EAST LANSING, Mich. — Over the years, fruit and vegetable growers have been asked to implement many produce safety practices. Some of these practices are required by law while others are a prerequisite to sell to certain buyers. All have left growers with many questions. Because of this, a lot of programs to help growers implement produce safety practices have emerged. Now growers often don’t know which program would help them best.
When implementing produce safety practices, growers could be asked to have an audit by a buyer or need to go through an inspection. Let’s quickly review the differences between produce safety audits and inspections. Audits are usually a prerequisite to sell to particular customers. Because a grower can choose to sell to customers that do not require audits, they are considered voluntary.
Audits usually follow a checklist with the relative risks of different food safety hazards weighted by a number of points. In some cases, growers only need to achieve a percentage of the total score to pass an audit. This allows growers to choose certain low risk practices to ignore or not implement and just “take the hit” on the audit. These audits are annual, and sometimes several may be conducted in the same year. In the case of several brands of audits, they only cover one crop per audit.
The Produce Safety Rule
The Food Safety Modernization Act (FSMA) Produce Safety Rule is a law that defines practices necessary to grow, harvest pack and hold safe food. Inspections using the law as a benchmark are not based on points. All key components to a law where an inspection is required need to be considered. Inspections are usually not annual, allowing for a facility to adopt changes gradually. An inspection also covers the entire farming operation, looking at how the whole farm handles the whole range of growing and harvest activities across different crops.
Two programs that are often confused to help growers prepare for audits and inspections are the Produce Safety Risk Assessment and the On-Farm Readiness Review. The Produce Safety Risk Assessment looks at a grower’s produce safety practices to provide an action plan of best practices specific to their operation. It can be done any time of the year and progressively over a season or more. The Produce Safety Risk Assessment has been calibrated to meet FSMA Produce Safety Rule requirements but covers more produce safety practices than just those found in the Produce Safety Rule.
The Produce Safety Risk Assessment is voluntary, free and confidential. It is conducted by a Produce Safety technician, one of several specially trained individuals located in Conservation Districts across the state. At the end of a Produce Safety Risk Assessment, a grower receives a certificate they can display at their point of sale signifying they have completed a Produce Safety Risk Assessment.
The On-Farm Readiness Review is specific to the Produce Safety Rule in that it only covers the requirements of the Produce Safety Rule. Food safety hazards, like physical or chemical contaminants are not covered by the Produce Safety Rule and are generally not addressed in an On-Farm Readiness Review. The scope of an On-Farm Readiness Review is a close example or run through of what an inspection could look like. As such, it is of limited utility for growers who only grow produce that is rarely consumed raw or who gross less than $25,000 in annual produce sales.
For best results, the On-Farm Readiness Review needs to be conducted during harvest. Like the Produce Safety Risk Assessment, an On-Farm Readiness Review is voluntary, free and confidential. On-Farm Readiness Reviews are carried out by one produce safety technician and one Michigan State University Extension educator with some training in on-farm produce safety. The grower retains all notes taken by the On-Farm Readiness Review team on the farm. No certificate is given for the completion of an On-Farm Readiness Review.
Funding for this article was made possible, in part, by the Food and Drug Administration through grant PAR-16-137. The views expressed in the written materials do not necessarily reflect the official policies if the Department of Health and Human Services; nor does any mention of trade names, commercial practices or organization imply endorsement by the United States Government.
— Phillip Tocco, Michigan State University Extension
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