FAQ: Food Safety Modernization Act (FSMA)

New NSAC Food Safety Modernization Act Resource:

Food Safety Training Requirements for Produce Farms

If my farm is fully subject to FSMA do I need to schedule an inspection?

No. If your farm does not qualify for any of the full or partial exemptions from FSMA than your farm is considered fully covered under the law. You do not sign up or register in this scenario. You are required to implement what the law requires you to do on your farm, but you do not register with the state department of agriculture. You also do not sign up for a FSMA inspection. There’s a small chance that the California Department of Food and Agriculture may randomly select your farm as a farm that they do a FSMA Inspection on. If that happens they will notify you before they show up for the inspection. You can not “sign up” for an inspection. Buyers can not require you to have a FSMA inspection done. Sometimes there is confusion about the difference between a food safety audit vs. food safety inspection. A food safety audit is often called a 3rd party food safety audit and is an in person audit at the farm that the grower elects to do on a voluntary basis. During an audit a grower gets a score based on the number of points they earn for their food safety practices on the farm. A FSMA Inspection is NOT a voluntary farm food safety inspection and is not something you can schedule. Rather, the California Department of Food and Agriculture will contact you to schedule a FSMA Inspection. A FSMA Inspection does not involve “points” and you do not get a score. Instead at the end you are either found in compliance with the law or non-compliance. If you are found in non-compliance you will have to make changes on your farm to get into compliance. Depending on the degree of non-compliance (ie if you have egregious problems on your farm) you may be banned from selling product until you make the changes.

Good Agricultural Practices (GAPs) Questions

What are GAPs (Good Agricultural Practices)?

Good Agricultural Practices, often referred to GAPs, are practical and voluntary practices that help minimize the risk of microbial, physical and chemical contamination of produce by understanding individual farm practices and the risks associated with such practices. GAPs focus on key areas of production and harvesting such as: Water, Manure/Compost, Animal Access (domestic & wildlife), Worker Health & Hygiene Training, Harvest Equipment, Tools & Containers and Land Use (including assessing potential risk from activities on adjacent property).

I am a small farmer and/or have been farming for many years/decades –we’ve never made anyone sick, why do I need to follow GAPs?

Pathogens can be found on any size farm, including new and old farms. It is essential to understand the risks on your operation and what can be done to minimize the potential risk of on-farm contamination.  Although we rarely hear about outbreaks linked to smaller growers there have been outbreaks, illnesses and deaths associated with the practices of small growers.

I’m certified organic. Do I still need a food safety / GAPs plan?

Yes, although some of the record keeping done with organic certification may help with GAPs or food safety record keeping, certified organic and food safety are two completely separate programs.

What are some common food safety related problems?

  • Employee Training
  • Traceability – specifically creating lot codes
  • Water Testing
  • Use of Sanitizer & Disinfectants for cleaning tools
  • Water Monitoring for fluming water used to wash produce

When testing agricultural water what do I need to test for and where do I go for testing?

Generic E.coli testing is all that is needed, as agricultural water standards use generic E.coli as an indicator organism to identify risk.

What do I need a potable water source for and what does “potable” mean when referring to washing?

Potable water means water that meets drinking water standards from a microbiological stand point, therefore it should be free of coliforms. This water is needed for the purposes of washing and ice making. Washing includes both product washing after harvest, and washing any food contact surfaces (ie. tools, totes, tables, etc. that come in direct contact with produce). Hand washing water must also be potable from a microbiological standpoint. Note: employees must have access to drinking water at all times.