June 18, 2024 , and

Getting Ready for Your Food Safety Audits

Scheduling USDA audits GAP, Harmonized or Harmonized Plus

Anyone who has not scheduled their audit needs to be aware of the documentation needed to be sent to the New Jersey Department of Agriculture prior to the audit.  They will want to see a copy of your food safety plan, proof of your food safety training, any current water tests, training records of all personnel, ten days of supporting records (for example – cleaning and sanitizing equipment, monitoring for wildlife, approved supplier list, etc.), mock recall and a self-audit.  Why do they want the records prior to the audit?  It saves time on their end plus it will save the grower money by them spending less time on the farm.

The audits can be scheduled in two ways either call the NJDA office at 856-839-3388 or go to fvinspection@ag.nj.gov .  There is a new request form so if you have an old form contact them for the new one.  The request should be at least two weeks prior to the audit.

Need for multiple audits.

Crops may be grouped together on the initial request to be included in the audit.  The audit needs to be scheduled so the auditor can see the distinct types of harvest activities.  For an asparagus and tomatoes example, if the asparagus is being harvested during the initial audit while the tomatoes are growing but won’t be ready for harvest until a later date, the initial audit can cover both commodities but an unannounced audit would be used by the auditor to observe the harvest of the tomatoes.  Also, the auditor will want to see all crops listed on the audit request form.

It is an option for the auditee to ask for commodities to be split on different audits.   To certify two audits that occur at separate times for different commodities the auditee would need to let the auditor know the intention for two audits in the season.  There would be a separate audit done, a certificate for each audit and a website posting for each audit.  The certification dates would be separate for each audit done.

USDA Audit Rates Increasing October 1, 2024

Anyone who is getting a GAP, Harmonized or Harmonized Plus Audit through the New Jersey Department of Agriculture will see the rates increase in October.  The basic hourly rate will increase from $155.00 to $163.00.  Those that are getting a Global Food Safety Initiative (GFSI) certification will have an additional $250.00 for each audit.

Filed Under: Food Safety, Fruit, Organic Production, vegetable, Vegetable Crops
March 7, 2024 and

USDA just released the new Harmonized GAP Standard and Harmonized Plus+ Standard Audits.

The standards go into effect May 1, 2024.

There are several changes related to section numbers and deleted numbers so if you have your audit plan setup by section number check to make sure they have not changed. Also, eight questions have been added.

Following is a summary of those questions:

  • G 2.4 – Approved service provider list required (the grower approves the list)
  • G 7.2 – A designated recall team is required
  • G 7.3 – Must perform a mock recall exercise annually
  • G 11.5 – Must have labels and instructions for any water treatment chemical used
  • G 11.8 – Compressed air or other gases contacting food or food contact surfaces must be maintained
  • F 6.3 – Must have a procedure for storing and handling growing media (e.g., perlite, peat, rock wool, etc.)
  • F 9.4 – Re-used water must be treated with a labeled product
  • P 5.2 – A master cleaning schedule with standard operating procedures (SOP) must be established ·

There are two documents for each audit: Harmonized GAP Standard (v 3.0) or Harmonized GAP Plus+ standard (v 5.0). Each also have a summary of changes document will be help finding the changes.

Go to:  Harmonized GAP | Agricultural Marketing Service (usda.gov) to download a copy of each standard.

Filed Under: Food Safety, Fruit, Organic Production, Vegetable Crops
February 29, 2024 and

Water Testing Requirements Under the Food Safety Modernization Act Produce Safety Rule for 2024

Does your farm fall under the FSMA: PSR? Find out at this link:   https://rutgers.ca1.qualtrics.com/jfe/form/SV_4IagP1mbPyrp42N.

The requirements for water management only apply to operations that are not exempt or qualified exempt. Check out the link above to determine whether you fall under an exemption category.

Note:  If you are third party audited (GA/GHP, Harmonized, Global GA, Primus, etc.) continue to follow the water testing requirements for your audit!

Harvest and Post-Harvest Water (including water used to wash hands, washing produce, ice making, hydrocooling, chemical application and for cleaning and sanitizing)

Water Test Requirements:

  • For Public Water: No test required, you need to have a copy of the report from the municipality.
  • For well water: You must test just wells used for harvest and post-harvest four times in the first year and then if there is no detectable generic E. coli on any tests you may test each well once per year after that initial year.
  • For surface water: Untreated surface water is not allowed to be used for harvest and post-harvest purposes.

Compliance Dates:

  • Large Growers (over $500,000): Currently in effect
  • Small Growers ($250,000-$500,000): Currently in effect
  • Very Small Growers ($25,000- $250,000): January 26, 2025

When complying a grower must inspect the agricultural water system that is under their control to determine any hazards. The water source test results must ensure that there is no detectable generic E. coli per 100 ml of water and untreated surface water cannot be used.

If a water test does not meet the criteria for non-detectable generic E. coli the farm must immediately stop using the water. The grower must take several steps before using the water including reinspecting the entire affected agricultural water system, under their control and make corrections or treat the water.

There are other required measures including having a water change schedule; visually monitoring the quality of water (for buildup of organic material) and monitoring the temperature of certain commodities.

The records required include the agricultural water system inspection; water test results; any water treatment; and corrective actions. Review Subpart E sections 112.41-112.48, 112.50, 112.151 and 112.161.

