Salmon Local Foods/Eastern Idaho Public Health Dept Meeting Thursday July 9, 2015 | 10-11:30 am | Salmon Valley Business & Innovation Center

IN ATTENDANCE:

Name

Org/Affiliation

Patrick Guzzle Leslie Hamilton Nathan Taylor Geri Rackow Jarryd Samples Glenn Hugunin Kellye Eager Leo Marshall Ken Miner Breland Draper

Dep. of Health and Welfare EIPHD EIPHD EIPHD EIPHD EIPHD EIPHD Mayor County Commissioner Idaho Organization of Resources Council Salmon Valley Stewardship Salmon Valley Stewardship Swift River Farm, local producer local producer The Kitchen, local retailer Salmon resident Salmon Valley Stewardship Salmon Valley Stewardship

Gina Knudson Rachel Layman Jessica McAleese Shannon Fayle Shannon Weaver Cindy Salo Madison Harper Linda Cung

Email Address

[email protected]

[email protected] [email protected] [email protected] [email protected]

[email protected] [email protected] [email protected] [email protected]

Revisiting May 2012 Public Health Meeting findings Previously, we had met with Eastern Idaho Public Health Dept (EIPHD) and Patrick Guzzle from ID Dept of Health and Welfare (IDHW) to clarify some points in the Idaho Food Code. We did a check-in on the primary findings to make sure the information and the interpretation were still accurate. A few items were clarified: ● #6 from the document “Local Foods in Restaurants” was clarified: o Once eggs are brought into a food establishment, food regulations still need to be followed – they need to be stored in a place with a temperature below 41⁰F ● Patrick reminded the group that there is no state jurisdiction for meat and poultry products. A USDA inspection would be needed for retail sale of locally produced meat products.

● Approved Food Sources 1

o Local producers of produce and shell eggs are considered an approved source for retailers, outfitters, and restaurants as defined by the Idaho Food Code. o The group clarified local produce can be washed at the farmers market as long as the water used is also from an approved source (i.e, city water spigot using RV hose at Town Square Park) and a thorough cleaning of the produce is done to remove all debris and the produce is then kept at 41 degrees or below. o The temperature requirement applies to Potentially Hazardous Foods or Time/Temperature Control for Safety (TCS) foods. At this time, the following produce items are considered TCS foods: - Cut leafy greens (leaf is torn, shredded, cut, or otherwise prepared for salads, sandwiches, etc.) - Seed sprouts including alfalfa sprouts and bean sprouts - Cut tomatoes - Cut melon

Protocol for Producers who want to Appeal a Decision by Health District 7 ● For any questions that are raised from a food establishment inspection, questions can be brought to Kellye Eager or Nathan Taylor from EIPHD o A Standard Operating Procedure (SOP) based on a similar precedent is most often used for decision-making by EIPHD regulators when dealing with industry-specific scenarios o If the issue cannot be resolved by EIPHD resources, it will be taken to IDHW Food Protection Program for further interpretation ● The timeframe for any question to be answered is dependent on the topic and how many sources of reference it needs to go through before being answered. o Important to note Dept. of Health and Welfare is completely separate from the Public Health Districts. o IDHW delegates authority to the Public Health Districts but IDHW does not surrender its own authority. ● Geri provided copies of the Idaho Administrative Procedures Act (IDAPA) Section 41, Title 08, Chapter 01, “Rules Governing Appeal from Administrative Decision and Request for Hearing.” o Several hard copies are available at SVS, and can be found online at http://adminrules.idaho.gov/rules/current/41/0801.pdf.

Education/Training to Help Strengthen the Local Food Network with an Emphasis on Food Safety

