Introduction to Food Safety for Wholesale Success This unit provides an overview of food safety regulations for agricultural producers and food entrepreneurs. How can food safety regulations help increase my economic success? Prevent loss and waste due to improper cooling or storage Reduce risk from foodborne illnesses and reduce liabilities Provide access to wholesale markets, where buyers require food safety certifications What will I learn from this course? Different types of food safety regulations and how to determine what applies to you How recordkeeping can increase your marketability Where to find in-depth training, resources, and support

Lesson Outline Overview of food safety regulations The Good Agricultural Practices (GAP) Voluntary Audit: USDA Food Safety Modernization Act (FSMA): FDA State Offices and Contacts Economic Success Wholesale Buyer Requirements Recordkeeping & Profitability Marketing Safe Products More Wholesale Resources

Part I: Overview of Food Safety Regulations The Good Agricultural Practices (GAP) Voluntary Audit: USDA Food Safety Modernization Act (FSMA): FDA State Offices and Contacts

Overview of food safety regulations Some types of food safety regulations are voluntary. Example: USDA Good Agricultural Practices (GAP) Certification Program Details: GAP is a voluntary, preventive program to ensure that you are following accepted food safety protocols for harvesting, handling, washing, cooling, and packing fresh produce. It is not required by USDA, but may be required by your wholesale buyer or distributor. USDA also maintains Good Handling Practices (GHP) programs for food handlers, GAP for mushrooms, and Harmonized GAP certification programs for some suppliers. Other types of food safety regulations are required. Example: Food Safety Modernization Act Program Details: FSMA is the first update to the U.S. federal laws about food safety in nearly 70 years. FSMA will typically only affect businesses who meet particular revenue levels or sell to particular markets. Generally, food safety regulations are enforced by the United States Department of Agriculture (USDA) or the Food & Drug Administration (FDA).

USDA GAP Certification Process USDA Good Agricultural Practices (GAP) Voluntary Certification Guidance that produce growers can use to prevent on-farm contamination of fruits and vegetables Developed by the USDA in 1985 Voluntary, although more buyers are requiring GAP Protect your farm business from the economic consequences of food contamination GAP is focused on prevention of contamination rather than remediation.

Basic Principles of GAP Prevent microbial contamination Implementation of a Food Safety Program Follow all applicable laws Traceability/recordkeeping/documentation 4 W’s +S Water, Waste, Workers and Wildlife + Surfaces

GAP Goals: Prevent Likely Sources of Contamination Biological: Bacteria, Yeast, Molds Physical: Stone, Glass, Metal, Surfaces Chemical: Pesticides, Fungicides, Food Allergens Where does contamination come from? Water Sources Unhealthy Employees Harvest Tools Dropped produce (bacteria) Previous Land Use Neighbor’s farming operations

Preparing For GAP Certification 1. Conduct an on-farm risk assessment. Farm History / Land Use Worker Health and Hygiene Restroom and Sewage Water Sources/Quality (microbial load) Animals Manures and Soil Amendments Equipment and Containers Product Traceability OTHER POTENTIAL RISKS: Harvesting Techniques/ Procedures Washing and Packing Produce

Preparing For GAP Certification 2. Write your food safety plan. Utilize the On-Farm Risk Assessment Write Standard Operating Procedures based on current practices (making minimal changes to daily operations). YOU determine the frequency that you feel you need to document certain risk mitigation strategies. Do not over-commit – make a feasible plan you can reasonably manage with your current capacity. Food Safety Plan Templates are available online. NC Cooperative Extension’s Online Food Safety Plan Course: https://ncfreshproducesafety.ces.ncsu.edu/ncfreshproducesafety-online-gap-food-safety-plan-creation-course/

Preparing For GAP Certification 3. Prepare for the audit: designate a Food Safety Officer. Responsible person who will ensure compliance with the Food Safety Plan that you have written. Must be present during the audit. Can be a shared position amongst owners. 4. Prepare for the audit: gather supporting documentation. Farm Maps (with field numbers) Facility Map Overview (keep it simple) Training Certificates Water Test Results (within 60 days of audit) Signage

Scheduling a GAP Audit 5. Submit application to Auditing Body. In North Carolina, the NC Department of Agriculture & Consumer Services Cooperative Grading Service conducts GAP audits. http://www.ncagr.gov/markets/gradnreg/foodsafety/index.htm Provide multiple dates to the auditing body. Timing is crucial in demonstrating multiple harvest techniques. Requesting an audit six weeks in advance is recommended. Cost: USDA mandates that all state auditors charge $92.00 per hour, including travel time. Canvass other farmers in your region who may be pursuing certification to apply for an audit on the same day. Some cost-share programs may also be available to assist you. Make sure you are fully prepared for the audit – it will be much less expensive if you are able to meet all standards on the first audit visit!

Recordkeeping It is not necessary to duplicate records (i.e., you may keep one set of records that meets both organic certification standards and GAP standards). Field Map Land History Manure Application Records Compost Monitoring Records Cleaning Records (equipment, transportation) Traceability Records

During the Audit: Automatic Failure Falsification of Records Failure to have a Food Safety Plan or Officer High presence of rodents or pests Failure to have water test on file (Total Coliform & Generic E.coli – quantitative results) Combining bleach with detergents Potential wash water hazards (high risk crops) Any immediate public health risk Immediate public health risks may include (but are not limited to) raw manure, cows in irrigation water source, birds nesting in packing houses, employees with communicable diseases, and other risks.

