Food Safety

Food safety refers to the measures and procedures in place for upholding the quality of food and prevention of contamination and food-borne illnesses. There are federal rules and regulations to comply with when growing, processing, and handling food. Much like organic certification, understanding the relevant rules as they pertain to your specific operation can be difficult to navigate.

What is the Food Safety Modernization Act (FSMA)?

The Food Safety Modernization Act (FSMA) was signed into law in 2011 and gives the U.S. Food and Drug Administration (FDA) authority to regulate the way foods are grown, harvested and processed. The intent of FSMA is to keep our food supply safe from contamination to prevent foodborne illnesses. Two important rules under FSMA include the Produce Safety Rule and the Preventative Controls Rule.

Produce Safety Rule

As of January 2020, farms with more than $25,000 in annual produce sales must comply with the federal FSMA Produce Safety Rule (PSR). Review this Produce Safety Rule flow chart to determine whether your operation is subject to the rule, and check out this factsheet that goes over key requirements to comply with the Produce Safety Rule

CCOF also provides a useful summary about how FSMA regulations apply to produce farms, as well as a two part webinar series focusing on produce safety for small organic farms:

• Part I - Includes an overview of the Produce Safety Rule, soil amendments, worker health and hygiene, and wild and domestic animals
• Part II - Includes information on agricultural water quality and usage, post-harvest handling, and developing a food safety plan

Preventative Controls Rule

The Preventive Controls Rule requires that food facilities have a safety plan in place for identifying and minimizing contamination and food-related hazards. CCOF provides a useful factsheet on USDA Preventative Controls for Human Food, as well as a webinar series explaining the different aspects of the FSMA Preventative Controls Rule and how it intersects with organic certification:

• Supplier Verification for Food Hubs and Farms
• Validation for Organic Food Processors
• Current Good Manufacturing Practices
• Fully Covered Facilities
• Qualified Exemption

Compliance with FSMA and the National Organic Program (NOP)

Navigating both FSMA and the National Organic Program can feel like a daunting task, but fortunately there are many resources available to help you streamline the process. As a good starting point, CAFF developed a factsheet on Balancing Food Safety and Organic Requirements which explains the three main farm categories under FSMA: fully exempt farms, qualified exempt farms, or fully subject farms. Reviewing this document will help you determine what category your operation falls under. CAFF also created a helpful guide on the different programs, costs, and requirements for the NOP, FSMA, and 3rd Party Audits.

For a more comprehensive dive into food safety, you can find more information on the following topics:

• Worker Health and Hygiene
• Worker Health & Hygiene: FSMA & NOP- outlines requirements for worker health and hygiene to be in compliance with FSMA and the NOP
• Cornell University provides an overview of how to make sure workers know about food safety risks in the workplace. This includes resources such as:
• Worker Healthy, Hygiene, and Training Decision Tree
• Sample Standard Operating Procedures
• Sample Log sheets
• Worker Health, Hygiene, and Training resources from UC Small Farm Food Safety website, which includes general recommendations, resources for training employees, and template records.
• Animals on the Farm
• Wildlife on the farm is natural and often unavoidable. Although animals can be beneficial, some may pose food safety risks. FSMA Produce Safety Rule: Dealing with Wildlife discusses actions to take to identify and mitigate risks associated with wildlife on farms.
• Wild & Domestic Animals: FSMA & NOP - outlines wild and domestic animal requirements to follow FSMA and the NOP compliance.
• Monitoring Animals: FSMA & NOP - what farms need to do to monitor animal contamination to be in compliance with FSMA and the NOP
• UC Small Farm Food Safety provides information on Wildlife and Domestic Animals with a list of useful resources.
• Land Use
• Land Use: FSMA & NOP - what farms need to do in regards to their land use to be in compliance with FSMA and the NOP
• Co-Managing Farm Stewardship with Food Safety GAPs and Conservation Practices - a resource from Wild Farm Alliance for conservation planners and growers to co-manage food safety and conservation by understanding food safety risks and management practices that reduce food safety risks.
• Community Alliance with Family Farmers, A Farmer’s Guide to Food Safety and Conservation- facts, tips and frequently asked questions about balancing food safety concerns with conservation.
• Soil Amendments of Animal Origin
• Soil Amendments from Animals: FSMA & NOP- CAFF provides useful information on what farms need to do with their soil amendments to be in compliance with FSMA and the NOP.
• UC Small Farm Food Safety provides useful information and resources on soil amendments and food safety, including:
• What are Biological Soil Amendments of Animal Origin (BSAAO)
• What are the risks associated with BSAAO?
• BSAAO FSMA Produce Safety Rule Requirements
• Certificates of Conformance for BSAAO

Recordkeeping Resources

Ensuring compliance with FSMA and Organic Standards can feel like a lot of bookkeeping and paperwork. Fortunately, NCAT developed a useful chart on Food Safety and Organic Co-Compliance to help streamline record-keeping that is needed for both.