Pre-Harvest (Irrigation, Frost Protection, Sprays) Water

There is some confusion as to whether growers need to test their water for pre-harvest uses in 2024. The pre-harvest irrigation water requirement is still under review by the Food and Drug Administration, so testing is not required in 2024.

What we suggest you do now:

  • For well water: Test once a year
  • For surface water: Test three times a year. (when the pump is started, mid-season and close to harvest.)

This will give the grower a baseline as to the quality of water being used. When the final rule goes into effect the largest growers (over $500,000) will have nine months; small growers ($250,000-500,000) will have 1 year, and nine months and the very small growers ($25,000-250,000) will have two years and nine months to start complying.

Source:  The On-Farm Food Safety Team (Meredith Melendez, Jennifer Matthews and Wesley Kline)

 

Filed Under: Food Safety, Fruit, Vegetable Crops
December 6, 2023 and

FDA Releases New Tools for the Food Traceability Rule Under Food Safety Modernization Act

On November 30 the Food and Drug Administration rolled out new tools and FAQs that will continue to inform stakeholders about the Food Traceability Rule and help covered entities come into compliance.  The rule is a key component of Section 204(d) of the FDA Food Safety Modernization Act (FSMA). This final rule was issued in November 2022 and will cover most growers who sell fresh fruits and vegetables.

The Food Traceability Rule is designed to facilitate faster identification and rapid removal of potentially contaminated food from the market, resulting in fewer foodborne illnesses and deaths. Foods subject to the final rule’s requirements appear on the Food Traceability List (FTL).

Featured in this update are the following:

  • New webpage about traceability lot codes, including examples of how Key Data Elements (KDEs) could appear on invoices and bills of lading.
  • Video highlighting some technological components of product tracing systems.
  • Examples of a traceability plan
  • New Frequently Asked Questions (FAQs)
  • New supply chain examples for deli salads
  • Information on how to apply for a waiver or exemption, if eligible

These featured tools are accessible from the FDA’s traceability webpage, along with:

  • Supply chain examples for different commodities
  • Fact sheets
  • Guide to Getting Started with the Food Traceability Rule
  • Translations of the codified portion of the rule as well as many of the supporting materials and tools
  • Interactive tool that explains Critical Tracking Events and Key Data Elements
  • Interactive tool that identifies partial and full exemptions to the rule
  • FAQs

The compliance date for all persons subject to the Food Traceability Rule is January 20, 2026. In September, FDA announced that routine inspections under the Food Traceability Rule will not begin until 2027, to give covered entities additional time to work together and ensure that traceability information is being maintained and shared within supply chains per the requirements of the rule.

Filed Under: Commercial Ag Updates, Food Safety, Fruit, Vegetable Crops
September 29, 2023

Use soil amendments of animal origin on your produce farm? Tell us about it!

If you use biological soil amendments (raw, composted, or processed) of animal origin on your fresh produce farm we would like to know more about it through this anonymous survey. Information provided will be used to inform extension educators and influence research and educational outreach nationally.

Poster of biological soil amendments of animal of origin

Filed Under: Food Safety, Fruit, Vegetable Crops
August 18, 2023

FSMA PSR Qualified Exempt? Keep Up with Your Paperwork!

If your farm is considered qualified exempt from the FSMA Produce Safety Rule you have probably needed to provide paperwork to the NJDA at least once.  Farms should be reviewing and updating their documentation that proves qualified exemption status annually and be prepared to show this again to the NJDA when required. Guidance and template forms are available online. Need a refresher on what a qualified exemption is? See below!

Under the FDA Food Safety Modernization Act (FSMA) Produce Safety Rule, farms are eligible for a qualified exemption and associated modified requirements if they meet certain criteria:

The farm’s food sales averaged less than $610,182 (adjusted for inflation) per year during 2020-2022; and
The average value of the farm’s sales to qualified end-users exceeded the average value of the farm’s sales to all others during the previous three years. A qualified end-user is either (a) the consumer of the food or (b) a restaurant or retail food establishment that is located in the same state or the same Indian reservation as the farm or not more than 275 miles away.
Because of COVID-19, state and local governments across the United States had instituted public health orders that resulted in many restaurants and retail food establishments either closing or significantly limiting their operations, leaving many farmers without their usual buyers during the 2020-2022 period. The guidance intends to allow affected farmers to shift their sales away from qualified end-users while still being considered eligible for the qualified exemption. Specifically, under the temporary policy announced in the guidance, farms that are currently eligible for the qualified exemption and associated modified requirements will still be considered eligible, even if they shift sales away from qualified end-users, so long as they continue to meet the requirement that their average food sales during the previous three years total less than $610,182 (adjusted for inflation). This temporary policy is intended to remain in effect only for the duration of the public health emergency, after which the FDA intends to issue additional guidance.

Qualified exempt farms must comply with modified requirements under the Produce Safety Rule, which include establishing and keeping certain records and prominently displaying their name and business address on food packaging or at the point of sale. Farms are responsible for ensuring that the food they produce is not adulterated under the Federal Food, Drug, and Cosmetic Act (FD&C Act) and they should use good agricultural practices to ensure the safety of their produce.

Filed Under: Food Safety, Fruit, Vegetable Crops