Interest in furthering the development of controlled environment agriculture (CEA) is propelled forward by the idea that we can create real solutions to some of humanity’s basic needs: like growing nutritious food. By bringing farming under cover, be that in a hoophouse, greenhouse or vertical farm, we have found ways to closely monitor and manipulate growing conditions. These efforts have resulted in extended growing seasons — all while improving food access, flavor and local economies.

But CEA’s improvements do not stop there. As this dynamic, ever-changing industry continues to adapt and evolve, new ideas coming to the forefront aim to solve challenges and streamline systems. Unsurprisingly, many of them are coming from women, who are asking the simple question: Why not?

Why not integrate greenhouse data into a user-friendly platform? Why not ask if an abandoned garden needs a revamp? Why not grow clean, healthy greens in the comfort of a home? Why not make a greenhouse three stories tall?

Below, we feature determined, inspiring women who are finding CEA success through their innovations and leadership.

DATA-DRIVEN: Kopf put together a team of highly skilled data scientists and engineers to form Agrilyst, an intelligence software platform for indoor farmers, in 2015. Agrilyst utilizes algorithms to track and record data from sensors throughout the greenhouse to help growers better understand their operation’s metrics to improve plant quality and output.

Since the company’s conception, Kopf and her 10-member team have nabbed first place in TechCrunch Disrupt’s prestigious technology startup competition, raised more than $1 million in investments for development, secured customers in five countries, and in January, launched Agrilyst Reporting, which helps growers curate their own customized data sets.

“We’re helping [growers] visualize data like never before,” Kopf says. “Big data is just a [phrase], but having insights and having meaningful visualizations is important to growers, so we’ve spent a lot of time focused on that.”

BRIGHT IDEA: Based in the startup central, NYC, Kopf has experience in helping to build companies. Before founding Agrilyst, she spent four years as the Real Estate and Government Relations Manager at BrightFarms, a hydroponic grower and greenhouse builder in New York. She was one of the first employees at the company back in 2011.

“It was a really easy jump for me to say, ‘I want to be in this startup world, and I want to do something that I believe in and work alongside a team on something that’s a big problem that’s solvable by us,’” she says.

In fact, much of the idea for Agrilyst came from her time at BrightFarms. “When I was on the operating side, my job was to essentially solve problems as they came up. And that was really challenging to do because we had fragmented data systems,” she says.

Essentially, climate control systems and other technological advances provided data to the growers — but they had no comprehensive way of gathering and analyzing it. “I said, ‘That’s it. We can’t do this anymore. We have to find a way to log this data somehow,’” Kopf says. “I can build this platform to integrate this data and build a team of people smarter than me to get [growers] insights into that data.” And Agrilyst was born.

LEVELED OUT: Part of Kopf’s success in the male-dominated technology space is due to her mindset. She was the only woman in her physics class in college; she’s spearheaded a legislative campaign; and also fearlessly pitched her business model to venture capitalists. No matter the space she’s in, she refuses to be intimidated based on her gender because she simply doesn’t factor it in.

“The way that I approach it is that I’m there because I’m the person to do this,” Kopf says. “I presented the company that I had built because I was the right person to build this company. This [is] the thing I was put on this earth to solve. That’s the way I operate … I’ve made myself the expert in the thing I’m doing, and that’s the only [way] you can have confidence standing up there and presenting something that’s yours, in my opinion.”

BORN LEADER: While Agrilyst takes up much of Kopf’s time, she hasn’t shied away from additional professional leadership opportunities. She’s an advisor for a nonprofit to promote young women’s involvement in tech called #BUILTBYGIRLS, as well as a mentor for Square Roots Urban Growers, a hydroponic vertical farm builder. Kopf was also named Entrepreneur of the Year by Technical.ly Brooklyn, and Changemaker of the Year by the Association for Vertical Farming earlier this year.

So it’s no surprise that her favorite part of starting a business is building a team.

“I get to work with people who are tremendously brilliant and interesting, especially in our space,” she says. “And we have not yet hired from a job posting. We’ve consistently hired through our team’s network. But what we’ve done a very good job at is expanding our network broad enough to find [those] people … and make sure we incentivize them to put them on our team.”

