FSMA Produce Safety Rule Now Final

CompostThe FDA Food Safety Modernization Act (FSMA) Produce Safety rule is now final, and the earliest compliance dates for some farms begin one year after the effective date of the final rule (see “Compliance Dates” below). The rule establishes, for the first time, science-based minimum standards for the safe growing, harvesting, packing, and holding of fruits and vegetables grown for human consumption. The FDA has created a factsheet highlighting the produce safety rule.

This rule was first proposed in January 2013. In response to input received during the comment period and during numerous public engagements that included public meetings, webinars, listening sessions, and visits to farms across the country, the FDA issued a supplemental notice of proposed rulemaking in September 2014. The proposed revisions were designed to make the originally proposed rule more practical, flexible, and effective.

The final rule is a combination of the original proposal and revisions outlined in the supplemental proposal, with additional changes as appropriate. The definition of “farm” and related terms were revised in the final Preventive Controls for Human Food rule, and the same definitions of those terms are used in this rule to establish produce safety standards. Operations whose only activities are within the farm definition are not required to register with FDA as food facilities and thus are not subject to the preventive controls regulations.
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On Farm Food Safety Winter Trainings Announced

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On-farm food safety trainings will be held this winter throughout the state.  Certificate based third party audit trainings will be offered in Rosenhayn and Chatsworth.   Three additional trainings, located in Atlantic City, Trenton and Pittstown, will offer the required curriculum for compliance with the Food Safety Modernization Act.  More information on who will need to comply with FSMA to be published soon, as the final rule was just released and we are working to understand its implications for NJ produce growers.

Registration is required for attendance at these trainings!

Audit Ready: Sanitizing Surfaces in Post Harvest

sanitation product contact surfacesSanitizing product contact surfaces is important in reducing cross contamination risks.  “Product contact surfaces” means anything that comes in contact with the product such as equipment, belts, rollers, brushes, tables, bins, sinks, tools, and reusable totes.  Writing a standard operating procedure describing the specific steps of your cleaning process will help ensure that the surfaces are properly cleaned.

Proper cleaning and sanitizing of contact surfaces includes these steps:

  1. Surface is rinsed to remove any visible debris
  2. Appropriate detergent is applied and the surface is scrubbed
  3. The surface is rinsed with water that is potable (drinkable)
  4. Appropriate sanitizer is applied, following the directions
  5. Let the surface air dry

An appropriate sanitizer for use in post harvest surface cleaning is one that has an EPA registration number, states that it is food grade, and gives specific instructions for the products use as a surface cleaner.  Remember the label is the law.

Audit Ready: Equipment Maintenance Records

tractorThe harmonized audit requires a listing of equipment (2.7.1) that has the potential to come into contact with the crop, and for each piece of equipment a maintenance record.
Just how detailed of a record do they want?

Anytime there is a repair, cleaning, or fluid change there should be a record of this task.  The auditor will look at the equipment for signs that there could be a issue, such as an oil or fluid leak under the equipment.  If they see an issue they will then ask to see the maintenance record for that piece of equipment.  This falls under the “are in good repair and are not a source of contamination of produce” section of standard 2.7.2.  Remember, this is only for equipment that will go out into the field or production area.

Audit Ready: Handling Unwritten Policies

Writing Your PlanIn both the GAPs and Harmonized audits there are standards that focus on policies, yet the checklist does not indicate that a written policy is required.

You can choose to not write these policies in your plan but you and your employees need to be prepared to answer questions from the auditor about these policies.  Your answer to the auditor needs to be the same as your employees; they will verify this!

If the auditor does not find the policy or the employee answer satisfactory, you will receive a “CAN” (corrective action needed).

Audit Ready: 10 Tips to Help You Prepare

Birds in the rafters1. Auditors will most likely look at aerial maps of the farm prior to their visit.  They may ask about water sources, buildings etc. that they see on the online map that you might not have included in your production area maps.  Take a look at your farm on google maps to make sure you included everything required.

2. Auditors will not tell you how to fix a problem but can prompt you to solve a problem by asking questions about what they are seeing.

3. If you contract pesticide applications out to a third party you will need to have these spray records on hand during the USDA audit.  Ideally growers should have a copy of these spray records on farm, regardless of an audit. [Read more…]