Chesapeake Harvest | Elizabeth Beggins

Production Manager & GAP Food Safety Educator

Elizabeth@chesapeakeharvest.com

410.200.8431

NAVIGATING THE FOOD SAFETY LANDSCAPE

FOOD SAFETY!!

FOODBORNE OUTBREAKS (1990 – 2003)

Illnesses Caused by Food

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Penn State Farm Food Safety © 2011

Why food safety? Why now?

Why food safety? Why now?

We eat produce raw more than ever before.

Why food safety? Why now?

We don’t control what comes from the outside.

GAP certification

Reassurance for wholesale buyers

Food Safety Modernization Act (FSMA)

Reassurance for consumers concerned about food borne illness

What is GAP certification?

A 3rd party auditor inspects your farming operations to see if they comply with Food Safety Standards.

Food Safety Standards are based on Good Agricultural Practices (GAP).

GAP are best practices and procedures for produce farms that may reduce the risk of food borne illness.

May be required by your buyer. It’s a business decision not the law!

What is the Food Safety Modernization Act?

FSMA - new FDA regulations for food production

FSMA regulation that applies to produce farmers - the Produce Safety Rule.

FSMA is The Law If you are covered you have to comply

Who does this apply to?

1. If you gross on average >$25K/yr in produce sales

2. And the produce is often eaten raw

3. And you sell more than 50% to “intermediated” markets - distributor, food hub,

retailer distribution center

It’s likely you will have to comply

GAP CERTIFICATION PRODUCE SAFETY RULE

Requires a manager to be trained in food safetyRequires a manager to attend the PSA Grower

Training

Requires workers to be trained Requires workers to be trained

Requires water testingRequires more complex water testing

– but this is under review

Requires GAP Policies, standard operation procedures and recordkeeping

– more rigorous than PSR

Requires similar GAP systems and standard operation procedures, but less recordkeeping

than GAP certification

Does require a food safety planDoesn’t require a food safety plan but it’s

recommended

Does require a 3rd party audit There will be Dept of Ag inspections

Industry driven – business decision Required by law

Your customer requires GAP certification

1. Get more information

a. Do they have a preferred food safety standard or audit program?

2. If they just want you “GAP certified”, you decide who audits your

farm.

Talk to your food safety savvy peersVisit farms and facilities with food safety programs in place

Take it seriously and take a training

What Should I Do First?

Food Safety is Everyone’s Responsibility Everyone involved in the operation should know and understand that food safety is serious business.

We do all we can to prevent microbial

contamination of fresh produce so that it is not

necessary to take corrective action after a

product has left our fields or our packinghouse.

• Train workers

• Develop standard operating procedures

• Test your water sources

• Create a traceability system – harvest logs, lot numbers…

Talk to your food safety savvy peers

Visit farms and facilities with food safety programs in place

What Should I Do First?

Write a Food Safety plan for your farm

• Many templates online

Chesapeake Harvest provides

one-on-one coaching.

Very cheap!!

• Start keeping records/logs to document

your practices

What Should I Do First?

Schedule your audit

Try to schedule when you are harvesting several crops at once so the auditor

sees more than one process.

Do I have to be GAP certified or FSMA compliantto sell wholesale?

Depends on who you are selling to:

1. Generally the schools, hospitals and colleges don’t themselves require GAP

2. Distributors, large retailers, food service contractors, or food hubs often

require GAP certification

3. FSMA compliance depends on your business size and scope

Do I have to be GAP certified or FSMA compliantto sell wholesale?

A customer’s demands trump all

1. Even if you are FSMA exempt, your customer may still require GAP

certification.

2. Getting GAP certified takes care of 99% of FSMA requirements

you still have to attend the PSA Grower Training

Train your workers:

Training Tools

Cornell Coop Extension Food Safety Training Video

https://www.youtube.com/watch?v=_fQTk14VE_o

Penn State FS Training Flip Chart

http://extension.psu.edu/publications/agrs-129/view

Carolina Farm Stewardship Association Food Safety Videos

https://www.carolinafarmstewards.org/food-safety-videos/

What Should I Do First?

