Training on food safety is an important part of bringing growers current on this important and developing topic. So for the 2nd year, a training was conducted at Morgan County Seeds in a similar format. It started with a general presentation about food safety (James Quinn) and was followed with step by step instructions on how to use the ‘Farm Food Safety Plan Guidelines and Procedures’ booklet and accompanying binder (Freeman Gingrich). This was developed by the Food Safety Education Team. The workshop benefited from having a USDA GAPs inspector on hand to answer questions, that being Mark Troup of Missouri Department of Ag.
Regarding the FDA article, there are a number of items that should be discussed or mentioned. First, the FDA has the legal right to pull samples from businesses and farms selling produce. It is very important that these samples are taken from typical produce being sold, therefore, it would be very beneficial for the auction manager to assist with sample collection at an auction. Any FDA inspector is expected to identify themselves and should be directed to the produce auction manager, as soon as coming to the facility. We encourage the auction to make any of these samples available at no cost and pull them from representative lots of commercial quantity (NOT from small lots). Second, it would be better for the samples to be pulled at the auction instead of a farm. The auction can (or should) assist in keeping track of what samples were pulled for which farms. The sampling methodology may be improved if samples are taken from several farms.
If a sample is pulled, a request should be made to have the results of that test be sent to the business or farm from which it was taken, as well as to the auction. We can’t predict what crops they will focus on, but we know cantaloupes (Listeria) and tomatoes (Salamonella) have been of interest.
Our understanding is that the FDA is not trying to ‘get’ farms for having contaminated produce and then quarantine or shut them down. Rather, the FDA wants to understand how widespread or how abundant a pathogen might be occurring. But if a farm has a contamination problem we really don’t know what further actions the FDA would take; we hope they would be reasonable in allowing the farm to remedy the problem and not cause serious economic harm.
The FDA has assured the Produce Auction Food Safety Team that produce auctions will receive an exemption from Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Controls for Human Food regulation as a food facility. A food facility is generally processing produce in some way, which an auction is not, and complying with these regulations would be very complicated and difficult. We hope that the final rule of the Food Safety Modernization Act, expected this fall at the latest, will define the situation.
REVISED: November 16, 2015