SMALL FARM FSMA SERIES – POST 4 of 4
Author: Stepheni Norton, Regional Food Safety Specialist
FSMA is serious business, so we have a few disclaimers before we dig in.
- Advice provided here is general in good farm practice and meant for ALL FARMS
- Although tools are mentioned here, CAFF does not endorse or recommend any specific platform.
BUILD FOR COMPLIANCE
Regardless of your size or farm status, here are some built for compliance best practices that you can implement any time.
Training
Requirement: you must establish and document training for paid and unpaid workers.
Interval: upon hiring, and periodically thereafter, at least once annually
Required Topics:
- Principles of food hygiene and food safety
- importance of health and personal hygiene
- Contaminated produce
- Inspecting harvest containers and equipment
- Correcting harvest containers and equipment problem
- PSA Growers training 112.22 (c) – supervisor only, does not expire
Record Must Include:
- Name of your farm
- Location of your farm
- Date of training
- Topics covered (attach training materials)
- The names of persons trained
- Be signed and dated by the trainee and trainer
Built for Compliance: FSMA § 112.22
Training Material Tip: CCE Cornell Vegetable Program has a set of free worker training videos. Videos 2-4 cover the required topics. Use them for your training main material, then provide a farm specific work instruction.
Record Keeping Tip: Use a tool like Asana. You can create a Training task with links to the training material. Trainee can log into Asana, take the training and mark the training as complete. Make sure the trainee logs in with their own account, to save the completion action as a training record.
Farm Made Soil Amendments of Animal Origin 21 CFR Part 112.60 (b)(2)
Requirement: for compost you make on farm, you must document process controls for biological soil amendment of animal origin to ensure time, temperature, and turnings) were achieved as defined in 112.54 (b)
Record Interval: at start, as turned, at finished
Record Must Include:
- Name of your farm
- Location of your farm
- Pile Identifier (locations, number, etc)
- Type of Compost
- Date Started / Finished
- Date Turned
- Temperature Check Results (check at multiple locations)
- Initials of person performing turn / temperature check
Built for Compliance: FSMA § 112.60 (b)(2)
Record Keeping Tip: Produce Safety Alliance has free record templates for farm use. Use them as is or as a starting point for your farm record keeping. Post a sign near the compost to remind you to log the turns and temperature checks.
Purchased Soil Amendments of Animal Origin
Requirement: for compost purchased, you obtain documentation showing the amendment was made following a scientifically valid process, as defined in 112.55(a)
Interval: annually
Record Must Include:
- Company Name
- Produce Name
- Dated
- Microbial testing
- Statement of controls
- Signature of Company Representative
Built for Compliance: FSMA § 112.60 (b)(2)
Record Keeping Tip: Request this documentation direction from the company you are purchasing the amendment from and schedule a reminder for yourself to obtain updated copy annually.
If they don’t have a standard report they can provide, you can point them to the Produce Safety Alliance has free certificate of conformance template .
Sanitary & Safe Practices
Purpose: to document your sanitary and safe practices.
Should Include:
- Name of your farm
- Complete business address of your farm
- Description of your farm
- Contact information
- Risk assessment of practices and conditions on the farm that can impact food safety
- Description of practices that the farm undertakes to reduce risks
Record Retention: review and update at least annually to reflect any changes in practices on your farm
Record Tool Tip: Use the CAFF Simplified Food Safety Plan Template or if you are Certified Organic, use your Organic Systems Plan.
Cleaning and Sanitizing
Requirement: you must use clean and sanitize harvesting, packing, or holding equipment and buildings.
Interval: as frequently as reasonably necessary to protect against contamination of covered produce
Record Must Include:
- Name of your farm
- Location of your farm
- Date / Time activity performed
- List of Tools / Equipment / Buildings Cleaned
- Cleaned or Sanitized (check box)
- Method Used
- Initials of person performing the activity
Built for Compliance: FSMA § 112.140(b)(2)
Tip: Build your post-harvest space with easy to clean surfaces. Use a Clean / Dirty baskets system for tools. Have different color bins for harvesting verse packaging.
Record Keeping Tip: Produce Safety Alliance has free record templates for farm use. Use them as is or as a starting point for your farm record keeping. Mount a cleaning log in each buildings / spaces to document the cleaning activities.
FSMA RECORD KEEPING REMINDERS
- Paper or electronic record keeping are acceptable.
- Do not recreate the wheel.
- You can use the records you already keep, just add the detail required by FSMA.
- You can use free templates
- Record must be stored on the farm.
- Records may be stored off farm if they are readily accessible
- Electronic records are considered to be onsite if they are accessible from a computer at your farm.
- Off season when your farm is closed, records can be stored off farm.
- Records must be readily accessible (accessible within 24 hours for official review)
- Records must be kept and maintained
- Farm records must be retained for at least 2 years
- Financial records must be retained as long as necessary to support the farm’s status, usually a rotating 3 years.
For more best practices check out CAFF Food Safety Resources or contact your location CAFF Regional Food Safety Specialist (scroll to bottom of page).