May 3, 2016

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.

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Filed Under: Blueberry, Commercial Ag Updates, Food Safety, Fruit, Tree Fruit, Vegetable Crops
October 15, 2015

Food Safety Modernization Act Update:
Farm Definition & Exemptions

FDA FSMAThe 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.”
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Filed Under: Blueberry, Cranberry, Food Safety, Fruit, Tree Fruit, Vegetable Crops, Wine Grape
June 26, 2015

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.

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Filed Under: Blueberry, Food Safety, Fruit, Tree Fruit, Vegetable Crops
May 7, 2015 and

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.

Filed Under: Food Safety
February 25, 2015 and

On-Farm Food Safety Decision Trees

Decision trees can ease the process of creating your farm food safety plan. Decision tree topics include all of the important components of a food safety plan.  Access them at the National GAPs Program website.

Decision-Tree-4These decision tress will:

  1. Help you identify risks and practices that reduce risks;
  2. Prioritize the implementation of practices to use limited resources wisely;
  3. Familiarize you with the terms and methods necessary to understand and follow requirements and expectations for food safety from buyers, farm markets, schools, and federal regulations.

Cornell, University of Minnesota, and University of Tennessee, developed these decision trees.

Filed Under: Food Safety
December 3, 2014 and

FSMA: Biological Soil Amendments of Animal Origin

CompostThe newly revised proposed Produce Rule is drastically different than the original provisional rule. Growers are encouraged to comment on the changes, and respond to several questions that the FDA has about animal based compost requirements. Please consider commenting – comments are due by December 15, 2014.

In the previously published FSMA proposed Produce Rule, regulations for animal based composts required a wait period of nine months for raw manure applications (not composted or composted in a non-approved manner). The revised rule recognizes the need for additional research and risk assessments, and has withdrawn the 9-month interval between the application of raw manure and crop harvest. This rule will be amended once sufficient research has been conducted and evaluated. The FDA has stated that “At this time, the FDA does not intend to take exception to farmers complying with the USDA’s National Organic Program standards, which call for a 120-day interval between the application of raw manure for crops in contact with the soil and 90 days for crops not in contact with the soil.” The 45-day interval between application of compost and crop harvest, specific to previously specified composting methods, has also been withdrawn.

The FDA is seeking comments on requiring the adherence to the NOP 120-day interval standards, the prevalence of animal based manures in composts, and information on barriers that will be faced for farms transitioning from raw animal manure use to only composted animal manures.

Filed Under: Food Safety