Progress on Produce Safety Rule Alignment
This is an important time in the world of produce food safety. On January 26, 2018, just a little over two months from now – most produce growers will be required to be in compliance with the federal government’s new Produce Safety Rule (PSR). Luckily, growers who are already following the LGMA’s Metrics are well positioned to meet these requirements, and we are working to make sure that compliance with the LGMA equals compliance with the produce rule.
When is Produce Safety Rule Compliance Required?
The deadline for compliance with the Food Safety Modernization Act (FSMA)’s Produce Safety Rule is quickly approaching. Farms who are considered large (most of those in the California leafy greens business) must be in compliance with the Produce Safety Rule on January 26, 2018.
When will Produce Safety Rule inspections begin?
The FDA has announced that no enforcement inspections will take place until 2019. The agency plans to spend the 2018 year focused on education, training, and outreach.
It is important, however, to understand that even though routine inspections will not begin until 2019, the FDA does expect growers to be in compliance as of January 26, 2018. If the agency has a reason to come onto a farm “for cause” in 2018, it will expect that farm to be in compliance with the Produce Safety Rule.
A Little More Time for Water Requirements
FDA has postponed compliance with the water section of the Produce Safety Rule for two years. Therefore, large growers must be in compliance with that portion of the PSR by January of 2020 (with two additional years to complete the required water testing).
LGMA Metrics align with FSMA Produce Safety Rule
In August, the California and Arizona LGMAs updated their Metrics (Food Safety Practices) in order to align with the FSMA Produce Safety Rule. These changes were made following a lengthy process of review led by Western Growers and after several discussions with the FDA’s subject matter experts. While our Metrics go above and beyond what the federal rules require in most cases, there were also some gaps that we needed to fill.
What changes have been made to the Metrics?
You can find the updated Metrics here, with the changes highlighted. Here is a brief review of the changes made:
There were no changes to these sections of the Metrics: Purpose, General Requirements, Environmental Assessments, Flooding, Production Locations, Soil Fertility
Some changes were made to the Introduction and Scope, and to the sections on Harvest Personnel and Animal Encroachment. For the most part, these changes are considered fairly minor in nature.
Along with adding several terms to the Glossary, some changes were adopted to the standards related to Soil Amendments and Buildings/Materials.
Finally, some new sections were added to the LGMA Metrics. In the areas of Documentation and Training, while the Metrics already included several requirements in these areas, the more prescriptive and thorough language from the PSR was adopted. And a new section was added covering transportation of product (from the field to the cooler).
When will the changes go into effect?
In California, the new Metrics will be part of the LGMA audit starting on April 1, 2018. On that date, which coincides with the start of our next fiscal year, we will begin to officially include new questions in the audit related to the accepted changes. We are working on several projects related to these changes:
Updating the Audit Checklist & Auditors
The LGMA’s audit checklist is being updated in conjunction with the AZ LGMA. Once it has approved for use by USDA, we will circulate the checklist to the industry for review and preparation. We will discuss the changes thoroughly with the CDFA and USDA auditors, so that we understand how the new questions will be interpreted, what documentation will be needed and what kinds of corrective actions will be required and accepted.
LGMA Workshops on New Metrics
A series of webinars and workshops have been set up to educate industry, answer questions and prepare growers and handlers for the new questions prior to the start of the new fiscal year. LGMA members and their growers are encouraged to register to attend.