The Almond Board of California (ABC) held its 18th annual Food Quality and Safety Symposium in Modesto recently with a keen focus on providing almond industry members with information and resources to help them comply with upcoming rules in the Food Safety Modernization Act (FSMA).
For handlers with more than 500 employees and subject to the Preventive Controls rule, the compliance period begins this September, while other operations have up to three years before compliance is mandatory.
The California almond industry has a long history of creating and implementing food safety programs to the extent that much of FSMA is not new to us because we have been building the foundation for many years.
Growers will find that many of the requirements under the Produce Safety rule are very similar to the ABC’s “Good Agricultural Practices for Almond Growers,” and handlers who operate under standard third-party auditing programs, including the Global Food Safety Initiative (GFSI), will find that they are already very close to compliance with the Preventive Controls rule.
Which rules apply?
Knowing which rules will impact a specific operation requires a close look at the categories and the qualifications that place an individual or company into a specific category.
Whether you are an almond grower, a huller-sheller, a handler or a processor, you may be surprised to learn that all four of these categories could also be considered a “farm” under FSMA rules.
As we learned from symposium speaker Elizabeth Fawell, who with colleagues at consulting firm Hogan Lovells developed a decision tool for almond industry members to determine which FSMA rules apply to their operation, the key factors that influence the type of operation you have include: location (proximity to an orchard); ownership structure; company size; and activities performed (growing, hulling-shelling, handling, manufacturing).
Engaging in multiple activities may mean that you are regulated under the Produce Safety rule for some activities and under Preventive Controls for other activities.
For instance, if you’re a huller-sheller or a processor who meets the definition of a farm, then you would have to comply with the Produce Safety Rule, which applies to food intended for consumption in the U.S. plus produce for export.
Another rule, Preventive Controls for Animal Food, applies to the almond industry for hulls used as an animal feed. An exemption to this rule would be granted if the hulls are consumed on the farm where the almonds are grown, or if growers who meet the “farm” definition do not engage in hull processing.
The decision tool for determining which FSMA rules to follow is provided in Fawell’s presentation, “Which FSMA Rules Apply to Me?” which can be found online at www.Almonds.com/FoodSafetySymposium, where you will also find all of the presentations at this year’s symposium.
Produce Safety rule
In a second presentation, Fawell provided an explanation and interpretation of the Produce Safety rule for California almond growers, while encouraging growers to read the entire rule for a more in-depth understanding of the requirements.
This rule applies to food intended for consumption in the U.S., whether grown here or imported, and it also applies to produce for export.
There are two exemptions from the Produce Safety rule: growers with sales less than $25,000 and produce that will receive a commercial-processing kill step (“pasteurization”). However, growers must obtain written documentation from the customer that the kill step will be applied.
In certain cases, the ABC mandatory program for salmonella reduction on almonds may provide sufficient assurances and thus qualify growers for an exemption. The Almond Board expects further clarification from FDA on this in the near future.
The Produce Safety rule has several subparts addressing agricultural water, biological soil amendments of animal origin, worker health and hygiene, equipment, tools and buildings, domesticated and wild animals, and harvesting and packing.
Most of these requirements are very similar to good agricultural practices (GAP), with the exception of agricultural water, which may pose a significant challenge. The rule requires water to be “safe and of adequate sanitary quality” for its intended use including irrigation, make-up water in crop sprays, and water used in harvesting, packing, and holding activities, including handwashing.
Water sources must be tested and meet microbial standards for the intended use, and either treated or subjected to other corrective measures. Recordkeeping of these activities will be essential; in fact, a lot of the FSMA rules require documentation.
If subject to the new rules, growers would have inspections quite different from GAP audits, which are for business or commercial purposes. Inspections will be to determine compliance with the rules and to enforce an action if you are out of compliance.
Preventive Controls rule
Symposium speaker Richard Stier, a consulting food scientist and member of the ABCs Technical Expert Review Panel (TERP), discussed differences between third-party audits and the Preventive Controls rule. Essentially, he says processors who participate in these audits, such as GFSI, will be very close to being in compliance and will be compliant with “add-ons” to their food safety plan.
He suggested the areas of concern would likely be with validation documents and verification programs.
It’s free – Western Farm Press Daily – agricultural news delivered to your Inbox.
Hazard Analysis Critical Control Point (HACCP) under the Preventive Controls rule was addressed by Linda Harris, microbial food safety specialist and now chair of the Department of Food Science and Technology at UC Davis. Harris has been working with the almond industry for 15 years.
Harris says a hazard analysis must have written documentation, including documentation of your thought process, prepared by or under a Preventive Controls Qualified Individual (PCQI).
Identify and evaluate known or reasonably foreseeable hazards in the food you produce.
Determine if any of the hazards require a preventive control.
Without a solid hazard analysis, everything else in your food safety plan starts to unravel because this is truly the foundation, she cautioned the handlers in the audience.
The rule includes a requirement to look at food allergen preventive controls, sanitation preventive controls, supply chain preventive controls, and you must have a recall plan.
Harris included resources for preparing a hazard analysis which can be seen in her presentation at www.Almonds.com/FoodSafetySymposium. I encourage you to go to this site to review presentations from other symposium speakers to expand your understanding of FSMA rules that pertain to you.
The Almond industry has a solid food safety foundation, and resources such as these will help us to build on that foundation.
For information on upcoming PCQI training or Hazard Analysis resources, please contact me at [email protected] or (209) 343-3222.