Good Agricultural Practices (GAP) for Fresh Fruit and Vegetable Growers

1. Good Agricultural Practices (GAP)for Fresh Fruit and Vegetable Growers Updates: What’s New? What’s on the Horizon

2. Addressing Flooding Irene 2011—help us to prepare for next time! Resources for best practices when produce fields are flooded: • Guidance for Industry: Evaluating the Safety of Flood-affected Food Crops for Human Consumption • Go to www.fda.gov • Click on Food • Click on Guidance • Compliance and Regulatory Information • Click on Guidance Documents and then search for flood guidance • Guidance on: flood waters contacting and NOT contacting edible portions of crops, assessment of fields before replanting and avoid cross-contamination after flooding

3. Addressing Flooding http://www.fda.gov/Food/RecallsOutbreaks Emergencies/Emergencies/ucm272322.htm Letter to State Agriculture Departments/Agencies 2011 • Assessment of field for replanting after flooding • Assess field history and crop selection • Time interval between flooding, planting and harvest • Source of flood waters and whether significant potential of human pathogens. • Allow soils to dry sufficiently • Sampling flooded soil of microbial concerns

4. Addressing Flooding • How does this relate to GAP? • Crop production areas that have been subjected to flooding have potential microbial hazards. • Soil tests are recommended, especially if there are potential hazards in the area such as nearby animal production operation, or a sewage treatment plant or sewers. • Safety assessment of flood –affected crops – microbial contamination? • Fresh fruits and vegetables inundated by flood waters and cannot adequately be cleaned – destroyed.

5. FDA Food Modernization Act of 2010: A Brief Overview New Food Safety Standards and Regulations: Impact on the Produce Industry FDA Regulatory Authority www.fda.gov/Food/GuidanceRegulation/FSMA/ www.fda.gov/Food/FoodSafety/FSMA

6. FSMA Exemptions, Registration, Fees, Recall, FDA Authority Produce Safety Standards Rule Preventive Controls for Animal Food Rule Preventive Controls Human Food Rule Foreign Supplier Verification Program Rule Accredited 3rd Party Certification Rule Only farms with raw agricultural commodities Farms with mixed-type activities may fall here as well

7. Provisions Effective November 2012:Part of Act • Consumer Information and Recall • Consumer friendly web search for food subject to recall • Mandatory recall authority • Facility Registration and Suspension: • Are you considered a processor? • Prior Notice for Imports and detention • Fees for re-inspection and mandatory recalls

8. Flexibility/Exemptions for Small Farmers (and others): Part of the Act • < $25,000, completely exempt • Partial exemption, must satisfy all: • 3 yr average sales < $500,000 ALL food sales • Distribution intrastate or within 275 mi. radius • Majority (over 50%)distribution to “qualified end-users” e.g. directly to customers, restaurants or retail food (NO distributors)

9. Flexibility/Exemptions for Small Farmers: Act Product label required: name/place business, if no label provided through placard at a retail, for example Exemption can be withdrawn by FDA with reason of contamination or outbreak Must document applying controls for hazards or in compliance with other state, local requirements

10. Produce Safety Rule

11. Covered Produce – Risk based • Grow, harvest, pack or hold most fruits and vegetables in raw agricultural state • Includes herbs, mushrooms • Produce not covered • low risk, rarely consumed raw • winter squashes, yams, potatoes, sweet corn, brussel sprouts, cranberries, beets, pumpkin….. • grains, peanuts (roasted) • will be receiving a kill step (documentation) • personal or on-farm use

12. Covered Produce – Risk based • For Non-exempt farms Produce Safety rules only apply to covered produce • Covered produce includes crops commonly consumed raw– almonds, apples, apricots, asian pear, aprium, avocados, bananas, Belgian endive, blackberries, blueberries, broccoli, cabbage, cantaloupe, carrots, cauliflower, celery, cherries, citrus, cucumbers, curly endive, garlic, grapes, green beans, guava, herbs (such as basil, chives, cilantro, mint, oregano, and parsley), honeydew, kiwifruit, lettuce, mangos, other melons, mushrooms, nectarine, onions, papaya, passion fruit, peaches, pears, peas, peppers (such as bell and hot), pineapple, plums, plumcot, radish, raspberries, red currant, scallions, snow peas, spinach, sprouts, strawberries, summer squash (such as patty pan, yellow and zucchini), tomatoes, walnuts, watercress, and watermelon; and mixes of intact fruits and vegetables (such as fruit baskets). THIS IS NOT AN EXHAUSTIVE LIST

13. Produce Safety Standards • Address growing, harvesting, sorting, packing/storage • Science-based minimum standards for • Agricultural water • Biological Soil amendments • Worker Health and Hygiene • Equipment, Tools, Buildings and Sanitation • Domesticated and Wild Animals • High Risk Produce - prioritize

14. Other parts of Standards Include: • Growing, Harvesting Packing and Holding • Mandates for key records e.g. water and water use, composting time and temperature • Training requirements • Specifics for sprouts • More….. • Regulations proposed, still comment period