Kopf’s also a huge proponent of hiring people of diversity. Agrilyst’s small team is made up of employees from many different backgrounds, and an even split of men and women. “It makes your company and product better, too, by having diversity and by having people who don’t look and think and speak like you do. By nature, you end up building a product that’s more inclusive for a broader set of customers,” she says. “Not ignoring colorblind people when you are building the colors of your platform; not ignoring left-handed folks when you’re building an iPad that doesn’t switch the right way … All of those things can be included earlier by broadening your community.”

BIGGEST CHALLENGE: Opportunities abound with any startup as it morphs into its own identity. So Kopf’s biggest challenge is keeping the company focused. “There are so many areas of agriculture that have a data problem,” she says. “This is why you see so many data companies sprouting up in the outdoor space — or cash commodities crops … It’s one of our biggest industries.

“But as a startup, and as 10 people,” she continues, “you can’t tackle every problem.” She says she’s proud of the way Agrilyst communicates with indoor growers, listening to them and building on what they want to see.

THE BOTTOM LINE: The most rewarding aspect of Kopf’s job is realizing results from what she and her team have created. “Seeing something physically change, or seeing operational management methods change based on using our platform and how that makes a grower able to reach profitability, or expand operations, or open a new facility, or expand into new crops — that, to me, is probably the most successful thing that we could possibly do,” she says.

TINY PRODUCT, BIG OPPORTUNITY: After working on the administrative side of the Calgary Farmers Market for about a year and a half, Hanel decided she wanted to be the grower, not the one sitting behind the desk. So in the basement of her home in Calgary, Alberta, Hanel launched Micro YYC and began to grow a plethora of microgreens varieties and other leafy greens for multiple clients, including a large local farmers market, a CSA-inspired subscription service, and local restaurants and specialty grocers. Hanel’s offerings include pea shoots, broccoli, kale, kohlrabi, arugula and other microgreen blends. “I’m super passionate about quality, delicious food,” Hanel says. “So it makes me happy every day to be growing these happy little sprouts.”

COMMUNITY COLLABORATION: One of Hanel’s biggest accounts is a cooperative with other local growers called YYC Growers’ Harvest Box. On a bi-weekly basis, customers can pick up a “harvest box” that includes a selection of seasonal produce from several different farms in the area. Hanel says not only does this bring her a good amount of business — the collective has grown exponentially from 80 shares in 2015 to more than 500 in 2016 — it also gives her a sense of belonging. The farmers frequently get together for meetings and potlucks and lean on each other for advice and moral support. “It makes you realize you’re not the only one doing something weird for a job,” she jokes.

SOCIAL STANDING: As a one-woman operation, Hanel says she hasn’t had much time to craft a website, but she’s acquired plenty of customers and mentors through social media marketing to keep her going. Every restaurant she’s worked with has found her either on Twitter or Instagram, and she’s acquired some helpful growing advice along the way.

“Instagram is amazing because it’s so easy to post good pictures on there,” Hanel says. “There’s a great community — it’s so easy to find other people in Calgary doing small local businesses, and food business, and other urban farms in other cities and countries. I connect with a lot of other microgreen growers on Instagram, just asking each other questions, like, ‘What trays are those?’”

PLUS ONE: While Hanel doesn’t necessarily need a large working area to bring in her produce-growing profits, she says her biggest challenge is keeping up with the daily workflow. Because her crop can turn over as quickly as nine days, Hanel plants every week. “I plant on Mondays, and I start harvesting last week’s planting and by the end of the week I clean everything up and I start again on Monday,” she says. It doesn’t leave her much time to strategically grow her business, which she says is her biggest challenge, and so she’s looking to bring on a part-time employee in the near future.

ENTREPRENEUR TIP: Since being featured in Modern Farmer in December 2015, Hanel says she receives many calls from people asking how to get started and where to go to acquire resources. She suggests hitting up local food events and being willing to network, listening to others and being willing to learn. “You can’t expect it to happen overnight,” she says. “But those things will end up counting in the long run.”

