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FSMA Rules are now available • Science-‐based!
– Focus on iden7fied routes of microbial contamina7on – Excludes certain produce rarely consumed raw – Excludes produce to be commercially processed (documenta7on required)
• Sec7on 105 of the Act • Worker health, hygiene & training • Agricultural water (for produc7on & post-‐harvest uses) • Biological soil amendments (compost, manure) • Domes7cated & wild animals • Equipment, tools, buildings & sanita7on • Produc7on of sprouts*
• Read more: hQp://www.fda.gov/Food/GuidanceRegula7on/FSMA/ucm334115.htm
Who should comply?
• Understand “Food Facility Registra7on Requirement”
• Under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002: – if it does not affect you, then you do not have to register
So, who has to register?
Broadly put: if you – manufacture, process, pack or hold food for consump7on in the US … • then you are a facility … must register with FDA
• Must follow: • cGMPs (current Good Manufacturing Processes) • HARPC (Hazard Analysis Risk-‐Based Preven7ve Controls)
– Need Food Safety Plan, Verifica7on Measures, etc
Who could be exempt from registra7on?
• In some cases … – medium-‐size, small and very small farms
• Businesses exempted include – stores, restaurants, certain types of direct market farms, etc
• For the PC Rule: – Bioterrorism Act was modified in FSMA
• to protect medium-‐size and family farms from heavy costs
the Preventive Controls Rule
BROADLY PUT: • Domes7c & foreign food facili7es – should follow cGMPs (current good manufacturing prac7ces)
• Establish/implement – hazard analysis – risk-‐based preven7ve controls for human foods
• (HARPC)
Am I a Farm? Or am I a Facility?
• Farm: • establishment under one ownership • in one general loca7on; not necessarily con7guous • devoted to growing & harves7ng crops, animals, or both
• Farms may also: • pack or hold raw agricultural commodi7es (RACs) • dry or dehydrate RACs and/or package/label them
-‐ without further processing
A ‘Primary Ac7vi7es Farm’
Is an operaDon under one management in one general (but not necessarily con7guous) physical loca7on devoted to the growing of crops, the harves7ng of crops, the raising of animals (including seafood), or any combinaDon of these acDviDes.
A ‘Secondary Ac7vi7es Farm’ Is an operaDon – not located on a primary producDon farm:
• devoted to harves7ng (such as hulling or shelling), packing, and/or holding of raw agricultural commodi7es [RACs].
– However, this defini7on only applies if the primary producDon farm(s) that grows, harvests, and/or raises the majority of the raw agricultural commodi7es harvested, packed, and/or held by the secondary ac7vi7es farm owns, or jointly owns, a majority interest in the secondary ac7vi7es farm.
Example 1: Secondary Ac7vity Farm 4 brothers farming cooperaBvely (farm and pack in their farm) Each contributes 25% to the enterprise Each owns 25% of enterprise Each lives 20 miles away from farm
Packing operaBon would be considered a secondary acBvity (it is not on a primary producBon farm) CollecBvely, the brothers produce a majority (100%) (and also own 100% of the business)
Therefore: The farm does not need to register; PCR does not apply
Example 2: Non-‐Secondary Ac7vity Farm Green Farm aggregates produce from various farms Has a distribuBon operaBon; sell to insBtuBons Each farm provides 25% of produce None of the farmers have an ownership interest in the distribuBon
Therefore: The farm needs to register; PC Rule applies
Aggregator does not saBsfy the secondary farm definiBon
Farmer/Distributor Jones
Example 3: Secondary Ac7vity Farm Green Farm aggregates produce from various farms Has a distribuBon operaBon; sells to insBtuBons Each supplying farm provides 25% of produce, and Each of the supplying farmers has a 15% ownership interest in the distribuBon
Therefore: The farm does not need to register; PC Rule does not apply
Aggregator’s farm saBsfies the secondary farm definiBon
Example 4: Non-‐Secondary Ac7vity Farm Green Farm aggregates produce from various farms Has a distribuBon operaBon; sells to insBtuBons The 4 farmers together provide 49% of produce; (the rest – 51% -‐ is from farmers who have no ownership in the aggregaBon) Each of the 4 farmers sBll owns a 15% interest in the distribuBon business
Therefore: The farm does need to register; PC Rule applies (majority produce is from farms that have no ownership)
Majority supply to Green Farm is by non-‐owners; Farm does not saBsfy the secondary farm definiBon
