FSMA Produce Safety Rule or GAPs?

The FSMA Produce Safety Rule compliance dates began January 26, 2018 for most requirements, except the agricultural water related requirements. The largest farm businesses have to meet this earliest compliance date, with small and very small farm businesses having an additional one year, and two years (respectively) for most requirements.

Now that the first wave of produce farm businesses are becoming regulated for the very first time, I thought it might be good to look at the differences between the FSMA Produce Safety Rule and GAPs (good agricultural practices).

Some questions might be…

Does the Produce Safety Rule replace GAPs?

As a farm, do I have to do both?

Do they work together?

Naturally, the answer to each of these questions is not so straightforward. First, lets look at a summary of both the FSMA Produce Safety Rule and GAPs:

FSMA Produce Safety Rule

This is a newly mandated program that governs the on-farm practices of growing certain fruits and vegetables. The list of covered crops is long, but basically any produce crop that is likely to be eaten raw is covered.

The Produce Safety Rule is a science- and risk-based approach that aims to minimize or prevent contamination of produce instead of react to an outbreak after the fact. It covers 5 identified contamination routes:

• worker health and hygiene
• agricultural water
• soil amendments of animal origin
• wildlife and domestic animals
• sanitation of tools, equipment and buildings

Baseline criteria and standards are prescribed, however, each farm has the flexibility to determine how they will comply, based on their specific farm operations. Food safety plans are NOT required, but the Produce Safety Rule requires records to be kept.

Some farm operations may be exempt from the Produce Safety Rule, but all farms are encouraged to comply with the standards to improve the quality of the US food supply.

GAPs (Good Agricultural Practices)

Prior to FSMA, the FDA and USDA developed the Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables, (released 1998). The common name is GAPs (Good Agricultural Practices ) and GAPs are voluntary guidelines for those grow, harvest, pack and transport produce. Guidance is given for the following points of contamination:

• agricultural water
• worker health and hygiene
• soil amendments
• sanitary facilities -restrooms and handwashing for workers, volunteers and customers
• field sanitation – harvest bins, totes, knives and equipment
• pack facility sanitation – sorting tables, bins, equipment, and pest control
• transport – growers, packers, distributors, wholesalers, etc.
• traceback

GAPs Audits

Although voluntary, GAPs compliance is also market and consumer driven. Buyers, farmers market organizations, school districts and consumers may require a farmer have a GAP audit as a condition of purchase, or presence at a farmers market.

Audits are conducted by 3rd party organizations (both government and private sector organizations), usually at a cost to the grower. In preparation for the audit, it is generally necessary for a farm to have a written food safety plan and at least one growing season of documentation for an audit to be performed.

As a grower in need of a GAPs audit, make sure to ask questions of your buyer(s) before hand and research the type of audit you need.

The USDA Produce GAPs Harmonized Standards  is a combination of the official two separate Produce GAPs Harmonized Food Safety Standards posted on the United Fresh website.

The ‘Harmonized GAPs’ standards (generally meaning GAPs) are designed to meet the majority of buyer requirements (with riders added as necessary). Just know if you need a ‘Field Operations and Harvest’ focused audit or a ‘Post Harvest Operations’ focused audit, or if you want both.

Produce Safety Rule or GAPs?

At the beginning of this article, we posed potential questions about compliance with the Produce Safety Rule or GAPs. Let’s review potential answers.

Does the Produce Safety Rule replace GAPs?

No. The Produce Safety Rule should be considered a baseline level of produce safety. GAPs are market driven, and buyers or consumers may ask for a written food safety plan or audit as a condition of sale.

As a farm, do I have to do both?

It depends. A farm’s business size (as defined in the Produce Safety Rule) and the crops grown will determine if they are regulated by the produce safety rule. As an additional standard, a farm’s buyer(s) may require them to have a written food safety plan only, or perhaps a food safety plan and GAPs audit.

Do they work together?

Probably, but at this writing, it’s not clear the exact extent. The Produce Safety Rule requires certain recordkeeping, but not an actual food safety plan. That recordkeeping will be a good start on a food safety plan but additional documentation is probably required.

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Thank you for stopping by!

So you want to know the longer story?  Okay, then 🙂

In my past life I was a county health inspector – you know the kind, where restaurant scores and inspection notes were sensationalized for ratings…but I digress.  Yeah, that kind of health inspector, except I mostly inspected septic systems.  Ewwww, right?

Not for me…getting paid to play in the dirt was awesome! To be fair, though, it was mostly inspecting the construction of the system before it was in use.

I loved meeting ordinary people who had no clue about the regulation process, educating them on the purpose behind the regulations and being their advocate to make sure their septic system was designed and constructed correctly and in compliance.

