Earthbound Farm: Balancing Food Safety From Seed to Shelf

It is always easier to avoid a problem than to fix it. When you’re managing the food safety program at the nation’s largest certified organic fresh-cut produce company—not to mention the largest grower and shipper of organic produce in North America—this simple adage is key to seed-to-shelf product safety.

For a company processing products that are consumed raw and for which the tools available for sanitizing them are limited due to their organic status under the U.S. Department of Agriculture’s (USDA) National Organic Program (NOP) certification requirements, preventing food safety hazards before they become a problem is vital to a successful food safety program, says Will Daniels, director of quality assurance for Earthbound Farm. “You cannot rely on restaurant workers or homemakers to control food safety hazards,” he says. “With the exception of potatoes perhaps, every vegetable is eaten raw some of the time and consumers don’t fully understand the necessity of properly cleaning their produce.”

Proactively preventing problems from farm to fork is the foundation upon which Earthbound Farm has built its food safety programs. And there’s plenty of area to cover. The San Juan Bautista, CA-based fresh-cut produce company’s certified organic produce is grown on more than 24,000 acres in locations from California to New Zealand and it processes and packages more than 100 different varieties of organic salads, fruits and vegetables in state-of-the-art production facilities in San Juan Bautista and Yuma, AZ.

The company’s forward distribution centers, located in West Cranbury, NJ, Atlanta, GA and Indianapolis, IN, are instrumental in moving product to more than 74 percent of supermarkets nationwide, as well as to a growing number of restaurant and foodservice customers.

Recently awarded the 2005 Fresh Cut Produce Award by the International Fresh-cut Produce Association (IFPA) in recognition of its pioneering industry leadership as the first company to successfully launch prewashed, packaged salad for retail sale in 1986, Earthbound Farms has grown into the largest producer of specialty salads, processing 22 million salad servings each week. Those 22 million servings include a wide variety of salads, including Mixed Baby Greens, Baby Spinach, Arugula, Fresh Herb Salad, Baby Romaine, chopped romaine blends and iceberg blends. Along with its popular organic spring mix and other green salads, Earthbound Farm offers fresh-cut vegetable mixes, including organic broccoli florets, broccoli and cauliflower, broccoli and carrots, broccoli slaw and vegetable medleys for steaming, stir-frys and raw vegetable platters, as well as a variety of organic fresh and dried fruits.

Daniels recognizes that it is his responsibility to see that Earthbound Farm’s customers are safe from food safety risks, and to do that, he doesn’t wait until produce comes in the door to remove them—he prevents them at the source. Everyone on the Earthbound Farm team goes to great lengths to prevent any harmful bacteria or other food safety risks from coming into contact with its succulent fruits and vegetables. From seed to soil, from picking to packing, every step is taken to ensure its products are the safest that they can be, while at the same time maintaining the integrity of their certified organic label.

Field Workers Fill in the GAPs
“A food safety program must begin in the field,” Daniels says, which is why the company spends considerable time and effort working with field workers to implement and audit for Good Agricultural Practices (GAPs). “It’s the best way to control hazards.”

Earthbound Farm follows the eight GAP principles, based on the U.S. Food and Drug Administration’s (FDA) “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables” (see, “8 Principles of Good Agricultural Practices,”). Daniels’ team customizes its approach to GAPs by incorporating organic practices into its food safety strategies in the field.

Says Daniels, “We certainly made sure that we addressed ranch history, water, documentation, pest control advisor requirements, etc. While this falls into normal GAP guidelines, we focus on it. We really rely on our organic inspections and approved supplier plan to support the organic practices.” Earthbound Farm’s team (EEF team) monitors for organic compliance during its GAP inspections, as well, he adds.

“The company’s GAP program begins before the seeds go in,” he says. Prior to planting, Earthbound Farm’s quality assurance (QA) supervisors, who’ve been formally trained in GAP, Good Manufacturing Practices (GMPs), Hazard Analysis and Critical Control Points (HACCP) and contamination and hygiene issues related to produce farming, visit every farm to inspect the fields with the workers. During these inspections, they check each field for foreign objects, such as broccoli or oat stalks left from a prior harvest that could get into the final product packaging and potential hazards, such as proximity to a compost facility, cattle operation or improperly stored chemicals. The EEF team members also conduct a series of tests in new fields, evaluating the soil for chemical residues, the compost and fertilizers for pathogens, and the water for harmful bacteria.