DREAM JOB: Ackley began her career in a different field, working as an engineer in the United States Agency for International Development (USAID) environmental sector for about seven years, but she aspired to own her own farming business while she was working and hobby gardening overseas in Sri Lanka. When she moved home to Washington, D.C. in 2013, she decided to pursue her love of farming. In 2014, Ackley established Little Wild Things City Farm, a microgreen and edible flower producer specializing in more than 50 different varieties. The produce is sold at local restaurants, grocery stores and farmers markets in the D.C. area. The farm also sells value-added products, like wedding cakes with edible garnishes and ready-made salads.

LAND HUNT: When it came time to find a space to grow, it was a bit difficult, as it can be in any highly populated urban area. Then she realized the only places where there was available land was at institutions, such as schools and churches, so she thought it might be best to ask to use an abandoned plot on another property, instead of purchasing one outright.

On a jog one afternoon, she came across a monastery with an abandoned garden, so she inquired about it. A monk had maintained the space for many years, but when he passed on, no one else had the know-how or passion to take it over — so Ackley offered to help. “To have someone young and ambitious come in to help grow something productive there and also maintain the space — and then [receive] produce — is great,” Ackley says. So in 2014, she started the business with edible flowers and leafy greens.

But that’s not the only location Little Wild Things is currently inhabiting. When a new restaurant, The Pub and the People, came to the area, Ackley did the same thing. But this time, she moved into the restaurant’s basement to grow microgreens under sole-source lighting.

MODEL FOR SUCCESS: Ackley wanted to grow something that had the shortest phase to maturity as possible, so she could have more crop turns in a smaller space. Microgreens fit her business plan well. “I was really attracted to the idea that farming in the most environmentally sustainable way would also be the most productive way of farming, and the most profitable way of farming, in theory,” she says. The shorter-term crops have also allowed her to improve growing techniques along the way. “With microgreens, you grow them every 10 days, so you’re learning everything about all these different varieties,” she adds. “Within two years you’re a total expert.”

TECH SAVVY: She and her four-member team have moved to online-only ordering, which has helped her streamline and organize the business. It’s also allowed for on-demand deliveries Monday through Friday. “A chef can log onto our website and place an order, and we’ll actually harvest it right then and there on the spot,” she says. Then a courier service delivers it to the customers. The process can be as quick as 45 minutes, or a maximum of about four hours. “It allows us to compete with farms that are farther outside the city that can’t provide that type of quick service,” she adds.

WORDS OF WISDOM: Ackley says jump in, even if your roadmap isn’t complete yet. “People spend a lot of time planning,” she says. “But sometimes you need to just give it a try, and get past the barrier of doing something ... You [won’t] know what the challenges are going to be until you actually are doing whatever it is you want to do.”

PROFESSIONAL PIVOT: An architect by trade, Yehia, and her co-founder Penny McBride, set out for an endeavor to create a sustainable business operation in the city of Jackson Hole, Wyo. in 2008. Providing local food through greenhouse growing was top of mind because of the city’s short four-month growing season. But the duo’s biggest challenge was to find an available construction site in Jackson Hole, a city whose proximity to a national park makes land extremely costly. A town councilman showed them a piece of property owned by the city in the heart of downtown, essentially left over from a parking garage construction. The land was 30 feet wide by 150 feet long and owned by Jackson Hole. “I’m sure, knowing him quite well, that he thought we would put [up] a hoophouse and extend the growing season by a few months,” Yehia says. “But we had bigger aspirations. We wanted to create a consistent source of local food that served the community year-round, and provided employment for people year-round at a substantial level.”

So up they went.

ONE-OF-A-KIND: Vertical Harvest opened a greenhouse that expands in height rather than square footage. The structure opened in March 2016. The entire building works as a complete ecosystem, Yehia says, but each of the three floors has a different microclimate.

The first floor is public-facing. There is an on-site market, as well as a small public atrium that allows people to “experience the verticality of the greenhouse,” Yehia says. It boasts a three-story living wall, as well as a living classroom where basil is grown and educational sessions will soon take place.

The second floor is used for lettuce and microgreen production, where the product is placed on vertically and horizontally rotating carousels. “Not only do we take advantage of as much natural light as we can give to those plants, but it balances out with supplemental artificial lights as plants rotate back into the depth of the building. It brings the plant to the farmer for harvesting and transplanting,” Yehia says.

