While the passage of the Food Safety Modernization Act (FSMA) will mean new policy and procedures for some, others already have been there and done that. Many growers practice good agricultural practices (GAPs) and have them confirmed through third-party audits. And, some grower groups have instituted mandatory food safety programs, which should put them ahead of the curve as the FSMA is implemented.
It remains to be seen exactly how the new law will impact groups with food safety programs in place, but leaders from these various organizations say they have been impressed by the collaboration FDA has shown in recent years after taking lessons from past high-profile incidents.
According to Reggie Brown, executive vice president of Florida Tomato Exchange, both the industry and FDA have come a long way since the agency incorrectly identified tomatoes as the source of a salmonella outbreak in 2008. It was later determined peppers from Mexico were the source. “I will be the first to tell you the events from 2008 were very much less than ideal,” says Brown. “But since then, both the industry and agency went through that process of excruciating pain, which led to an opportunity to establish a much closer working relationship. The level of communication and cooperation between FDA and the tomato industry has gone up very significantly.”
Today, Florida tomatoes operate under a mandatory food safety program, which is enforced by the Florida Department of Agriculture and Consumer Services. The program was developed using the guidance document developed by FDA.
“We worked with the agency to develop our tomato metrics, and they have endorsed our program,” says Brown. “Florida has established and had significant success in tailoring the metrics to the different ranges of production in the state. We believe it will be viewed as a model on how to ensure tomato food safety nationally.”
So how have growers and packers taken to the program in Florida? Brown says the program has been running well. The biggest adjustment for some are the recordkeeping requirements, but he adds once these procedures are in place, maintenance becomes less of a burden.
“We have had a few enforcement actions, but the violations have not been great,” he says. “Most people already are doing the right things routinely just as a part of doing good business.”
In 2006, a major E. coli outbreak traced back to leafy greens in California, which resulted in a media firestorm that nearly brought the industry to its knees. The California Leafy Greens Marketing Agreement (CLGMA) was established in 2007 in response to the disaster. The program is voluntary to join, but mandatory once a grower or handler becomes a member.
According to Scott Horsfall, chief executive officer of the CLGMA, about 99% of the state’s leafy greens producers now participate in the program. “We are almost four years into the program and members accept our food safety metrics and confirm this through audits by state officials,” he says. “We audit our handler members four to six times per year and growers at least once per year. We have a very thorough program that has really brought the industry to a new level when it comes to food safety.”
Horsfall reports the CLGMA has developed a good relationship with FDA as the agency has been working on its produce food safety rule over the past couple of years. He believes the FSMA could put a more specific timeframe on these rules, but will not likely change the basic set of metrics that FDA has already been developing. “We are optimistic the FSMA will not add another layer of inspections and requirements,” he says. “Rather, we will continue to work closely with FDA to show them what we are doing could be a model for its ultimate rules.”
The Ohio Produce Marketing Agreement (OPMA) is currently being developed in response to concerns over the imposition of a national order the group fears would not take into account its growers’ local concerns.
According to Bob Jones Jr., who chairs the group’s advisory board, the OPMA takes what works from other food safety programs and takes the opportunity to improve the process to protect growers in Ohio. “Our program is a voluntary agreement and will operate under the guidance and approval of the Ohio Department of Agriculture,” he says. “We have worked closely with their food safety division to develop a program that will bring food safety to a higher level in the state.”
The OPMA provides a three-tiered approach, with tier I being the smallest grower and tier III the largest. The intensity of requirements is scaled to the size of operation. “We believe it is important for smaller growers to be included in the program,” says Jones. “Food safety is every grower’s social responsibility — regardless of size. This program is designed for growers by growers and will stand up to a high level of inspection from the state.”
The group has had an open dialogue with FDA as it builds its program. FDA officials were taken on a tour of Ohio produce farms both large and small to illustrate that rules must be scalable to the size of operations.
“FDA is very serious about the food safety charge it has been given, but not quite sure how to get there,” says Jones. “It is very refreshing to see them reach out for input at the grower level prior to rulemaking versus post rulemaking and taking comments after the fact.”
Currently, the OPMA is collecting signatures on a petition that will go to the Ohio Department of Agriculture this spring for codification. Growers already are signing up for membership in the group and will be implementing its four core food safety principles. Audits will begin this year and the program should be operating at full capacity by the 2012 growing season.
Training Is Key
Providing growers and packers with knowledge of how to implement the practices mandated by any food safety program is critical to success. “We have been providing training for our tomato metrics even before the program was mandatory,” says Brown. “The training is now a mandatory part of the program, but we’ve been providing it for three years now. “The biggest challenge has been the educational process because there was some ignorance of what the requirements are. However, that is becoming less of a factor every month, as they understand what they need to do, put the procedures in place to do it, and record and validate they are doing it.”
Harmonization A Must
While existing food safety programs might have different approaches to achieving goals, they almost all agree there must be harmonization in the auditing process. “I believe we have to get to a point of harmonization,” says Horsfall. “Even setting the FSMA aside, there is way too much duplication in the system. We see a lot of the same standards in place across various third-party audits. What we don’t have and need is a single recognized way for a grower to verify to his or her customers that food safety standards are being met.”
“We are getting some acceptance from our tomato customer base for harmonized metrics in Florida and California,” says Brown. “Ultimately, our goal is to cut the inefficiencies of auditing duplication out of the system to the benefit of not only producer community, but also further up the chain.”