By Sarah Everhart
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Farmers who grow produce that is often consumed raw (e.g. berries, leafy greens, tomatoes, cucumbers, etc.) are likely covered by the Food Safety Modernization Act (FSMA) Produce Safety Rule and are required to attend a Produce Safety Rule Training and take certain steps, including but not limited to, identifying and reducing food safety risks on the farm. Although the compliance dates for the Produce Safety Rule are staggered based on the size of the farm business, as of January 27, 2020 even the smallest operations to which the Rule applies had to be in compliance (certain aspects of the Rule related to water have later compliance dates).
Although the Produce Safety Rule is a federal law, in many states including Maryland, it will be enforced by state departments of agriculture. Compliance inspections began last year for the largest farms (those with average produce sales in excess of $500,000/year) and will continue this spring. Produce Safety Rule inspectors will be taking an “educate before and while we regulate” approach and as part of that approach are offering growers the opportunity to request a voluntary pre-inspection On-Farm Readiness Review (OFRR).
OFRRs are a free, non-regulatory review conducted on-the-farm by a team of experts from your state’s university extension and departments of agriculture. The OFRR team, over the course of a couple of hours, walk the farm and discuss with the farmer how the farm’s growing conditions, harvesting practices, packinghouse operations, and water sources compare with the requirements of the Produce Safety Rule.
An OFRR is meant to increase compliance readiness and assist growers with prioritizing food safety compliance needs. All of the notes taken during an OFRR are left on the farm and an OFRR will not result in any further regulatory action unless egregious conditions which pose an immediate threat to public health are discovered on the farm. For some growers, compliance with the Produce Safety Rule is daunting and an OFRR is meant to provide a level of comfort with the new requirements imposed by the Rule.
Common deficiencies that have been found during OFRRs include, but are not limited to, record keeping issues, inadequate post-harvest sanitation, and insufficient worker food safety trainings. According to experts in our region who have been conducting OFRRs thus far, growers who have an OFRR prior to inspection are much better prepared for the eventual inspection. To arrange an On-Farm Readiness Review contact Deanna Baldwin at 410-841-5769 or produce.safety@maryland.gov.