Food Safety Audit Perils
May 18, 2011 Many smaller growers were relieved earlier this year when the Food Safety Modernization Act was passed with the inclusion of the Tester Amendment, which exempts growers with sales under $500,000 from FDA food safety laws. However, besides the obvious damage a food safety problem could do to any grower’s business, there are other practical reasons for implementing a thorough food safety program.
Chief among them is that such a program will allow smaller growers to widen their scope of potential customers. University of California Cooperative Extension Small Farm Adviser Richard Molinar says you should be thinking about where the crops you grow will eventually end up. “You don’t have to be third-party audited; it depends on your buyers — whatever they require,” he said. “If you gross less than $500,000, there’s no requirement, it’s all up to your buyers.”
Molinar recently hosted a seminar in Fresno titled “Food Safety for the Small Farm.” The keynote speaker was from the California Department of Food & Agriculture’s (CDFA) Inspection & Compliance Branch, Assistant Branch Chief Steven Thomas of the Dinuba office. Thomas reviewed what goes into a USDA audit, which government officials are trying to get all buyers to accept. There are many audits available, which makes for a confusing system. In California, the USDA audits are conducted by the CDFA. Like Molinar, Thomas told the audience — mostly all growers — that this is buyer-driven. “It’s not going to be the FDA,” he said, “it’s going to be the industry that forces you to do this.”
Thomas emphasized that many of the practices required in the audit are already done by most growers, they’re just not always documented. He emphasized that there are seven sections to the USDA audit, with titles such as “Farm Review and Storage.” Part of the reason he emphasized that growers don’t need to do all seven parts, much less at once, is that growers get charged $92 an hour for the inspection. “The costs get rough on a small, 5-acre farm,” he said. Here are a list of tips on preparing for the audit.
• Each audit section has a checklist, and you must score 80% or better to pass. If you pass, you receive a USDA certificate and then the farm name is posted on the Web as having passed so buyers can easily check. There are practices that will trigger automatic failures. “Say you spill diazinon next to a well, or your workers take a break from strawberry picking, and then come back without washing their hands, that’s an automatic failure,” he said. “There’s no rejection notice, but you don’t get a certificate or your name on the website.”
• While the hourly rate for an audit isn’t cheap, they generally don’t take all day. For example, a typical Farm Review takes two to three hours, which would cost $184 to $276. The auditors are well-trained and go as quickly as they can, said Thomas, but paperwork does take time. “I don’t want to charge you a lot of money,” he said. “I want to get out of your hair quickly.” Molinar added that you can help by taking some time to prepare for the audit. He suggested compiling a binder about your operation with tabs on such things as water quality that the auditor can flip through quickly. “If you take out a shoebox and go searching for a receipt, remember you’re doing it at $92 an hour,” he said. “The shoebox is definitely not a good idea.”
• Everything must be documented. For instance, all water sources need to be documented. If you use a well and a pond, you can’t show the auditor one test. Even if you get water from the city, it must be documented. “I kind of take it for granted that the municipal water is OK,” Thomas said, “but I still need to see the test.”
• You can do all your own training, just document it. You can’t just tell the auditor. Also, it doesn’t matter if you contracted for labor; you’re the person being audited. Whether the contractor conducts the training or you conduct the training, you have to have the documentation. “And we will ask the workers,” said Thomas. “For example: What do you do if you get a cut and there is blood?”
• One of the most common questions Thomas gets is: Why can’t I use hand sanitizer? “You just can’t. You need to wash your hands,” he said. “Ten years ago, we told everyone hand sanitizers were fine. But then came word that they were not OK.”
• It’s not enough just to have restrooms available. “Are they placed properly in the field? And are they supplied?”
• Packing crates need to be clean. You have to get your employees in the mind-set that harvest containers are harvest containers, period — they’re not to be used for anything else. They can’t use it as an impromptu table for lunch — a common practice — because that’s considered contamination. They don’t need to be sanitized daily, but auditors have seen trays sitting in muddy water. “You know what clean is,” said Thomas. “Use common sense.”
• You need to cover loads of product. If you’re not going to do that, that’s fine, but you’re not going to get the points. You’re not going to fail the audit, unless you miss too many of them. Molinar noted if it’s only a five-point question, but it’s something that’s really costly and/or time-consuming, such as covering every load of harvested product between the field and the storage area or packing plant, you can just decide to forego those points. But if you do that with too many items, you won’t pass the audit.
• If you don’t have a food safety training manual, and you’re going to compile one, consider using the USDA audit questions as a guide, said Molinar. “It can be 2 inches thick, but you can get by with a much smaller food safety manual, because as long as it addresses these questions, it’s good,” he said. “He (the auditor) is giving you the answers — this is an open book test.”
• However, if you’re not going to implement a food safety program, don’t bother producing a manual. “Falsification is the biggie with us. If you falsify one thing, we have no trust in anything you’re doing,” said Thomas. “And if there’s no trust, the audit is over.”
• Each audit only covers one ranch, or location. If you want an audit to cover your whole operation, and you have five ranches, an auditor needs to visit all five. Otherwise, the audit will specify that it just covers the one ranch.
• Keep in mind that there are seven sections to the entire audit program, and you choose which parts you want to do. Perhaps your buyers don’t care about certain sections. You can skip those. “The best way to decide what parts you want done is to see what your buyers require,” he said. “You do what you have to do. Many do a farm review, and then build from that.”
• Don’t forget that your food safety program covers not just your employees, but all visitors to the ranch. It’s up to you to educate all involved. “If someone shows up, they need to know this,” said Thomas. “The old days of an open-door policy are pretty much gone.”
• As a practical matter, one of the biggest hurdles is that any time your workers take a break, they need to wash their hands. “We used to say 15 years ago, that’s impossible, getting 200 people to wash their hands in 10 minutes,” said Thomas. “But you should see them now — they’re like soldiers.” He added that hand washing is such a challenge on very large farms that they have people who all they do is make sure that workers are routinely washing their hands.
• If you have a policy, you must show you can implement said policy. Because of that, it might not be in your best interest to be overly specific, said Molinar. “If you’re going to put in your manual that you will clean with a 10% bleach solution, you have to have a 10% bleach solution on hand,” he said. “You might want to just state that you will clean it with a bleach solution.”
• One five-point question asks if crop production areas are monitored for the presence or signs of wild or domestic animals entering the land. “We understand that birds fly over,” said Thomas. “But you need to document a flock of geese, for example.”