DUE DILIGENCE RESPONSE OF FARMERS

GOOD AGRICULTURAL PRACTICES DUE DILIGENCE RESPONSE OF FARMERS DECEMBER 2006 IICA Office in Saint Lucia

WHAT IS IICA The Inter-American Institute for Cooperation on Agriculture (IICA) is a specialized agency of the inter-american system, and its purposes are to encourage and support the efforts of its Member States to foster agricultural development and rural well-being in their territories. With more than six decades of institutional life, the Institute is responding to new mandates issued by the Heads of State and Government of the Americas, the General Assembly of the Organization of American States (OAS) and the ministers of agriculture of the Americas, to reposition itself so that it can meet both the new challenges facing agriculture and the requests for support it receives from its member countries. As it pursues its vision and mission, the Institute has competitive advantages it can draw on to carry out its new role. It has accumulated a wealth of knowledge regarding agriculture and the rural sector, the diversity of peoples and cultures, and the agro-ecological diversity of the hemisphere, all of which are important for crafting creative solutions to a wide variety of problems and challenges. Its presence in all of the Member States gives the Institute the flexibility it needs to move resources between countries and regions, in order to design and adapt cooperation initiatives intended to address national and regional priorities, facilitate the flow of information and improve the dissemination of best practices. The Institute has its Headquarters in Costa Rica, and Offices in 34 countries of the Americas, as well as an Office for Europe located in Madrid, Spain. The Directorate for Strategic Partnerships works out of the IICA Office in Washington, D.C.

ISSN-0534-5391 CaRC/LC-06-001 GOOD AGRICULTURAL PRACTICES DUE DILIGENCE RESPONSE OF FARMERS DECEMBER 2006 IICA OFFICE IN SAINT LUCIA

MISCELLANEOUS PUBLICATIONS ISSN- 0534-5391 CaRC/LC-06-001 December 2006 Castries, Saint Lucia The views expressed in articles are those of the authors and do not necessarily reflect those of the Inter-American Institute for Cooperation on Agriculture (IICA). Mention of a proprietary product or commercial firm does not necessarily imply endorsement by the Inter-American Institute for Cooperation on Agriculture (IICA) or the authors of any paper.

TABLE OF CONTENTS Acronyms I Acknowledgements ii 1.0 Introduction 1 1.1 Steps in Due Diligence 1 2.0 Risk Analysis. 2 2.1 Introduction... 2 Annex 1A: Example of Risk Analysis Flow Chart. 5 Annex 2A: Example of Risk Analysis Follow up Action.. 6 Annex 1B: Example of Risk Analysis Flow Chart. 8 Annex 2B: Example of Risk Analysis Follow up Action.. 9 3.0 Farmer Self Audit...... 11 4.0 Examples of Audit... 12 Packhouse Audit... 12 Animal Management 13 Pesticide Residue Analysis.. 14 Control of Harvesting and Field Packing Operation 16 Water Audit. 18 Pesticide Use Records. 19 Irrigation Water Records 20 Planting Materials.. 21 Storage... 22 Application Machinery Calibration... 23 Processing Water... 24 Management Plan and Cultivation Site. 25 Temperature Control. 26 Organic Manure 27 Maintenance of Records 28

ACRONYMS CPEC HACCP IICA OAS OECS Caribbean Programme for Economic Competitiveness Hazard Analysis Critical Control Point Inter-American Institute for Cooperation on Agriculture Organisation of American States Organisation of Eastern Caribbean States i

ACKNOWLEDGEMENTS This document is one of a series produced as an output of a project on Good Agricultural Practices funded by the Caribbean Programme for Economic Competitiveness (CPEC) and implemented by the Inter-American Institute for Cooperation on Agriculture (IICA) Office in Saint Lucia. I am grateful to those who sent comments. Special thanks to Ms Una May Gordon, IICA Representative in the Eastern Caribbean States, for her encouragement and for reviewing the document. It is hoped that maximum use will be made of its contents. I wish to thank Mrs Deborah Biscombe for her assistance in the production. Everton Ambrose ii

