Having the right grower training for FSMA compliance
As a fresh produce grower, are you getting the right training to be Food Safety Modernization Act (FSMA) compliant? Find out if your training will meet FSMA requirements.
October 13, 2016 - Author: Phil Tocco, Michigan State University Extension, and Don Stoeckel, Produce Safety Alliance, Cornell University
On farms looking to be Food Safety Modernization Act (FSMA) compliant under the Produce Safety Rule, provision 112.22(c), “One supervisor or responsible party for each farm must have successfully completed food safety training at least equivalent to that received under standardized curriculum recognized as adequate by the FDA.”
It’s important to ask questions to ensure the time and money you spend on the training is money well spent to comply with the FSMA rule. There are a few hallmarks to look for to help determine if you’ll get what you pay for.
Is the course material recognized by the U.S. Food and Drug Administration (FDA)?
As of this writing (Oct. 13, 2016), there is only one standardized curriculum recognized as adequate by the FDA. It was created and is administered by the Produce Safety Alliance. If the slides and print material as part of the class you are in do not have the Produce Safety Alliance logo on them, it may not meet the training requirement of the FSMA Produce Safety Rule written in provision 112.22(c). Other non-Produce Safety Alliance training offerings may be developed in the future and considered equivalent.
Is the training being conducted by a Produce Safety Alliance lead trainer and trainers?
All current (2016) trainings that meet the training requirements for the FSMA Produce Safety Rule must have a Produce Safety Alliance lead trainer present and all training must be conducted by Produce Safety Alliance trainers. This means they must have attended the Produce Safety Alliance Train-the-Trainer Course and, in the case of the Produce Safety Alliance lead trainer, have submitted and been approved through a lead trainer application process. Each training must have at least one of these Produce Safety Alliance lead trainers, but other Produce Safety Alliance trainers that have completed the Produce Safety Alliance Train-the-Trainer Course may present modules during the Produce Safety Alliance Grower Training Course.
Each Produce Safety Alliance trainer should have a certificate and a Produce Safety Alliance trainer number, either online or with them at the time of training. If the team of people teaching the class does not have at least one Produce Safety Alliance lead trainer, it is not a Produce Safety Alliance course and it may not meet the supervisory training requirements of the FSMA Produce Safety Rule.
Will you receive a certificate from a third party organization upon completing the training?
Individuals who complete the Produce Safety Alliance Grower Training will be eligible to receive a certificate from the Association of Food and Drug Officials. The Association of Food and Drug Officials is an independent organization working in collaboration with the Produce Safety Alliance to serve as the long-term records archive for Produce Safety Alliance training. If you are not given the opportunity to obtain a certificate from the Association of Food and Drug Officials, you are not in a Produce Safety Alliance course.
To help you take the guesswork out of what does and does not qualify as the right training, Michigan State University Extension will be offering three pilot grower trainings in Michigan in November 2016. The pilots will be held Nov. 2 in Hart, Nov. 9 in Bay City and Nov. 10 in Benton Harbor. These are only the first dates and will be followed by many more beginning in January 2017. For more information or to register, visit: 2016 Grower Produce Safety Course.
The FSMA Produce Rule Grower Training will cover a broad swath of produce safety. Topic areas include worker health and hygiene, water quality in pre-harvest and post-harvest environments, crop inputs and wildlife. Much of this training will help reinforce what growers already know and put into practice on their farms. Training doesn’t, and shouldn’t, end with the grower on a farm. A robust food safety culture on-farm depends on regular training of farm workers as well as continuing education at conferences and field days.
If you have difficulty tailoring good agricultural practices (GAPs) to your farm or would like to enroll in a grower training, contact the Agrifood Safety Work Group at firstname.lastname@example.org or 517-788-4292.