Proactive Measures To Promote Citrus Food Safety

Editor’s Note: This article is the first in a series of six special features on research presentations from this year’s Florida Citrus Show. Special thanks to KeyPlex for sponsoring this series.

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Food safety good agricultural practices (FSGAPs) are risk assessment and risk reduction programs from the farm to packinghouse. Food safety is everyone’s responsibility and FSGAPs are a key component of many food safety plans.

Florida’s fresh citrus export companies were early adopters of FSGAPs programs. Though this process was initially encouraged by the retail trade, FSGAPs are now widely adopted among exporters and companies operating primarily in domestic channels. Many third-party food safety audit programs require FSGAPs. Traceability and recall programs require FSGAPs documentation. In the future, buyer requirements might include FSGAP documentation. Though FSGAPs are not presently mandated, growers would be well served to establish FSGAPs now.

The Food Safety Modernization Act will provide expanded authority, funding, and enforcement capability to FDA to enact food safety regulations. It is expected that FDA will publish its Produce Food Safety Rule (expected to be called “Preventative Controls for Fresh Produce”) by late 2011. FSGAPs will undoubtedly be a key component of FDA produce regulation.

In early 2010, FDA requested input from industry to learn how FSGAPs should be structured for fresh produce. As a proactive effort the Indian River Citrus League (IRCL) and Florida Citrus Packers crafted a FSGAP working paper guideline by referring to United Fresh’s GAPs Harmonization Initiative, the Food Marketing Institute’s Global Food Safety Initiative, and the Association of Food and Drug Officials’ Model Code for Food Safety. The Fresh Florida Citrus document has been posted at IndianRiverCitrusLeague.org. Growers should understand that this document is not prescriptive, nor is it a one-size-fits-all. This guidance document is intended to enable growers to understand fundamental and essential food safety requirements identified in various standards to assemble evidence required when GAPs are audited; and to develop their own individualized plans.

Road To Harmonization

 
Commonly employed Florida citrus production and packing practices can and do result in safe food. The working group focused its efforts on identifying essential elements of FSGAPs programs, referencing credible science that substantiate their use, and providing examples of how growers might address these issues in their FSGAPS plan. The document posted in the IRCL website is a working paper, in the sense that content and form will be improved as better information becomes available.
United Fresh has been working toward a harmonization of FSGAPs standards. This project has identified the essential components of FSGAPs programs, and has harmonized the commonalities among numerous third-party plans. This is the most comprehensive and credible effort of its kind. The Florida fresh FSGAPs working group is in the process of benchmarking its working paper against the United Fresh template.
Other produce industry working groups and regulatory bodies also are aligning with the United Fresh harmonization standard. Both the Florida fresh citrus FSGAPs working paper and the United Fresh harmonization address pre-and post-harvest issues. Though traditional GAPS are on-farm (stopping at the farm gate), FDA has clearly communicated a desire that produce FSGAPs move beyond the farm gate to include the packinghouse.
Comprehensive FSGAPs plans should address: risk analysis, pesticide use, worker hygiene, water, nutrients, traceability, recall, irrigation, pest management, training, education, food defense, management responsibility, and recordkeeping. Though guidance, road maps, and sample plans are certainly beneficial, it is neither possible nor practical to develop a one-size-fits all FSGAPs program for industry. It is critical that growers consider the unique aspects of their operation, taking into account issues related to land, production practices, water source, water use, etc. There will be much in common between plans, but each will be unique.

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