwashing behaviors in the bathroom. The team observed 170 subjects in a public restroom and found that the action of hand washing and for how long were based on the activities the subjects conducted in the restroom. In the study, 91% of women washed their hands. This was attributed to all the women using a cubicle to go to the bathroom. When looking at the men, 87.5% of men washed their hands when using the cubicle but only 59.4% washed their hands when using the urinal. The conclusion was that to the subjects, going to the bathroom in the cubicle warranted more hand washing.

In addition to whether each subject washed their hands, those that did were timed. An important note is that the median time for handwashing showed both men and women washing their hands for less than ten seconds. This is troublesome since the Center for Disease Control (CDC) suggested time for handwashing is 20 seconds. This study shows that if your staff is more likely to use a urinal when going to the bathroom, a greater emphasis on handwashing procedures must be put in place to protect food from being contaminated.

When to Wash Your Hands

The more someone washes their hands, the less likely they are to spread germs and disease. In a manufacturing facility all employees should wash their hands before or after the following:

  • Before beginning work
  • Before preparing food
  • Before handling an injury such as a cut
  • After using the bathroom
  • After sneezing or coughing
  • After touching your hair or face
  • After taking out the trash
  • After using cleaning materials
  • Before changing jobs handling raw and ready to eat food

How to Wash Your Hands

As directed by the Center for Disease Control(CDC):

“Follow these five steps every time.

Wet your hands with clean, running water (warm or cold), turn off the tap, and apply soap.

Lather your hands by rubbing them together with the soap. Lather the backs of your hands, between your fingers, and under your nails.

Scrub your hands for at least 20 seconds. Need a timer? Hum the “Happy Birthday” song from beginning to end twice.

Rinse your hands well under clean, running water.

Dry your hands using a clean towel or air dry them”.

The Science Behind Handwashing

Not washing your hands after going to the bathroom is a leading cause of the spread of infections and diseases. Feces is a common source of Salmonella, E.coli 0157, and norovirus, and can also cause certain respiratory infections. “A single gram of human feces—which is about the weight of a paper clip—can contain one trillion germs”. For this reason, in your facility, it is important to ensure that handwashing practices always remain front of mind by having handwashing diagrams with instructions at every hand washing station.

In addition to germs being spread because hands are not washed after using the bathroom, germs can also spread is animal feces inadvertently on raw meat. Cross-contamination and poor sanitation practices can cause these invisible germs to spread.

The Impact Hand Washing Can Have

“Teaching people about handwashing helps them and their communities stay healthy. Handwashing education in the community:

Reduces the number of people who get sick with diarrhea by 23-40%

Reduces diarrheal illness in people with weakened immune systems by 58%

Reduces respiratory illnesses, like colds, in the general population by 16-21%

Reduces absenteeism due to gastrointestinal illness in schoolchildren by 29-57%

https://www.cdc.gov/handwashing/why-handwashing.html

It is not easy to establish a handwashing program that works. To do so you need an engaged staff who feels a sense of ownership for your company’s food safety culture and understands that they are a determining factor in whether your company produces safe food. Hand washing training and seminars need to be part of your “always-on” food safety program because ultimately your entire staff affects your end product and the bottom-line.

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Food Labeling Requirements for Manufacturers and Updated Compliance Dates

By Michael Shabaka, Ph.D., Manex Director of Sales and Innovation Excellence

On May 27, 2016, the U.S. Food and Drug Administration (FDA) published the final rule amending food label requirements.

The final rule amends the labeling regulations for conventional foods and dietary supplements to provide updated nutrition information on the label to assist consumers in maintaining healthy dietary practices with a compliance date of July 26, 2018 for manufacturers with $10 million or more in annual food sales, and July 26, 2019 for manufacturers with less than $10 million in annual food sales.

The FDA recently extended these dates to January 2020 and January 2021 respectively. The FDA has created a Small Industry Compliance Guide to help companies better understand who needs to be compliant and how to become compliant. The FDA does not intend for the document to serve as legal advice and refers to this document as recommendations for compliance. Upon review of the 38-page document, it notes that all food, including supplements and infant foods must be compliant with the new labeling requirements, but there are some exceptions.

