Comments on the revisions made to the produce safety rule are due on December 15th. Regular posts will be made to the Plant and Pest Advisory focusing on the changes that have been made. Please consider commenting on the produce rule!
The way that the FDA defines “farm” is important in determining what types of production activities would qualify a farm to comply with additional regulations, specifically the Preventive Controls FSMA rule. Compliance with the Preventive Controls rule would require a Hazard Analysis Critical Control Point plan. The revisions regarding these definitions are now much more specific and offer broader exemption of certain farm activities from the Preventive Controls rule. Previously a “farm” would have been required to register as a food facility and comply with the Preventive Controls rule if it packed or held raw agricultural commodities grown on another farm. Packing and holding are now considered normal farm activities and would not, in most cases, require a farm to comply with the Preventive Controls rule. Additionally, gathering, washing, trimming of outer leaves of, removing stems and husks from, sifting, filtering, threshing, shelling and cooling of raw agricultural products are examples of harvesting and are also exempt from the Preventive Controls rule. The transformation of a raw agricultural commodity into a processed food would be still be subject to the Preventive Controls rule.
