As the shortened days and long nights of winter begin to lighten, organic producers are spending time with family, poring over seed catalogs, considering cropping plans, and maybe even scouting for new ground. While not at the top of the list of things to do, some producers are using the slow winter months to prepare for the Food and Drug Administration’s (FDA) Food Safety Modernization Act (FSMA) requirements, including obtaining mandatory trainings for key staff, understanding compliance dates, and potentially preparing for buyer-required third party food safety audits.
The FSMA Produce Safety Rule, written for producers of crops generally eaten fresh, lumps farms into three tiers with corresponding compliance dates. This coming year is significant because the last group of growers (very small businesses averaging >$25k to $250k in annual produce sales over the last three years) are required to be in compliance by January 26, 2020.
If you only grow product(s) on FDA’s list of rarely consumed raw products (see www.fda.gov), if the products you grow are commercially processed using a verified “kill-step”, or if you average <$25k in gross annual produce sales, your operation is fully exempt from the FSMA Produce Safety rule. If you average <$500k in total food sales (not just produce, but also items such as milk, eggs, wheat, etc.) and you sell over 50 percent to qualified end users (such as direct sales to restaurants or retail stores located within 275 miles of your farm), then you are eligible for a “qualified exemption,” meaning only some of the FSMA rules apply. Ultimately, all growers should understand the requirements and take action to reduce food safety risks on the farm.
Training is the linchpin in a good food safety program, and growers who are required to comply with the FSMA produce safety rule must have at least one person on the farm who has taken the Produce Safety Alliance (PSA) training. Generally, these are subsidized, offered in English and Spanish, and being held regularly throughout the country. Visit the Produce Safety Alliance website at www.producesafetyalliance.cornell.edu for a list of upcoming trainings.
CCOF food safety certification staff have had a busy harvest season. We traveled to speak at the CCOF Pacific Southwest Chapter meeting in September, marched on Capitol Hill in Washington, D.C. to lobby for food safety certification cost share, attended the United Fresh Food Safety & Technology Council meetings to ensure organic voices were represented, and hosted a panel at the Organic Grower Summit on Organic Farming in the Era of FSMA.
CCOF’s food safety program offers competitive, GFSI benchmarked food safety certifications for farms and packinghouses. Often, we can combine your organic and food safety inspection. Contact our Director of Food Safety Jacob Guth at firstname.lastname@example.org for more information.