Under 21 Code of Federal Regulations (CFR) 101.9(j), product exceptions to the new label requirements generally include:

  1. foods offered for sale by a retailer who has annual gross sales made or business done in sales to consumers that is not more than $500,000;
  2. foods offered for sale by a retailer who has annual gross sales made or business done in sales of food to consumers of not more than $50,000;
  3. medical foods; and
  4. foods that contain insignificant amounts of all nutrients (e.g., coffee beans, tea leaves).

If your small business does not manufacture foods that fall within these four exceptions, then you must be fully compliant with the new rules by January 2021.Compliance with the new labeling requirements can be confusing. For example, section V titled: “Which Nutrients Must Newly be Declared, and What Changes Have Been Made to Nutrients Previously Required or Allowed to be Declared?” provides an example of how to address added sugars and what is considered added sugar.

The guideline states that added sugars are defined as sugars that are either added during the processing of foods, or are packaged as such, and include sugars (free, mono- and disaccharides), sugars from syrups and honey, and sugars from concentrated fruit or vegetable juices that are in excess of what would be expected from the same volume of 100 percent fruit or vegetable juice of the same type, (21 CFR 101.9(c)(6)(iii)). This definition includes single-ingredient foods, such as individually packaged table sugar (see Section V.A.1.(a).(i) and Ref. 1). But there appears to be another twist that can make the new rules confusing and why I believe the FDA is giving smaller manufacturers more time to comply.

For example, the following do not fall under the definition of added sugars. Sugars in fruit or vegetable juice concentrated from 100 percent juices that are sold to consumers (e.g., frozen 100 percent fruit juice concentrate) (21 CFR 101.9(c)(6)(iii)).  Sugars in fruit juice concentrates that are used to formulate the fruit component of jellies, jams, or preserves in accordance with the standards of identities set forth in 21 CFR 150.140 and 150.160 (21 CFR 101.9(c)(6)(iii)). Sugars in the fruit component of fruit spreads (21 CFR 101.9(c)(6)(iii)).  Sugar alcohols and Sugars in juice concentrates that are counted towards percentage juice label declaration under 21 CFR 101.30 for 100 percent juice or 21 CFR 102.33 for juice beverages (21 CFR 101.9(c)(6)(iii)). Sugars in juice concentrates that are used to standardize the Brix values of a single species juice consisting of juice directly expressed from a fruit or vegetable in accordance with 21 CFR 102.33(g)(2) (21 CFR 101.9(c)(6)(iii)). Naturally-occurring sugars found in milk and dairy ingredients, except lactose as defined in 21 CFR 168.122.

The food labeling laws can be a daunting task, especially if there are product changes or reformulations. The additional year that the FDA has provided to ensure manufacturers are compliant can help businesses become fully compliant with the new food label requirements. Does your business understand the new label rules, and will your business be fully compliant with the new food label requirements on January 1, 2021?

About the Author

Michael Shabaka, Ph.D., is the Director of Sales and Innovation Excellence for Manex. He has over 20 years of business development, sales and marketing experience, spanning several industries including biotech, high tech, publishing, environmental lab services, and the non-profit sector. Dr. Shabaka holds a Ph.D. in Organizational Behavior with a concentration in Transformative Learning and Change from the California Institute of Integral Studies, San Francisco. He also holds a Master of Business Administration degree in Marketing and Finance and a Bachelor of Arts degree in International Affairs from Holy Names College, Oakland. He can be reached at mshabaka@manexconsulting.com.

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Four Takeaways from the 2019 Safety and Maintenance Expo

On October 22, 2019 West Coast Industrial Solutions hosted the first annual Safety and Maintenance Expo! It was held in Clovis California in the Clovis Veteran’s Memorial District’s state-of-the-art event space. Representatives of industry ranging from food growing and processing, manufacturing, education, utilities, services, and regulatory agencies walked
the trade show floor. Attendees were also able to participate in presentations on Valley Fever training, the FDA’s Food Safety Modernization Act (FSMA), business safety and risk management, and workplace violence prevention and response. Here are the key takeaways from the four presentations made during the expo.

1) Valley Fever training will be required May 1st, 2020.

What is Valley Fever and what are its causes? According to the Mayo Clinic, Valley Fever is a fungal infection caused by spores of coccidioides organisms that can be found in the soil. These spores can be breathed into the lungs after they have been made airborne by any activity that stirs the soil: farming, construction, or strong winds. The first major presenter was Protec Safety Consultants’ Ralph Morales, who provided training for the awareness, prevention, and treatment of Valley Fever. This training was in compliance with California’s Assembly Bill 203 requiring certain construction employers in areas most affected by Valley Fever (including, but not limited to, the counties of Fresno, Kern, Kings, Madera, Merced, Monterey, San Luis Obispo, and Tulare) to provide effective awareness training by May 1st, 2020. This training will be required annually for all employees for professions that participate in digging, grading, or other general earth moving operations; Even if your company is operating vehicles on dirt roads—because the activity can cause the Valley Fever fungus spores to become airborne.

