MSU Extension Agrifood Safety

Phil Tocco
Extension Educator, Preharvest and Postharvest Food Safety

Implementing food safety practices on fruit and vegetable farms has been challenging. In response to this, a lot of different programs have sprung up to help. Growers have so many different programs to choose from, it can cause confusion as to what is the best route to take to ensure they are implementing the best practices for their operation. This article will review a few programs that often are confused.



Audits vs. Regulation

Over the years, fruit and vegetable growers have been asked to implement many produce safety practices. Some of these practices are required by law, while others are a prerequisite to sell to certain buyers. All have left growers with many questions. Because of this, a lot of programs to help growers implement produce safety practices have emerged. Now growers often don’t know which program would help them best.

When implementing produce safety practices, growers could be asked to have an audit by a buyer or need to go through an inspection. Let’s quickly review the differences between produce safety audits and inspections. Audits are usually a prerequisite to sell to particular customers. Because a grower can choose to sell to customers that do not require audits, they are considered voluntary. Audits usually follow a checklist with the relative risks of different food safety hazards weighted by a number of points. In some cases, growers only need to achieve a percentage of the total score to pass an audit. This allows growers to choose certain low risk practices to ignore or not implement and just “take the hit” on the audit. These audits are annual, and sometimes several may be conducted in the same year. In the case of several brands of audits, they only cover one crop per audit.

The Produce Safety Rule

Food Safety Modernization Act (FSMA) Produce Safety Rule (PSR) is a law that defines the practices necessary to grow, harvest pack and hold safe food. Inspections using the law as a benchmark are not based on points. All key components to a law where an inspection is required need to be considered. Inspections are usually not annual, allowing for a facility to adopt changes gradually. An inspection also covers the entire farming operation, looking at how the whole farm handles the whole range of growing and harvest activities across different crops.

Two programs that are often confused to help growers prepare for audits and inspections are the Produce Safety Risk Assessment (PSRA), and the On-farm Readiness Review (OFRR). The PSRA looks at a grower’s produce safety practices to provide an action plan as to best practices, and how to implement specific to their operation. It can be done any time of the year and progressively over a season or more. The PSRA has been calibrated to meet FSMA PSR Requirements, but covers more produce safety practices than just those found in the Produce Safety Rule. The PSRA is voluntary, free and confidential. It is conducted by a Produce Safety Technician, one of several specially trained individuals located in Conservation Districts across the state. At the end of a PSRA, a grower receives a certificate they can display at their point of sale signifying they have completed a PSRA.

The OFRR is specific to the Produce Safety Rule in that it only covers the requirements of the Produce Safety Rule. Food safety hazards, like physical or chemical contaminants are not covered by the Produce Safety Rule and are generally not addressed in an OFRR. The scope of an OFRR is a close example or run through of what an inspection could look like. As such, it is of limited utility for growers who only grow produce that is rarely consumed raw or who gross less than $25,000 in annual produce sales. For best results, the OFRR needs to be conducted during harvest. Like the PSRA, an OFRR is voluntary, free and confidential. OFRRs are carried out by one produce safety technician and one MSU Extension educator with some training in on-farm produce safety. The grower retains all notes taken by the OFRR Team on the farm. No certificate is given for the completion of an OFRR.

If you would like to talk through what exactly you need you are welcome to reach out to either your local Produce Safety Technician (listed here) or MSU Extension Agrifood Safety Team (gaps@msu.edu).

Funding for this article was made possible, in part, by the Food and Drug Administration through grant PAR-16-137. The views expressed in the written materials do not necessarily reflect the official policies if the Department of Health and Human Services; nor does any mention of trade names, commercial practices or organization imply endorsement by the United States Government.