On the third floor is tomato production, which looks very similar to a standard tomato greenhouse. “It’s really hot up there because we get the solar gain from not only the south but the roof, and it creates the perfect environment,” she says.

HELPING HANDS: Vertical Harvest employs persons with developmental disabilities, which resonates with Yehia because she has a brother with developmental disabilities. “That was important to my involvement with the project because growing up, I was acutely aware of our ability as a society to really nurture this population during education, but when it comes to employment, there are still a lot of challenges out there.”

Employee positions vary widely, from market associates, to spokespersons and marketing personnel, to IPM assistants, production associates and even an assistant greenhouse manager. “One of the big models that we use to make this whole thing work is something that’s just recently been adopted in the disability world,” Yehia says. “So some people work three hours, some people work 40 hours, depending on skill and ability, and we have a customized plan for each employee.”

STARTUP TAKEAWAYS: Yehia advises aspiring startup owners to let others challenge your ideas. “Listen to your skeptics and critics and value them just as much as your supporters because they will ask you the hard questions,” she says. “And if you can answer them, then you know you’ve got a dream that’s worth pursuing.”

The first phase of production for any hydroponic food crop, whether leafy greens or vine crops, is propagation. In ornamental horticulture, there are numerous propagation methods that are used to produce new plants. For hydroponic food crops, there are three primary methods of propagation: seed propagation, cutting propagation and grafting. The aim of this article is to discuss when these different propagation techniques are used, as well as key points to managing the greenhouse environment, culture and systems.

Seed propagation

Propagating young plants for hydroponic production with seed is the most common method of propagation (Fig. 1), since the clear majority of food crops can be easily grown from seed. The cost of seed for hydroponic crops varies widely across different crops. For instance, seed for some culinary herbs is extremely cheap, while seed for some greenhouse cucumbers can cost close to $1 per seed!

Seedlings are grown in either organic or inorganic substrates. Inorganic substrates such as stone wool or phenolic foam are the most commonly used substrates for seedlings. These inorganic substrates are commonly sold in sheets that have from 50 (large cubes) to more than 200 individual cells (small cubes) in the same sized sheet. Organic substrates such as ground sphagnum peat moss or coconut coir may also be used, though these loose materials need to be stabilized chemically (using glues or binders) or physically (using paper or mesh wrappings).

Closely managing the environment — moisture, temperature, light and mineral nutrients — can have a big impact on seedling production time and quality. After seeds are sown, they should be thoroughly watered in using a low-strength fertilizer solution from the beginning. While the seeds are germinating, air and substrate temperatures should be warm, ranging from ~70 to 75°F, depending on the species. After germination has occurred, air and substrate temperatures can gradually be reduced to levels similar to the grow-out environment. While some seeds need light to germinate, the intensity of light doesn’t need to be high at first. However, once the cotyledons start to expand, increase light intensity to enhance seedling growth and development. The time to produce transplantable seedlings varies with species and culture. Some lettuce can be ready to plant in as little as two weeks, and tomatoes and pepper seedlings can be ready to transplant into larger 4-inch blocks in three to five weeks.

Seedlings can be grown in a wide variety of systems and with a range of methods, all ranging widely in price, level of automation, etc. The simplest method is to produce seedlings right on the greenhouse bench or floor, like how other seedlings or transplants may be grown. Electric heat mats can be used to provide bottom heat to maintain substrate temperatures. Alternatively, seedlings can be produced in more specialized systems (Fig. 2) that are designed specifically for producing young plants.

Cutting propagation

Plants are also vegetatively propagated through cuttings for certain crops. Though seed is the most common method used for propagation, certain plants such as perennial culinary herbs are propagated by cuttings. Stem-tip cuttings are most frequently used, as opposed to root or leaf cuttings. Unrooted cuttings can be purchased from commercial suppliers or you may choose to grow stock plants and harvest your own cuttings. If you do decide to grow your own stock and propagate cuttings, be sure that you are only propagating non-protected varieties or are paying the royalties to propagate any protected varieties.

