What’s The Latest News?
By now if you’re on our distribution list you’re probably well aware that the Food Safety Modernization Act includes multiple new regulations; most of which have recently been released, with two more on the way. You’re probably also aware that the Produce Safety rule and the Preventive Controls rule, which are expected to have the most significant impact on the food industry, both require specific, specially developed training for certain employees.
For those who fall under the Preventive Controls rule, the Food Safety Preventive Controls Alliance (FSPCA) has already made the official Preventive Controls rule training available, and DFA is offering sessions throughout this spring and summer. However for those who fall under the Produce Safety rule, which applies to farming operations, the official training isn’t yet available.
The Produce Safety Alliance (PSA) has been developing the course materials for the official Produce Safety training; however there have been delays as indicated in a recent release by the alliance:
“Although several options were considered, after much discussion it was decided that the PSA should delay all training until September 2016. It was suggested by the PSA Executive Committee members, that the PSA consider hosting several pilots before the September launch. This is a consideration we are taking seriously and if the curriculum is complete by late spring, we will proceed to do several pilots.”
As a result, DFA does not expect to be able to offer this training until sometime toward the end of 2016.
What Should I Be Doing Now to Prepare?
1. Determine how the rule applies to your operation
The FDA has release an excellent decision tree that you can use to help you determine how the new regulation applies to your operation. You can find it here: http://www.fda.gov/downloads/Food/GuidanceRegulation/FSMA/UCM472499.pdf
2. Identify key individuals responsible for compliance
As we’ve discussed above, farms will need to have trained individuals who are knowledgeable with regard to the regulation. Per FDA requirements:
“At least one supervisor or responsible party for your farm must have successfully completed food safety training at least equivalent to that received under the standardized curriculum recognized as adequate by the Food and Drug Administration (FDA).”
We strongly recommend that all operations rely on more than one person for this role, as redundancy will allow coverage for vacations, illnesses, or job changes. Once these individuals are identified, they should start understanding the basics of the regulation – which leads us to our next point.
3. Understand the basics
There are a number of sources of information you can turn to, to help you understand the regulation. Several of them are identified in point #5 below. However if you haven’t already reviewed a basic summary of the requirements of the regulation, the FDA has provided a very good synopsis here http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334114.htm.
4. Begin to document basic requirements
A great starting point as you follow the link above and begin to learn about the regulation, is to begin to develop simple written policies with regard to how some of the requirements apply to your operation. This is particularly true with the worker health & hygiene training requirements. It’s never too early to start building awareness and lay the foundation for future programs. You can always augment these later with additional details, but at least starting with some basics is a great idea.
5. Begin (or continue) testing your water source
If you aren’t already submitting your water to an accredited laboratory for analysis of generic E. Coli, we suggest that you begin doing that now on a periodic basis. The regulation requires that you collect a baseline of laboratory testing data so that you understand your water source, and are able to detect if an issue arises and manage it in a timely manner. If you need help with sampling and testing your water, you can contact our laboratory in Fresno at (559) 233-7249 or lab@safefoodalliance.com.
6. Watch for new information
The FDA does plan to release some guidance documents for the industry in the near future, and they will continue to update the public as more information is released. You can get more information and sign up for email updates from FDA regarding the Produce Safety rule (and more) at http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334114.htm
If you’re interested in getting updates on the Produce Safety Alliance activities you can visit their web page at www.producesafetyalliance.cornell.edu. Of course, DFA will continue to issue new information to you as it becomes available!
