Requirements: Dictates that farms implement science-based standards, processes, and training for food safety throughout the growing process, addressing risks in water, fertilization, sanitation, animal control, facilities and equipment, and human intervention.
Exemptions or modified requirements: Farms with annual sales of $25,000 or less or only selling direct-to-end users, such as farmers’ markets, local grocers, or restaurants. Also exempt are “rarely eaten raw” commodities like asparagus, cranberries, eggplant, okra, potatoes, pumpkins, sweet corn, and water chestnuts. Conversely, problem-prone commodities such as sprouts are subject to specific and additional regulations and have earlier compliance dates.
The Produce Safety rule is complex and a whole new world for growers, which—unlike many processors—have not had to be FDA-registered in the past. The provisions of this rule encompass everything from water testing, use of manure and compost, and control of domestic and wild animals to training, cleanliness standards (for equipment, tools, and buildings), and sanitation practices and worker hygiene. The rule requires setting standards, implementing ongoing preventive and mitigation procedures, and training.
“The Produce Safety rule is the most important [part of FSMA for us], as it impacts supply chains beginning at the farm,” says Lynch. “The expectations necessary for a food-safe supply chain are a significant change in the produce industry,” he adds, noting that RPE has been working for years to upgrade procedures, verifications, and training to support food safety. Continuous evaluation, communication, and improvement are essential to accomplish a culture of zero tolerance of food safety incidents.”
Companies doing business abroad may already be compliant with some of the rule’s requirements. Katsurayama notes that Jasmine Vineyards has GlobalGAP certification, as required by its global customers, so “we’re already doing a great part of it.”
Some commodities are innately easier to monitor than others. Jasmine’s table grapes grow five feet off the ground. Irrigation water, a focus of the Produce Safety rule, never touches the fruit. “I do feel lucky about the structure of our business,” Katsurayama observes. “For other produce companies, all the monitoring in the field and across the supply chain is a big challenge.”
For Rast Produce, Inc. in Visalia, CA, which sells California-grown and imported produce to chain stores and foodservice companies on the East Coast, “there’s a lot more tracking and attention to detail,” contends John Rast, president of the eponymous grower and Sierra Agricultural Transportation, also based in Visalia. “It’s not that different from what we’ve been doing; it just needs to be more vigilant.”
Unfortunately, Rast has experienced pushback from growers about the increased paperwork. “Very rarely does a week go by that a new grower doesn’t contact us about selling a commodity, but they have to adhere to our standard operating procedures. Until I have the paperwork in order, [a grower] can have the most beautiful oranges in the world—but I can’t buy them.” Rast notes that even growers he’s worked with for years are balking at the new requirements, until they realize he won’t purchase from them until they comply.