Being the Program Coordinator for many years, I made sure every aspect of the program ran smoothly, trained other inspectors, creatively solved difficult situations while adhering to the regulatory process and diffusing difficult conversations with property owners who were angry just having to deal with us.

I understood their point of view, that from a regulatory perspective, I essentially told them what to do on their property, when it had to be done by and how much it was going to cost.

As you can imagine, that didn’t always make me popular.

In this technical-oriented job I also did a lot of writing – land development proposal recommendations and presentations to elected officials, grant application and report writing to funding agencies, and educational materials for the public.  But even in college, I loved the researching and writing required for my Chemistry Minor.

I’m a natural writer, educator and innovative problem solver, and I thrive on finding win-win solutions, so from that perspective, I loved my job.  But, it wasn’t always easy and I know my personal relationships suffered.

Along the way, I discovered a fun and memorable way to apply personality styles to improve relationships – both personal and professional.  Getting certified as a trainer,   I began putting my skills into practice, recognizing peoples’ personality styles and communicating in their ‘language’.

It was amazing and rewarding to see people’s resistance melt, and you know what?  Those difficult conversations weren’t so difficult after all. They actually became fun!

And my writing improved immensely, too.

But being in that position you really have to develop thick skin because people don’t like the ‘regulator’ person, even if you are trying to enforce regulations and be their advocate at the same time.  So, after 20 years, it was time to switch gears and step into the regulatory consulting role.

When the buy local produce movement gathered steam with the USDA Know Your Farmer, Know Your Food Initiative in 2009, I put my regulatory knowledge to use in consulting, educating and writing about food safety regulations and practices, bridging the gap between on-farm good agricultural practices and retail food regulations.

I’m happier.  I’m still the educator, and advocate, problem solver and solution provider, but without the regulator/enforcer hat.  That is a win-win for me!

So now I help busy people in the local foods, produce food safety and public health spaces who need copywriting, consulting and training support so they can confidently get on with serving the people they were meant to serve.

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13 Top Menu Trends Grounded in Agriculture [Infographic]

Earlier this year, the National Restaurant Association put out a report on What’s Hot for 2016 for menu items.  This is an annual report which is intended to give insight to consumer’s food and menu preferences for the upcoming year – in this case, 2016.   These results will drive menu planning, meal creativity…and purchasing requirements!

The list features 192 items total, in various categories such as: food, beverages (alcoholic and non-alcoholic), kid’s meals, ingredients, preparation methods and the moer.

When reviewing the list, I noticed there were quite a few items that were ‘grounded in agriculture’, but some items I thought would be high on the list, weren’t – heirloom tomatoes, for example are #93, while heirloom apples are #26.

So I decided to compile a list of menu trends ‘grounded in agriculture’ – meaning, they start at the farm, and included grains and meats (in honor of my son-in-law’s family!), and a category I called Farm Legacy.

It is interesting to look at predicted restaurant menu trends for 2016 and where my own family’s food trends match.

This list reminds anyone working in the food growing, raising, or distribution sectors that the local food movement is still top of mind for consumers.  They want to feel good about the food they’re eating, and support local agriculture, businesses and local economies at the same time.

Useful for Marketing Purposes, Too!

Put this information to use in your marketing channels (website, print, blog or other channels).  Whether you are growing or raising the foods listed on the infographic or are the food distributor, help your customers recognize your part in the local food movement.  AND provide them marketing materials they can use to show their consumers they support it too!

Think About Your Marketing

If your various marketing channels can’t clearly help your customers see your connections to these menu trends, you have a profit gap that needs to be closed.

If you need help with your marketing copy, or would like ideas on how to use this information to maximize your marketing efforts,  contact Pam for a free consultation.

P.S. If you would like a free, printable version of this 13 Top Menu Trends Grounded in Agriculture [Infographic], plus 4 tips for using these in your marketing copy, fill in the form below.

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Crack the People Puzzle Code to Success

People are predictable,  once you understand them.  Using simple, easy-to-apply, proven principles we show you how to solve your communication problems quickly. Communication is key to success in business and personal relationships.

Communication is Key

Solve communication problems quickly.

People do business with people they like… and who produce results.

Relationships are the key to growth for any company.  As your company grows, relationships become even more important.

Clients may talk to several people in your office in the process of getting your product or service delivered to them.  Trust me, they can tell when you’re not communicating!

If you don’t understand the power of relationships, a lot of business could be walking out the door.  And you may not even realize it.

Business Application

How well you communicate not only affects your business successes, but your personal relationships, too.  And whether we like to admit it or not – our personal relationships affect how well we function at work.