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 How to provide more training locally that meets food regulation standards and also helps progress local food sustainability ● Nathan reported that the Moscow Farmers Market holds an annual food safety training for its farmers market vendors; the health department works in coordination with the market manager ● Patrick Guzzle is willing to come to Lemhi County to provide food safety training o We would need to schedule trainings with him in advance ● EIPH used to have a dedicated trainer, but that is no longer the case, so their capacity is more limited now. ● Good Resources o Jeff Kronenberg – is a HACCP expert with the University of Idaho o Dr. Brian Nummer – a Process Review Authority at Utah State; teaches series of classes on the scientific aspect behind food safety in understandable terms o University of Idaho Extension Offices o The Idaho Food Code is posted online o Free Hazard Analysis And Critical Control Point (HACCP) plan templates can be found online ● Barriers and Challenges as seen from perspective of Food Inspector Glenn Hugunin o Food safety and sanitation, specifically the handling of any food product, including but not specific to local produce. ▪ Ex.: lettuce head from garden that gets hand shredded – it becomes a potentially hazardous food then. Food producers may have done everything correctly and then retailers have quality control problems. ▪ Education of both producers and retailers is needed to advance food safety. ● Patrick stated that part of the problem local producers deal with is that the role/responsibility of the Health District is to enforce regulations, not necessarily to serve as education providers. ● Geri stated that although this is true, they would do their best to help provide trainings. ● Gina said Salmon Local Foods acknowledges that they may need to bring in their own trainers, but they would like assurance that the training is sanctioned by EIPHD. ● Jessica said a training with all farmers market vendors pre-season could cut down on EIPHD workload rather than increase it.

Temporary Food Establishments [TFE] at the Farmers Market

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● Interpretations of Idaho Food Code with regard to TFE in all 7 districts in Idaho are not consistent. Geri said there is an effort underway to provide more consistency. ○ Jessica noted that in more affluent parts of Idaho, food producers are more easily able to navigate regulations while resource-strapped areas like Lemhi County have more barriers. ■ Two businesses had considered establishing a TFE but did not follow through because of conflicting interpretations of food regulations ■ Patrick asked if examples could be provided, because rules should be the same throughout the state. ■ Nathan added that lack of specificity about a food preparation process could result in answers being somewhat different ● Nothing in the State Code prohibits a Farmers Market manager from enforcing their own policies and procedures ○ Breland reported that Boise Farmers Market was hearing differing interpretations about the need to prepare food in a commercial kitchen, so they mandated that all farmers market vendors must use commercial kitchen. They achieved their own consistency until better guidance from health districts. ○ IDHW is working on non-potentially hazardous foods policies – held 18 public meetings about Cottage Foods Bill HACCP Plans ● HACCP plans are generally required for low-acid canned foods and acidified foods. o Low-acid canned foods – these naturally don’t have much acidity o Acidified foods – these are foods where acid ingredients are added to make the final product ▪ A common added ingredient is vinegar ▪ A pH above 4.6 signifies the risk of bacteria growth and botulism ● Patrick stated there is no government approval necessary for a HACCP plan. It is for the food business’s use and record. ● Nathan stated when a food product does require a HACCP plan, that plan does need to be submitted to the Health District for review. ● If it was determined that a product fell under Food and Drug Administration jurisdiction, the food processor would be required to have both a process review letter and a HACCP plan. ● Process Review Authorities o This is a federal requirement, required for the reviewal of all low-acid canned food recipes. o Idaho refers to Process Review Authorities at Utah State University and Washington State University (University of Idaho food safety program and WSU’s combined)

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o The issue of Process Review Authorities being difficult to find was brought up by Shannon Weaver. She has contacted several businesses similar to hers for a reference, and nobody seems to be using one. They are not or do not seem to be readily available nor accessible. ▪ Patrick suggested using the FDA as a resource ● Weaver’s Hot and Spicy Mustard experience with HACCP: o Weavers referred to Food Technology Center in Caldwell to test the acidity of the food product.The product tested at a pH below 4.6, and the Food Technology Center notified the Weavers a HACCP plan wouldn’t be required. o Patrick noted that the Food Technology Center was qualified to test the product, but not the authority for determining if a HACCP plan would be required. o Now that Weaver’s Mustard falls under FDA jurisdiction, EIPHD does not inspect that product. If Shannon Weaver bottles other products, she needs to be prepared to show FDA the Process Review Authority’s information of the products. ▪ EIPHD still is the regulatory authority for The Kitchen’s catering side of the business. Action Items ● Salmon Local Foods will share meeting minutes and other correspondence with EIPHD, IDHW, and Commisioner Miner so all have access to what the group is working on, local experiences, etc. ● Salmon Local Foods will coordinate with EIPHD and IDHW as we develop and schedule workshops o Training targeted for Farmers Market vendors around February-March ● Salmon Local Foods and EIPHD will work together to develop local food standard operating procedures (SOPs)

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