In our February 2018 FSMA Fridays session, Eric Edmunds, JD of The Acheson Group joined Brian Sharp, VP Marketing at SafetyChain to discuss FSMA-related news, including recently released guidance documents. The session included an overview of the topic of the Produce Safety Rule. Our presenter provided a preview of what the industry should expect in anticipation of the roll out of the Produce Safety Rule, including inspection requirements.
In early February, the FDA hired former VP of Food Safety and Technology for Produce Marketing Association Jim Gorny to fill a new role as Senior Science Advisor for Produce Safety. According to FDA officials, the new Produce Safety Guidance documents are in their final stages, so it is anticipated that they will be released within the near future.
Who Is Affected by the Produce Safety Rule?
The Food Standard Modernization Act’s (FSMA) Produce Safety Rule applies to many farms, though there are some exemptions. Farms with annual sales of less than $25,000 are exempt.
When Will It Be Enforced?
Compliance deadlines are staggered based on farm size. While large farms were required to meet the January 26, 2018 deadline, farms with annual sales of $500,000 or less have a deadline of January 26, 2019. The FDA has announced that inspections will not be conducted until 2019, but it’s possible some inspectors could begin visiting farms earlier to assess programs and provide advice without performing in-depth produce safety inspections.
How Will Inspections Be Performed?
Because the FDA does not have the resources to send inspectors to every farm, in many areas they will enlist the help of state agencies to perform inspections. In fact, 43 states have participated in the FDA’s grant program, which will help states establish their own inspections. Additionally, state inspectors have the regional expertise and familiarity with local growing processes.
How Will It Affect the Supply Chain?
Until inspections begin taking place, it will be difficult for purchasing companies to ensure members of their supply chain are compliant with the Produce Safety Rule. In the meantime, they can rely on third-party audits or similar programs to ensure best practices are in place. Food and beverage companies must therefore maintain strong lines of communication with suppliers.
What Should Be Expected for the Future?
The rule’s agricultural water quality requirements are still in the public comment period, and if they should go through, the earliest date they could be enforced is January 2022. The FDA is also partnering with the National Association of State Departments of Agriculture (NASDA) to encourage participation in voluntary inspections. While official inspections may not begin until 2019, farms should already have the necessary programs in place to ensure compliance. Because farms have never had mandatory food safety inspections before FSMA, it’s especially important for those under the Produce Safety Rule to fine-tune their safety programs.
Missed the session? Click here to access the recording.
Click here for the presentation deck on SlideShare.
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