Bridging the GAPs: Approaches to Treating Water On Farms

• How much product is at risk if the critical limit is exceeded? If a large amount of produce is at risk, more frequent monitoring may be warranted.

Who will perform the monitoring? It is important that growers identify the person(s) responsible for monitoring and provide adequate training. This training should be supplemented with written procedures and directions on recordkeeping. The trained individual should also be trained to know what steps to take in case a critical limit is not met.

Discuss the importance of properly written SOPs (standard operating procedures) for monitoring critical limits.

Corrective Actions

Once critical limits and monitoring have been established, it is extremely important to understand what actions to take if a critical limit is not met. When critical limits are not met, a deviation has occurred and it is then assumed that the potential hazards (pathogens) are not controlled. In this case, corrective actions must be implemented and documented. Procedures for carrying out corrective actions include multiple components. Correct and eliminate the cause of the deviation and restore process control through both short-term, or immediate actions, and actions that impact long-term activities. Immediate corrective actions could include increasing the concentration of free chlorine. Long-term activities include a root cause analysis to determine what may have caused a drop in free chlorine and the determination of how it can be prevented in the future. In addition, it is important to identify the area within plots or fields that were impacted by the deviation.

Take a deeper dive into root cause analysis - https://www.pewtrusts.org/en/research-and- analysis/reports/2020/03/a-guide-for-conducting-a-food-safety-root-cause-analysis

Corrective actions should be in place to address the following:

• Fix or correct the cause of the deviation, i.e., untreated or improperly treated water. This may be as simple as a quick fix (e.g., reconnecting a hose or plugging in the UV light).

• Assess and determine what should be done with the produce that may have been exposed to untreated water.

• Maintain records of the deviation and corrective actions that have been taken.

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