1.0 INTRODUCTION Due diligence means taking care or ensuring that every reasonable precaution is taken in the circumstances to protect the worker, consumer and the environment. This may be the only defense available to the grower to prove he/she is not liable and to avoid litigation. It requires the identification of hazards and the introduction of preventative measures to address the hazards. It encourages the assessment of specific work place hazards carefully and systematically and to document the specific actions needed to prevent the problem. Since it requires documentation of the implementation steps, it can also serve as a performance measure of safety and health and environmental management in the workplace. 1.1 Steps in Due Diligence 1.1.1 Be aware - Know the accepted practices for the operations that you are undertaking. - Get acquainted with what is being undertaken in the workplace. - Carry out the appropriate assessments of the operations. - Establish safety policy and procedure for the operations. - Ensure that employees receive appropriate training in the various practices. - Conduct safety audits, risk assessments for hazards and put preventative measure in place. 1.1.2 Ensure that all other persons engaged in the operations know their responsibilities. 1.1.3 Be objective. It may sometimes be hard to see risks in familiar environment. In order to detect problems in one s workplace, one has to be objective. It would be useful to have persons not connected with the particular operation to participate in work place hazard analysis. 1.1.4 Be proactive. All reasonable precaution have to be taken to ensure compliance with standards. This means that there must be continuous monitoring to identify risks and hazards, developing procedures to address hazards and communicate the safety programme to employees. The following will be necessary. - Develop detailed policies, procedures and practices aimed at specific hazards. - Fit the practice to the situation. - The more serious the potential hazard, the greater the action. There must be options available to prevent the problem and these options have to be taken as an appropriate standard of care. - Distribute the policies, practices and procedures to everyone at the workplace. - Revise practices and procedures. Respond to situations, circumstance and other feedback. 1

- Train employees in safe policies, procedures and practices. Keep records of the persons trained, type of training, when the training took place and when is the next training expected. - Enforce compliance with requirements and internal procedures by everyone including visitors. - Communicate the policies, practices and procedures on a continuous basis. Communication should be in place whenever there is an opportunity new employee, new machinery, change in policies, practices and procedures. - Keep good records. Good record keeping is a sign of good management and proof of due diligence. The due diligence system for production of fresh fruits and vegetables in the OECS discusses the actions in place at the farm level. This includes a Risk Analysis used to identify health hazards along the production/ harvest/postharvest processes and the actions necessary to manage the risk. Additionally, there is the Farmer Self Audit System which is to be used to determine whether the approved guidelines are adhered to and what actions are required. 2.0 RISK ANALYSIS 2.1 Introduction The identification of areas where health hazards may occur and the prevention of the identified hazards can be done by a modified Hazard Analysis Critical Control Point (HACCP) System using a Risk Flow Process Chart with a risk management report form. The HACCP system is generally not applied directly to primary agricultural production, as there are many uncontrolled hazards but it can assist in a Safety Assurance Programme. The implementation of complete HACCP involves only those stages where control can be applied. However there are stages in the production process where the hazards can be minimized. The hazard analysis approach is common to most safety assurance programmes including HACCP. This involves a series of steps to identify and solve potential problems. The approach involves: - Analysis of potential hazards during production/harvest/processing - Identification of points where food hazards may occur - Decision on which of the points are critical to food safety - Implementation of effective control(s) to minimize hazard - Monitoring of those critical points - Review constantly the analysis of potential hazards, the critical control points and established monitoring procedure In carrying out the risk analysis, it is recommended that at least one person should not be involved directly in the process being investigated. The complete process to be assessed starts with pre-production through to harvesting, transportation, handling, packaging and storage to 2

