If your Freshcare management system is the blueprint, then the Hazard Analysis (F1) is the crucial site survey you conduct before you build anything. It’s where you identify the specific, underlying risks on your property. Getting this element right is the foundation of your entire food safety program and something every auditor will scrutinise.
The term “Hazard Analysis” might sound technical, but Freshcare provides a clear, step-by-step process. It’s a method of identifying potential hazards, assessing the significance of the risk they pose, and determining the practices to prevent or minimise them.
At AgriQulture Consulting, we help growers navigate this process every day. Let’s walk through the four mandatory risk assessments you must complete under Freshcare F1.
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Persistent Chemicals Risk Assessment (F1.1)
This assessment deals with the legacy of past farming practices. Certain agricultural chemicals used decades ago can remain in the soil and potentially contaminate your crops.
What you need to do:
You must complete a risk assessment for each growing site to determine the risk of contamination from persistent chemicals in the soil or growing medium. The Freshcare decision tree asks two key questions:
- Does the edible part of your crop grow in or in direct contact with the soil (e.g., carrots, lettuce)?
- Have persistent chemicals been previously used on the site, or are you unsure of the land’s history?
Why it matters:
Chemicals like organochlorines (OCs) can persist in soil for many decades, especially in cooler areas. Root and leafy vegetables grown in this soil are at the greatest risk of absorbing these residues.
How it works:
If your crop has soil contact and you answer “Yes or Unsure” to the land history question, the likelihood of a hazard is considered high. A high-risk outcome means you must implement additional control measures, which involves either testing the soil before planting or, more commonly, testing the harvested produce for chemical residues to ensure they are compliant with legal limits.
Heavy Metals Risk Assessment (F1.2)
This assessment focuses on naturally occurring or introduced heavy metals, primarily Cadmium and Lead.
What you need to do:
You must assess each growing site for the risk of heavy metal contamination. The assessment looks at specific risk factors for each metal.
- For Cadmium: Are you growing leafy greens, root/tuber vegetables, or peanuts? Is your soil sandy, acidic, low in organic matter, or is your irrigation water salty?
- For Lead: Was the site previously treated with sewage sludge, used as a rifle range, or is it near old buildings with lead paint or a smelter?
Why it matters:
While heavy metals occur naturally, their uptake by plants can be increased by certain soil conditions and crop types. Exceeding the Maximum Levels (MLs) set by Food Standards Australia New Zealand (FSANZ) can make produce unsafe for consumption.
How it works:
If you meet the criteria for a high-risk scenario (e.g., growing spinach in acidic, sandy soil), you must implement additional controls. This means you need to test the harvested produce for cadmium and/or lead residues to verify you are meeting the legal limits.
Fertilisers & Soil Additives Risk Assessment (F1.3)
This is a critical assessment for managing microbial risk from organic inputs.
What you need to do:
For every growing site, you must assess the risk of microbial contamination from fertilisers and soil additives, particularly those containing animal manure. The key question is whether the product is “untreated” (raw manure) or “treated” (e.g., properly composted to standard AS4454:2012).
Why it matters:
Untreated animal manures are a significant potential source of human pathogens like E. coli, Salmonella, and Listeria. These microbes can transfer to fresh produce through direct contact or via wind and water splash.
How it works:
The outcome of this risk assessment determines your exclusion period—the minimum number of days you must wait between applying untreated manure and harvesting your crop.
- High Risk (e.g., using untreated manure on produce eaten uncooked, with soil contact) requires a 90-day exclusion period.
- Low Risk (e.g., using untreated manure on all other produce) requires a 45-day exclusion period.
- No Exclusion Period applies if you only use fertilisers that contain no manure or use compost that has been treated according to a verified process.
Pre-Harvest Water Risk Assessment (F1.4)
Water is essential for growing, but it’s also a primary vehicle for spreading contaminants. This assessment manages that risk.
What you need to do:
You must assess the risk of microbial contamination from all water used pre-harvest (e.g., irrigation, crop sprays). The assessment hinges on when water is applied and if it touches the edible part of the crop.
Why it matters:
Contaminated irrigation water has been linked to numerous foodborne illness outbreaks globally. While pathogens on plant surfaces tend to decline over time, water applied close to harvest presents a significant risk.
How it works:
This assessment establishes the “48-hour rule.” If water is applied to the crop within 48 hours of harvest, touches the harvestable part of the crop, and the crop may be eaten uncooked, the risk is considered high. A high-risk outcome requires you to test your water to prove it meets the quality standard of less than 100 cfu/100mL of E. coli.
A Note on Justifying “Not Applicable” (F1.6)
If you believe an element of the Freshcare standard doesn’t apply to your farm, you can’t just ignore it. You must complete a risk assessment that clearly details the reason for the exclusion. This shows the auditor you have actively considered the risk, not just overlooked the rule.
These risk assessments form the custom-built foundation of your food safety plan. Getting them right isn’t just about passing your audit; it’s about genuinely understanding and managing the unique risks on your property.
Frequently Asked Questions (FAQ)
Yes. Freshcare requires you to review all your risk assessments at least annually, or whenever changes occur that might impact the risk (e.g., you start growing a new crop). You must keep a record of this review.
This is a common challenge. If you cannot find historical records, you must select "Unsure" on the risk assessment. This will lead to a high-risk outcome, meaning you will likely need to get your soil or produce tested to establish a baseline and prove compliance.
An MRL (Maximum Residue Limit) is the highest legal limit for a residue of an agricultural chemical (like a pesticide) on produce. An ML (Maximum Level) is the highest legal limit for a contaminant, like a heavy metal (e.g., lead or cadmium), in a food.
Yes. While town water is generally potable, you must still complete the assessment. You can use compliance reports from your water supplier as evidence of water quality, but you also need to ensure your on-farm infrastructure (pipes, tanks) isn't introducing contamination.
Completing your hazard analysis accurately can be complex. AgriQulture Consulting can help you work through each risk assessment on-site, ensuring your conclusions are practical, defensible, and keep your farm audit-ready. Contact us to schedule a consultation.