To ensure your company is Valley Fever ready and AB 203 compliant, you can visit protecsafetyinc.com, contact Ralph Morales at ralph@protecsafetyinc.com, or call his office at (559) 900-7471.

2) The FDA’s Food Safety Modernization Act and Changes in Enforcement.

The FDA’s most sweeping reform of U.S. food safety laws in 70 years is the Food Safety Modernization Act (FSMA). The act was meant to address food safety issues and how to prevent them in the U.S. food supply. It was originally signed into law in 2011, with the seven rules being finalized in subsequent years. The second presenter, Safe Food Alliance’s Senior Food Safety Manager, Jon Kimble, explained the FDA’s rules in this law, how they intend to approach addressing these food safety issues, and what is expected of the food industry. These rules include: preventative measures to be implemented in growing and harvesting crops; the proper procedures for processing, transporting, and storing food; the proper importing of food items; and preventing tampering in the food supply. Mr. Kimble punctuated the outlining of these rules with the latest changes the FDA was making to enforce them.

If your company requires food safety training, food safety system development and implementation, root cause analysis, management of internal audits, or advisement on conducting third-party audits, you can contact Jon Kimble at jonk@safefoodalliance.com, or browse Safe Food Alliance’s website safefoodalliance.com/food-safety-training/.

3) Establishing a Safety and Risk Management Plan can Improve Employee Relations and Keep Costs Down

After having over 20 years experience in occupational safety and risk management James G. Parker Insurance Associates’ Vice President, John Cleveland, suggested that the foundation of risk management policies can help businesses have better employee relations and work practices as well as cost savings and mitigation of volatile insurance related expenses. Cleveland outlined the four main rules he has established for businesses to follow and how to apply them. Firstly, he suggested establishing clear expectations, policies, and procedures to ensure peak task performance. Secondly, Cleveland stated employees will generally meet performance expectations and criteria communicated to them. Thirdly, he warned each individual employee comes with their own safety and risk causes that they will bring to the workplace with them. Lastly, the manager working most closely with the employees should be motivating, recognizing, and communicating expectations appropriately.

If your company could benefit from a safety and risk management plan, reach out to James G. Parker Insurance at jgparker.com/ or contact John Cleveland at jrcleveland@jgparker.com.

4) Workplace Violence is Preventable–Know the Signs and How to Respond

Annually, an estimated two million U.S. workers experience violence on the job. Though the warning signs are often overlooked, there are almost always ways to prevent impending violence. Our fourth and final presenter, Alvarez Associates’ President, Hector V. Alvarez, taught a course on Workplace Violence Prevention and Response. He used his over 25 years of experience to craft a course suitable for all staff to learn awareness, tools, and resources to help protect the workplace—and those in it—from the threat of violence. Alvarez covered the dynamics of workplace violence, how to establish personal safety strategies, how to establish workplace safety strategies and resources, how to recognize safety warning signs, and how to form a protocol for properly responding to Active Violence.

If your company requires training in workplace violence prevention and response browse wvpexperts.com/ or contact Hector V. Alvarez at halvarez@wvpexperts.com.

These presenters exhibited alongside our other event participants:

If you missed 2019’s event, don’t worry! The magazine is planning another event on September 17, 2020 at the Clovis Veterans Memorial District. Register for your booth today and you will receive a complimentary business card ad in the July-September 2020 quarterly issue! Final deadline for the booth and advertising space special is May 25, 2020.

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COMPANY PROFILE: United Health Centers of the San Joaquin Valley

United Health Centers of the San Joaquin Valley (UHC) began as a grass roots health care initiative in the early 1970s by Orange Cove and Parlier community members. People who lived and worked in these small rural California cities had to drive over 40 miles to reach the nearest emergency room, and local healthcare resources were few and far between. As a 501(c)(3) non-profit organization and designated as a Federally Qualified Health Center (FQHC), UHC does everything it can to serve everyone, but especially people in underserved populations to receive the quality of healthcare they deserve.

