Definition: Fresh produce that has been peeled and/or cut for the consumer is considered “processed food” as defined by the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321(gg)). Thus fresh-cut processors of fruits and vegetables are subject to the Colorado Good Manufacturing Practices (GMP) regulations. Colorado requires packaged, fresh cut produce and ready-to-eat salad mixes to be processed in an approved GMP-compliant facility or licensed retail food establishment.
Food Safety: Processing fresh produce into fresh-cut products increases the risk of bacterial growth and contamination by breaking the natural exterior barrier of the produce. The release of plant cellular fluids when tomatoes are cut provides a nutritive medium in which pathogens, if present, can survive or grow.
For example, the processing of fresh tomatoes in the absence of proper sanitation procedures, like other fresh produce, increases the potential for the tomatoes to be contaminated by pathogens. In addition, the degree of handling and product mixing common to many fresh-cut processing operations can provide opportunities for contamination and for spreading contamination through a larger volume of product. In addition, when fresh-cut products such as packaged salads are produced, many different lots of lettuce and other leafy greens may be commingled, making traceability difficult in the event of a foodborne outbreak.
All fresh-cut produce should be washed thoroughly with cold water to remove any dirt, debris, and harmful bacteria. Good Agricultural Practices and Good Manufacturing Practices should also be followed to prevent foodborne outbreaks.
Fresh-cut produce should always be refrigerated (maintained at 41°F or below), unless it is cut and immediately served to the consumer, since certain produce supports the growth of harmful pathogens.
Licensing: When you go from a whole piece of fruit or a whole vegetable into a cut fruit or vegetable, you go from being exempt from licensing to being required to have a Retail Food Establishment License, issued by your county health department and/or registering with the Colorado Department of Public Health and Environment (CDPHE) as a wholesale food manufacturing facility.
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