Putting your FSMA plans in writing

Huddled over a laptop in a Syracuse, New York, basement meeting room, Eric Darrow and his father, Nate, debated about what to do if they caught an employee violating their food safety plan.

The owners of New York’s Saratoga Apple farm both favored a three-strikes type of policy, but they found it hard to commit to firing somebody for, say, not washing their hands. “The problem is, if you say you’re going to do it, you have to do it,” Nate Darrow said.

A disciplinary method was just one of the elements called for in a written food safety plan workshop put on by Cornell Cooperative Extension in January at the Empire State Producers conference.

Growers are coming under more pressure to document their methods of growing and handling food safely, typically called good agricultural practices and good handling practices. Several different private and public organizations act as third-party auditors for such practices, and many of them seek slightly different standards.

The workshop’s literature was designed to meet standards of U.S. Department of Agriculture audits. Others include GlobalGAP (short for Good Agricultural Practices) and Primus.

Provisions of the federal Food Safety Modernization Act soon to take effect only increase the pressure. The new law, signed in 2011 and implemented by the Food and Drug Administration, does not require a written food safety plan the way many of the audits do, but the Cornell facilitators have included more language into the workshops to meet the legislation and its complex array of requirements.

In fact, to participate in the food safety plan workshop, growers must attend a seven-hour session the day before from the Produce Safety Alliance about a variety of food safety practices that specifically address the new law’s requirements, as well as GAPs.

The Produce Safety Alliance is a cooperation of Cornell University, the Food and Drug Administration and the U.S. Department of Agriculture to help bring growers into compliance with the new regulations.

Roughly 500 growers have participated in the food safety plan writing workshops over the past six years, said Craig Kahlke, a Cornell tree fruit extension educator.

Most are from New York, but out-of-state growers have gotten involved at times. Only 25 percent to 33 percent of the participants finish their plans and sign up for an audit, Kahlke said. Most of the others tell him their buyers don’t yet require an audit.

However, that figure increases each year as more buyers require audits in reaction to foodborne illness outbreaks, such as cases involving melons in Colorado and caramel apples in California.

Northeast grocery chain Wegman’s, Subway and Burger King all ask their suppliers for U.S. Department of Agriculture’s Harmonized Good Agricultural Practices, an audit that attempts to cover the provisions of several third-party audits, Kahlke said.

The New York Grown and Certified program, which attempts to create a state-produced label, will require food safety audits, as well as some environmental reviews.

“It’s like the cost of doing business,” Kahlke said.

The plan-writing portion of the workshops goes beyond theory or hypothetical situations. Growers who want a food safety plan actually write them then and there, under the tutelage of Kahlke and Robert Hadad, a Cornell extension area vegetable specialist. They give everyone a thumb drive with reference material and a food safety plan template.

They even loan laptop computers at times. Some older growers have been known to bring computer savvy members of their families or farm staff to help. “People were bringing their junior high kids out of school to help,” Kahlke said.

Representatives from the New York State Department of Agriculture and Markets, which audits for the U.S. Department of Agriculture standards, also attended the Syracuse workshop to help.

The Washington State Tree Fruit Association plans to offer individual consultations to draft food safety plans on a contract basis, said Jacqui Gordon Nunez, director of education and member services. The consultations were designed to help meet different GAP requirements but have since been modified to include the new regulations.

Nunez and a team of certified trainers also may begin offering workshops on how to update food safety plans for those who fall under certain provisions of the new legislation.

The exercise forced some intimate discussions among a few farmers, such as the Darrows. They wanted something workable and enforceable but also that would pass muster with an auditing agency. They had to decide who they were going to consider a “visitor” because food safety plans apply to them, too. They had to detail how they would go about a recall if need be. And they had to put on paper how they would discipline employees for not following their new policy.

“You want to give your folks some wiggle room,” Nate Darrow said.

“I think the wiggle room is they have three strikes,” Eric Darrow said.

Like many farmers, they left the session vowing to complete the plan later but appreciated the head start.

They have some reprieve at Saratoga Apple, a small farm that does not sell wholesale. They sell year-round through several farm markets and their own busy farm stand, so nobody has pressured them to certify their farming and handling practices with an audit.

At least not yet. They believe it’s the right thing to do and figure more stringent rules are only a matter of time. “That doesn’t mean it’s not going to be required for us in the future,” Eric Darrow said. “So we want to get ahead of that.” •