[Billy Mitchell]

Hi Chloe!

I’ve got a short and long answer, hopefully helpful – at least to the conversation. Would also love to know if anyone has had this discussion with an auditor or inspector or know of some super secret guidelines out there!

TLDR – There is a TAN question where FDA neither says yes or no. https://foodsafetyclearinghouse.org/resources/tan/fsma-toilet-facilities-requirements

“Question:Would pit toilets where all the waste is collected in a large dug hole be allowed under FSMA toilet facilities requirements (112.129) and (112.131) control and dispose of sewage requirements?

If the toilet is set up in a location that is not too far from the field, but far enough away from produce to prevent contamination and the waste will not contaminate water sources because it is contained within deeply dug hole that does not come in contact with the water table?Is a pit toilet that breaks down wastes considered an “other adequate method” for disposing of sewage?112.129 – Toilet Facilities Requirements112.131 – Control and Dispose of sewage

Answer:The Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption (80 FR 74353) (21 CFR Part 112) do not specify the type of toilets a farm must use; however, toilets are required to meet the requirements of 112.129. Additionally, as the inquirer mentioned, sewage must be managed in a manner the prevents contamination into the fields, on food and food contact surfaces, and in structures that hold or convey agricultural water.”

Way too long nobody wants to read all this, but I typed it out anyways answer – Great question! And great to see your name pop up! I can see why composting toilets might give an auditor/inspector reason to pause, but I don’t see why a well maintained facility could not meet the requirements. I’m not aware of any compost toilet specs that are GAP/FSMA approved.

I really don’t think it should be a steep hill to climb if It prevents contamination, is well maintained (serviced and cleaned), has toilet paper, and allows for the sanitary disposal of toilet paper. I’ve been in a few compost toilets that meet those requirements – and a few that don’t. I’ve also been in some traditional bathrooms that definitely do not meet those requirements – never on a farm, but they are out there. : )

I’m not going to touch on the handwash requirements, but let’s review some of the FSMA and GAP toilet requirements – I don’t see anything in here that would automatically disqualify compost toilets.

FSMA PSR 21 CFR 112.129 – What requirements apply to toilet facilities?

All of the following requirements apply to toilet facilities:

<ul type=”disc”>

[Lindsay Gilmour]

Love this question!

I have worked with 4 farmers who have composting toilets so far. Two of them have passed GAP audits with no problem – one HGAP, one USDA GAP. 2 haven’t been audited yet. The way we approached it on each farm was to do a risk assessment on the composting toilet system – how risk to water, crops and people is mitigated, and how the waste is handled – and we wrote an SOP describing the safe design and management of the system and waste disposal. Each of them had different systems and handled the waste differently but all did it safely. Some had long drops, some buried the waste, some composted it (it’s mixed with so much carbon rich material that there is no smell at all) and used it on non-edible flower beds at the end of the growing season. They all had dedicated tools for handling the waste. They all have livestock on their farms too, so in a way it wasn’t much different for them from assessing risk of animal waste management and the humanure was easier to manage in most cases. All the toilets were clean, had no smell of waste at all, were stocked with toilet paper, and had a hand washing station adjacent – and as Billy says, I’ve been in plenty of regular toilets that were nasty on and off farms.