Many packinghouses in New Jersey have not been updated in many years. If you haven’t, now is the time to be thinking about what changes will be needed to comply with a third-party audit or the Food Safety Modernization Act. Analyzing your packinghouse may also save money. Any time saved during packing will save money. If your produce moves quickly through the packing process it will maintain higher quality and be fresher.

Start by making a drawing of your packinghouse showing how the product comes from the field to the point it is loaded on the truck. Make sure to include how the produce is received, where the produce is dumped on the line or grading table, whether it goes through a washer, holding area after packing, the cold room, if applicable, and the [Read more…]

The United States Department of Agriculture just announced that anyone wanting a GAP or Harmonized Audit will see the base and hourly rate increase on October 1, 2017 from $92.00 per hour to $108.00 per hour. There also will be a base fee of $432.00 for either audit. This means if you have two or three audits a year each one will be charged $432.00 then the hourly rate will be added. Growers should try and combined as many crops as possible into one audit. Also, if a grower has been getting their audit in October or November, try to schedule them before October 1 to reduce your cost for this year.
For anyone calling for a quality or grade inspection the cost will increase to $191.00 per hour.

There is continued confusion about the difference between a third party audit and the produce safety rule under FSMA. The biggest difference is one is voluntary (third party audit) and one is government regulation (FSMA). Whether you need a third party audit depends on who is purchasing the produce. Some buyers will require an audit and specify the audit firm. This is mainly related to wholesale growers.

Whether you have a third party audit or not, FSMA applies to operations with produce sales over $25,000 (adjusted for inflation) averaged annually over three years.
Farms may be eligible for a qualified exception and modified requirements (section 112.5 and 112.6). To be eligible the farm must meet two requirements:
1. The farm must have all food sales (including animal feed) averaging less than $500,000 per year adjusted for inflation during the previous three years.
2. The farm’s direct sales to qualified end-user (restaurants, CSA, farmers markets, etc.) that is located in the same state or within 275 miles must exceed sales to all buyers combined during the previous three years.

A farm with the qualified exemption must meet modified requirements, including prominently displaying the name and the complete business address of the farm where the produce was grown either on the label of the produce or at the point of purchase.

Compliance Dates

1 Compliance dates for certain aspects of the agricultural water requirements allow an additional two years. Provisions with extended compliance dates include:
 The specific microbiological criteria that apply to agricultural water
 Corrective measures that must be taken if agricultural water does not meet requirements
 The frequency of testing agricultural water
 Records associated with data to support a microbial die-off rate, corrective measures, test results from a public water system, or data used to support alternative die-off rates, criteria, or sampling strategies
2 Guidance published 8/24/16 indicates that a farm has the option of collecting surface water samples over two to four years. For example, a farm that is not small or very small would begin sampling in 2018 and complete the water quality profile in 2020, 2021, or 2022.
3 A farm eligible for a qualified exemption must notify consumers as to the complete business address of the farm where the food is grown, harvested, packed, and held.
4 A farm is a small business if, on a rolling basis, the average annual monetary value of produce sold during the previous 3-year period is greater than $250,000 but no more than $500,000.
5 A farm is a very small business if, on a rolling basis, the average annual monetary value of produce sold during the previous 3-year period is greater than $25,000 but no more than $250,000.

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…]