Colleen Curtis, UHC President and CEO

Colleen Curtis has been President and CEO since 2008 and is UHC’s biggest advocate. With the implementation of the Affordable Care Act and effective strategic planning with an all-volunteer Board of Directors, UHC has been able to dramatically expand from only seven health centers in 2010 to seventeen health centers today and have plans for growth to reach twenty-four by the end of 2020. UHC currently has a staff of over 800 employees to deliver care to more than 90,000 patients with 515,000 clinical appointments annually to underserved communities primarily composed of Hispanic farm laborers and agricultural workers.

Through the expansion of health centers located across three Central Valley Counties of Fresno, Tulare and Kings, the UHC mission has remained focused on the underserved:

“We are committed to the lifetime wellness of our communities by providing accessible, comprehensive quality health care to everyone, with compassion and respect,
regardless of ability to pay.”

And in each health center, UHC provides state-of-the-art healthcare in all of its beautifully designed and furnished facilities including those in rural communities like Huron, Mendota, and Earlimart which are among the poorest towns in California.

Each UHC health center offers a combination of comprehensive primary healthcare services
including medical, dental, optometry, integrated behavioral health, chiropractic, prenatal care, as well as, other specialty services, ancillary services including pharmacy, x-ray, and clinical laboratory along with urgent care extended hours on weekends and free patient transportation. UHC also provides free enrollment services to assist patients with medical coverage and has a sliding scale for noninsured patients. The majority of their employees are bilingual, and everyone is incredibly welcoming and provide excellent patient focused services.

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The Basics of Food Tolerances and Maximum Residue Limits

Written by Wiley A. Hall, 4th, Ph.D.
Originally Published in Safe Food Alliance, Testing & Analysis

An MRL (Maximum Residue Limit) or a food tolerance, as it is known in the USA, is the maximum amount of a pesticide residue that can be found in or on food. While any food with a pesticide residue under an MRL should be safe to eat, it is important to remember that an MRL is not a safety limit. That being said, a residue over an MRL is not necessarily a safety hazard, but rather a violation of good agricultural practices (GAP).

If you are growing, packing, importing/exporting, or otherwise involved in the domestic or global trade in agricultural commodities, it is critical that you be aware of any MRLs that may affect your commodity and the regulations around them. This article is meant to give you a basic introduction of pesticides and their limits, but no single article can cover all the complexities and local variations in MRLS. If you have questions about your specific situation, reach out to your PCA, local farm advisor, grower group, or a Safe Food Alliance representative.

Let’s start with some definitions.

Pesticide

A pesticide is defined by the EPA as: “Any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest.”, “Any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant.” or “Any nitrogen stabilizer”.

Active Ingredient

The active ingredient (AI) in a pesticide is the chemical or chemicals that actually have the desired effect and do the heavy lifting (the AI in Round Up is glyphosate). The rest of a pesticide product is the inert ingredients such as solvents (e.g. water) and adjuvants which are additives that improve pesticide performance (spreaders, wetting agents).

Pesticide Residue

A pesticide residue is the trace amount of any pesticide remaining on the crop after treatment
(and any post treatment steps required by the label, such as a reentry period). It is important to note that an MRL may refer to an AI, adjuvant, or any other residue that results from a pesticide application, like metabolites. Remember, all MRLs are specific to a pesticide and crop combination. For example, if you find the fungicide Imazalil on oranges, and the market does not have an MRL for it, then any Imazalil residue found on an orange is illegal (a positive list system or PLS).

Default MRLs

Some markets, like Europe or Japan, have default MRLs where if there’s no specific MRL for a given crop/ pesticide, but the pesticide isn’t specially banned, the MRL defaults to a given value (usually 0.01ppm). These default MRLs are generally set to around the current limit of detection for most pesticides, though, so there’s often little difference between a default MRL and no MRL.

Residue Definition

The last important definition we’ll discuss is the residue definition. The residue definition tells you what chemicals need to be measured to determine if your commodity conforms with the MRL. For example, the residue definition for the herbicide oxyfluorfen is just the chemical oxyfluorfen, but for fosetyl-aluminum both the parent compound, fosetyl-aluminum and the chemical it degrades into in the environment, phosphonic acid, needs to be measured. This can also change based on the commodity and market: the residue definition for glyphosate for wheat in the United States is different than the definition for almonds in Australia.

How are MRLs made?

