By: Chelsea Losh-Jones, Babe + Sage Farm
The Food Safety Modernization Act of 2011 (FSMA) regulates the way foods are grown, harvested and processed. FSMA requires the Food and Drug Administration (FDA) to review or inspect a host of reports, plans, strategies, standards, notices, and other tasks from farmers and food processors. This article is the first in a series written by farmers as they work their way through FSMA.
FSMA has many farmers nervous about what’s coming down the pipeline and how it will affect their farm. After some in-depth research, let me tell you – don’t worry, it’s really not that scary.
Most small farms, including ours, will be qualified exempt from most FSMA rules. Basically, if a farm has less than $500,000 in sales of all food (not just produce), based on an average of the previous three years, and more than 50% of your sales are to “qualified end-users,” then you are considered exempt from many of FSMA’s requirements. Although we are fully committed to food safety, this “qualified exemption” is a way to reduce some of the administrative burden for small farms. Some examples of “qualified end-users” are your CSA members, buyers at farmers markets, chefs at restaurants, and, for Georgia growers, groups like PeachDish or Fresh Harvest–at least, for now.
Still, at Babe + Sage Farm, we’ve taken it upon ourselves to ensure we’re compliant with most of FSMA’s requirements, even the ones we’re exempt from. We want to document that we’re taking steps to keep our customers safe, and we want to reduce our chances of making a product liability insurance claim.
We’ll need to make some small changes on the farm, like putting together a farm safety plan, developing a few more records, and labeling our produce, but it will not be much of a burden.
One way to prepare for a federally required FSMA inspection is to go through the GAP certification process (Good Agricultural Practices). Though voluntary, many wholesale, farm-to-school, and restaurant buyers may require GAP certification in the near future. If that’s your customer base, you may want to consider getting ahead of the curve.
GAP requires an audit and certification that are expensive for many smaller operations. If you are interested but cost is a concern, you may qualify for mock audits, cost-share programs, paperwork help, and/or group certification programs. Billy Mitchell at Global Growers (email@example.com) is working with other agricultural organizations in Georgia, and has a lot of information on available resources.
What documentation will help you be prepared for certifications like GAP and FSMA?
A Farm Risk Assessment Map, a Food Safety Manual, an Action Plan, Completion Records, and Labels are all a big part of the process.
These names may sound onerous, but you likely have most of this information already.
Your Farm Risk Assessment Map is simply a map that shows where people, animals, and vehicles move, where crops grow, and where you may come into contact with different water sources on your farm. The map can be hand-drawn, and the purpose is to start thinking about ways to limit the possible transfer of pathogens from your surroundings to your crops.
Your Food Safety Manual spells out the steps you’re taking to manage contamination risk from seed to sale. You may already be doing many of these steps, such as sanitizing your equipment or excluding chickens from the garden, for example.
Your Action Plan lists who is in charge of implementing food safety practices, who to call when something goes wrong, and how it gets fixed.
Your Completion Records are a basic record of when food safety-related tasks were completed (i.e. Chelsea cleaned the harvest bins on April 4th).
Finally, you must label produce or your market display with the name and complete address of your farm. This documentation is all about creating traceability: if someone gets sick, we can figure out where it came from and how to fix it.
In addition to preparing you for GAP certification, these records can get you lined up for Organic Certification as well. We’re looking to start the Organic Certification process in a couple of years and plan to use GAP record keeping to help us get into the right record-keeping groove.
Georgia Organics can guide you through this process, as well as offer marketing support, educational opportunities, and cost-share reimbursement for getting Organic Certification through their 200 Organic Farms campaign.
I encourage you to start thinking about FSMA, not get discouraged, and reach out to Georgia Organics at firstname.lastname@example.org if you have any questions. Let’s get modern, y’all!