Farmers Asking Questions

Check back regularly to find answers to questions we’re fielding from farmers.

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What is the Produce Safety Rule?

The Produce Safety Rule is part of Federal Drug Administration’s (FDA) implementation of the Food Safety Modernization Act (FSMA). The Produce Safety Rule establishes minimum standards for the safe growing, harvesting, packing, and holding of produce for food intended to be consumed by humans. Farms are required to implement procedures and controls to minimize the risk of severe adverse health consequences. Serious negative health consequences include death and long-term illness or injury. Even if a farm is not covered by the Produce Safety Rule, food safety is the responsibility of all farms that produce food for human consumption.

I have heard about Good Agricultural Practices (GAP) audits. What is the difference between inspections conducted under PSR and GAP audits?

GAP audits are a voluntary program that assess the food safety processes of an agricultural producer. The audits verify that fresh fruits and vegetables are produced, packed, handled, and stored according to food safety practices that minimize the risk of microbial food safety hazards. While voluntary, many retail purchasers contractually require satisfactory GAP audits from their farmers. The Produce Safety Rule is a federal law that requires farmers to develop programs and processes to ensure the safety of their produce. If a farm is covered by the Produce Safety Rule, as discussed below, compliance with the requirements of the Produce Safety Rule is mandatory. The requirements of the Produce Safety Rule are comparable to what is typically assessed in a GAP audit.

Is my farm covered by the Produce Safety rule?

The Produce Safety Rule does not apply to farms that:

  • Averaged annual produce sales of $25,000 or less over the last three years (when adjusted for inflation)
  • Only produce food for personal or on-farm consumption
  • Grow, harvest, pack or hold produce that is “rarely consumed raw,” namely, fruits and vegetables that are almost always cooked before eaten
    • This analysis is done for every produce item the farm produces – it is possible that only a portion of a farm’s products will be exempt from the Produce Safety Rule
    • The FDA has provided an exhaustive list of produce that is rarely consumed raw, available here:
  • Are eligible for a Qualified Exemption

All other farms that grow, harvest, pack, or hold produce for human food are covered by the requirements of the Produce Safety Rule. FDA has provided a flow chart outlining the coverage and exemptions of the Produce Safety Rule, available here: https://www.fda.gov/media/94332/download

Do I need to worry about having the COVID-19 virus on my produce? Should I be using sanitizer on my crops?

As of March 17, 2020, there has been no known transmission of the novel coronavirus through fresh produce (verified 3-19-20). That said, for many commodities, you might want to think about adding sanitizer (PAA, Chlorine, etc.) to your wash water for increased shelf life. As always, read and follow label rates and directions. It is a violation of federal law to use any sanitizer in a manner inconsistent with its label.

For a deeper dive into whether or not COVID-19 is a food safety issue, check out the fact sheet, “COVID-19 and Food Safety FAQ: Is Coronavirus a Food Safety Issue?” (verified March 19, 2020), from North Carolina State University and University of Florida.

With all this focus on handwashing, I think I need a few handwashing stations on and around my farm. How do I add handwashing stations without going broke?

It is possible to build a low-cost, gravity-fed handwash station for less than $50. The components are widely available, and the setup can be easily customized to use materials you may already have around the farm. You can find plans in, “ How to Build a Low-cost Handwashing Station,” (verified March 19, 2020) from the University of Minnesota Extension from this link. You can also follow instructions to build a foot pump option (verified March 19, 2020). Note that you will need to add somewhere for paper towels to be dispensed and disposed of.