Additional Resources, State Offices and Contacts The NC Growing Together Project (NCGT), with partners NC Cooperative Extension (NCCE), NC State University (NC State), and the Carolina Farm Stewardship Association (CFSA), sponsors one- and two-day workshops across the state to assist farms in achieving GAP certification: www.ncgrowingtogether.org. CFSA offers free one-on-one consultations: www.carolinafarmstewards.org. For a comprehensive list of upcoming GAP training events, visit www.ncgrowingtogether.org. NCGT’s Guide to Cost-Share Programs & GAP Assistance https://www.ncgrowingtogether.org/ncgt-resources/assistance-for-farms-pursuing- gap-certification-in-north- carolina/?portfolioCats=192%2C195%2C187%2C188%2C189%2C211 GAP Workshop Manual (NCGT & CFSA) https://www.ncgrowingtogether.org/ncgt-resources/fresh-produce-good-agricultural- practices-workshop- manual/?portfolioCats=192%2C195%2C187%2C188%2C189%2C211 USDA GAP&GHP Online Resources https://www.ams.usda.gov/services/auditing/gap-ghp Several resources are available for learning more about GAP and the voluntary USDA audit process.

Food Safety Modernization Act The U.S. Food and Drug Administration (FDA) has published an update to the Food Safety Modernization Act (FSMA), which includes rules for various types of food producers. Although the official federal guidance on these rules has not yet been released, some resources are available now for producers and food facilities who wish to determine whether they will be subject to the new guidelines.* The law was signed on January 4, 2011, but has not been enforced yet. The federal government, through FDA, has been developing guidance on how to enforce the new regulations and who is subject to them. The update to the existing food safety legislation is the first in more than 70 years, and shifts the focus of food safety enforcement away from responding to contamination and towards prevention efforts. *As of September 1, 2017

Food Safety Modernization Act Exemptions: Farms selling less than $25,000 per year over a three-year average If produce is not consumed raw Those growing only for personal consumption What counts as raw? http://bit.ly/usuallyraw http://bit.ly/rarelyraw

Food Safety Modernization Act You may be covered fully or with modified requirements: Some types of processing can kill pathogens, which may mean you are not subject to full requirements Depending on whether you qualify as a small business and who your end users are, you may not be subject to full requirements More info: http://bit.ly/nsacproduce

FSMA: Additional Resources, State Offices and Contacts NCGT’s FSMA Resources & NSAC Flowchart https://www.ncgrowingtogether.org/ncgt-resources/fsma- resources-sept- 2016/?portfolioCats=192%2C195%2C187%2C188%2C189%2C211 NSAC Guidance on FSMA Impacts: Produce https://www.ncgrowingtogether.org/wp- content/uploads/2016/09/FSMA-PRODUCE-RULE-FINAL.pdf NSAC Guidance on FSMA Impacts: Facilities https://www.ncgrowingtogether.org/wp- content/uploads/2016/09/FSMA-FACILITIES-FINAL-.pdf FDA’s Page on FSMA http://www.fda.gov/Food/GuidanceRegulation/FSMA/ NC Cooperative Extension FSMA Guides, Area Agent Contacts, and Training Events: https://ncfreshproducesafety.ces.ncsu.edu/ FSMA: Additional Resources, State Offices and Contacts

Part II: Economic Success Wholesale Buyer Requirements | Recordkeeping & Profitability Marketing Safe Products | More Wholesale Resources

Wholesale Buyer Requirements Wholesale produce buyers & institutional purchasing agents are enthusiastic about helping farmers understand postharvest needs. They see value in: Educating growers Providing packing information Extending shelf life Often, buyers will attend training workshops and other events to help clarify needs for wholesale handling and packing, meet farmers, and assist in the education of growers interested in selling into wholesale markets. Regardless of whether your farm sells wholesale or direct-to-consumer, postharvest handling methods can increase shelf life and provide valuable marketing tools for your farm!

Wholesale Buyer Requirements Consumers are demanding local products, and wholesalers are trying to meet this demand by supporting small farms in the wholesale market. Many small farms, however, represent a risk to the wholesale buyer or distributor. If farms do not demonstrate safe handling practices, the buyer’s risk of loss, poor shelf life, or liability for foodborne diseases increased. As a result, even though USDA does not require GAP certification, many buyers have their own requirements for their vendors. Logistics Shelf Life Grading, Sorting, and Packing Communication Warehouse Space Reduced Liability and Risk

Recordkeeping & Profitability The recordkeeping for most food safety programs is not an undue burden. Most of these records are similar to those needed for a comprehensive business plan, a loan application, or applications for grants or cost-share programs to help with farm costs. Consistent recordkeeping is one of the most important things a farm business can do. It’s tedious, but it provides invaluable information on losses, harvests, and trends, as well as a shield against liability that arises from problems with food safety along the supply chain. Best of all, proper recordkeeping can help you identify risks and inefficiencies early, reducing overall costs, lowering insurance premiums, and preventing catastrophic contamination events.

Marketing Safe Products Even in direct markets, safety is a priority for the consumer. As more consumers become aware of the risks of food contamination, your safety practices become a marketing tool – even at the farmers’ market. A premium product demands a premium price. Buyers are willing to pay more for products that they know are safe. Wholesale buyers are more likely to take you seriously – and negotiate with you seriously – if they know that you take food safety and liability seriously.

More Wholesale Resources NCGT’s “For Producers” Resources (including vendor contacts, market channel selection, certifications and training, postharvest handling resources, wholesale pricing, and more) www.ncgrowingtogether.org Cornell University Extension Small Farms Program https://smallfarms.cornell.edu/ NC Cooperative Extension www.ces.ncsu.edu Center for Environmental Farming Systems www.cefs.ncsu.edu Dozens of resources are available to help producers who are prepared to move into wholesale markets, from state and national resources.

Next Steps https://www.ces.ncsu.edu/local-county-center/ Contact your local Extension agent first. They can help you navigate what food safety regulations apply to you and where to access the resources you need. https://www.ces.ncsu.edu/local-county-center/