By Dave Colson
MOFGA Agricultural Services Director
Food safety issues came back into the spotlight for many farmers and agricultural groups this year. In January 2013, the Food and Drug Administration (FDA) released its proposed rules for implementing the Food Safety Modernization Act passed by Congress in 2011. A year in the writing, these proposed rules would have a broad-reaching effect on farmers marketing fruits and vegetables in their raw state. These rules, covering many aspects of raw food commodities, can be linked generally into four categories.
Standards for Growing, Harvesting and Packing
Good Manufacturing Practice, Hazard Analysis and Preventive Controls for Human Food
Qualitative Risk Assessment
Requirements for Imported Raw Products
Of these the first two, covering vegetable and fruit production and defining and regulating “facilities” for food production, most concern Maine farmers.
These rules were accompanied by the history of and justification for how the rules were formulated, encompassing many hundreds of pages, a daunting task for any individual to digest. While the proposed rules do lay out exemptions for farms selling the majority of their products directly to consumers with a total sales under $500,000, the produce and grocers’ industries as well as some consumer groups pushed hard for removing these provisions. A mechanism for some type of “small farm exemption” is part of the original law (the Tester amendment), but how it will be implemented is yet to be seen.
Recording and answering all the comments received during the official comment period, which ended in November 2013, will probably take at least two years to complete, FDA officials admit. During this time FDA will attempt to write a final rule, which will need to be published in the Federal Registry for public comment. Included in the current proposal are phase-in periods for different farm scales, ranging anywhere from two to five years. However, farmers in various parts of the country report that during the 2012 farm season, FDA inspectors were already using the proposed rules in their farm food safety inspections. Most dramatically affected are highly diversified farms that may sell value-added products or aggregate products from other farms in their own sales. These farms would fall under the definition of “facility” and would be subject to the rules for Good Manufacturing Practice.
While MOFGA encourages farmers to take advantage of educational opportunities on food safety, remember that the final rule has not been written, so be cautious of groups offering fee-based workshops or technology purporting compliance with FDA rules. Resources and training are available at little or no cost that can help farmers evaluate their systems in relation to food safety.
Food safety and quality are part of the reason many folks choose farming for their livelihood. MOFGA remains committed to supporting Maine’s food producers and working toward sensible food safety rules that allow this vibrant local food movement to continue.
Wholesale Success: A Farmer’s Guide to Food Safety, Postharvest Handling, Packing and Selling Produce. The recently revised 312-page book is the definitive training source on selling into wholesale markets. It includes topics such as Calculating Return on Investment; Cleaning, Drying and Curing Produce; Traceability; Packing Shed Design; and Maintaining the Cold Chain. https://www.familyfarmed.org/
The On-Farm Food Safety Project includes a free, easy-to-use, online tool that generates customized on-farm food safety plans based on user input. This tool has been designed specifically to provide small and mid-scale produce growers with a full set of recordkeeping tools to document their food safety program and to provide training to their employees. https://onfarmfoodsafety.org/
“Navigating the Food Safety and Regulations Maze,” by Cheryl Wixson, The Maine Organic Farmer & Gardener, Sept.-Nov. 2012; https://www.mofga.org/Publications/MaineOrganicFarmerGardener/Fall2012/Regulations/tabid/2285/Default.aspx
A Farmer’s Guide to Food Safety and Conservation: Facts, Tips & Frequently Asked Questions provides a boots-on-the-ground guide for small and mid-sized fruit and vegetable growers looking to address both food safety and conservation on their operations. https://www.wildfarmalliance.org/resources/FS_Facts_Tip_FAQ.htm. The supporting Training Scenarios for USDA and Third Party Auditors on the Co-management of Food Safety and Conservation as well as Small Farm Concerns serves as a training opportunity for food-safety auditors and as a resource that farmers can share with their auditors to help them better understand conservation and small- and mid-size farm issues. https://www.wildfarmalliance.org/resources/FS_Training_Scenarios.htm
Food Safety Information and Resources for Producers, National Farm to School Network; https://www.farmtoschool.org/foodsafety.php