Water testing is a major component of FSMA. The Food and Drug Administration (FDA) requires that growers begin sampling agricultural water to create a microbial water quality profile when they need to start complying with FSMA. No grower needs to start sampling until January, 2018 (growers over $500,000), small growers 2019 (growers between $250,000 and $500,000) and very small growers 2020 ($25,000 to $250,000). All growers have 2 to 4 years to complete sampling. How many samples are needed is not clear at this point. FDA is revisiting the water [Read more…]
April 19, 2017 Wes Kline
Updated USDA Harmonized Audit Standards
The updated USDA Harmonized Audit Standards and Checklists are to be used starting on May 1, 2017. The USDA has made changes to the Harmonized audits. Most changes are minor. Listed below are the section numbers with major changes for each audit.
Field Operations and Harvesting Standard:
2.1.3, 2.4.3.4, 2.4.3.5, 2.4.3.6 and section 5 has been added
Post-harvest Operations:
1.5.3, 1.12.1 (moved from 1.23.2 and numbers shifted down one), 1.13.12, section 4 added
To obtain the updated Harmonized Standards that are to be used with the new Harmonized checklists starting on May 1, 2017, please go to the United Fresh’s website. Also, there is a redline version of these Standards that show the items that were changed on the United Fresh website.
For the checklists that go with the standards go to the USDA Audit Services webpage and select the version for 5/1/17.
May 3, 2016 Wes Kline
On-Farm Food Safety:
The Difference Between an Audit & an Inspection
Over the last 15 years we have talked about third party audits to verify your food safety plan. Now you are hearing about inspections.
What is the difference?
Audits
Audits are voluntary evaluations that growers are doing at the request of their buyers. Some growers may not think that audits are voluntary since some growers have been told if they did not have one, a specific buyer would not purchase their produce. That is true, but you still had the choice to sell to someone else if you did not want to go through the audit process. The audit was verifying what you said you were doing for food safety.
Inspections
The Food Safety Modernization Act (FSMA) has added the inspection component to food safety. The final FSMA rule went into effect January 2016. As FSMA is implemented over the next two to four years, growers will hear more about inspections and how it may impact their operations. The Food and Drug Administration (FDA) now has more authority for fresh produce which adds another layer of compliance for growers. Inspections will be done by a government entity with specific requirements and implies some type of enforcement in the future. FDA is not in any hurry to start an enforcement program. They have made it clear that education is the first priority, but in reality sometime in the future there will be enforcement. Who will do the inspections is still being decided between FDA and the different states. In New Jersey, the New Jersey Department of Agriculture will probably be the lead agency as it relates to farms and on farm packinghouses.
Coping with New Rules: On-Farm Readiness Review
There is a group of extension personnel from Florida, Michigan, New Jersey and North Carolina working with the National Association State Departments of Agriculture on a grant from the FDA to develop an On Farm Readiness Review. This will be a self-assessment tool for growers, extension personnel and inspectors to help everyone when a farm is inspected. The plan is to have the final version available next year.
Growers will receive training over the next year to help comply with the Produce Rule in FSMA. The good news is growers who have been through a third party audit already meet or exceed most requirements for FSMA. Water testing is the one area where there are differences, but the training will help clarify those differences.
October 15, 2015 Wes Kline
Food Safety Modernization Act Update:
Farm Definition & Exemptions
The Risk-Based Preventive Controls for Human Food final rule was published in the Federal Registry September 17, 2015. This is the first of two which may directly impact fruit and vegetable growers. To review the complete rule go to https://federalregister.gov/2015-21920.
This rule updates good manufacturing practices related to processing and clarifies the farm definition and exemptions. Under the original proposed rule there were several activities on farms in our region that would have had to comply with this rule. However, with the revised definition most activities are exempt or fall under the Produce Rule which will be published at the end of October.
Under the final definition there are two ways to be considered as a farm: as a “Primary Production Farm” or as a “Secondary Activities Farm.”
[Read more…]
June 26, 2015 Wes Kline
Audit Ready: Heads Up on Handwashing Stations, Well Water Sampling, & Traceability
Handwashing Stations
Auditors have noted that on handwashing stations some have a label which says “Not potable water.” If a grower is doing the USDA GAP or Harmonized audits, the water in handwashing stations must meet the “Microbial standard for drinking water.” If a label is on the wash station marked not potable, the grower is not in compliance. Check G-9 in the GAP or 2.2.5 in the Field Operations and Harvesting Harmonized Food Safety Standard for more details.
From Grower Self Audit for USDA GAP Audit General Questions G-1 to G-15:
G-9. All toilet/restroom facilities are clean and properly supplied with single use towels, toilet paper, and hand soap or anti-bacterial soap and potable water for hand washing.
G-9. All toilet/restroom facilities are clean and properly supplied with single use towels, toilet paper, and hand soap or anti-bacterial soap and potable water for hand washing.
May 7, 2015 Wes Kline and Meredith Melendez
Audit Ready: Unannounced Verification Visits Are Coming
Growers who schedule a USDA GAP or Harmonized audit this year should be prepared for an unannounced verification visit later in the growing season.
These unannounced visits have been talked about during our educational sessions, but have mostly not happened due to a lack of auditors in the state. The NJ Department of Agriculture Commodity Inspection and Grading Division now has enough staff to conduct these unannounced visits.
Unannounced visits will take place after the initial scheduled audit is completed. These visits are used to verify that the farm is consistent with the written requirements of the food safety plan and the USDA audit requirements. You cannot schedule these visits and you will not know specifically when the auditor will arrive to perform the audit. The auditor may ask to see documentation during this visit, but will mostly focus on conformance to audit standards and your food safety plan through visual inspection.