final delivery to the market. Since this chain of events is so long, it is better to divide it into manageable sections. Draw a flow process chart (Flow Diagram) (Annex 1) describing the operation in various stages. For each stage, describe the nature of the risk that is likely to occur and allocate a risk reference number. When all the risks have been identified, preventative actions are defined for each. A risk management follow up action sheet is developed from the flow process chart with crossreference to the stage of the process and risk reference for each with full description of the nature of the risk. The level of risk is recorded on a suitable scale (1-3 with 1 = minimum risk and 3 = serious risk requiring urgent action). For each risk reference, the action required, frequency of action and personnel responsible for ensuring action is taken to correct the problem is clearly indicated. It is essential that the risk analysis is repeated every two months to check that the action required has been followed up. Serious hazards should be remedied immediately. Example Identification of hazards and taking steps to prevent them using Risk Analysis Flow Process Chart backed up by a follow up report form. Method 1. Draw a flow process chart (Flow Chart Annex 1A and 1B) describing the processes in various stages. In the example, the production/post harvest processes are separated into preproduction/production and pre-harvest/harvest/post-harvest. Each of these is separated into stages. 2. For each stage, describe the nature of the risk that is likely to occur and allocate a risk reference number. In the example, the risk that are likely to occur in the preplant operation are the planting material with a risk reference number 1.1 and choice of cultivation site 1.2. The procedure is repeated for each of the operations in the various stages. 3. Compile a follow up action sheet (Annex 2A and 2B) from the flow process chart with cross-reference to the stage of the process and risk reference for each, with fuller description of the nature of the risk (level of risk on a scale of 1-3 with 1 = minimum risk and 3 = serious risk requiring urgent action). 3

4. For each risk reference, the action required, frequency of action and personnel responsible for ensuring action is taken to correct the problem. 5. The analysis should be repeated every two months to check that the action required has been follow up. However, serious hazards should be remedied immediately. 4

ANNEX 1A: EXAMPLE OF RISK ANALSYSIS FLOW CHART Crop:. Compiled by:.. Location:.. Date: Process Preproduction/Production Risk Ref Preplant 1.1 Preparation of planting material 1.2 Choice of cultivation site - history Risk Ref 2.1 Soil management 2.1 cultivation practices 2.2 Soil treatment Risk Ref Fertilizer Usage (Inorganic fertilizer) 3.1 Application 3.2 Storage Risk Ref Fertilizer Usage (Organic manure) 4.1 Storage 4.2 Application 4 Stage in process 1 2 3 Risk Ref Water Use Irrigation 5.1 Application 5.2 Storage 5 Risk Ref Pest Control 6.1 Monitoring 6.2 Registration of chemical 5 6

ANNEX 2A: EXAMPLE OF RISK ANALYSIS FOLLOW UP ACTION Crop:. Compiled by:.. Location:.. Date: Stage No Risk Ref Nature of Risk Process Preproduction/Production Level of Action Required Frequency Person Risk* Responsible 1 1.1 Not accepted by consumer Agreement with consumer At planting. 2 3 1.2 Presence of heavy metals Risk assessment. Check field records. 2.1 Soil erosion contamination Use practices to minimize erosion. 2.2 Pesticide not registered Check if alternative treatments are available. 3.1 Contamination of river Train workers in proper application. At planting. At planting. At planting. Before fertilizer application. 3.2 Contamination of produce Store produce separately. At harvest. 4 4.1 Contamination of water course Check roof and drainage from shed. Annual. 4.2 Infection Ensure equipment is available. During application. 6

Stage No Risk Ref Nature of Risk Level of Risk* Action Required Frequency Person Responsible 5 5.1 Residues of heavy metals Check water quality analyses. Close to harvest. 5.2 Contamination of produce Check storage tanks. Weekly. 6 6.1 Pesticide residue Check likely areas for signs. Every 3 months. 6.2 Rejection of produce by market Check registered pesticide/ pest list. At application * Level of risk 1-3, 1 minimal, 3 serious 7

ANNEX IB: EXAMPLE OF RISK ANALYSIS FLOW CHART Crop:. Compiled by:.. Location:.. Date: Date of last assessment Process Preharvest/Harvest/Postharvest Risk Ref Preharvest 1.1 Maturity check records Risk Ref Picking 2.1 Fruit selection 2.2 Field handling Stage in process 1 2 Risk Ref Transportation to packhouse 3.1 Picked fruit awaiting transport delay, protection 3.2 Transport to packhouse - damage sanitation containers 3 Risk Ref Unloading packhouse 4.1 Produce unloading inspection at packhouse 4 Risk Ref Wash and dry 5.1 Washing - qualities 5.2 Drying - damage Stage in process Risk Ref 8.1 Transport to market dirty vehicles 8 8 Risk Ref Packing 7.1 Fruit packed in container dirty and damage 7 5 Risk Ref Selection and grading 6.1 Quality Selection 6.2 Size 6

