Agricultural Field Toilet Inspection Program

State: CA Type: Promising Practice Year: 2019

As recent as April and November of 2018, E. coli outbreaks associated with romaine lettuce have caused infection among 275 people and unfortunately, five deaths. The events caused huge losses to growers, a drop in sales for retailers, and disruption of supply chains as food service facilities scrambled to find romaine lettuce alternatives. As result of the prior E. coli outbreaks in 2002, 2003, 2004 and the nationwide spinach outbreak in 2006, the California Department of Health Services (now California Department of Public Health), in a letter to Monterey County, recommended that the county enforce existing regulations that would aide in reduction of factors that would potentially lead to outbreaks. In response, the Monterey County Health Department's Environmental Health Bureau (EHB), Consumer Health Protection Services, proactively strengthened its regulatory Agricultural Field Toilet Inspection Program (AFTIP) that was only enforced as a complaint-only response prevention program to address a very modern, resurgent, and serious food safety issue. 

The EHB developed the AFTIP to accomplish two imperative goals: (1) reduce the potential and perceived threat of food contamination from agricultural field worker hygiene concerns and (2) increase opportunities for proper field worker hygiene to eliminate this as a factor during any outbreak investigative process. Our objectives are to:

  • Ensure all agricultural workers have access to a clean and operable portable toilet facility with soap and running water and paper towels to properly wash their hands and have an ample amount of fresh potable drinking water. We inspect and register 6,370 field toilets annually throughout Monterey County. AFTIP permits are separated into three categories by the number of field toilets an operator has in their inventory: 1-5 field toilets, 6-99 and 100 and above. EHB currently has 100 AFTIP permits issued of which 17 permits are of the 1-5 toilet category, 63 are 6-99 toilets and 20 permits are 100 and above.
  • Provide education and outreach to 100 field toilet operators regarding the importance of maintaining portable toilets through scheduled cleaning and removal of liquid waste and stocking them with soap, water and paper towels. Following these practices would aide in reduction or elimination of the potential threat of contamination of food crops due to any worker hygiene issues and to reduce the dangers of communicable diseases, agrichemical residues, dehydration, and heat exhaustion.

Historically, agricultural field workers were provided with inadequate or no portable toilet in the agricultural settings and many lacked adequate hand washing facilities or a supply of fresh drinking water. By California law (Cal OSHA), field toilets must be within a five minute or less walk from the working field to prevent workers from relieving themselves in or adjacent to the agricultural fields in which they work. Risk factors that may be associated with cross-contamination of agricultural food products may include improper handwashing and vectors (flies). While field contamination may also potentially be caused by feedlot and pasture runoff or wild animal invasion, this NACCHO Model Practice Application addresses agricultural field toilet sanitation, which had previously been an unaddressed factor that may have contributed to crop contamination).

John Steinbeck rightfully christened Monterey County as the Salad Bowl of the World,” where family and large commercial farming operations of over 2 million acres in row crop production contribute to the county over $4 billion dollars in annual yields and employ over 75,000 workers. Monterey County produce is shipped globally to trading partners in Canada, Taiwan, Japan, Mexico, the European Union, and Hong Kong. The potential population that could be affected by agricultural contamination is staggering.

EHB found that two California laws were directly related to maintaining sanitary conditions of agricultural field toilets: the California Code of Regulations, Title 8, 3457 and Title 17, 8006 8011, which rested regulatory authority with the California Occupational Safety and Health Administration (Cal-OSHA); and the California Health and Safety Code (CH&SC) Sections 113310 113355, which states: the primary responsibility for the enforcement of this article shall be vested in the local health officers; county agricultural commissioners may participate in enforcement. The State Department of Health Services (CDPH), Industrial Relations, and food and Agriculture may also enforce this article.”

As the first implementation step, EHB developed an inspection criteria based on verifying compliance with CH&SC Sections 113310 113355. The AFTIP inspection form distinguishes items that can be addressed in the field, with some items requiring immediate correction (ex. no soap, no water, etc.). Specific criteria for AFTIP compliance are fundamentally equal to that of toilets in permanent food facilities. Water, soap, and paper towels for hand washing must be available. Toilets must be accessible and available in relatively close proximity to workers. Potable water must be from an approved source, and waste water must be contained. Field toilets must be kept in sanitary conditions, clean and properly maintained. Some operators make use of a posted cleaning schedule and maintenance crews. Permitted liquid waste haulers are also verified to close the loop” on liquid waste disposal. Re-inspections may be required based on observations and separate Return to Compliance” forms are used for that purpose.

The second implementation step was the development of the inspection process. This was done in three phases. The first phase involved conducting initial inspections at the agricultural farm site or storage yard. This allowed a first time, baseline look at the field toilet units before they were put in use and before recommendations were made. The second phase was done in the field, following up to ensure repairs or upgrades were made. The third and final phase of the process was to develop a fee structure. Although typically a first phase or planning stage step, placing the fee structure in the final phase of the implementation helped expedite field intervention as well as local acceptance by members of the agricultural industry.

AFTIP start-up costs for program development were not included into the fee structure. The EHB Director conducted stakeholder outreach through meetings with the Farm Bureau and Farm Labor contractor organizations. Non-traditional stakeholders such as insurance groups were also presented with information to help build a needed foundation of acceptance. Partnerships with local media were established to help promote the program on a wider basis.

