Food Safety Modernization Act: Lessons in compliance (2019)
ISSUE
The Food Safety Modernization Act (FSMA) Produce Rule went into effect in 2016. Under the rule, growers of fresh consumed produce must attend an approved training. The Produce Safety Alliance (PSA) Grower Training Course is the current way to satisfy the FSMA Produce Safety Rule requirement outlined in § 112.22(c) that requires “at least one supervisor from the farm must complete food safety training at least equivalent to the standardized curriculum recognized by the [U.S. Food and Drug Administration (FDA)].”
In addition, produce farms will be coming into regulation according to size and income with the first farms to be inspected in 2019. The Food Safety Modernization Act (FSMA) brought fresh consumed produce production under FDA regulation starting in 2016 under the Produce Rule of FSMA. State Departments of Agriculture are administering and regulating compliance with this Produce Rule.
RESPONSE
Produce Safety Alliance (PSA) Grower Training
Gordon Johnson, Kali Kniel and Jennifer Jones took the Produce Safety Alliance’s train the trainer course and have served as trainers for sessions offered in Delaware and Maryland. Extension Agents Dan Severson and Jake Jones, in New Castle and Kent counties respectively, also qualified as trainers in 2019. Johnson further qualified as lead trainer (one is required for each session) and has since served in that capacity as the only lead trainer in Delaware. A total of four PSA trainings were conducted in 2019.
In Delaware, each attendee gets a detailed 358-page manual with the training slides, references to the regulations and explanations of the regulations. Growers that complete the training receive a nationally recognized certificate from the Association of Food and Drug Officials (AFDO) that is recognized by the FDA.
On-Farm Readiness Review (OFRR)
To help growers comply with FSMA on-farm inspections, a team comprised of food safety leaders from the National Association of State Departments of Agriculture (NASDA), the state, the FDA and Cooperative Extension, developed the On-Farm Readiness Review (OFRR). Designed to move farmers away from the audit checklist scheme, the OFRR is meant to foster a dialogue between the farmer, the regulator and the educator about the requirements of the Produce Safety Rule.
In Delaware, the On-Farm Readiness Reviews are conducted jointly by Produce Safety Specialists from University Delaware (UD) Cooperative Extension and staff from the Delaware Department of Agriculture (DDA). A team consisting of Gordon Johnson, Kali Kniel and Jennifer Jones (UD) and Andrea Jackson and Anna Wicks (DDA) received the required training in May of 2018. The OFRR consists of on-farm observations that identify areas for produce safety improvements, help growers prepare for FSMA Produce Safety Rule inspections and assist growers in utilizing best produce safety practices on their farm. Each farm receives an OFRR manual and checklists to comply with the FSMA Produce Rule.
RESULTS
Produce Safety Alliance (PSA) Grower Training
In 2019, 109 PSA attendees received AFDO certificates. This included growers from Delaware and Maryland as well as several agency officials.
- 31 attended the February 9, 2019 training at the Delaware Department of Agriculture (DDA)
- 46 attended the March 19, 2019 training at the Delaware State Fair
- 17 attended the March 20, 2019 training at Delaware Technical Community College Georgetown campus
- 15 attended the November 6, 2019 training at the Delaware Department of Agriculture (DDA)
To evaluate the PSA Grower Training sessions, pre and post tests are given and each session is evaluated using a nationally standardized evaluation.
- The average increase in score after the training is 21%.
- After 3 years of PSA trainings, 95 % of attendees felt that the level of FSMA Produce Safety Rule information provided in the curriculum materials prepared them to implement regulatory requirements.
Comments throughout the evaluations include:
- “It was nice- friendly meeting”
- “Great lunch”
- “Increased my knowledge of what I was doing wrong”
- “Great class”
- “Good materials distributed, good presenters”
Under additional education materials that should be included:
- “post-harvest cleaning and sanitizing procedures by produce type”
- “sample food safety plans and SOPs”
On-Farm Readiness Review (OFRR)
Ten On-Farm Readiness Reviews were conducted in 2019 with 23 farm personnel present during the reviews. Growers valued the suggestions for farm improvements to comply with FSMA during sessions that averaged 3 hours per site.
Some specific issues identified during reviews:
- Lack of adequate hand washing facilities
- Poor restroom or portable toilet sanitation
- Poor employee hygiene
- Cold storage facilities with condensation
- Produce contact surfaces that are difficult to clean or are not cleaned with adequate frequency
- Inadequate employee training on produce food safety
- Produce wash facilities without good drains to handle used water
- Inadequate understanding of cleaning and sanitizing procedures
- These issues are being address through follow up communications or visits.
Outreach to Asian Growers on Produce Food Safety
During 2019, University of Delaware Extension agent, Jennifer Jones, and Delaware Department of Agriculture staff, Anna Wicks and Amanda Ziegler, visited nine farms operated by Asian growers of Korean, Chinese and Japanese background. Because these growers and their employees had no produce food safety training, a program is being developed to bring training to and improve produce food safety on these farms.