Cuttings can be rooted in the same substrates used for seedling production. While rooting hormone isn’t necessary, it can improve the uniformity of your cuttings and, therefore, your finished crop. Like any seedling production, light, temperature, nutrition and water all affect the growth and development of new, or adventitious, roots and, therefore, the final quality rooted cuttings. Since the cuttings lack roots, mist needs to be applied to keep them turgid. While the mist needs to be applied frequently in the beginning of propagation, it should be reduced as adventitious roots emerge and grow into the substrate; after seven to 14 days (depending on the species), mist may be discontinued and cuttings may be irrigated on an as-needed basis. The air and substrate temperature should be warm (~72 to 75°F) at the beginning of propagation. As roots develop and shoot growth resumes, bottom heat may be discontinued and air temperatures may be lowered. Alternatively, while some shade may be used for the first few days in propagation to help keep cuttings turgid, light intensity should increase as cuttings grow to promote root growth and reduce the time to transplanting. Finally, even though roots are not present, fertilize cuttings periodically beginning at sticking to maintain tissue nutrient concentrations, increasing concentrations as the roots develop and the cuttings start to actively grow.

To successfully propagate cuttings, the two most important components of any propagation system are: 1) a mist system; and 2) bottom heat. The mist system is vital to keep these rootless cuttings turgid; an automated system is easily the most convenient method for applying mist. Bottom heat is used much like in seed propagation — to maintain warm substrate temperatures. However, instead of maintaining substrate temperatures to promote seed germination, the warm temperatures promote adventitious root initiation and subsequent development.

Grafting

Another type of propagation method that is increasing in popularity among some hydroponic vine crop producers is grafting. Grafting is the process of combining a desirable root system, or rootstock, from one plant with a shoot, or scion, from another plant that produces desirable fruits (Fig. 3). While grafting is used to impart some type of disease resistance to plants when planted into field soils in high tunnels, grafting vine crops for hydroponic production is primarily to improve vine vigor.

The most widely used grafting method is the tube graft. It is the most commonly used method for the most popular greenhouse vining crop from seed in the U.S., tomatoes. Although grafting is considered a type of vegetative propagation, the rootstocks and scions come from young plants propagated from seed. To produce the rootstocks and scions for grafting, follow the procedures for seedling propagation and production.

One of the most critical aspects of grafting is healing, when the vascular tissues of the rootstock and the scion are connecting to allow water uptake by the scion from the rootstock. By providing the appropriate conditions, the healing period is between five to seven days.

As previously mentioned, the vascular tissues of the scion and rootstock are forming connections during this period, after which water will be able to be taken up by the roots and translocated to the shoot. As a result, the healing environment should be one that inhibits transpiration and water uptake while maintaining turgidity. Keeping the relative humidity high helps reduce transpiration and water loss, keeping the scion turgid. Additionally, since light promotes transpiration, recently grafted plants should be placed in darkness for one or two days, after which time the light intensity can increase up to ~100 µmol·m^–2·d^–1.

The take-home message

The ultimate goal of propagating hydroponic food crops is to efficiently produce high-quality young plants in a timely fashion. Whether you are using growing seedlings, rooting cuttings, or grafting plants, starting off with healthy young plants can improve uniformity and yields. Careful monitoring and management of the greenhouse environment (light and temperature) and culture (water and nutrition), coupled with the appropriate systems for the different propagation methods, will allow you to start each crop off with the best plants.

Christopher is an assistant professor of horticulture in the Department of Horticulture at Iowa State University. ccurrey@iastate.edu

At Vineland Research and Innovation Centre in Ontario, Plant Pathology Research Technician Travis Cranmer is working to analyze the efficacy of biopesticides against root diseases in hydroponic tomato production.

Cranmer’s objective is to imitate the production of a commercial grower. He uses both available biological products and those soon to be released in the early stages of grafted and nongrafted plants.

The study’s findings were released at the Canadian Greenhouse Conference in Niagara Falls in October 2016. Cranmer shares some of his conclusions below.

Produce Grower: Can you give us an overview of the bio-inoculant study?

Travis Cranmer: I’m looking specifically at microorganisms, whether they are bacterial or fungal — as well as microbial extracts — to see how they can suppress pathogen development. Our pre-commercial greenhouse mimics the same fertilizer, equipment, cultivar, media and growing practices that Ontario greenhouse vegetable growers would have. My experiment is also set up to test a wide range of products on the same crop at the same time, without contaminating plants on adjacent slabs.

