Farms of all sizes must now meet updated federal food safety regulations. Here’s what you need to know.
The nationwide recalls of fresh produce in recent years have stirred consumers’ fears and prompted tightening of regulations on farmers and food handlers. The FDA Food Safety Modernization Act (FSMA), signed into law in 2011, defined and provided for the enforcement of minimum safety standards for the production, processing, packaging, and transportation of food for humans and animals.
Beginning this year, all but the smallest farms are subject to the FSMA Final Rule on Produce Safety, which establishes new standards for the safe growing, harvesting, packing, and holding of fruits and vegetables for human consumption. Sections of the rule address use of agricultural water; biological soil amendments; domesticated and wild animal exposure; workers’ training, health, and hygiene; and equipment, tools, and buildings. Sprouts sold for fresh eating have a history of association with food-borne illness outbreaks, so they are subject to more stringent standards.
“Most of the requirements are pretty basic, commonsense food safety measures that will go a long way toward keeping you, your customers, and your employees healthy and happy,” says Kali Feiereisel, a food safety specialist with the Community Alliance with Family Farmers (CAFF), a California-based nonprofit that supports sustainable agriculture.
Some elements of the enforcement process will seem familiar to certified organic farmers—who are required to keep detailed records and be ready for inspectors to show up unannounced to evaluate their operations. “If you are certified organic, you are probably keeping most of the necessary records already,” Feiereisel says.
As of January 2019, farms with average annual fresh-produce sales of more than $250,000 (for the previous three years) are required to be in compliance with the standards outlined in the FSMA Final Rule on Produce Safety. By January 2020, only farms with average annual fresh-produce sales of $25,000 or less (for the previous three years) are exempt. You are required to be in full compliance unless you satisfactorily prove to your local inspector that you meet the exemption criteria in the produce safety final rule, says Ken Kimes, a greenhouse-based certified organic microgreens producer for over three decades and an outspoken sustainable food activist with extensive experience in on-farm food safety. “Unlike your friendly local extension advisor,” Kimes says, “[an inspector aims] to protect the public, not to help you, and don’t ever forget that.”
He offers these hints to help you ensure your operation meets the latest food safety standards.
Know the regulations
Print and read the official FSMA Final Rule on Produce Safety document. Highlight sections that apply to your farm, says Ken Kimes, a member of the Organic Farmers Association Policy Committee, and be ready to pull them out when inspectors show up. Then you can address questions about your specific operation with them. Search for “produce safety rule” at fda.gov.
Train the team
Your local extension office may be able to recommend food safety workshops for your labor force. You can also sign up for the courses offered by the Produce Safety Alliance at a variety of locations or watch recorded webinars by the Community Alliance with Family Farmers.
Preparing for, or even passing, an official Produce GAPs (Good Agricultural Practices) Food Safety Standard Audit is not a substitute for an inspection, Kimes says, “but it can be a helpful step in making sure you are ready for an inspection when it does happen.” Audit information worksheets and checklists are available here.
Clean up and organize all of your farm’s work and packing areas, and be certain you and your staff keep them looking neat, even (especially!) when your operation is in the midst of its busiest times. Any visible evidence of rodents—including areas where the pests could nest or hide—or clutter in general often attracts the attention of inspectors.
Maintain up-to-date records and store them where you can access them quickly. Inspectors have the right to arrive without prior warning and at any time during normal business hours. You want to be ready when they do.
Stay calm, courteous, and professional
“Inspectors are licensed and trained by the FDA, and they take food safety very seriously,” warns Kimes. “If they decide that any of your records are lacking, that even one of your products might be injurious to consumers, or anything doesn’t seem right, they can force a recall or shut you down for the duration of an investigation.”
Install an eyewash station
“Inspectors love to see the eyewash,” Kimes concludes.
This article originally ran in the fall 2019 issue of New Farm Magazine, the magazine of the Organic Farmers Association. All OFA members receive a complimentary issue of New Farm annually. Join today.