Example 5: Non-‐Secondary Ac7vity Farm Green Farm aggregates produce from various farms Starts a distribuBon operaBon; sells to insBtuBons The 4 farmer owners together provide 100% of produce; The 4 farmers each owns a 10% interest in the distribuBon business (there is majority supply of RAC’s by the ‘minor’ shareholders (the 4 farmers – they do have a majority ownership)
Therefore: The farm does need to register; PC Rule applies (majority produce is from farms that have no ownership)
Majority RAC supply to Green Farm is by non-‐owners; Farm does not saBsfy the secondary farm definiBon
Agricultural Water & Microbial Water Quality
• Water quality in some cases • No detectable generic E. coli
• Examples • wash water, contact surface wash water, edible por7on wash water, sprout irriga7on water • correc7ve ac7on needed if generic E. coli is detected
2nd Set of Numerical Criteria for AW
Other waters: 2 sets of criteria for quality – Geometric Mean (GM) (an average number)
– 126 or less CFUs of E. coli per 100 ml of water
– Sta7s7cal Threshold Value (STV) • reflects amount of variability in water quality
» e.g. aqer a rainfall, or river flood, washing into canals, ponds, … – 410 CFUs or less of E. coli per 100 ml of water
– Online tool by FDA, analyses data
Monitoring Untreated Water
• Agricultural Surface Water (GM and STV figures) – Ini7al 2-‐year survey:
• Minimum 15 samples collected close to harvest • 2nd Year: 5 samples (total 20 samples) • Over the course of 2 to 4 years – “microbial water quality profile”
• Agricultural ground water: – ini7al 1-‐year survey:
• collect 4 samples, as near as possible to harvest 7me
– Calculate GM and STV • In subsequent years, minimum of 1 water sample
E. Coli Levels in Irriga7on Water
courtesy W. Kline
New Jersey Agricultural Experimental Sta7on, Rutgers University
Biological Soil Amendments
• Raw manure: • Risk assessment by FDA:
– Interval between manure applica7on and produce harvest – Currently: use NOP standard:
» 90 days for non-‐soil contact crops; 120 for others
• Raw manure • Apply carefully to avoid contamina7on of edible produce
– during and aqer applica7on
• Stabilized compost • there are set microbial limits for bacteria • apply same as raw manure
Food Safety - Sprouts • A vulnerable commodity
– too many outbreaks, hospitaliza7ons; a couple deaths (last 18 years)
• Properly disinfect plan7ng seed – difficult to wash sprouts
• Test spent irriga7on water • from each produc7on batch of sprouts • perform correc7ve ac7on(s) if water is contaminated
• Test for contamina7on • by Listeria monocytogenes
Animal Management
• Domes7c: – must allow “adequate” 7me between harvest and grazing
• Wild: – Must not harvest visibly contaminated produce
• FDA Vs NRCS: – rules do not intend to remove conserva7on prac7ces
• riparian zones, wildlife habitat, etc
Worker Training; Health & Hygiene
• Health & Hygiene: • Illness repor7ng • Hygienic prac7ces • Providing hygienic facili7es
• Training • Importance of health & hygiene
• All (incl. supervisors, etc) • Be trained; educated; experienced
Equipment, Tools & Buildings
• Can be sources of contamina7on • Incl. greenhouses, germina7on chambers, etc
• Required preventa7ve measures incl – appropriate storage – maintenance & cleaning of equipment & tools
Rule exempts … • Produce that is not raw agric commodity (RAC) • Farms with a 3-‐yr-‐average income of $25K/yr • Produce rarely consumed raw:
• examples: – asparagus, many beans, garden beets; collards; etc – food grains – food for personal/on-‐farm consump7on
• Qualified exemp7on & modified requirements – farms with less than $500K per year for the last 3 years; – farm’s sales to qualified end-‐user is more than to other buyers
Compliance Dates • Very small businesses
– more than $25,000 but no more than $250,000 in average income during the previous 3-‐year period : four years
• Small businesses – more than $250,000 but no more than $500,000 in average income during the previous 3-‐year period: three years
• All other farms: two years
• Compliance dates vary for – certain aspects of the water quality standards, and – tes7ng and recordkeeping provisions Allow an addi7onal two years beyond each of these compliance dates for the rest of the final rule
So, what next? • Become GAPs-‐trained – Jan. 11: Online GAPs training by U of IL Extension – See www.extension.illinois.edu/gkw
• If you do not sa7sfy exemp7on status, register your farm
• If not exempt, comply … • for very small farms -‐ up to 4 years
• View the final Rule here: hQp://www.fda.gov/Food/GuidanceRegula7on/FSMA/ucm334115.htm