Growers located outside the United States who export food into our country must also comply with the same regulations applicable to their operations. Other FSMA regulations that may impact various segments of the growing community include Intentional Adulteration, Sanitary Transportation, and Accredited Third-Party Certifiers—but these regulations will come into effect at a later date.
Education
On many occasions, the FDA has stated the need to “educate before we regulate.” For this reason, the USDA is heavily involved in the educational components of the FDA’s implementation strategy via the Produce Safety Alliance and is involved to a lesser degree in the activities of the Food Safety Preventive Controls Alliance and the Sprouts Safety Alliance.
The Produce Safety Alliance was established in 2010 and will continue to at least 2017. The Alliance is supported financially and relies on staff from both the FDA and USDA represented on the Executive Committee. The standardized curriculum will be aimed at helping growers better understand food safety implications and integrate practices into their farming operations. This includes ensuring food safety and conservation practices can coexist (sometimes referred to as “co-management”), and helping farmers understand the specific requirements of the Produce Safety regulations. Cooperative Extension specialists associated with the Land Grant University System are likely to take on a primary role as trainers working with farmers. There will also be instructional events held across the nation in farming communities, and growers can meet the training requirement in the Produce Safety rule by attending these workshops. Interest from agriculture consultant firms, trade associations, and others looking to become trainers for this curriculum is also expected. All are welcome to apply as trainers to the Produce Safety Alliance.
The USDA is committed to helping the FDA understand the diversity of the nation’s farming community and to assist growers and packers, processors, and sprouts producers of all sizes and production systems gain a better understanding of how to comply with the applicable regulations. Even growers excluded or exempt from the FDA’s regulations can benefit—as some buyers may expect all of their produce suppliers to meet the new FDA requirements. For this reason, exempt farms may want to come into compliance to maintain or gain access to these markets.
Assistance
The USDA’s personnel serve as technical advisors on the produce safety and preventive controls “operational teams” established by the FDA to develop its implementation and compliance strategies. The USDA continues to provide input to the FDA related to the Good Agricultural Practices (GAP) program, the USDA’s voluntary food safety certification program. This program continues to be a useful tool for growers to demonstrate compliance with FDA’s Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables.
Once the FDA’s Produce Safety rules are final, there will be some modifications to the USDA GAP program to ensure that USDA GAP audits align with the new FDA regulations. Furthermore, the FDA has stated its intent to leverage existing marketplace accountability measures that stakeholders (i.e., farmers and packers) already have in place, such as one of the USDA GAP programs (e.g., harmonized GAP, generic GAP, mushroom GAP) or Marketing Orders/Agreements that incorporate food safety elements.