The cost to the field toilet operators was based on the number of toilets provided annually. The fees partially covered staff time for communications, transportation, inspection, and data recording. Initially, the fee schedule for 1 to 19 toilets was $100 each annually, 20-49 toilets were a flat fee of $2,736 annually, and 50 or more toilets were a flat fee of $3,420 annually. To reduce cost expenditures, an intern from California State University, Monterey Bay provided 10 hours of data analysis per week for three semesters, and wrote a program summary that the student also utilized for their college capstone..

Currently there are more than 8,000 registered AFTIP units with more than 100 registered owners. EHB conducts ongoing education efforts in collaboration with the agricultural industry, agricultural food safety teams and Leafy Green Marketing Agreement (LGMA) auditors. Because of an increasing rate of compliance, staff time in the field to conduct inspections has reduced, resulting in reduced fees for small farm operations that operate less than 100 field toilets.

Summarizing, the original field toilet inspection program was active up to the mid-1980s, when due to budget constraints over time, routine inspections were discontinued and activities were limited to complaint-only responses and a simple registration program. EHB fully reinstated the AFTIP in 2007 with modifications that put the program in the realm of prevention, rather than strictly remediation. As the program continued, REHS staff began providing worker hygiene (handwashing) trainings to field workers. Soon agricultural operations began doing the same.

The Monterey County Health Department, Environmental Health Bureau AFTIP website is:

The AFTIP is a new procedure and regulatory practice that was developed by Monterey County Health Department Environmental Health Bureau staff. At the time the AFTIP was developed, it was unique to Monterey County and California, and we believe it remains so. We have received inquiries from Santa Barbara County and Ventura County in California, however, they have yet to implement this program. Our data confirm that the program as one of many agricultural industry initiatives has aided in a reduction in the number of potential foodborne related out breaks from the consumption of whole cut produce from our county, and we take every opportunity to provide program information to interested regulatory agencies as we wish to see AFTIP replicated in other regions. Other regions may benefit from our lessons learned, such as conducting field toilets inspections in storage yards, prior to their delivery to the agricultural field. While there may be other ways that agricultural products can be contaminated during harvesting, packing/packaging and transportation , we believe the AFTIP has greatly increased field worker sanitation and through availability of clean portable field toilets that help reduce factors leading to outbreaks.

AFTIP is innovative as there is, to our knowledge, no other program like it that addresses farm worker hygiene and addresses the lack of or unclean portable field toilets. Importantly, the program roll out was also innovative, as we approached the stakeholders in an educational manner. Stakeholders, while bearing some of the initial costs, quickly saw the ways AFTIP would ensure crop safety. Although we were prepared for a challenge, the roll out of AFTIP was initially met with resistance by the agricultural community and only through perseverance and educational outreach to farm operators through the Monterey County Farm Bureau and Growers Shippers Association of California we were able to slowly gain acceptance that has now resulted to full acceptance of the program. Surprisingly we annually receive phone calls requesting our inspections from farming operations as agriculture operations now recognize the importance of worker hygiene as a preventative factor.

We would like to see the AFTIP become designated as an evidence-based practice for agricultural production across the nation. While we are increasing worker hygiene that aides in protecting crops from contamination from improperly maintained field toilets in Monterey County, those same field toilets and other farming equipment are transferred to agricultural areas in Arizona each winter, where our efforts can become undone without similar diligence for inspection and certification.

As for stakeholders, EHB collaborated with farming operation owners, farm labor contractors, and field toilet operators to develop and launch AFTIP; the Leafy Greens Marketing Agreement (LGMA) certification program regarding produce production and monitoring; the California Food and Drug Administration and the  California Department of Public Health on food safety and outbreak investigation; the Grower-Shipper Association of Central California and Monterey County Farm Bureau to promote the program among growers; and California Rural Legal Association to address and monitor complaints.

AFTIP evaluation includes monthly inspections and resulting data collection; data are stored and analyzed using Envision software. A minimum of 90% of all units in use are inspected annually and re-inspected as required.  Portable toilet operators contact the EHB when their units arrive from other states to facilitate our inspections. 

REHS staff log raw data into Envision regularly following field inspections, and results are then aggregated for review by supervisors on a weekly basis. Data elements include the field toilet identification number, location, name of liquid waste hauler, health permit number(s), frequency of disposal, solid waste disposal, proper identification, and 22 compliance measures. When the individual field toilet meets all requirements, it is affixed with a dated certification sticker carrying the county seal and issued by the EHB.

Close collaboration with agricultural industry stakeholders and field toilet operators was an important contributor to the success of AFTIP, as was initiating the practice with a focus on education and safety. The initial fees assigned to the field toilet operators was reduced in year two of the program and again in subsequent years, and the cost of the program is fairly well sustained by the fee structure.

Some of our initial lessons learned were to Provide necessary safety equipment to staff that included safety boots, head lamps for use when working in late or early morning hours, and using proper utility vehicles to navigate through agricultural farmland. 

Supporting the field activities, EPB created an AFTIP application form, inspection procedures and inspection forms, compliance documents, an Envision database, a handbook for stakeholders, and a training manual for agricultural field superintendents.

The AFTIP has been in operation for just over a decade. Since the time of its revival, major changes in the attitude and approach to food safety have occurred in commercial farming. The work that 

Monterey County's EHB has contributed for farm food safety through the AFTIP has achieved what many environmental health programs strive for; empowering the community to make positive public health choices and actions. We find it satisfying that substantial stakeholder commitment exists to this day, and that staff are often thanked by the agricultural field employees for their service. The most fulfilling result is that Monterey County's effort ensures farm worker hygiene with access to clean field toilets, with hand washing supplies in the prevention of foodborne illnesses

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