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.
May 20, 2017
USDA Audits and Inspections Rates to Increase
May 8, 2017
Difference between a third party audit and the Food Safety Modernization Act (FSMA)
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
| Farm Size | Compliance Dates | Water Compliance Dates 1,2 | Labeling Dates for Qualified Exemption 3 | Compliance Date for Retention of Records to Support Qualified Exemption |
| >$500,000 | 1/26/18 | 1/27/20 | ||
| $250 – 500K4 | 1/28/19 | 1/26/21 | 1/1/20 | 1/26/16 |
| $25-250K5 | 1/27/20 | 1/26/22 | 1/1/20 | 1/26/16 |
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.
May 5, 2017
Water testing requirements under the Food safety Modernization Act (FSMA)
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
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
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
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…]
