The Produce Safety Rule under the Food Safety Modernization Act is now fully implemented.  This means that one person from an operation who sells over $25,000 in fresh produce needs to attend a training course.  There are some exemptions and modifications to the rule, but the best way to find out is to attend the course.  We will have the next online training September 15 and 16 if 10 people register by September 1.  The preregistration is required since training material must be sent to each participant prior to the training.  Visit our website to register.

Produce Safety Training:

The Produce Safety Alliance Grower Training Course is one way to satisfy the FSMA Produce Safety Rule requirement outlined in § 112.22(c) that requires ‘At least one supervisor or responsible party for your farm must have successfully completed food safety training at least equivalent to that received under the standardized curriculum recognized as adequate by the Food and Drug Administration’.  This is the only training recognized by the FDA at this time!

Fruit and vegetables growers and others interested in learning about produce safety, the Food Safety Modernization Act (FSMA) Produce Safety Rule, Good Agricultural Practices (GAPs) and co-management of natural resources and food safety should also attend this training.

What to Expect at the PSA Grower Training Course?

This is approximately a seven-hour course to cover these seven modules:

• Introduction to Produce Safety
• Worker Health, Hygiene, and Training
• Soil Amendments
• Wildlife, Domesticated Animals, and Land Use
• Agricultural Water (Part I: Production Water; Part II: Postharvest Water)
• Postharvest Handling and Sanitation
• How to Develop a Farm Food Safety Plan

In addition to learning about produce safety best practices, parts of the FSMA Produce Safety Rule requirements are outlined within each module and are included in the grower manual provided.  There is time for questions and discussion, so participants are encouraged to share their experiences and produce safety questions.

Benefits of Attending the Course

The course provides a foundation of Good Agricultural Practices (GAPs) and co-management information, FSMA Produce Safety Rule requirements, and details on how to develop a farm food safety plan.  Individuals who participate in this course are expected to gain a basic understanding of:

• Microorganisms relevant to produce safety and where they may be found on the farm
• How to identify microbial risks, practices that reduce risks, and how to begin implementing produce safety practices on the farm
• Parts of a farm food safety plan and how to begin writing one
• Requirements in the FSMA Produce Safety Rule and how to meet them.

After attending the entire course, participants will be eligible to receive a certificate from the Association of Food and Drug Officials (AFDO) that verifies they have completed the training course.  To receive an AFDO certificate, a participant must be present for the entire training and submit the appropriate paperwork to the trainers at the end of the course.

Inspections:

The New Jersey Department of Agriculture (NJDA) began inspections for the U.S. Food and Drug Administration (FDA) for operations over $500,000.  The other size operations will also be delayed by one year i.e. 2020 for small operations and 2021 for very small operations.  The first inspections will be educational with the NJDA evaluating the farming operation.  This will give the grower an opportunity to see what the NJDA considers area where improvement may be needed.  After the inspection NJDA may do another inspection with possible enforcement in the future.

We continue to get questions about what signage is required for an audit or the Produce Safety Rule and where to get them.  Not all the signs listed below are, but handwashing and visitor signs need to be posted in English and in the language of the workers.  For example, if you have a mixture of Spanish and Creole speakers, you will need signs in three languages.

The signs and posters listed below are available at the following locations – Rutgers Cooperative Extension office in Cumberland County (291 Morton Ave., Millville Tel. 856-451-2800 x 1) or Rutgers Cooperative Extension office in Mercer County (1440 Parkside Ave., Ewing, NJ 08638 Tel. 609-989-6830). If you would like any of the signs, please call the office to schedule a pick-up.

Please Wash Your Hands Often! (8.5x11inches) – English, Spanish, Creole, Chinese, Greek, Polish, Portuguese, Russian and Vietnamese.

Please Put Used Toilet Paper in the Toilet (8.5×11 inches) – English and Spanish

Please Use Toilets Provided in the Field (8.5×11 inches) – English and Spanish

When Must Hands Be Washed (8.5×11 and 21.5×27.5 inches) – English and Spanish

Health and Safety Notice for Visitors (21.5×27.5 inches) – English and Spanish

Cleaning and Sanitizing Food Contact Surfaces (21.5×27.5 inches) – English and Spanish

Service Animals Covered by the ADA are Welcome Here (8.5×11 and 21.5×27.5 inches) – English and Spanish

Many of these signs can also be downloaded from our revised website onfarmfoodsafety.rutgers.edu starting July 1^st.

