In January 2013, the Food and Drug Administration published food safety guidelines relating fresh culinary herbs.
The guidelines address the growing of basil, chervil, chives, cilantro, culantro, dill, lemon verbena, marjoram, mint, oregano, parsley, rosemary, sage, savory, sorrel, tarragon and thyme.
The guidelines are meant to set standards for large commercial growers. But home gardeners growing kitchen herbs who wish to learn more about the government food safety standards would do well to consult this publication.
Just as importantly, food safety experts at the FDA who want to learn more about fresh culinary herbs should consult with smaller growers, herb gardeners.
According to the FDA, its regulation of the produce industry has been in the works since 1998. Its records indicate that between 2004 and 2011, a harmful strain of bacteria called Salmonella was detected in 28 samples of the herb, cilantro.
In response to another finding of Salmonella in cilantro in January, 2011, the FDA issued a letter to growers of cilantro. In this letter of March, 2011, the FDA asked growers to identify potential hazards specific to the cultivation of cilantro. The fresh culinary herb producers took the hint. They decided to address not only cilantro but also 16 additional edible herbs. The growers would work with the FDA and academic experts to develop food safety guidelines “specific” to culinary herbs.
The Guidelines are difficult to understand without a background in large scale farming.
For instance, an herb is not simply an herb but a “RAC,” meaning “raw agricultural commodity. “
An herb that is rinsed is an “RTE,” a “ready- to-eat food” that is edible without additional preparation to achieve food safety because it has been thoroughly washed before being cut.
An “RTU” means an herb that is “ready-to-use” but has been only minimally processed. RTU herbs have been cleaned, trimmed and possibly cut, but require further washing and preparation prior to consumption.
The FDA’s list of abbreviations and definitions should be read first and understood.
The Guidelines recommend that growers keep detailed records of all potential physical, chemical and microbiological food safety hazards and that growers monitor conditions such as water, soil amendments, environmental factors and equipment. These records, along with scrupulous labeling, enable the FDA to trace contamination problems from the supermarket package back to the field. Contaminated herbs in the field and in the supply chain can then be destroyed.
The FDA recommends that growers review topography, land history, risk of flooding, adjacent land use and domestic animal and wildlife presence. It also recommends that the growers operate in sync with their actual weather conditions as specific weather conditions produce different risks of food contamination.
The Guidelines set forth best practices to be followed. The FDA indicates that before planting, during the growing season and at harvest, growers must assess environmental conditions, water conditions, soil amendments, hygiene of field and harvest personnel, equipment cross contamination, flooding and field packing operations.
The FDA suggests actions to mitigate potential problems, such as specific instructions on the distance to be maintained between fields of herbs and adjacent problem areas.
As to water, the FDA urges farmers to evaluate water’s potential to produce human pathogens. The FDA urges the growers to evaluate if their watering method will, for instance, deposit soil on the crop, free moisture on the plant’s surfaces or pool water that attracts animals. If the grower’s watering method would possibly lead to contamination, corrective action should be taken.
The FDA has strong admonishments concerning soil amendments that include raw or under-composted materials, particularly animal manure. It’s simple: don’t use it.
In a section titled “Post-Harvest Unit Operation,” the FDA notes that the time between harvest and cooling should be minimal since microbes multiply rapidly under warm, moist conditions. Finally, the FDA gives its recommendations as to the construction, design and maintenance of packing houses, cooling facilities and processing plants.
The “Take Away” for Herb Gardeners
The purpose of the FDA’s food safety guidelines for fresh culinary herbs was to establish best practices so that large scale herb growers and processors could prevent their crops from making people ill.
The FDA’s report is useful to commercial growers with large fields of culinary herb plants tended to by farm workers. However, the backyard beds that are most often maintained by only one gardener should follow the same “best practices.”
Gardeners should look for the best place to site their garden. The home garden should not for instance be downhill from a septic system or contaminated land.
Herb gardeners should address potential hazards to the plants in their garden. Gardeners should for instance, know that their garden is not a place to walk their pets. They should not use herbicides and pesticides that will leave a residue on their herbs. Soil amendments should be appropriate for the growing of vegetables and herbs. Hand tools should be kept clean. Watering should be done only when needed and where needed.
While written in terms of facilities and equipment, the guidelines should be adapted as best practices in the kitchen of the herb gardener. The kitchen’s cutting boards, counters, refrigerator and sink should clean.
Most of the FDA recommendations are meant to apply to leafy green crops harvested by machine and placed in containers. But the guidelines also address herbs harvested by hand. Since herb gardeners would harvest by hand, the FDA’s input as to knives, containers and other hand tools is helpful.
For instance, the FDA points out that the cut surfaces of fresh culinary herbs are more vulnerable to microbial contamination than the uncut surfaces. The agency recommends knives be constructed of stainless steel with plastic or stainless steel handles and smooth seams, welds and joints so that they can be effectively cleaned and sanitized.
The agency further notes that wooden handles do not lend themselves to efficient sanitation and hand held tools constructed with standard, rather than stainless, steel will not hold up to routine sanitation with most sanitizing or oxidizing agents.
Herb gardeners should also follow the FDA’s recommendation to harvest, wash, dry and cool or process quickly.
How Herb Gardeners Might Inform the FDA
The FDA so-called “commodity specific” food safety guidelines relating to fresh culinary herbs are simply not specific enough. Herb gardeners growing culinary herbs long before pesto became popular enough so that basil would be mass “produced” as a “commodity” know better.
The standards seem to concentrate on the fields rather than the plants. Some herbs have very delicate foliage and others strong leaves. Some herbs sprawl on soil; others grow upright. Some edible perennial herbs have woody stems and are actually considered shrubs.
No two herbs are quite the same. Each herb is grown and harvested in a different way and certainly in a way that is different from leafy green vegetables. It follows then that guidelines as to food safety might differ from herb to herb.
When the FDA has the opportunity to take a second look at food safety guidelines for fresh culinary herbs, it might wish to ask for more input from the smallest of growers, those with herb gardens. While the commercial growers focus on the fields, herb gardeners focus on the plants.