While an MRL is not a safety limit, the setting of an MRL begins with safety testing.

How It’s Done

  1. The registrant of a pesticide performs animal studies to determine the smallest amount of the active ingredient that the animal can be exposed to before having an adverse reaction. This amount is the no observable adverse effect level or NOAEL.
  2. From there, they take the NOAEL and multiply it 100 times to give a range (Safety Margin) to include as much of the population as possible.
  3. The safety margins and two toxicological values are then applied: the smallest amount that it is acceptable for humans to consume at one sitting (acute reference dose or ARfD) and the smallest amount that it is acceptable for humans to consume on a long-term basis (acceptable daily intake or ADI) are calculated.
  4. The registrant carries out field trials, where the pesticide is applied to the commodity at the highest proposed rate and the crop is then handled according to GAP.
  5. Finally, the MRL is set based on statistical analysis on the range of pesticide residues found on the crop from the field trials, after all applicable harvest activities. What that means is they analyze how much of the crop is left after harvest and measure if it might get people sick.

Following The Directions

Again, while the MRL needs to be at a safe level (all sources of consumption are summed and the MRL is only approved if the public’s estimated consumption is under the ADI and ARfD), it is really a way of ensuring that GAP was followed in the application of the pesticide. If the instructions in the pesticide label are followed, the pesticide residue, by the time the commodity reaches the consumer, should be under the MRL. It is important to follow the label, as an MRL violation is a sign that GAP was not adhered to, possibly risking harm to the environment, workers and those who live nearby the spray site.

How to Stay Informed on MRLs

The world of pesticide regulations is large and constantly changing. Even the basic information
covered in this article may seem like a lot to have to keep track of, without getting into the specifics of how MRLs work in each individual market. Europe alone is worth its own (much longer) article, one that might go out of date in the time between writing and reading. The good news is that all the information you need to stay informed on the state of MRLs is publicly available if you know where to look.

For the most up to date information, make sure to stay in communication with any PCAs, farm advisors, or grower groups who may have firsthand knowledge of your crop, growing methods, and target market.

Second, visit an online database where you can find information on what MRLs there are for your crop and market. Online databases are available for the United States, Europe, Japan, Korea, Canada, for starters, but that can still be a lot to have to keep straight. Bryant Christie Inc. keeps an excellent MRL database that covers over “…1000 pesticides, 875 commodities, and 125 markets”; due to a grant from the federal government. Access is free to users within the United States.

Remember, the key to avoiding pesticide residue issues is to stay informed. By knowing where there may be potential issues ahead of time and testing for residues before you ship your commodity, you can manage your pesticide risk.

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Unions Can – and Will – Play a Leading Role in Tackling the Climate Crisis

Written by Matt Perry, Reader in Labour History, Newcastle University
Originally Published in The Conversation

How did a billionaire win over coal miners in Pennsylvania and West Virginia to become president? Three words: “Trump digs coal”. By linking deindustrialisation and the decline of working communities in America’s “rust belt” to environmental regulation, Donald Trump could paint his greener rivals as out of touch with the concerns of ordinary Americans. Never mind that climate change and pollution will hit working class people hardest – when it’s “jobs or the planet”, the former will always be a more immediate worry for the precarious and impoverished.

It needn’t be that way though. The campaign for One Million Climate Jobs, organised by the Campaign against Climate Change Trade Union Group, has put workers at the forefront of its vision for tackling the climate crisis. The proposals for a Green New Deal in the US and the UK are supported by trade unions which represent millions of workers. Both projects demand jobs are protected and new ones created as part of a “just transition” from the carbon economy.

The Trade Union Congress (TUC) backed the September 20 day of international climate strikes and millions of workers joined the protests that school students had launched. This kind of mass mobilisation will be crucial to climate action and the role trade unions play will be indispensable. But worker-led environmentalism isn’t a recent phenomenon – the history of labour and green movements are intertwined.

You have nothing to lose but your planet

Trump’s “workers-versus-the-planet” framing misunderstands the origins of the climate crisis, which go back to the private enclosure of common land in the UK. This forced people from rural areas and into crowded urban slums, creating the first proletariat. Once there,industrialists switched from water-powered mills to coal-powered factories to intensify the work routines of these new urban workers.

The ‘dark satanic mills’ of ‘Cottonopolis’: Manchester, England
in 1840 during the height of its cotton industry.

