Not that there haven’t been plenty of warnings, not the least in the form of the 2011 Food Safety Modernization Act that calls for inspectors to visit produce farms and packing houses under the act’s Produce Safety Rule.
The rule opens the way for inspections, which began in July this year, for farms and orchards making more than $500,000 in annual gross product sales. Smaller farms will have another year to come into compliance with the rule.
As for packing houses, even though there have been some questions over whether a packing house is a farm or not, the FDA is developing an amendment to the rule that may have more to do with what happens in the packing house than who owns the packing house. In any case, the FDA wants all packing companies to follow the packing and holding requirements of the Produce Safety Rule or the good manufacturing practices portion of the Preventive Controls for Human Food Rule.
And while farms will, for the most part, be inspected during harvest, packing line inspections may happen any time that food is running over the lines.
This is the first time in history that produce farms will have to deal with regular inspections on their farms.
No, these inspections aren’t going to be heavy-fisted actions aimed at doling out penalties. Instead, according to what FDA and state inspectors have said, they’ll be educational and even collaborative.
“We won’t come down like a ton of bricks right out of the gate,” said Hector Castro, spokesman for the Washington State Department of Agriculture. “The goal is to help farms comply with the Produce Safety Rule to ensure that food is safe — not to hand out fines and penalties.”
But that doesn’t mean that farms and packing sheds that pose an immediate danger to public health won’t be subject to penalties. After all, these inspections are aimed at preventing conditions that could lead to foodborne diseases. That’s what the Food Safety Modernization Act is all about: preventing health problems, not just reacting to them, as was the case before the act was signed into law.
Whereas in most states, state Agriculture Departments will be conducting the inspections, six states — Oregon, Wyoming, North Dakota, South Dakota, Iowa, and Illinois — will let the FDA do the job.
According to the FDA, the Produce Safety Rule establishes mandatory science-based, minimum standards for the safe growing, harvesting, packing, and holding of fruits and vegetables grown for human consumption.
These standards are designed to work effectively for food safety across the wide diversity of produce farms.
In other words, they aren’t a hodge-podge of standards. Instead, farms covered by the rule will need to comply with certain standards that focus on making the nation’s food supply safer by reducing the presence of dangerous bacteria that can get people sick. This, in turn, will reduce the number of illnesses caused by contaminated produce.
CDC estimates that each year 48 million people get sick from a foodborne illness, 128,000 are hospitalized, and 3,000 die.
What are the priorities
Higher-risk farms will obviously be higher on the priority list than lower risk farms, which means it will be necessary to categorize farms by risk. Here are some of the known food-safety risks, according to a report, “A Model Produce Safety Implementation Framework, (https://s3.amazonaws.com/nasda2/media/Updated-NASDA-Model-Produce-Safety-Implementation-Framework.pdf?mtime=20180905101546)” prepared last winter by the National Association of State Departments of Agriculture’s Food Safety Modernization Technical Working group.
- Known food-safety risks: History of class 1 recalls and outbreaks;
- Soil amendments: Type of amendments (manure and compost, for example) used by the farms;
- Volume of produce that is covered under the Produce Safety Rule that the farm or packing shed is producing;
- Compliance history (once the program is established);
- Sample results;
- Third Party audits;
- Marketing agreements;
- Geographical location of the farm;
- End user of the farm’s produce;
- Weather conditions (drought, flooding,etc);
- Reportable food registry notices;
But because cooking produce before it is eaten can reduce the risk of serious adverse health consequences or death, FDA has decided that it is not “reasonably necessary” to subject produce that is “rarely consumed raw” to the requirements under the Produce Safety Rule.
Go here (http://sustainableagriculture.net/blog/produce-rule-analysis-part-1/) to see which foods are and are not covered by the rule.
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