ANNEX 2B: EXAMPLE OF RISK ANALYSIS FOLLOW UP ACTION Crop:. Compiled by:.. Location:.. Date: Stage No Risk Ref Nature of Risk Process Preharvest/Harvest/Post Harvest Level of Risk* Action Required Frequency Person Responsible 1 1.1 Pesticide Residues Check field records, arrange for residue analysis. Prior to first harvest. 2 2.1 Poor standard of picking Ensure all persons are trained in standard requirements. 2.2 Contamination of produce Clean boxes and picking bags, field toilets and hand washing. Prior to first harvest and at intervals. Throughout harvest. 3 3.1 Fruit deterioration All picked fruit to be covered and held in shade. Throughout harvest. 3.2 Contamination of produce Ensure clean vehicles, cover produce avoid damage. 4 4.1 Inadequate inspection Check inspectors work, check records Throughout harvest. Daily. 9

5 6 Stage No Risk Ref Nature of Risk Level of Risk* Action Required Frequency Person Responsible 5.1 Water quality not checked Ensure only public water At all times. supply used. Certificate available. 5.2 Dried damage of produce due to dirty brushes Check equipment Maintenance 6.1 Inadequate removal of poor quality. Staff training, supervision or At all times. adequate amount of staff. 6.2 Size grader badly set. Check performance of grader. Twice daily. 7 7.1 Dirty boxes, fruit, damaged on packing Ensure box storage area is clean, no birds or pests. At all times. 8 8.1 Contamination of produce. Clean vehicles. Through out. *Level of risk 1-3, 1 minimum, 3 serious 10

3.0 FARMER SELF AUDIT It is insufficient to lay down what should be done in a manual of procedures or to give instructions if no monitoring system is in place. There must be constant review and amendment to ensure that the aims and objectives are achieved. It is necessary to establish a self audit programme to cover the systems, facilities and operations covering all areas within the production/harvest/post-harvest processes. The type of audit and its frequency will depend on the products being handled and the types of operation. A programme and timetable of audits of all systems must be drawn up and adhered to. Audits should be carried out by persons not involved in particular operations to verify that the actions and procedures are being carried out. The audit system should be based on the available guidance document. Some examples of audits are outlined below with selected documentation. This list is not exhaustive and the other audit actions may be drawn up within a Farm Self Audit Programme. - Packhouse Audit: undertaken every three months sample sheet. - Due Diligence Audit: Frequency depends on the crop. (Review all records, date coding or lot marking of consignment and efficiency of traceability procedures and other relevant records. - Quality Assurance Audit: (Review all quality control records, calibration procedures, check operations). - Growing Field Audit: (Review ground history, adjacent land use, fertilizer use (manure and inorganic) water use, pest control usage, employment safety and hygiene). - Maintenance of Files and Records Audit: (Review maintenance of supplies, files, rejections, visit reports). 11

4.0 EXAMPLES OF AUDIT PACKHOUSE AUDIT To be undertaken every three months. Record any actions required and ensure that it is carried out. LOCATION:. Date:.. Date of previous audit:.. Audit Team:.. ITEM ACTION BY WHOM 1. Structure of building Site visit Repairs required (if any) Improvements WHEN 2. Pest and Bird Control Entry points doors, windows etc Site visit, check record. Routine controls baits in place and numbered - visits report in file - baiting plan in file 3. Contamination/hygiene risks Toilets - cleaning schedule in force - hand drying facilities - training in hygienic practices Reports signs and symptoms of infection by workers Packhouse - cleaning schedule in force - clearance of garbage - storage of packaging Glass - lights protected etc 4. Equipment - maintenance and condition - repairs, improvements - weight checks records - calibration records - cleaning of equipment 5. Ventilation - adequate and maintains temperature for produce Check records, site visit Interview Check records, site visit Check records, site visit Check records, site visit 12

