By Sarah Everhart
If you are a regular reader of this blog, you have likely read many posts in the past year on the Food Safety Modernization Act (FSMA) and the Produce Safety and Preventive Controls Rules. Although we have tried to make FSMA understandable, it is a dense federal law with many varying requirements and compliance dates depending on the type and size of a farmer’s operation. Recently, FSMA training courses available to growers in 2017 were announced. The purpose of this post is to help farmers understand whether or not they need to attend a training course on FSMA. However, even if a farmer is not legally required to attend a FSMA training course, given the importance of food safety, it is still advisable for growers to attend either a FSMA course or a Good Agricultural or Handling Practices course this winter. Training course dates and locations will be provided on the ALEI website.
Farmers required to be certified in the FSMA Produce Rule are those who grow, harvest, pack and hold produce covered by FSMA, unless they fall into one of the following categories:
The produce grown by the farm is rarely consumed raw. The Food and Drug Administration has a list of this category of produce.
The produce grown by the farm will be commercially processed in a manner that kills pathogens (for example: canned tomatoes).
The average annual produce sales of the farm over the last 3 years are less than $25,000.
The average annual food sales (produce and all other crops) of the farm over the last 3 years are less than $500,000 and more than 50% of those food sales are to qualified end users such as restaurants, retail food establishments (located in your state or within a 275-mile radius of the farm) and to consumers through direct marketing (farmers markets, CSA, internet sales, etc.).
Unless you fit into one of the categories above, according to FSMA, “at least one responsible person” at the farm needs to be trained in the FSMA Produce Safety Rule. The answer to the question of when the training must occur depends on the size of the operation.
If a farm has over $500,000 in average annual produce sales during the previous 3-year period, then the farm must be in compliance with the Produce Safety Rule by January 2018 which means “one responsible person” must be trained and the practices must be implemented by that date. Certain water quality standards and testing requirements allow an additional 2 years for compliance.
If a farm has less than $500,000 in produce sales during the previous 3-year period, then the farm must be in compliance with the Produce Safety Rule by January 2019 which means one responsible person must be trained and the practices implemented by that date. Certain water quality standards and testing requirements allow an additional 2 years for compliance.
If a farm has less than $250,000 but more than $25,000 in produce sales during the previous 3-year period, then the farm must be in compliance with the Produce Safety Rule by January 2020 which means one responsible person must be trained and the practices implemented by that date. Certain water quality standards and testing requirements allow an additional 2 years for compliance.
As for the Preventive Controls Rule, check out this past post with an easy to use diagram created by the National Sustainable Agriculture Coalition. In a nutshell, most farms are not subject to the Preventive Controls Rule if they only grow, hold, and pack food for consumption.
The first round of FSMA training courses (combined Produce Safety and Preventive Controls Rule training) will take place as follows:
February 8-11 2017, Baltimore County Extension Office, 1114 Shawan Road, Cockeysville, MD 21030. Snow dates: February 15-19.
February 22-25. 2017, Wye Research and Education Center, 124 Wye Narrows Drive, Queenstown, MD 21658. Snow dates: March 1-4.
March 8-11 2017, Western MD Research and Education Center, 18330 Keedysville Road, Keedysville, MD 21756. Snow dates: March 15-18.
Click here to register for one of these courses. The Maryland Department of Agriculture will also be hosting training sessions in 2017, dates and locations to be announced.