Once an inspection is successfully completed, seeds are planted and the fields are checked continually throughout their growing cycle by the EEF team members who regularly visit each farm.

During the growing season, all field harvesters also receive food safety and GAP training on how to achieve the company’s strict quality standards and to ensure proper sanitation in the field. “Education is extremely important,” Daniels says, noting that the training doesn’t just cover what they need to do, it emphasizes why it’s important. “They need to know why they should wash their hands, or cover an open wound, or not eat in the field, and the role that plays in food safety. Without that knowledge, they won’t follow the program.”

Before the harvest begins, fields are checked again for foreign materials that should be removed. During the harvest, which lasts around eight to 10 hours depending upon supply, manufacturing demands, product quality, weather and other factors, every harvest field crew receives weekly GAP audits by the EEF team, who focus much of their attention on equipment and personnel. “We are really proud of this part of our food safety program,’ Daniels says. “It’s one of the most comprehensive harvest audits out there.”

It’s a weighted audit and teams are expected to receive a 90 percent or higher to pass. “The audits are intended as a tool to help growers not to penalize them,” Daniels points out. If a crew fails due to many minor offenses, such as wearing jewelry in the field, the EEF team will help them make the necessary changes to get back up to peak performance. However major infractions, such as insufficient bathrooms or hand washing facilities, or the presence of animals in or near crops, could shut a field down.

To add incentive, the EEF team members produce summary reports and grade harvest groups within each company against each other. It creates peer pressure in the field, which drives compliance, Daniels says. This season, most of the teams have averaged 95 percent or better on their audits.

Even though the harvest teams continually score well above the 90 percent minimum, Daniels says the weekly audits are a crucial piece of the food safety program. “It’s human nature to take the path of least resistance, and sometimes that can jeopardize food safety,” he says. “You need a check and balance monitor for compliance, and the best way to do that is to go out every week and observe.”

It’s also important because crew teams can change week to week, and during the busy season contract crews may be brought in who may not have the full food safety training that staff field workers have completed. “Any changes create risks for the process,” he says.

When HACCP and Organic Collide
Once the harvest is complete, the produce is immediately loaded onto refrigerated trucks and shipped to the processing facility. Receipt of the truck is the next critical step in the food safety chain, Daniels says. Before produce will be accepted, the driver must provide several documents, including proof that the shipment comes from an approved supplier; organic certification papers; signed contracts from the supplier agreeing to abide by Earthbound Farm’s GAP principles; and annual water monitoring and reporting paperwork documenting that all water used in the field is free of contaminants. The truck must also be inspected to be sure it is clean and functioning properly.

Once the produce is accepted, it is evaluated by quality control inspectors at the facility, who again look for hazards or HACCP risks that might have been missed at the field.

In processing, washwater is the first of two critical control points in Earthbound Farm’s HACCP program. Each wash system is monitored every half hour with a colorimeter to check the parts per million (ppm) of chlorine in the water, and a handheld monitor to check its pH balance. If measurements fall outside the established limits, the line is immediately stopped and the situation is evaluated, Daniels says. “There is no one common problem. Each case is different.”

For example, chlorine can fall below established limits due to the presence of a large amount of organic matter on the produce, such as dirt from the field. The chlorine dissipates as it attacks the organic matter, creating the risk that produce won’t be cleaned and free of harmful bacteria. If this is the case, the produce can be rewashed with fresh washwater and retested. If however, chlorine levels are too high, usually caused by accidentally adding too much chlorine to the water, the batch may have to be dumped.