ANIMAL MANAGEMENT Crop:.. LOCATION:. Date:.. Date of previous audit:.. Audit Team:..... ITEM ACTION BY WHOM WHEN Animal housed or grazed nearby Diary farm present within one mile If yes, type of animal and distance from field Fences are used to keep animals away from crops and water sources. Animal production areas drain into field or water courses. Wild animals observed in the area (numbers and frequency). Method used to discouraged or restrict animals. Evidence of animal faeces on the field. Amphibians or reptiles (frogs, snakes) can be a source of contamination in the field or water sources. Farm animals (horses and donkeys) used in the field. Domestic animals are intentionally introduced into crop production areas (indicate time close to harvest), Relevant health problems in farm animals. 13

PESTICIDE RESIDUE ANALYSIS Whilst it is unlikely that any pesticide residue will exceed maximum residue limits if correctly applied and in accordance with Good Agricultural Practices or any illegal residues will be present it is advisable and some customers may require that routine, random pesticide residue analysis be carried out. Each exporter/farmer can draw up its programme in consultation with the consumer. In most cases it is sufficient to carry out sampling after the last application but before marketing. LOCATION:. Date:.. RISK ACTION 1. Pesticides are used. 2. Pesticide application at a higher frequency. 3. Pesticides used as a post harvest treatment or treated just prior to harvest to improve postharvest keeping of produce. 4. Pesticide which have been the subject of enquiry or special interest in any of the countries for which the produce is destined. 5. Where residues of a pesticide near to or above the MRL have been reported by an importing country. 1.1 Check field application records 1.2 Take random sample if no established harvest period. 1.3 Take sample from crops with most treatments. 2.1 Check field application records 2.2 Take random sample if no established harvest period. 2.3 Take sample from crops with most treatments 3.1 Check records and method of application. 3.2 Sample if no established period for treatment and use. 4.1 Check with customers or authorities of receiving countries. Minimize or ban the use of these pesticides, if required 4.2 Sample at least once during the production season. 5.1 Check field application records. Select samples from crops with most treatments. 5.2 Sample at least twice each season or three times where the source of a potential problem has been identified. 14

RISK ACTION 6. Where produce is collected from a group or from new suppliers or a number of small suppliers. 7. Crop has been treated with pesticide having long persistence long harvest period. 6.1 Check field application records. 6.2 Select samples from crops with most treatment. 6.3 Sample at least twice each season from the bulk product. 7.1 Check field application records. 7.2 Select samples from crops with the most treatments. ACTION PLAN Investigation into the possible cause of the unsatisfactory result. Resampling or repeat of residue analysis. Withdrawal from sale or distribution of the produce from which the sample was taken, its isolation from any other product until it has been declared safe. Informing the appropriate authorities and customers of the incident immediately it comes to light if the produce is already in the marketing chain. 15

CONTROL OF HARVESTING AND FIELD PACKING OPERATION LOCATION:. Date:.. ITEM ACTION 1. Field Workers Contamination/hygiene risks Toilets - cleaning - hand washing with soap - hand drying facilities Health status - Abilities - Training - operating - Supervision - Smoking, eating or chewing - High standard of personal hygiene required. - Cleaning schedule. - Hand washing and drying facilities. - Check health status (free from infectious diseases). - Check ability for example grading, selection. - Training in required operation. - Adequate supervision. - No smoking, eating or chewing allowed near the operation. 2. Equipment Picking containers Storage of empty containers - Clean containers that provide protection, no nets or bags for produce that are easily damage. - Check containers before filling to ensure that they are clean - Do no allow containers especially cardboard boxes to become soiled or wet by direct contact with soil. - Empty containers are stored in clean and pest free premises. 16

ITEM ACTION 3. Field handling Harvest Facilities Transportation Water Field packing sites - Harvested produce should be removed from the field or put in shady area to cool. - Harvest product when it is cool or at the cooler time of day and when it is dry. - Do not allow harvested product to stand unprotected in the sun. - Any structures used in the field operation should be kept clean. - Control garbage and prevent accumulation of pest and disease - Benches and tables must be of easily cleaned materials. - Transport of produce should be carried out with care to avoid damage and bruising of product. - Water used for washing produce should be good quality and stored in clean closed containers. - Inspect and audit before harvesting commences and another during the harvesting season for short season crops. - For long season crops, inspection and audits should be made and records retained for at least one year after the end of the production period. 17