Risk assessment - begin to assess the food safety hazards in your operation

Assess food safety risks in key areas

Water, workers, manure, animals, chemicals, equipment, buildings, land use

What needs to change?

Create an action plan

What Should I Do First?

Make it as easy as possible to do the right thing

What Should I Do First?

Get Organized

Traceability and recall

• Important when you are selling to a wholesale

customer.

• Create a method to trace your product from the

buyer back to your farm.

• Decide on a lot system.

• Labels, bar codes…

• Your customer may have specific requirements

What Should I Do First?

Timeline for GAP Certification

It depends…

Customer requirements

Complexity and scale

Training needs and availability

Food safety literacy

Internal capacity

External use of consultants/contractors

Realistically - at least 6 months

What will it cost me in time and money?

It depends…

1. The biggest challenge is to your brain and your routine

2. Likely it’s not so scary or overwhelming as you expect

3. Usually true that you wont need expensive improvements

4. Analysis leads to improved efficiency, higher quality

5. Systemic change easiest step by step

6. Everyone is engaged

7. If complexity or customer requirements make it very costly and time intensive is it worth the ROI?

Someone has to do the work

A. You can write the manual yourself or pay someone to help you

B. But you can’t outsource management and implementation

The cost of the 3rd party audit will vary

A. Size, complexity, distance

i. An audit could cost $550-$3000 for a small to midsize operation

ii. Ask about cost sharing

What will it cost me in time and money?

Food Safety Consulting Services

• GAP food safety education, plan writing and implementation – group and one-on-one

• Templates for Food Safety plans, records and SOP’s

• USDA Group GAP development and implementation

• QMS and related SOP templates

• Single entity group certification – an alternative or stepping stone to Group Gap

• Experience guiding groups to appropriate structure for food safety certification – assessing scale, structure and

characteristics

Lindsay Gilmour • lindsaygilmour@comcast.net • 215-696-9780

What about FSMA?

The relevant FSMA regulation for produce farmers is the Produce Safety Rule.

Who is exempt?

1. If you gross less than $25K/yr in produce sales

2. If your produce is only eaten cooked (potatoes) or you sell to a processor

3. If you gross <$500K in total food sales and >50% goes direct to end user – farmers market, CSA,

restaurant, school kitchen

But you have to be able to prove it and still fulfill most requirements

Timeline: Produce Safety Rule

What about FSMA?

The Preventative Controls for Human Food rule – applies to non-farm holding, storage, distribution, processing…

1. Does require a food safety plan

2. Requires Preventative Controls training – a “Qualified Individual”

3. Requires that you register with the FDA as a facility

4. FDA approved inspections

The Sanitary Food Transport Act

>$500K in sales (shippers, receivers, carriers…)

1. Requires Standard Operating Procedure’s for cleanliness, temperature control, record keeping and worker training

Timeline: Preventative Controls Rule

Compliance Dates

1. Very small businesses (VSB) - averaging less than $1 m/yr : 9/17/18

a. Only packing and holding produce: 1/27/20

b. Must keep records to support status as a VSB from January 2016

2. Small businesses - <500 full-time equivalent employees: 9/18/17

a. Only packing and holding produce: 1/28/19

3. All other businesses: 11/19/16

a. Only packing and holding produce: 1/26/18

Which standard should I certify to?

GAP/GHP or Harmonized GAP Harmonized GAP Plus+Many to choose from.

Ask for help:

• Coop extension

• Experienced farmers

• Consultants

Which auditor should I use?

Many to choose from.

Ask for help:

• Coop extension

• Experienced farmers

• Consultants

GFSI (Global Food Safety Initiative) BENCHMARKING

• Establishes equivalency between audit programs

• Goal is “harmonization” of standards to prevent audit fatigue

GFSI Benchmarked

Harmonized Gap Plus+