Follow These Rules When You’re Down on the Farm

Good Agricultural Practices, or GAP, is serious safety business for your customers who harvest food.

Question: Can you explain the basics of Good Agricultural Practices, or GAP, where portable sanitation is concerned?

Answer: GAP is an inspection program for the fresh fruit and vegetable industry with the goal of food safety in the field. In October 1998, the U.S. Department of Agriculture issued general guidelines for this industry “in order to reduce the risk of contamination of fresh produce by microbial organisms.” In 2002, the USDA’s Agricultural Marketing Service formally implemented GAP in addition to Good Handling Practices.

The standard audit form used by the USDA entitled “USDA Good Agricultural Practices Good Handling Practices Audit Checklist” has general guidelines for portable sanitation. In the “General Questions – Implementation of a Food Safety Program,” there is an entire section called “Worker Health and Hygiene.” The requirements are as follows:

  • Potable water is available to all workers.
  • All employees and all visitors to the location are required to follow proper sanitation and hygiene practices.
  • Training on proper sanitation and hygiene practices is provided to all staff.
  • Employees who handle or package produce are washing their hands before beginning or returning to work.
  • Readily understandable signs are posted to instruct employees to wash their hands before beginning or returning to work.
  • All toilets/restroom/field sanitation facilities are clean. They are properly supplied with single-use towels, toilet paper, hand soap or antibacterial soap, and potable water for hand-washing.
  • All toilet/restroom/field sanitation facilities are serviced and cleaned on a scheduled basis.

It should be noted that these are the minimum requirements; and individual states, counties, and even specific companies may have additional requirements. The most daunting of these minimum requirements for PROs is “potable water for hand-washing.” Potable water is drinkable water. Eric Giffin, of Cal-State Site Services in Simi Valley, California, says one customer had the additional requirement of “monthly testing of the potable water by an independent contractor.”

Giffin also reports the requirement of E2-rated hand soaps as opposed to “hand soap or antibacterial soap” that GAP requires. E2 Soap is a one-step foaming hand wash and sanitizing soap that contains 50 ppm of chlorine. The cost of this product is significantly higher than soaps normally used by portable restroom companies.

Alton Green, former owner of T&M Portable Restrooms in LaBelle, Florida, and current owner of Jackson Citrus in LaBelle is knowledgeable about the food agricultural industry. He confirms the existence of additional requirements, standards and conditions and also states that some requirements are specific to the crop itself. Furthermore, certain buyers such as Walmart also impose standards. All of these requirements raise the cost of service provided by the PRO.

Restroom units are typically required to be secured to trailers. A standard arrangement is a trailer with two portable restroom units on each end and a sink between them. Again, it just depends on the specific location’s requirements.

While there are no specific requirements for portable restrooms or “approved” portable restroom manufacturers or models, the Portable Sanitation Association International in 2013 implemented standards to assist in this process. PROs can use these as standards to present to their customer as a way of showing their responsibility in this process:  

  • Portable restrooms should be in good repair, this includes having screens in place to protect from insects and other vermin. Durable and rigid constructed units should have adequate tanks that prevent splashing (in transit or while in use) while holding enough liquid to cover waste products.
  • The cleanliness of the restroom should be paramount. They should be constructed of materials that are not absorbent and easily cleaned.
  • Portable restrooms should have self-closing doors, be lockable from the inside, and be constructed to ensure privacy.
  • Toilet paper must be provided in a suitable holder at all times.
  • Effective odor control deodorizer must be used in waste holding tanks.
  • Hand-washing access must be adjacent to every (or group of) portable restrooms.
  • All spillage or leakage must be cleaned up immediately.  
  • Contents of portable restrooms must be disposed of by pumping into a sanitary sewer or by a liquid waste hauler transporting the waste for proper disposal. The disposal of waste from the restrooms and/or hand-washing facilities must not cause unsanitary conditions, nuisance, or contamination.
  • Hand-washing facilities should be self-contained or should drain into a separate and dedicated waste tank ensuring no risk of cross-contamination. They should also be properly stocked with soap and single-use towels with a trash receptacle provided.
  • Hand-wash stations should have a minimum of 15 gallons of water per spigot.
  • Providers/operators should have and provide customers with a spill containment cleanup plan and have materials available to execute such a plan.
  • All services need to be recorded on a service sticker inside of each portable restroom.
  • Bilingual signs need to be posted stating “workers must wash hands before returning to work.”
  • All restrooms should comply with ANSI Z4.1, Z4.3 and Z4.4 standards and all services to portable restrooms meet or exceed PSAI Certification Standards.

The best advice when you are contacted about providing portable restroom service to an agricultural field is summed up by Green: “Do your homework.” Find out all requirements prior to accepting the job. GAP standards, state laws, and local and municipal ordinances will all impact the cost of doing business with this customer.      

A wide variety of information about USDA GAP requirements may be found at www.ams.usda.gov.



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