Do not forget to include your cleaning procedures for irrigation water tanks and pesticide application tanks in your food safety plan.  Auditors will be looking for this information during the audit process.  The cleaning and maintenance of these tanks falls under standard 2.8 Vehicles, Equipment, Tools and Utensils.  Auditors will look for the following:

1. Equipment and other items or materials used in farming operations that may come in contact with produce are identified
2. Equipment is in good repair and pose no food safety risk
3. Cleaning and sanitizing procedures do not pose a risk of product contamination
4. Tanks are cleaned at a sufficient frequency so as not to be a source of contamination

Traceability, which we often talk about as one step forward and one step backwards, is an important part of your food safety plan.  Expect the auditor to spend time discussing and looking at examples of your traceability program.  Here is what should be included in your traceability program:

One step forward:

1. Reconciliation of product that has been delivered to recipients.  This includes auction houses, co-op’s, repackers, retail establishments, etc.

 One step backward:
1. If the produce was grown at the farm
– Seed source or transplant source (this should also be indicated on your raw materials supplier list)
– Pesticide applications
– Fertilizer applications
– Field location
– Soil amendments

2. If the produce was purchased and not grown at the farm
– Source of the produce
– Source of raw materials and supplies used with this produce
– Items and date of receipt
– Lot numbers, quantities, and transporter

Mock trace back:
A trace back and trace forward exercise is required annually to verify that your traceability program is effective.  100% of product involved in the trace back and trace forward exercise must be reconciled within four hours to be considered effective.  If there are no records of this mock trace back exercise the auditor will require it be completed during the audit.

Click for a sample mock tract back log.

Growers who schedule a USDA GAP or Harmonized audit this year should be prepared for an unannounced verification visit later in the growing season. 

These unannounced visits have been talked about during our educational sessions, but have mostly not happened due to a lack of auditors in the state.  The NJ Department of Agriculture Commodity Inspection and Grading Division now has enough staff to conduct these unannounced visits.

Unannounced visits will take place after the initial scheduled audit is completed.  These visits are used to verify that the farm is consistent with the written requirements of the food safety plan and the USDA audit requirements.  You cannot schedule these visits and you will not know specifically when the auditor will arrive to perform the audit.  The auditor may ask to see documentation during this visit, but will mostly focus on conformance to audit standards and your food safety plan through visual inspection.

Third party audits can be stressful for everyone at the farm.  Farm management and employees need to think about how they will react should something not go as planned during the audit.  Growers need to understand that the auditor will allow for some corrective actions to take place during the audit, if they are reasonable and if they show the food safety plan in action.

For example:  An employee exits the bathroom and does not wash their hands.  The auditor would expect the supervisor to tell the employee to wash their hands before returning to work.   If there is a situation that occurs during the audit that can be easily remedied every opportunity should be taken to do so.  If the auditor deems a situation as “Immediate Action Required” the audit will end without an opportunity to resolve the issue during that visit.  Additionally auditors will not give guidance on how to remedy a corrective action or an immediate action required, they will refer you to the Rutgers On Farm Food Safety team for information.

Want to better understand how the Food Safety Modernization Act (FSMA) will impact your farm?  On Monday, March 23rd the New Jersey and Delaware Departments of Agriculture will host an informative meeting at the Rutgers EcoComplex.

Monday, March 23, 2015 9:15 a.m. to 3:00 p.m.
Rutgers EcoComplex, 1200 Florence-Columbus Road, Columbus
RSVP: Jeff Beach Jeffrey.beach@ag.state.nj.us or 609-439-2038