Because Earthbound Farm’s products are organic, the amount of chlorine residue allowable on finished products is highly controlled, which means the sanitation team may not overuse this chemical. “This is one of the areas where we need to balance organic standards with food safety,” Daniels says. NOP regulations require that any residual chorine must comply with the same rules contained in the Safe Drinking Water Act. To comply with these requirements, Earthbound Farm limits the amount of chlorine in the wash water and uses a graduated decline rinse system that reduces the chlorine residue as it completes the wash cycle.

From the processing line, product goes straight to the packaging operation, where it is bagged and sealed, then sent through a metal detector at the end of the line before being packed in cartons and placed on pallets. Metal detection is the second and final critical control point and is placed furthest downstream to ensure it is the last step in the process. If metal is detected in a sealed package, the line is stopped and the situation evaluated. “We figure out what it is, where it came from, and if there’s a chance that other packages are contaminated,” Daniels says. Based on their conclusions, products might be rechecked, approved or dumped.

The EEF team members also randomly sample products for quality and food safety, while also checking for packaging integrity and mechanical damage.

To further support the food safety program, the facility goes through a daily sanitation process at the end of the second shift, where walls, floors and equipment are washed and sanitized. The processing and packing areas have epoxy floors and wash-down walls, which resist corrosion from chlorine that can cause harborages for bacteria, and every piece of equipment has a formal cleaning and sanitation protocol. “Prior to bringing any piece of equipment into our facility, we evaluate it to make sure it will work for manufacturing, quality assurance and sanitation,” Daniels says. That means that not only must it function effectively, it must be easy to clean, with no hard-to-reach areas or electronic components that limit water-washing options.

Smile, You’re On QTV
Earthbound Farm’s strict adherence to food safety standards is also evidenced by its participation in the U.S. Department of Agriculture’s (USDA) Qualified Through Verification (QTV) program, a voluntary third-party HACCP auditing process for the fresh-cut produce industry. Only companies that are able to meet existing good manufacturing and sanitation practices and that demonstrate that they are following their QTV plan, including adherence to the required HACCP-based techniques, are qualified to participate in the program.

“The beauty of the USDA QTV program is that it is based on mandatory unannounced audits,” says Daniels, who decided to join the program in 1999 after watching how hard the staff worked to prepare for planned audits. Before the QTV program, employees at the facility would spend the two weeks leading up to an audit working to make sure all the paperwork was ready and that everything in the facility was up to audit standards, he says. “We’d get close to perfect scores every time but two weeks later it was back to the old habits.”

Instead, through QTV, the facility has to be audit-ready every day. “It is a change in paradigm. QTV forced us tie all areas of food safety together and apply them all the time,” he says.

QTV has four levels and participants move up through the levels as they achieve increasingly higher ratings on their audits. New program participants begin at level four, at which point they receive unannounced HACCP inspections every two weeks. During the audits, USDA inspectors review and assesses the facility’s documented HACCP plan, review records, observe and interview employees, conduct pre-operational sanitation inspections, and follow a specialized systems audit checklist to confirm that the company is following its QTV plan.

Any infraction impacts the final QTV score. Facilities need to score at the next higher level or better for two consecutive audits in order to advance to the next tier. At level three, inspections happen every month; at level two, inspections happen every two months; and at level one, they occur every three months.

If during any audit a facility receives a lower score than its current status, it is dropped back down to that level and has to work its way up again. Daniels once had a third-party contractor cost him a level one audit for wearing a necklace in the facility. “Little things can do it, but it’s an incentive to always aim for that goal.”

Only 24 percent of all companies who participate in the QTV program hold a Level One rating. Earthbound Farm achieved Level One status in 2003 and 2004, and now maintaining that status is a daily goal for every employee. “Having unannounced visits makes the inspection process easier to handle,” Daniels says. “Everyone is in inspection mode all the time, and it drives improvements faster because you never know when you are going to be audited.”

Daniels’ team also has financial incentive to maintain a good rating. Each inspection costs $3,000, and a Level One rating is the difference between four inspections a year and 26 inspections a year. “That adds up to a $66,000 savings,” he says.

The rating is also tied to his team’s end-of-year bonus pay, but, says Daniels, it’s not about the money. “It’s about pride, and making sure that safety is just business as usual.”