Produce Safety Rule Inspections: What You Need to Know

By Taylor O’Bannon, Matt Krug, Michelle Danyluk, Chelsea Peebles and Kirby Quam

Produce Safety Rule (PSR) inspections conducted by the Florida Department of Agriculture and Consumer Services (FDACS) are continuing throughout the state as compliance dates for all farm sizes have now passed.

The industry is also nearing the compliance date set by the Food and Drug Administration (FDA) for agricultural water (Subpart E), with large farms to begin in January 2022. While FDA has not released guidance or extended the current compliance dates for agricultural water, the hope is that these dates will be further delayed to allow time for education and compliance with rule changes.

Scheduling of inspections generally follows the patterns of produce production across the state. Florida citrus farms with seasons in the fall and winter should be preparing for inspections. Citrus growers and packers who are “large farms” and have not yet received a PSR inspection by FDACS should expect their inspection to be scheduled soon.

As more farms receive inspections throughout the state, trends among findings are emerging. One of the main trends being seen is centered around recordkeeping. Deficiencies related to recordkeeping include: record components, (date, time and supervisor review), missing worker training, cleaning and sanitiation, and Biological Soil Amendments of Animal Origin (BSAAO) records.

RECORD COMPONENTS
The description of the components that must be included in a record for the PSR are detailed in the Code of Federal Regulations Title 21, Section 112.161 (Subpart O). The citrus growing, harvesting and packing industry is encouraged to review all records to ensure they contain the legally necessary components. According to the PSR, records must include these general requirements:

• The name and location of the farm
• Actual values and observations obtained during monitoring (not a checklist)
• An adequate description of covered produce applicable to the record (commodity, lot numbers and other identifiers)
• The location of a growing area that defines the specific field, packinghouse or location applicable to the record
• The date and time of the activity documented
• Created at the time an activity is performed or observed
• Accurate, legible and indelible
• Dated and signed or initialed by the person who performed the activity documented
• Records reviewed, dated and signed by a supervisor within a reasonable time period after the record was created (i.e., weekly or when a log sheet is completed)

WORKER TRAINING
Worker training records are frequently noted as not meeting all the rule requirements. They must be kept for all workers who handle covered produce, touch food-contact surfaces or supervise covered activities. Each farm is required to train personnel before they begin covered activities, at least once annually, and periodically as needed. Training for farm workers must include:

• Principles of food hygiene and food safety
• The importance of health and hygiene for all workers and visitors, and how to recognize symptoms of foodborne illness
• Any PSR or food safety principles that are applicable to the employees’ responsibilities on the farm

Additionally, those who take part in harvest activities must be trained to:

• Recognize and not harvest produce that may be contaminated
• Inspect harvest containers to ensure they are working properly, clean and maintained to prevent contamination of fruit
• Correct problems and report problems to a supervisor

Records for worker training must also include the:

• Date of the training
• Topics covered during training
• Person(s) trained
•  Other record requirements outlined in Subpart O

CLEANING AND SANITATION
Cleaning and sanitation records must be kept by farms who conduct or contract third parties to conduct covered activities. Frequently, third parties are contracted to conduct harvest or cleaning and sanitation activities on farms. Farms are responsible for keeping records of the covered activities performed by their own employees and by the third parties.

Section 11.140(b)(2) requires that farms keep a record of the date and method of cleaning and sanitizing used in covered activities. Records that may be kept in a citrus growing or packing environment include: cleaning and sanitation of harvest or packing tools, equipment and transportation vehicles, in addition to the worker training requirements detailed above.

BSAAO
Biological Soil Amendments of Animal Origin are applied by the citrus industry to increase organic matter for water and nutrient retention in Florida’s sandy soils. The risks associated with application of BSAAO must be addressed to prevent fresh fruit contamination. Section 112.51 requires documentation of handling and treatment methods or a third-party supplier certificate of conformance records and application records.

GROWER RESOURCES
Recordkeeping templates and resources are available to assist growers with compliance of the PSR, including a recordkeeping tool developed by FDACS.

To best prepare for PSR inspections, growers, harvesters and packers should, at a minimum, follow Good Agricultural Practices, and a supervisor should attend a Produce Safety Alliance (PSA) grower training. This training continues to be offered at the highly subsidized price of $30 for remote and $40 for an in-person class through collaborations with the University of Florida Institute of Food and Agricultural Sciences (UF/IFAS) and FDACS. See crec.ifas.ufl.edu/extension/events for a list of upcoming PSA grower trainings.

The On-Farm Readiness Review (OFRR) program is another way to help growers prepare for a PSR inspection through a personalized site visit. UF/IFAS and FDACS representatives can address questions about specific practices or conditions at a farm or packinghouse. There is no cost associated with an OFRR. Sign up at fdacs.gov/FSMA for an OFRR.

For more information on resources and training, contact Taylor O’Bannon (taylorlangford@ufl.edu).

Taylor O’Bannon is a state specialized Extension agent in food safety, and Michelle Danyluk is a professor, both at the UF/IFAS Citrus Research and Education Center in Lake Alfred. Matt Krug is a statewide food science Extension agent at the UF/IFAS Southwest Florida Research and Education Center in Immokalee. Chelsea Peebles is an inspection supervisor, and Kirby Quam is an education and outreach coordinator, both for the FDACS Fruit and Vegetable Division in Bartow.

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