CAFF also provides an overview of records required by the NOP that can also fulfill recordkeeping requirements for farms fully covered by FSMA. You can also find guidance on developing a written plan for food safety.

It is important to note that if you are using Biological Soil Amendments of Animal Origin, you will need to keep records of use to be sure you are in compliance with FSMA. Kansas State University provides a useful template for effective record-keeping.

Technical and Financial Assistance for Food Safety

Technical Assistance:

• Your local UC Cooperative Extension Farm Advisor can be a great source of information for food safety.
• NCAT has a lot of resources for food safety as well as Sustainable Agriculture Specialists that can provide technical assistance
• CCOF Chapters - (for CCOF members only) help CCOF members maintain successful organic businesses, networking opportunities, and connections to farming organizations and resources.  If you would like to get involved in your CCOF chapter, contact your local chapter leader to find out about future meetings and activities.
• The National Sustainable Agriculture Coalition (NSAC) has great resources on food safety.
• Produce Safety Alliance provides useful information on food safety for growers to meet regulatory requirements included in FSMA.

Certificate Courses

• Produce Safety Alliance Grower Training: meets the training required under the FSMA Produce Safety Rule.  At least one person working on the farm, a manager or individual handling food safety, should attend this course and receive a certificate (available in multiple languages).
• Good Agricultural Practices Training: in depth course covering definitions and applications of food safety practices. It is highly recommended for individuals new to on-farm food safety to attend this course. In person courses are available, however Cornell Extension also provides an online program offered throughout the year.

Financial Assistance

• Food Safety Certification for Specialty Crops Program - if you grow specialty crops and have sold less than $500,000 worth of specialty crops, each year, for the past three years, the Farm Service Agency (FSA) has a program to reimburse you for a portion of the expenses associated with obtaining or renewing your on-farm food safety plan. USDA is providing up to $200 million in assistance for specialty crop producers who incur eligible on-farm food safety program expenses to obtain or renew a food safety certification in calendar years 2022 or 2023. See the announcement for this program here. For the 2023 expenses eligible for reimbursement (February 1, 2023 – January 31, 2024), applications are being accepted through January 31, 2024.
• To learn more about the Food Safety Certification guidelines and eligibility, check out this webinar and presentation from the USDA.  
• Food Safety Outreach Program (FSOP) is a competitive grants program administered by USDA National Institute of Food and Agriculture (NIFA) that funds outreach, education, and training to help farmers, processors, and wholesalers adapt to new food safety requirements. Community based organizations, NGOs, Cooperative Extension, tribal agencies, colleges, and universities are eligible to apply for funding through this program.

Food Safety for Agricultural Professionals

Are you working as a technical assistance provider? CCOF has a webinar series specifically aimed at Ag Professionals to learn about Food Safety Requirements:

• Food Safety Modernization Act 101 – covers different FSMA compliance categories for farms and how organic farms may already address some FSMA requirements through their OSP.
• Requirements for Farms that Must Fully Comply with FSMA – details specifics for organic compliance with FSMA, including worker training, health and hygiene requirements, recordkeeping, equipment, buildings, harvest, and postharvest.
• Food Safety & Organic - this webinar provides detailed information on key concerns for organic operations, including use for manure, compost, and animal products.

Additional Food Safety Resources

• UC ANR California Urban Agriculture Food Safety Guide: Laws and standard operating procedures for farming safely in the city – useful guide that covers best practices for fresh produce safety, urban soils safety, as well as food safety in the context of small animal husbandry in urban environments.
• University of Minnesota provides an overview of GAP audits, including what GAP audits are, what gets audited, and actions to take before requesting an audit.
• UC Small Farm Food Safety provides a useful information on what growers should do if their operation has come in contact with flood water.
• Center for Produce Safety (CPS) is a non-profit partnership of industry, government, and the scientific and academic communities to focus on providing research to enhance food safety.