WATER AUDIT LOCATION: Audit Team:.. CROP: Date: Prevalence of animal production ITEM ACTION BY WHOM WHEN Fences or barriers used to minimize access Is manure applied by farmers in the area? Do rainfall and topography impact likelihood of contaminated run off Practices that minimize the potential for contaminated water to be in contact with produce 18

PESTICIDE USE RECORDS CROP: LOCATION:.. Date: ITEM RECORD Personnel training o Operator s name o Experience o Position o Date of training o Instruction Records/Certificates o Signature Technical sheet Pesticide registration Medical checks 19

IRRIGATION WATER RECORDS CROP: Audit Team: LOCATION:.. Date: ITEM STATUS ACTION BY WHOM WHEN Prevalence of animal production Fences or barriers used to minimize access Is manure applied by farmers in the area? Do rainfall and topography impact likelihood of contaminated run off Practices that minimize the potential for contaminated water to be in contact with produce 20

PLANTING MATERIAL CROP: Audit Team:.. LOCATION:.. Date: ITEM STATUS ACTION BY WHOM WHEN Type (seed, rootstrock etc) Quality - certificate o Germination rate o Variety Name o Batch number o Material vendor Degree of susceptibility to pests and diseases Purchase stock certification 21

STORAGE CROP: Audit Team:.. LOCATION:.. Date: ITEM ACTION WHOM BY WHEN Fertilizer: Labelled Unlabelled Separated from pesticides Separated from produce Location: clean dry Water irrigation drinking processing 22

APPLICATION MACHINERY CALIBRATION CROP:.. LOCATION:. Date:.. Audit Team:... ITEM ACTION BY WHOM WHEN 1. Organic Fertilizer liquid solid Inorganic Fertilizer liquid soil Pesticide fungicide insecticide nematicide herbicide Irrigation 23

PROCESSING WATER CROP:.. LOCATION:. Date:.. Date of previous audit:.. Audit Team:..... ITEM ACTION BY WHOM WHEN 1. Practices to ensure water quality Record of initial water quality Water change schedule (based on periodic sampling) Standard operating procedures (based on water change schedules) Clean produce Routine inspection and maintenance of machinery 24

MANAGEMENT PLAN FOR CULTIVATION SITE LOCATION: Date: Audit Team:. ITEM ACTION BY WHOM WHEN Management Plan Spray drift Floods Water table contamination Land used for garbage and toxic waste disposal Soil status with method of sampling Levels of bacteria and heavy metals Crop rotation Cultivation system 25

TEMPERATURE CONTROL LOCATION:. Date:.. Audit Team:... ITEM Cool Chain Principle Instrumentation ACTION Check temperature of produce from field harvest to final dispatch to ensure no undue build up of product temperature. If possible do not use glass thermometers. Discard produce if temperature has been taken by inserting into and damaging the produce. Use clean probes and clean between use in different samples. Use surface temperature probes for small sized produce where there is little variation between surface temperature and flesh temperature. Air temperature of stores and vehicles can be recorded using air probes. 26

ORGANIC MANURE CROP:.. LOCATION:.. Date: ITEM RECORD Organic Manure o Supplier (if purchased) o Date of delivery o Treatment applied o Times and temperature during treatment application o Results of Analysis Micro organism Heavy metals o Place of storage prior to application (distance from field) 27

MAINTENANCE OF RECORDS LOCATION: Date: ITEM ACTION Records o Non conformity with standard o Record sheets o Storage - Clearly written - Dated - Signed by person entering data - Written account of the action taken to correct the fault of defect - Fill carefully and make available for inspection - Store is chronological order. Length of storage period depends on importance relative to the produce. - Record should not be destroyed within the period of a product being marketed and consumed and for a one year period. - Some records can be of historical value, e.g. pesticide application data can be kept up to 3 years. - Pesticide residue data can be kept for a much longer period. 28

INTER-AMERICAN INSTITUTE FOR COOPERATION ON AGRICUTLURE OFFICE IN SAINT LUCIA 4 TH Floor, Sir Stanislaus Anthony James Building, Waterfront, Castries Saint Lucia, P O Box 1223 Tel: 1 (758) 451 6760/61 Fax: 1 (758) 451 6774 Email: iica.lc@iica.int Website: www.iica.int/saintlucia