Coal powered travel helped bosses find cheaper labour overseas and strengthened their authority over an insurgent working class. At every step, workers resisted this transition. The high point of this long battle was the English plug riots of 1842 – viewed as the world’s first general strike – when textile workers literally pulled the plug on the coal-fired boilers of their factories.

In their new urban grimescapes, workers suffered from the toxic raw materials and effluence of the factories they worked in. Class determined whether city dwellers lived in the smog around chimneys or with clean air in leafy suburbs, and it still does.

Born out of the acute stress of living in polluted and disease ridden slums, working class movements won public health reforms that have became the standard, such as proper sanitation and rubbish disposal. Working class people have always valued nature in leisure time too, whether it’s cycling, fishing, pigeon-fancying, dog walking or tending allotments.

Unions have long campaigned against workplace hazards, and it’s workers who fight the impacts of climate change every day. Firefighters risk their lives to rescue people from more frequent flooding and wildfires and the Fire Brigades Union has campaigned against staff cuts, inadequate levels of equipment and a lack of training to deal with hazards like polluted floodwater.

A world to win

Environmental struggles litter labour history, but they’re not always the stories you read about. The modern environmental movement emerged, to a large extent, from Rachael Carson’s brilliant Silent Spring – a book published in 1962 which revealed the devastating ecological consequences of pesticides in post-war America. But the book overlooked the acute burden on vulnerable agricultural workers who are forced to use these chemicals.

During a spectacular organising drive and protests by the United Farm Workers in the 1960s, union leader Cesar Chavez exposed the damage these toxins caused to Latino labourers, winning concessions from their employers and standing up for them against anti-migrant racism.

Belfast, July 30 2019:
Workers from the Harland and Wolff shipyard, where the Titanic was built,
protest against the potential closure of the yard.
DJ Wilson/Shutterstock

Today, the shipyard that built the Titanic – Harland and Wolff in Belfast – is threatened with closure, but its workers are defiant. They demand that the shipyards be nationalised and used to create renewable energy infrastructure. This offers an exciting glimpse of the leading role that workers can take in the enfolding response to the climate crisis.

Elsewhere in the world, labour organisations have allied with indigenous people against developments that threaten their lands and destroy the local environment. In British Columbia, unions supported First Nation resistance to pipelines and tar sands oil extraction, while the rubber tappers’ union demonstrated against destruction of the Amazon rainforest.

Such a broad alliance is needed to tackle climate change, and that means mobilising labour in its widest sense – women in the household economy the rural poor, indigenous people, fishing communities, the unemployed and school students. Equally, understanding the configuration of power and ideology that drives the fossil fuel economy – big businesses, geopolitical rivalry over oil and gas resources, nationalistic buck-passing, corporate PR and those who blame overpopulation. With CO2 emissions rising, there’s little time to waste.

Working class environmentalism is part of the solution to the climate crisis. If successful, the movement will give new meaning to the old maxim: “the cause of labour is the hope of the world”.

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Innovations in Irrigation for SGMA Compliance Ease: Fresno State #AgTechDay Showcase

Written by Tara Sweeney

Sustainable Groundwater Management Act

USDA State Shares of Total U.S. Irrigated Acres 2012 Pie Chart

Anyone in California can tell you—California is facing a water problem. The majority of that water is being consumed by agriculture—according to the USDA, it accounts for 80 percent of the United States’ water consumption. In many Western States, it can account for over 90 percent. In 2012, California was the state with the second largest agricultural acreage at 7.9 million—at about 14 percent of the Nation’s total.

In the wake of increasing drought risk in “The Sunshine State” the Sustainable Groundwater Management Act (SGMA) was signed into California law in September 2014, the act requires local governments and water agencies to reduce water use, reaching a balance between pumping and recharging groundwater basins by 2040 for critically overdrafted basins, then 2042 for the remaining high and medium priority basins.

Groundwater Sustainability Agencies (GSAs)

Localized GSAs work within city governments to meet their specific land-use and water-management requirements; SGMA groundwater management is a platform that can help local growers, GSAs, and local governments track and monitor water use in relation to current basin levels. UC Davis defines the SGMA online portal, under the California Department of Water Resources, as a platform for local GSAs to create groundwater sustainability plans to show how they plan to balance groundwater pumping with groundwater replenishment within 20 years, without undesirable results such as subsidence—the sinking of an area of land due to the movement of underground materials. These local agencies will create local solutions that will vary from basin to basin.