15. Some Proposed differences from GAP? • Manure • 120 days vs. 270 days • Composted, 0-45 days depending if in contact with crop • Microbiological standards treated bio soil amendments for Listeria, Salmonella and E. coli 0157:H7 • Water testing • Risk-based: weekly vs. monthly growing season • E. coli, 126 cells/100 ml • > 235 CFU/100 ml for any single sample OR > 126/100ml for 5 samples, must discontinue • Re-inspect, implement controls, re-test or treat water • Potable water only after harvest • 10oF temperature difference? More info needed

16. Some Proposed differences from GAP? • Maintain and clean non-food contact equipment and tools • Repair tools • Pest control and documentation required • Birds and nests specifically mentioned! • Water to wash hands, hand sanitizers considered ineffective. • Food safety plan not required • Training required and record proof • More ………

17. Compliance Dates Produce Standard Regulations: Very Generous • Very small farms, >$25,000 ≤ $250,000 • 4 years from effective date • Some water requirements, 6 years • Small farms, > $250,000 ≤ $500,000 • 3 years from effective date • Some water requirements, 5 years • Others • 2 years from effective date • Some water requirements, 4 years

18. Prevention Controls Rule

19. Registration:Bioterrorism and FSMA Acts Requirement • Not for harvesters/farmers/retail • Certain on-farm activities that would require registration • Processors, wholesalers, distributors – Are you one? • Extension of Public Health Security and Bioterrorism Preparedness and Response Act of 2002 • Re-registration every even-numbered year – every 2 years • Introduction of food into commerce without registration – prohibited • Suspension authority for food suspected of causing illness or death

20. Do you have to register with FDA? • Who is exempt? • Ownership drives registration • Farmers: Growing, harvesting, washing, trimming outer leaves, and/or cooling • Farmers: Raising animals • Foods processed exclusively consumed on farm or another farm under same ownership • Roadside stands – direct to consumer • NOT exempt: • Warehouse, produce auctions holding food for resale • Buying and packing from another farm

21. Registration • Guidance for industry: Q and A Food Facility Registration • www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/ default.htm • www.fda.gov/downloads/Food/Guidance Regulation/UCM332460.pdf

22. Exemptions as previously mentioned • Low risk processing • GMPs still must comply If I have to register, does that mean full compliance with Prevention and Controls Rule as written?

23. Exclusions/Exemptions Preventive Controls: • Warehouses storing raw agricultural commodities for further processing • Facilities subject to ONLY produce safety standards • Processors subject to other HACCP regulations • Dietary supplements • Alcohol-related facilities • Qualified facilities based on size (average annual sales) OR size/sales to qualified end users/275 mile distribution. Must notify FDA of status AND • Notify FDA addressing hazards through preventive controls/monitoring OR • Proof that complies with applicable local regulations AND • Notify customers complete address place manufactured

24. If you only grow, wash and trim off outer leaves and cool produce and if you only pack at your farm and sell products you grow – Registration and Preventive Controls Rule does not apply to you!

25. Preventive Controls… Summary • Hazard Analysis and Risk-Based Preventive Controls HACCP Approach: • Risk Assessment Food Safety Plan • Risk Management • Updated Good Manufacturing Practices

26. Preventive Controls – HACCP-type Processors Hazard evaluation for reasonable biological, chemical, physical, pesticide etc. hazards - written Include bio-security issues Implement preventive controls to prevent, minimize or eliminate hazard - CCP Includes sanitation, training, recalls, GMPs etc. Monitor controls, Corrective Actions, Records, Verification steps to make sure plan working

27. Flexibility But…… Buyers Requirements: Food safety applies to all sizes! Small does not equal safe Things are changing

28. Third Party Audit Requirements: RIGAP • RIGAP certification accepted in RI, Farm to School • Others? • A beginning • Marketing yourself – we help

29. Marketing – Up to RI Farm Marketing resources: • Consumer brochure • GAP Signs with Logo • Certificate from RIDEM/Division of Agriculture • Hats • Magnet (farmers market participants only) How does URI Help? Outreach and Training • Market displays at Farmers Markets • University/RI Division of Agriculture commitment beyond funding

30. English and Spanish(grant funded)

31. English and Spanish Magnet, 4X7 inches (grant funded)

32. Third Party Audit Requirements Beyond Regulations • USDA GAP/GHP Audit • Harmonization Audit • Selling to USDA directly for lunch programs • Major markets moving in this direction • Wholesalers/Distributors: What will they accept? • More stringent then regulations • www.ams.usda.gov/AMSv1.0/HarmonizedGAP • RIGAP training is a start for future

33. Required vs. Needed: Things to consider if no “official” program Food Safety Plans – Written documents about what you are doing for on-farm food safety - GAP Records– Proof, many already being kept. Most of all, just look – even if not required to • Use the RIGAP audit