About This Website

I’ve spent hours and hours learning what it takes to have better relationships with the people I care about.  I also started noticing how it spills over into my work, helping me be more successful there, too.  No matter whether you know them in your personal or professional life, people want to be appreciated, not tolerated.

I found a system that’s not only simple and fun (yes, a lot of them are) but this system takes it to the next level and shows you how to apply the principles to get results.

There are online tools and resources available to help you, too.

Personal Application, Too

This website focuses on information for businesses, but if you want to improve your personal relationships, takes a look at the information offered in the Complimentary Resources section.  Acquire the knowledge and skills available there.

You don’t have to settle for the relationships you have – but you do have to do something if you want to improve them.

That’s what we’re about…

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4 Reasons to Have a Food Safety Plan

You’re busy doing what you do best – and love – growing, beautiful, mouthwatering fruits and veggies.  Who has time for paperwork, right?

I hear you!

I don’t care how good Your food safety plan is,  if it’s  IN.  YOUR.  HEAD.  it’s only good for the person who has access to it, YOU!

I hate to break it to you, but if a food safety plan isn’t documented, it doesn’t count.  Here are 4 reasons to have a food safety plan (and there are probably more):

1.   No worker can follow it – as a farm manager or operator, you can’t be everywhere all the time.

• What time of day (outdoor temperature) do you aim to finish harvesting for optimal crop quality,
• Do you have to wash and sanitize tools before harvesting,
• How to mix sanitizers.

2.   No buyer can review it – check to see how you are handling  key aspects of your farming operation.

• Crop cooling at harvest and during storage and transport to the point of sale,
• What you do if a worker comes to work sick,
• Rules on allowing pets in the fields,
• Application of soil amendments and time to harvest,
• Water quality documentation,
• Or other food safety related questions.

3.   No audit can happen – if you are selling directly to a buyer, they may want to do an informal food safety plan review and audit themselves.  Other wholesale or retail buyers may require a 3rd party audit as a part of the transaction.

• You can’t write a plan at the time of harvest, when you are negotiating a sale to a wholesale or retail buyer
• Not documenting an existing written plan’s practices (with receipts, SOPs, log sheets, water test results, etc) on what you did during the growing season

4.   No proof can exonerate you during an outbreak – if your farm’s crop(s) are identified as potentially being part of a suspected outbreak, you want to quickly be able to clear your farm’s name from suspicion.

Fine Tune Your Food Safety Plan

The good news is that you probably already have good agricultural practices in place on your farm.  Maybe it just isn’t written down in a food safety plan.  You probably even have some informal documentation happening in various forms – pocket-sized notebooks, email receipts and the like.

With the new Food Safety Modernization Act (FSMA) produce rules finally in effect, the earlier in your growing season would be a good time to see how your existing practices measure up.  That way you can start the season off on the right foot.

I would hate to see you miss out on a sale because you don’t have a food safety plan.

If you need help reviewing your existing plan or documenting your food safety practices better, let me help.

So YOU can get on with growing that beautiful produce!

The post 4 Reasons to Have a Food Safety Plan appeared first on Happy People Enterprises.

According to the National Restaurant Association’s What Hot 2016  Culinary Forecast,  these are the 4 top produce trends, including their rank.

#3    Locally Grown Produce

#26  Heirloom Apples

#30  Organic Produce

#31  Unusual Herbs

The post 4 Top Produce Trends in the Food Industry 2016 appeared first on Happy People Enterprises.

USDA AMS screenshot capture 3/19/2015

UPDATE 3/23/2016:  The USDA website has been updated and the report is no longer posted on their website. Colorado regulations have also changed, so references to those regulations in the report are also outdated.  BUT the report can still be valuable if you want to get a general idea of how Federal and State of Colorado regulations impact the local food system.  Use this link to access the report –> Food Hubs and Food Safety Regulations.

In 2011, I researched and wrote a report on the Federal and State of Colorado food safety regulations that a startup food hub would need to consider as a part of business development.

This was for the client I was working for at the time, and provided valuable information for any food hub enterprise that was subject to Colorado regulations.

It was written from the perspective of understanding the regulatory chain of enforcement and what regulations a local food hub would need to comply with based on their product offering. It focuses primarily on produce, but also includes regulations for meat, poultry, dairy, and eggs.

I am very pleased to find that this Food Hubs and Food Safety Regulations report has been listed on the USDA Agricultural Marketing Service website!!

I have no idea how it found its way to USDA, but now that it’s gone beyond my client’s initial use, am excited to be able to share it publicly.

Regulations have changed in Colorado, and the Food Safety Modernization Act implementation coming later in 2015 (page 8 of link) will impact local food production further, so you must take that into consideration when reading this report.

