Adhering to Good Agricultural Practices has always been key to growing a successful agricultural business. In the past, voluntary FDA guidance documents provided a general idea of what to do in order to minimize risks throughout the production process. However, in 2011 the Food Safety Modernization Act (FSMA) brought about the most significant changes to U.S. food safety laws in more than 70 years. One of the seven major overarching rules under FSMA is the rule on Standards for the Growing Harvesting, Packing and Holding of Produce for Human Consumption, better known as the Produce Safety Rule. The Produce Rule applies to farms engaged in the growing, harvesting, packing, or holding of raw agricultural commodities (fruits, vegetables) for human consumption. This rule is the first mandatory federal law requiring growers to adhere to specific science-based standards to grow and pack products for human consumption. While the law came into effect on January 26, 2016, the FDA understood there needed to be time allotted for the industry to comply. The Produce Safety Rule compliance dates vary on the size of the facility—very small farms were given four years to comply, small farms were given three, and larger companies were given two. Additionally, the Produce Safety Rule offered additional time for monitoring the agricultural water quality requirements as this is a complex area and one which FDA anticipated the need for training and education within the growing community. Commercial farms with average annual produce sales of at least $25,000 are covered under this rule.
There are; however, qualified exemptions to the rule. Commodities, such as beans or potatoes, which are rarely consumed raw would not fall under the Produce Safety Rule, nor does produce that is grown either for personal consumption or consumption on the farm. The FDA has created a Produce Safety Rule decision tree that can help determine if your farm needs to be compliant or is eligible for a qualified exemption.
It is important to note that the Produce Safety Rule is derived from Good Agricultural Practices or GAPs and the principals FDA first laid out two decades ago. The Essentials of Produce safety course aimed at produce managers and supervisors across the supply chain reviews GAPs in detail and traces their evolution into what we recognize today as the Produce Safety Rule. One example of this approach might worker health, hygiene and training from subparts C and D in Good Agricultural Practices guidance and its prominent role in the Produce Rule and then in the revision of Good Manufacturing Practices (GMPs) included within the Preventive Controls Rule which covers manufactured products. We are all familiar with the FSMA requirements to have Produce Rule or Preventive Controls Rule-specific training for a designated individual depending on what type of operation you have, but we also know that it is essential that field or line workers receive training not only when they are hired, but in regular increments afterward. Similarly, we recognize the need to educate supervisors and managers overseeing our daily produce safety activities, so they not only understand what needs to be done, but why it is being done. Experience demonstrates that when employees understand why a task is important, they are more likely to own the responsibility for getting it done and done properly. Therefore, it is important to offer training in language the workers customarily speak and outline learning outcomes to inform them of sources of foodborne pathogens, routes of contamination, preventive measures, and corrective actions. Highlight the importance of good hygiene and how to recognize the symptoms of an illness that might cause contamination. Inform employees of sanitation procedures for food contact surfaces, tools, and equipment, as well. By instructing and reinforcing the best sanitation and hygiene practices, other aspects of FSMA and specifically the Produce Safety Rule will fall into place.
Learning is always essential to protecting your products and your company. Alchemy Academy offers exclusive content from the Produce Marketing Association that is complimentary to the FDA’s produce safety training curriculum and provides not only what needs to be done, but why it is important and offers insights on how best to not only be compliant with the FSMA rules, but also best protect your company, your customers and your employees from the disruption of a produce safety illness outbreak. In Essentials of Produce Safety, individuals will learn how to better identify and manage produce safety risks within their operation and more. Get started with PMA’s exclusive online course today!