Food Safety Practices Guidance for Sprout Manufacturers
Appendix B: Seed Production – Good Agricultural Practices
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Section 3 of the Code of Practice for the Hygienic Production of Sprouted Seeds, February 2007, published by the Canadian Food Inspection Agency, outlines several steps in the production of seeds where the application of GAP is aimed at preventing microbial pathogen contamination of seeds.
3 Seed Production
Microbial and chemical contamination may occur during the cultivation and harvesting of seeds in fields or during storage and transportation. The safety of sprouts is highly influenced by the degree of preventive measures used on-farm to avoid contamination of seeds. Seeds used for sprout production should be produced using GAP at all stages of planting, growing, harvesting, cleaning, storage and transportation. Sprout manufacturers should prescribe that seed producers adopt GAP and provide evidence that the product was grown according to specifications. The general aspects of GAP to minimize the risk of contamination of seeds for spout production include:
3.1 Land usage
Whenever possible, potential sources of contamination from the environment should be identified. In particular, primary production should not be carried out in areas where the presence of potentially harmful substances would lead to an unacceptable level of such substances in or on seeds after harvest.
Where possible, seed producers should evaluate the previous uses of the sites (indoor and outdoor) as well as adjoining sites in order to identify potential microbial, chemical and physical hazards. The potential for other types of contamination (e.g. from agricultural chemicals, hazardous wastes, etc.) should also be considered.
To the extent possible, steps should be taken to prevent the access of farm and wild animals to the sites to avoid potential fecal contamination of the soil and the risk of contaminating the crop. Runoff or wind contamination from intensive livestock operations and flooding by contaminated water sources should also be considered.
3.2 Natural fertilizer
Composting and other treatments may reduce but not necessarily eliminate pathogens in manure. It is particularly important to prevent microbial contamination during the production of seeds because of the potential for pathogens to grow during the sprouting process. Consequently, manure, bio solids and other natural fertilizers should only be used when they have undergone treatment or have been subjected to environmental conditions that achieve a high level of pathogen reduction.
3.3 Agricultural water
Water used for irrigation and other agricultural uses is a potential source of microbial contamination. Seed producers should evaluate the source of water used on-farm (well, open canal, reservoir, reused irrigation water, municipality, rivers, lakes, ground water, etc.), monitor its safety and control potential sources of contamination. Water known or suspected to be contaminated with animal or human waste shall not be used.
3.4 Chemical control
Seed producers and distributors should only use chemicals for agricultural purposes and post-harvest treatments acceptable for seeds intended for sprout production. These chemicals should be used according to manufacturer's instructions for the intended purpose. Their use must not result in exceeding Maximum Residue Limits in sprouts. Seed producers and distributors should keep records of chemical applications (agricultural or post-harvest chemical used, rate and date of application, etc.).
3.5 Worker hygiene
Hygiene and health requirements should ensure that people who come directly or indirectly into contact with seeds do not contaminate them. People known or suspected to be carriers of a disease or illness should not be allowed access to areas of the fields or indoor premises where there is a potential for contaminating seeds for sprout production. To ensure good personal hygiene, seed producers should provide toilets and hand washing facilities easily accessible to all workers who come directly into contact with seeds.
Harvesting equipment should be adjusted to minimize soil intake and should be cleaned of any debris or earth before harvesting. Handling equipment (augers, conveyors, etc.) should be cleaned and inspected. Transport trucks, wagons, etc. should be cleaned and sanitized if used to haul manure and soil. Storage bins, totes, etc. should be clean and be bird and rodent proof and/or stored in a rodent controlled facility.
Diseased or damaged seeds which could be susceptible to microbial contamination shall not be used for sprout manufacture. Seed lots intended for sprouting should be segregated from product to be used as animal feed (e.g. for hay production).
Seeds for sprouting should be free to the extent possible from foreign matter, including soil, insect fragments, bird and rodent droppings, metal and glass fragments. Conditioning utilizes a variety of equipment to remove soil, weed seeds and other debris from seeds. Conditioning should be carried out in a hygienic manner, employing practices that minimize potential sources of contamination.
- Equipment should be constructed to allow for easy cleaning and, when necessary, sanitizing.
- Equipment should be protected from pests.
- All equipment should be thoroughly dry cleaned (compressed air, brushes, etc.) between lots and sanitized if required.
- Seed conditioning facilities should ensure that the equipment has not been used to handle animal products. If equipment has been used to handle animal products, it should be thoroughly cleaned and sanitized before seed cleaning operations are undertaken.
- Packaging of seeds for sprouting should be carried out in a hygienic manner.
- Equipment should be constructed to allow for easy cleaning and when necessary, sanitizing.
- Equipment should be protected from pests.
- Solid bags must be used; open weave bags should not be used.
- Contaminated or recycled bags should not be used.
- Each package should be marked to identify its source and lot. Any seed that has been treated must clearly state the source and the lot on the label.
- Packaged seeds should be stored in a clean and dry area and protected from vermin and pests.
3.9 Transportation and storage
Seeds should be packaged in bags or containers that are impermeable to contamination during storage and transportation. Containers, vehicles, and storage facilities should be cleaned and sanitized before use. At all times, seeds, equipment, storage bins and shipping bags should be protected from rodents and birds with a complete pest control program in place that includes monitoring, eradication, cleaning, sanitation and record keeping.
3.10 Analyses, documentation and records
Seed distributors should analyze each lot for the presence of microbial pathogens of concern such as salmonella and E. coli O157:H7 using internationally accepted analytical methods. Microbial analysis of seeds may help identify highly contaminated lots. Seed producers and sprout manufacturers must be aware that negative results do not guarantee pathogen free seeds because of analytical and sampling limitations. It is important to use random sampling techniques, sufficient sample sizes and sub sample numbers to represent the lot as best as possible.
Lots of seeds for which positive results are obtained shall not be used for sprout production. Other lots which were produced under similar conditions (e.g. on the same sites or with the same agricultural inputs) that present a similar hazard shall not be used for sprouting. These lots should be held and detained until they are disposed of properly.
Seed producers should keep all records on agricultural activities current, such as: the site of production; suppliers' information on agricultural inputs; lot numbers of agricultural inputs; irrigation data; agricultural chemical and fertilizer usages; water quality data; cleaning schedules for premises, facilities, equipment and containers; and, details of disposition of rejected lots. Records shall be retained for a minimum of five years.
3.11 Trace-backs and recalls
Producers of seed for sprout production must ensure that trace-back records and recall procedures are in place to effectively respond to health risk situations. Procedures must enable the complete and rapid recall of any implicated seed lots and provide detailed information to assist in the identification and investigation of any contaminated seeds and sprouts. The following should be adopted:
- Seed production and distribution practices should minimize the mixing of multiple lots of different origins that could complicate trace-back and provide greater opportunity for cross-contamination.
- The CFIA and the required provincial or municipal authorities should be notified of all recalls.
- Seed producers and distributors, and sprout manufacturers should maintain a record of traceability for each lot. The lot number, the producer and the country of origin should be indicated on each bag.
- Seed producers should have a system to effectively identify lots; trace the sites and agricultural inputs associated with the lots; and allow physical retrieval of the seeds in case of a suspected hazard.
- Where a lot has been recalled because of a health hazard, other lots that were produced under similar conditions (e.g. on the same sites or with the same agricultural inputs) and that may present a similar hazard, should be evaluated for safety. Those lots presenting similar risks (e.g. containing a pathogen) must be recalled. Blends with potentially contaminated seeds also must be recalled.
- Seeds that may present a hazard must be held and detained until they are disposed of properly.
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