How are growers meant to track their ET (evaporation to transpiration) ratio efficiently, to ensure that they are compliant with GSAs by adopting Groundwater Sustainability Plans? Each GSA has specialized requirements to react to their specific local legislation as well as their local water needs. As such, growers need to start looking into innovations in irrigation. Innovations for both assistance in monitoring water-use for ease of reporting to their GSA’s, and to streamline the efficiency of their growing operations.

Fresno State AgTechDay Showcase

That’s where Fresno State’s AgTechDay comes into play; on November 15, 2019 The Center for Irrigation Technology (CIT) hosted the event at Fresno State’s Water, Energy, and Technology (WET) center that acts as a hub of innovation incubating companies that can create products that will make tracking water usage—and meeting SGMA regulations more manageable.

Bill Green, Center for Irrigation Technology’s Education Manager was quoted as saying,

“The Center for Irrigation and Technology is excited to host, encourage and facilitate conversations surrounding real-world issues in water, energy, and agriculture. Our goal is to help lead those conversations, but also inform and educate those who wish to learn more, or reach a higher level of sustainability within those three industries.”

The event provided monitoring and controlling device option overviews for the industry with examples. An Agricultural Consultant, Researcher, and Sales Representative explained how their methods and devices worked at the water source at the plant source, and devices that worked in-between. Below is a brief explanation of their offerings and how they can benefit growing operations at each stage in the water management process.

At the Water Source

Some of the technologies proposed would help growers and GSAs monitor water use at the source. Examples of which are specialized fertigation—injection of fertilizer or nutrients into the irrigation system—methods, collecting data via digital platforms to upload to the SGMA online platform, and monitoring power and water data wirelessly at the point of utility power meters.

Stock Image of Blueberries

Among the orchards in Fresno State’s Agricultural Laboratory, Agricultural Consultant William D. Jones proposed a strategy—based on his research with blueberries and similar crops—for more efficient fertigation. Firstly, that the measurements of concentration of fertilizer in the water source (parts per million) and amount of fertilizer applied to the field (pounds per acre) of fertilizer nutrient elements. Secondly, placement of the elements directly in the root zone. Thirdly, more suitable fertigation equipment were key to improving crop yield and quality for growers while protecting the groundwater resource from the leaching of those chemicals.

Most growers base their fertigation measurements on the amount (lbs/acre) of fertilizer; Jones suggested that this can cause an inconsistency and overuse of fertilizers. As such, Jones suggested fertigation be measured by concentration (ppm) in the water provided at the root source to both provide consistent fertilizer application, as well as preventing excess fertilizer nutrients being carried into the groundwater resource. Jones created a chart outlining the amount of fluid fertilizer and pounds of nutrient element per one acre inch of water for each element. Useful dry fertilizer products he noted were urea, ammonium sulfate, ammonium phosphate, MAP, DAP, calcium nitrate, ammonium nitrate (scarce), and potassium nitrate. Useful fluid fertilizer products he noted were CN 9, CAN 17, UAN 32, and 10-34-0 Polyphosphate.

Considerations that he suggested for the implementation of a more efficient fertigation system are whether the injection installation system were to be stationary or mobile; whether nutrient configuration be in single tanks—either single nutrient or multinutrient with chemical compatibility considerations— or multiple tanks for multiple elements; along with nutrient types and concentrations to be mindful of.

For more information you can contact William D. Jones, Certified Crop Advisor via email rootstockspecialty@sti.net or call his office at (559) 642-3650.

Alongside the canal in the outreaches of Fresno State’s Agricultural Laboratory, PowWow Energy presented on how their digital platform provides integration and reporting. PowWow uses the currently installed SmartMeters to monitor water use—saving on the cost of hardware in that respect—for reporting to GSAs, along with telemetry stations to track the groundwater table. Their system’s algorithms can help set a baseline of data, potentially identify problems, and track measurable results.

Stock Image of a Water Meter

Morgan Halpenny presented the Pumpsight meter, which provides measurement of power and water data via a wireless receiver. providing measurement of power and water data via a wireless receiver. Pumpsight also uses telemetry—the process of recording and transmitting the readings of an instrument—and they are compatible with radio frequency systems that have a common published interface (LoRa, Zigbee, SigFox.)