We have been watching as the state executive orders continue to roll out and how this impacts the agricultural community.  The two key take-aways for farms this season are:

1. Ensure that your customer capacity limits allow for 6′ of social distancing
2. Communicate to customers that masks will be required when indoors and when social distancing isn’t possible out of doors

Guidance documents have been updated on the following topics 
U-Pick Operation Guidelines under COVID-19
RCE Wholesale Grower Questions
Best Practices for Direct Market Sales
Complying with NJ Executive Orders – Pick Your Own

The Rutgers On-Farm Food Safety Team now has a COVID-19 Information For the Agricultural Industry webpage where these updated documents are housed, along with other COVID resources and vaccine information including printable posters in multiple languages.

Before scheduling an audit review the standards to understand what is required.  Go to https://www.ams.usda.gov/services/auditing/gap-ghp/harmonized and download the latest versions dated February 8, 2021.  There have been changes since the 2018 version so review carefully.  Compare the new version with your written food safety plan and make the necessary changes.  If you need technical assistance or want to discuss parts of the audit email “Ask the Experts” at onfarmfoodsafety@njaes.rutgers.edu.  The on-farm food safety team can be contacted at the same address to schedule a walkthrough to assess your readiness for an audit if requested.

Once the food safety plan is complete and you are ready for an audit email fvinspection@ag.nj.gov to schedule the audit.  You will receive an agreement to review and check which audit and audit sections you want audited.  You will be asked to send certain documents for review prior to the on-site audit.  This reduces the amount of time the auditors are on the farm for Covid considerations.  The auditors want to see at least 10 days of records prior to the audit.

Again, this year the Harmonized and Harmonized Plus+ audits in New Jersey will be reimbursed 100% through the USDA Risk Management Agency.  Once the audit is finalized, USDA will generate a bill to the auditee which summarizes the cost breakdown of the audit, and then showing a credit for that same amount. A note will be added to the bill stating, “Cost of your 2021 USDA Harmonized GAP Audit covered by a bill credit made possible through a grant from the USDA Risk Management Agency Agricultural Management Assistance Program”.  For more details and frequently ask questions visit the AMS website mentioned above and look under resources.

Once the audit is complete it will be reviewed by USDA personnel and a certificate will be sent to the grower.  Also, the farm name, address, date and commodities audited will be posted on the USDA AMS website.

This is the time of year when growers start to think about scheduling there USDA Harmonized and Harmonized Plus+ Audits.  There have been changes to both audits which take affect May 1.  Growers should download the latest versions from https://www.ams.usda.gov/services/auditing/gap-ghp/harmonized.  The Harmonized Audit is version 2 dated February 8, 2021 and the Harmonized Plus+ with the same date is version 3.  If anyone is still getting the GAP/GHP audits there are no changes.

There are changes to both the Harmonized and Harmonized Plus+.  New questions for the Harmonized Audit include:  G-8.2, G-10.7, G-12.1, G-12.2, P-3.1, P-8.2 and P-8.4.  Amended questions include: G-3.2, G-10.1, G-10.3, G-10.6, G-10.8, G-10.10, G-10.12, G-10.16 and G-10.19.  All of these apply to the Harmonized Plus+ in addition to four new questions:  F-8.2.c, P-6.5.a, P-3.1.a and P-9.4.a.  Two questions were also amended:  G2.2.2 and G-6.1.a.

Other than the new questions which must be reviewed and addressed in the food safety plan there are certain things audits will be stressing this year.  One is G-3.2 related to documentation and protection of those documents.  Documents must be maintained for two years and be available for review.  The one document which has not been assessed in the past is the portable toilet record.  This year they will be checking for it.  There are two ways growers can comply.  First make sure the starting and ending dates are on your contract for the portable toilets.  Also, take a picture of the log inside the toilet door at least at the end of the season.  It may make sense to do it mid-season and at the end.  Maintain those photos with your other documents.

The second is F-8.2 related to cleaning and sanitizing equipment, vehicles, tools and utensils and their storage.  There needs to be a schedule for those activities and records must include the date and method of cleaning and sanitizing.  One thing that gets overlooked at times are knives for field harvesting of vegetables and herbs.  These must be included, and the auditors will be looking for the logs this year.

Example templates are being updated on the Food Safety website https://onfarmfoodsafety.rutgers.edu/ that will include most of what would be needed for an audit.  These can be modified to fit any operation.