We inoculated these products with biopesticides, as we know that plants actively respond to a variety of environmental stimuli. These stimuli can either induce or condition plant host defenses, to subsequently suppress infection from pathogens such as Pythium, or Fusarium, or other brute raw pathogens that hydroponic growers often have problems with.

My role is to see how they perform, so that a grower can make an informed decision when they select the product based on their growing practices, the media they use or the cultivar that they choose.

PG: Why did you decide to look at Pythium first?

TC: I wouldn’t say it’s the most severe pathogen, but a lot of growers struggle with it. It’s something that even a grower who is careful can sometimes have. It’s a relatively easy pathogen to inoculate and to monitor. We developed a [biological assessment] for it, and now we’re answering questions about Pythium with different media.

With Pythium, wilting occurs seven, 10, 14 days after inoculation. As those plants wilt following innoculation with Pythium, we record any symptom development. We take a height measurement at week 9 for the grafted, and week 7 for ungrafted plants. We do fresh weight, open up slabs, flip them over, look at root development and root rot, and we rate them on a 0 to 100-percent root rot scale. Then, we have a disease severity index that we also use.

PG: And what have you discovered about Pythium in tomatoes?

TC: We have found that we can see significant differences at the nine-week tomato harvest. It’s very likely that if we were to let the crop grow for another six months, the plants with poor root development would be stunted and have smaller yields. That’s why we test everything over so many weeks.

Our healthy controls had excellent root development, and they scored near 100 percent. And our infested controls, the grafted ones, really got swept off. But [with] the ungrafted, there were significant differences. Some of the products such as Trianum, Rootshield, BW240, had better root development and performed almost as well as the chemical control.

PG: What studies are on the horizon for hydroponic tomato pest and disease?

TC: We’re switching [the media] up. We’re basically using most of the products [from the first experiment], and a couple more. And instead of looking at grafted versus ungrafted, we’re looking at coco versus rockwool. We’re still trying to figure out which product works best for Pythium. We’d also like to know which product works best to cause suppression of whitefly or twospotted spider mite. And it’s tricky, because these biologicals don’t behave the same way in every growing media. I can’t say right now which product is our clear frontrunner, and which ones are runners up. But at the end of the day, I want to be able to help growers make informed decisions — to be able to pick the right bio-inoculant for their crop.

Editor’s Note: This interview was edited for length and clarity.

The Produce Safety Rule of the Food Modernization Act (FSMA) set a new era in food safety for produce growers. As the Food and Drug Administration (FDA) states in the Introduction to the final rule, “The rule establishes, for the first time, science-based minimum standards for the safe growing, harvesting, packing, and holding of fruits and vegetables grown for human consumption.”

With an effective date of Jan. 26, 2016, the first major compliance date (except that for sprouts) comes due on Jan. 26, 2018, which means that produce growers have 2017 to get their (green)houses in order for compliance — even many who are legally exempt.

Two of the key provisions of the rule intended to reduce what FDA assessed to be major routes of contamination of fruits and vegetables include a focus on pathogen detection and prevention in agricultural water and biological soil amendments. A brief overview of these follows.

Agricultural water quality and testing

“The overarching mandate of the requirements for agricultural water quality is that it be safe and sanitary,” says David Acheson, former FDA associate commissioner of foods and founder and president of The Acheson Group. Based on the presence of generic E. coli, which can indicate fecal contamination, the rule establishes two sets of criteria for microbial water quality:

• No untreated water or water with detectable generic E. coli is allowed for uses such as washing of hands, food-contact surfaces or produce during or after harvest, through which the pathogen could be transferred to produce directly or indirectly. If E. coli is detected, use must be stopped and corrective action taken.
• For agricultural water that is directly applied to growing produce (other than sprouts), FDA set criteria based on two values: the geometric mean (GM), of 126 or less colony-forming units (CFUs) of generic E. coli per 100 mL of water, and the statistical threshold (STV), of 410 CFU or less of generic E. coli in 100 mL of water. Further details on establishing a microbial water quality profile and tools for conducting these calculations are available through the universities of California and Arizona, with links to both at bit.ly/2jHbaIZ. FDA is also considering the publication of an online tool for growers.