Firstly, Pumpsight offers pump optimization with efficiency and cost analysis, measuring when and how much water is applied, and being able to respond to line pressure and water table changes. Secondly, the system offers failure prevention by identifying degrading equipment, monitoring well levels for rehab and maintenance needs, and system alerts for blowouts, power outages, or equipment failures. Pumpsight’s data logging feature’s higher frequency of sampling can provide better information resource for making water management decisions, measure the impact of conservation efforts and equipment upgrades, along with recording historical water consumption. Halpenny suggests that the increased frequency will allow users to respond more quickly to water needs, instead of the traditional measurement comparing the beginning of the season to the end of the season.

For more information PowWow can be contacted at info@powwowenergy.com or (415) 658-7125.
Pumpsight can be contacted at info@pumpsight.com or (213) 793-5894

The previous technologies monitor water use at the source, further on we will discuss technologies that are attached to the plant and one that acts as a water control measure between the source and the plant.

Attached to the Plant

Researchers from the Electric Power Research Institute (EPRI) evaluated a series of devices that measure sap flow in individual plants, equipping vineyards to optimize irrigation — meeting water conservation goals and realizing energy and financial savings.

EPRI Engineer/Scientist Ryan Berg presented research led by EPRI’s Sudeshna Pabi and Marek Samotyj on “Plant Aware Irrigation” (PAI) developed by Fruition Sciences, supported by the California Energy Commission’s Electric Program Investment Charge Program, through Commission Agreement Manager, Karen Perrin. Researchers assessed PAI’s potential benefits by quantifying water and electricity savings, along with crop quantity and quality at harvest.

The technology uses sap flow sensors installed directly on vine stems. Vines are selected using aerial imagery, and ground-based laser mapping. Proprietary algorithms use sap flow data along with climate data to derive a daily Water Deficit Index (WDI) alerting staff to irrigate crops when an established threshold is reached.

Researchers installed PAI technology at three test vineyards in Northern California’s wine country, each producing a different type of grape (cabernet sauvignon, pinot noir, and chardonnay). They evaluated results relative to traditional irrigation practices. The vineyards were selected to provide insights into the water/energy nexus and its relevance to climatic and grape variations. In addition to water consumption, data included berry sugar accumulation profiles to assess fruit ripeness and yield measurements over 12 months.

Stock Photo of Grape Vines

They reported that the water stress imposed in PAI treatment blocks indicated an average of 61% water and energy savings across all locations, with no effect on fruit ripening or yields. In fact, researchers and vineyard owners noted a qualitative and quantitative improvement, as measured by earlier berry ripening leading to:
• higher berry color content and more flavors;
• more uniform berry sugar accumulation profile; and
• similar or higher individual berry weight.

The research suggests that monitoring vines directly can potentially help keep plants healthy and producing to meet requirements, while enabling environmental and fiscal sustainability.

For more information you can contact Ryan Berg at rberg@epri.com or (650) 855-8627.

The last technology to discuss goes between the plant and water source to act as a way to control the irrigation process.

And In-Between

Joseph Gallegos of Drought Diet Products presented a new technology, previously only used on smaller-scale urban, organic farming growing operations—used on berries and similar root systems—where the irrigation system creates a miniature virtual water table for application of water and fertigation nutrients at the root level. The system consists of post-industrial ABS plastic for the piping that is installed at the depth of the root system to release the water directly where it is needed instead of surface treatments which may not penetrate the soil completely. His company is looking for large-scale orchard operations to install an enlarged version of this system alongside every other row of trees. The goal of this is to reduce the loss of water through evaporation, and only use what the trees need. In the winter time the same pipe is used to recharge the groundwater from winter storms or snow runoff—equal to the amount of water
that was taken out during the summer months. End goal is groundwater balancing each crop year. More research needs to be done, to measure how this technology can be translated from small-scale urban farms to large-scale industrial farming methods.

For more information you can contact Joseph Gallegos at joseph@droughtdietproducts.com
or call his office at (562) 301-5598

These innovations mentioned were only those of the featured presenters, for more information on other innovations available through those that participated in the trade show at Fresno State’s AgTechDay, please contact Courtney Meinhold, (559) 278-2066, cemeinhold@mail.fresnostate.edu); for more information about Fresno State’s Center for Irrigation Technology (CIT) contact Charles Hillyer, hillyer@mail.fresnostate.edu; for more information about the Water, Energy, and Technology (WET) center call (559) 278-2066 or fax (559) 278-6033).