Whether you’re a grower; you purchase from a grower; or you provide a service to growers, it’s time to ask yourself the question: Are you ready for compliance with the FDA’s Produce Safety Rule as part of the Food Safety Modernization Act (FSMA)?
As we always tell people, training is the first step – you must understand before you can comply. We are very proud to be one of the first organizations in California qualified to conduct the official, FDA-approved Produce Safety training, and we’re doing our best to make it available to our business partners. With few training providers available, and the first compliance dates arriving quickly (January 2018), here are new updates that may help your understanding of the requirements.
First, for those unfamiliar with FSMA rules, we highly recommend watching a short video by FDA, as it does a great job of explaining the set of rules referred to as FSMA. It’s also a good way to introduce your team to FSMA and what it’s all about.
FDA’s Recognized Produce Safety Training
So, what’s the training all about? First, it’s important to note that the training meets a key requirement in the regulation:
“At least one supervisor or responsible party for your farm must have successfully
completed food safety training at least equivalent to that received under standardized curriculum recognized as adequate by the Food and Drug Administration.”(112.22(b)(3)(c)
The training we’re offering is this recognized curriculum, and is managed through the “Produce Safety Alliance” that was set up by FDA.
Here’s an overview of what the training covers:
- Introduction to Produce Safety
- Worker Health, Hygiene, and Training
- Soil Amendments
- Wildlife, Domesticated Animals, Land Use
- Agricultural Water – Part 1: Production Water
- Agricultural Water – Part 2: Postharvest Water
- Postharvest Handling and Sanitation
- How to Develop a Farm Food Safety Plan
Some Important New Developments – Take Note!
There are key areas of the regulation that have been contested by the agricultural industry and its representatives, so FDA is currently re-assessing some of them to determine if modifications are appropriate. FDA is meeting with industry members to continue collecting feedback as part of this process, including Safe Food Alliance staff who was recently part of a coalition meeting with members of FDA, the Almond Board of California, the California Walnut Board, and others. This provided an opportunity to give valuable input about how the rule can better meet industry needs.
Water testing is the section of the rule for which the most concerns have been raised by the grower community. Although the amount of testing for surface water is a concern for some, the main concern shared by everyone is the requirement that method 1603 be used, as it is not widely available and is very restricting.
A colloquium was held this April by the Center For Produce Safety which included academics, members of industry, and a technical advisory group that included members of regulatory bodies.
Subsequently, a set of recommendations were made for possible changes to the water testing requirements to make them more reasonable for industry to implement.
Following that, in June FDA announced that it will be further extending the compliance dates for water testing to allow for additional consideration. Originally the first compliance dates were set for January 2020, separate from the general compliance dates for the regulation, which start in January 2018 as mentioned above.
As new developments continue to emerge, look for further information in upcoming newsletters. For upcoming training, including the approved Produce Safety Course, go to safefoodalliance.com/events.
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