Testing of agricultural water and its frequency is based on the type of source. If untreated surface water is directly applied to produce, an initial survey is to be conducted with at least 20 samples collected near harvest over two to four years. For untreated ground water applied to produce, an initial survey of at least four samples is to be collected close to harvest, during the growing season, over a period of one year. In both cases, the survey results are used to conduct GM and STV calculations. Then, after the initial survey, growers are to conduct annual surveys of at least five samples, combine those with the previous most recent 15 samples, and create a rolling database for updating the calculations.

Biological soil amendments

“Although FDA focuses on biological soil amendments of both animal origin and human waste, FDA would never allow the use of human waste on produce,” Acheson says. As such, this article discusses only those of animal origin, for which the rule addresses two key points: raw manure and stabilized compost.

FDA states that raw manure must be applied so that it does not contact covered produce during application and so post-application contact is minimized. The agency is currently conducting a risk assessment to determine the number of days that should be required between application and harvesting. Meanwhile, it “does not object” to compliance with USDA’s National Organic Program standards, which call for a 120-day interval for crops that contact the soil and 90 days for crops that don’t.

The rule also sets microbial standards for limits on detectable amounts of Listeria monocytogenes, Salmonella, E. coli 0157:H7 and other bacteria for processes used to treat biological soil amendments, including manure. Stabilized compost that meets these standards (two examples of which are given in the rule) is then to be applied in a way that minimizes contact during and after application.

For complete information on the agricultural water, biological soil amendment, and other provisions of the Produce Safety Rule, see the full rule in the Federal Register at bit.ly/2iBEdjg

Regulatory vs. customer requirements

With FDA having determined, in its 2013 Analysis of Economic Impacts of produce standards, that 956 of the 1,128 produce-growing greenhouses (as cited from the 2007 Census of Agriculture) would be considered small or very small operations, up to 85 percent of greenhouse growers could expect to be exempt from the rule or at least have extended compliance dates. However, it’s not quite that simple.

The rule does state that “farms” that have an average annual value of produce sold during the previous three-year period of $25,000 or less are exempted, and qualified exemptions are granted for farms that have food sales averaging less than $500,000 per year and whose sales to local (same state or within 275 miles) end-users exceed all other sales combined.

But, even when legally exempt, produce growers may need to comply with the rule to meet requirements of its downstream customers. That is, if you sell — or want to sell — produce to a retailer whose supplier requirements include compliance with FSMA, you will need to ensure you are following all the rules, even if you are exempted by the language of the law.

For example, in 2007, well before FSMA was introduced as a Congressional bill, Walmart created a rule that all food suppliers who wanted to sell in its stores would have to be certified to the Global Food Safety Initiative (GFSI) standards. “We saw that suppliers were trying to do the right thing, but many were doing different things,” said Walmart Vice President of Food Safety Frank Yiannas. The requirement put many suppliers well on the road to FSMA compliance — even exceeding compliance in some areas. Additionally, as found by a Walmart study which analyzed the impact of GFSI certification on product recalls, “The results suggest that a food manufacturer that achieves a GFSI-recognized certification is significantly less likely to experience a food withdrawal or recall.”

This was further validated in a presentation Acheson made at a GFSI briefing in January, in which he revealed the results of a comparative analysis of the GFSI Benchmarking Requirements V7 and FSMA’s Preventive Controls Rule. “GFSI generally meets or exceeds all of the requirements in the FSMA preventive control rule,” he said. “In some cases, GFSI has requirements not reflected in FSMA.”

With the combination of food companies requiring certification to GFSI standards and FSMA’s new supply chain control requirements, many downstream food facilities and retailers are enforcing increasingly more robust supplier requirements. “Customer requirements are often stricter and of even greater significance to a company’s bottom line than are those of our federal regulators,” Acheson says. Thus, exempt or not, produce growers can either meet the requirements or seek out another buyer with lesser requirements.

Lisa is editor of sister publication Quality Assurance & Food Safety (QA) magazine. llupo@gie.net