Organic Broadcaster

Produce growers: Take steps now to comply with FSMA Produce Safety Rule

By Teresa Wiemerslage,  Produce Safety Alliance Lead Trainer

The Food Safety Modernization Act (FSMA) Produce Safety Regulation is the country’s first mandatory federal standard for the safe production of fruits and vegetables. It is being implemented in stages, with some rules in effect since 2016, and more taking effect in January 2019.

While small- and medium-sized farms will be exempt from the regulation, all farms that grow and handle vegetables and fruits should understand and follow best practices to keep produce safe to consume. These eight steps will help improve your farm’s understanding of best practices and get your farm ready to comply with the FSMA Produce Safety Rule (PSR).

1. Document your farm’s FSMA PSR Status.

The FDA has created a flowchart to help growers determine their FSMA status—exempt, qualified-exempt, or covered by the regulations. See the chart online at mosesorganic.org/food-safety.

To determine your farm’s FSMA status, you will need to know whether the commodities grown on your farm are covered or not; the average annual produce sales of your farm; the average annual food sales of your farm; and which of your customers are “qualified end users.”

Farms were required to start keeping these records in March 2016. If you have not been keeping records, go back now and gather as much financial documentation from March 2016 onward as possible. You could use tax filings or accounting reports to show your annual produce sales and annual gross sales for each year. Simple worksheets are available to help farmers with this documentation.

2. Attend a PSA Grower training.

The best way to learn about the PSR is to attend a Produce Safety Alliance (PSA) Grower Training. This curriculum covers the FSMA Produce Safety Rule requirements as well as Good Agricultural Practices (GAPs) for on-farm food safety. PSA is a collaboration among Cornell University, FDA, and USDA to prepare fresh produce growers to meet the regulatory requirements included in the FSMA Produce Safety Rule.

Official trainings are offered by individuals trained by the PSA and are generally eight hours long. Attendees are sent official certificates upon completion. See producesafetyalliance.cornell.edu and click on “Training” to see a list of upcoming grower trainings planned around the country. In addition, check with your state department of agriculture to find local trainings.

The PSA Grower Training also meets a requirement of the PSR that “at least one supervisor or responsible party from a farm subject to the FSMA Produce Safety Rule must have successfully completed food safety training at least equivalent to that received under standardized curriculum recognized as adequate by the Food and Drug Administration.”

3. Track what you grow, where you sell it.

Exclusions and exemptions to the PSR are largely based on the types of commodities grown, total annual sales of produce, and where and to whom the food is sold. Farms should have a record-keeping system to collect those figures. Sales records, harvest logs, and packing logs can be useful documents. Create a list of your buyers and sort them as “qualified” or “non-qualified” end users. Farmers market and CSA sales can be lumped into one category.

4. Update your labels, signage.

A qualified exempt farm is subject to certain labeling requirements. Any product that leaves the farm in a box (going to a restaurant, grocery store, or CSA member) needs to have a label on it that includes the farm name and complete business address. When you sell products at a farm stand, farmers market, or other direct point of sale, you must post a sign with the farm name and business address where the produce was grown. Check your box and container labels, farmers market signage, and invoices to see if they need to be updated. Make this change when you re-order supplies.

5. Update records for required elements.

The PSR requires a few specific records. If your farm is already doing some record-keeping and documentation of food safety efforts, your log sheets may need to be updated. New items to include are the name and location of the farm; the date and time of the activity documented; initials of the person making the record; and space for a reviewer signature and date.
There may be some overlap between organic and food safety records. Farms are encouraged not to duplicate records for food safety if they are already tracking those details in their organic record-keeping.

6. Test your agricultural water for generic E. coli.

The FDA is exploring ways to simplify the agricultural water standards established by the PSR. They have extended the compliance dates for agricultural water requirements out to 2022 and beyond. Until then, make sure you are testing all water sources used for irrigation, fertigation, packing, cleaning, and hand-washing for generic E.coli at least once a year (more frequently for surface water). If your farm is covered by the PSR, there are specific water tests that are acceptable. Many states are compiling lists of labs that offer the accepted tests. Check with your extension service or state department of agriculture.

7. Create documents to train workers, visitors.

The PSR potentially presents fully covered organic farmers with a whole new set of duties related to training workers and ensuring that health and hygiene practices are followed. Workers must be trained at least annually, and one representative of the farm must attend a PSA training. Field sanitation requirements are the same as existing OSHA requirements, but FSMA has a long list of practices that workers must follow. Written records must be kept to document several of these requirements. You must also make farm visitors aware of your health and hygiene practices. This can be done verbally or through signage.

8. Follow organic rule for using soil amendments of animal origin.
The FDA is conducting a risk assessment of the number of days needed between the applications of raw manure as a soil amendment and harvesting, to minimize the risk of contamination. This is estimated to take between 5 and 10 years to complete.
At this time, the FDA does not object to farmers complying with the USDA’s National Organic Program standards, which call for a 90 or 120-day interval between the application of raw manure and harvest. In areas where raw manure is applied, covered crops that do not touch the ground can be harvested 90 days after manure application. Crops that do touch the ground cannot be harvested until at least 120 days after manure application. Composted manure needs to follow an approved process and have logs or supplier documentation of process.

Teresa Wiemerslage is a certified Produce Safety Alliance lead trainer and Food Safety Field Specialist for Iowa State University Extension and Outreach.

 

 

From the July | August 2018 Issue

 

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