Dr. Brian Nummer PhD


Page: Microgreens (Retail-foodservice)

Introduction / Regulatory

Produce is important to the nutrition and health of consumers.  However, a variety of produce has been associated with foodborne illness outbreaks.  In 2015, the FDA released new food safety standards for Growing, Harvesting, Packing, and Holding of Produce for Human Consumption or the FSMA Produce Safety Rule.

Restaurants and retail operators are exempt from the FSMA standards but are not exempt from “Special Process” food safety requirements in the US FDA model Food Code.  Special Processes require a HACCP or similar food safety plan per 3-502.11.


Based on produce outbreaks (including sprouts), the main hazards are Salmonella, E. coli O157:H7, and Listeria monocytogenes.   Waterborne parasites (e.g Cryptosporidium) and human vector viruses (e.g. Norovirus) are less of a concern in retail operations where potable water and fecal presence is minimized.  Seeds have been implicated as a main source of pathogens.  Pathogens (if present) can proliferate mostly in sprout growing processes where there is little microbial competition and suitable growing conditions.


Agriculture seed production is generally not done under a pathogen-free guarantee.   It is questionable whether a supplier would provide a letter of guarantee or Certificate of Microbiological testing of their seeds. In the absence of a COA, an operator could periodically do a verification microbiological assay of seeds or seed wash water for coliforms (indicators of fecal contamination).

Seeds are typically rinsed before treatment.  While the Produce Safety Rule does not require pre-treatment rinsing (or a sanitation process), it is recommended that seeds be water rinsed thoroughly to reduce pathogens.  A seed sanitation step can be optionally used to enhance reduction of pathogens.

Most standard growing media have not been implicated in food safety hazards.  Coconut coir and peat moss are considered safe.  There is no need to have them sterile or sterilized, just free of pathogens.

No animal excreta should be used or introduced into a retail or foodservice environment — e.g. no MANURE.

A PIC must inspect, maintain, clean, and sanitize all FCSs of tools and equipment as frequently as reasonably necessary to protect against contamination of produce.

To minimize hazards greens and microgreens should be harvested by cutting them above the stem/root interface.  This will leave the roots behind along with any potential bacterial growth in the roots.

(Optional) Microbial testing of seed wash and irrigation water can be done as a verification step.  Test for Salmonella spp and E. coli O157:H7.  A suitable composite sample should be used and a presence/absence test is appropriate.

The US FDA model Food Code considered cut produce as TCS foods.  Therefore, harvested greens must be used immediately after harvest or refrigerated.


Compliance with and Recommendations for Implementation of the Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption for Sprout Operations: Guidance for Industry. 2017. US FDA and US FDA model Food Code 2013.

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