However, if the food regulatory oversight picture is confusing to you, this Food Hubs and Food Safety Regulations (see the link at the top of the page) report will still give you an overview of how Federal and State of Colorado regulatory requirements impact the local food system.

Please remember this report represents a ‘snapshot in time’ of applicable Federal and Colorado food safety regulations in 2011. Do your homework to confirm which regulations are currently in effect for your specific situation as you develop your business model.

If you have questions, please feel free to contact me.

Pam

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Is Your Business Plan Sitting On The Shelf or a Guiding Document?

Many times, business documents get written and then sit on the shelf collecting dust until it’s time to revise them again. Maybe that sounds like you business plan.

BUT it doesn’t have to be that way.  With the end of the year rapidly approaching, maybe you are starting to put ‘updating the business plan’ on your radar.  Here are 10 tips for making your business plan functional and grow with your business this next year:

1. Your Plan Should Guide You to Growing Your Business

Think of your business plan as a business guide for the next year.  No matter whether you have 5 year or 3 year financial projections, make sure you include incremental for goals, marketing and brand identity to  give you a strategic roadmap to get you where you want to be in that identified time frame.

2. Review and Update Annually

Take a look at what has changed since your last plan. What goals did you meet?  What is your identity? Not only what public accolades, awards and recognition did you receive, but what are your employees saying about you?

You don’t have to survey them, but you can evaluate how they feel about working for you by their engagement level. How has the competitive landscape changed and how do you need to adapt to stand out? Need help with that?

Get our Engaging the Multi-Generational Workforce paper to learn more about employee engagement and what the ROI is for having an engaged workforce.

3. Make Your Business Plan Flexible, Quick and Timely

Don’t make writing you business plan an painstaking, 6 month project to complete. In this fast-paced world time sensitive assumptions will be outdated before the plan is finished if you draw out the writing of it.

4. Keep It Appropriately Sized For Your Business

Are you seeking outside investment?  Then in addition to goals, marketing and brand identity, you will need sections like market forecasts, and management team profiles to convince investors the market exists and you are capable.  These areas can also identify weaknesses to address.

Are you in a rapidly growing industry sector?  Then personnel, equipment and infrastructure needs and strategic focus sections should also be included. Only make the business plan as detailed as you need to guide your business for the timeframe you have identified in #1.

5. Get Buy-In

To some, this might sound strange, but giving your management team the opportunity to help create the goals and strategies empowers them to go the extra mile to hit the mark. This helps improve employee engagement.  This also gives managers a specific roadmap, enabling them to become more effective.

6. Include Metrics to Track Progress

Naturally, it starts with money metrics: sales, costs, expenses, profits, assets, liabilities, capital, interest and taxes.  What else do you want to track progress on?  Orders, deliveries, repeat customers or clients, complaints, employee turnover, web traffic? Think outside the box, and make your business plan work for you.

7. Milestones

Answer these three questions: What do you want to do?  By when? Who is in charge of it? Think in terms of concrete, specific dates and deadlines.

8. Financial Considerations

Include anything that has an expense or revenue attached to it. Some or all of these might apply to your situation: budgets, forecasts, what will it cost, how much will it bring in, equipment and infrastructure additions or upgrades (both future and immediate), personnel, membership fees, etc.

9. Marketing Analysis, Research or Trends

Depending on how formal a business plan you need (meaning if you are seeking outside investments or lender) will determine you need to have an emphasis on special research and analysis. Possibly identifying industry, social and political trends that are driving your market is sufficient.

10. Identify Gaps

No matter how simple or formal, a good business plan will likely identify gaps or weaknesses to reaching your goals. While it might seem disappointing at first, to not be able to write stellar sections that show you have it all together, you can look at it as a benefit.  Not being able to see your weaknesses is going to hold you back from reaching your goals. Knowing this, you can strategize how to solve the problem and close the gap.

Overwhelmed at the thought of updating your business plan?  Need help making your plan more of a guide?  Contact me for a free consultation and see if we are a good fit.

Adapted from Tim Berry’s The Plan-As-You-Go-Business Plan, 2008.

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Engaging the Multi-Generational Workforce

Not only is an engaged workforce profitable for the employer and share holders, but it is also a satisfying place for the employee to work. Whether employees specifically seek out the ‘contentment’ component, the majority of employees leave because of the lack of workplace satisfaction.

Where you find organizations that are considered Good Places to Work, you find engaged employees, and usually a sizeable percentage of them.

Most employees don’t become engaged on their own. If an organization wants to increase employee engagement, they must be an engaged employer.

An engaged employer expresses several observable characteristics: strong, authentic values that they operate by, an overwhelming demonstration of trust, fairness, and mutual respect for all, and a clear reputation for understanding and fulfilling promises and commitments.

Click HERE to get instant access to the free paper.

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