Produce Rule Training Requirements

In January 2016, Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption, otherwise known as the Produce Rule, became law. This rule, as part of the Food Safety and Modernization Act, sets a standard for produce food safety. Not all growers are covered by the rule. An excellent flowchart to help determine coverage may be found at http://www.fda.gov/downloads/Food/GuidanceRegulation/FSMA/UCM472499.pdf. For those growers who are covered by the rule, there is a training requirement. Growers will have from 2-4 years, depending on farm size (defined by gross sales), to comply with training requirements.

The general requirement of the produce rule is that all personnel who handle covered produce (i.e. commodities covered under the rule) or food contact surfaces or are engaged in supervision of those personnel must receive adequate training, appropriate to the person’s duties, upon hiring and at least once annually thereafter.  The rule goes on to say that personnel must have a combination of education, training, and experience necessary to perform their assigned duties in a manner that assures compliance with the rule. Training must be conducted in a manner that is easily understood by personnel being trained. The rule also requires that training be repeated as necessary and appropriate in light of observations or information indicating that personnel are not meeting standards established by the rule.

At a minimum, training should include:

  1. Principles of food hygiene and food safety.
  2. The importance of health and personal hygiene for all personnel and visitors, including the recognition of symptoms of a health condition that is reasonably likely to result in contamination of produce or food contact surfaces.
  3. Standards established in the produce rule that are applicable to the employee’s job responsibilities.

Additionally, for those workers who are involved in harvest activities, training should include:

  1. Recognition of produce that should not be harvested due to potential contamination with known or reasonably foreseeable hazards.
  2. Inspection of harvest containers and equipment to ensure proper function and cleanliness.
  3. Correction and reporting of problems with harvest containers and equipment.

Also, at least one supervisor or responsible party per farm must have successfully completed food safety training at least equivalent to that received under the standardized curriculum recognized as adequate by the FDA. The standardized curriculum has been developed by the Produce Safety Alliance (PSA). Presently, as stated in the produce rule, FDA intends that the PSA curriculum will be the only curriculum officially recognized by FDA. The rule does allow for other curricula to be used as long as it is equivalent to the PSA curriculum. Presently, no mechanism exists to assure the equivalency of other curricula to the officially recognized curriculum.

Currently, PSA has delayed all training programs until September 2016. This was done in order to allow FDA time to review the official curriculum. Once training begins, training for those who are delivering the curriculum will commence. In Indiana, at least eight individuals have started the process of becoming certified lead trainers who are able to offer this curriculum on a statewide basis. Once PSA resumes trainings, certifications will be completed and trainings will be offered shortly thereafter.

As stated previously, each covered farm will need to have at least one supervisor or responsible party complete training. The rule does not take into account any previous trainings that growers may have had. Based on the most current information that I have, trainings will be managed through the Association of Food and Drug Officials (AFDO). Pricing will be $50 for registration and materials and $35 for a certificate at the conclusion of the training.

As we gear up for the 2016 season, please feel free to contact me at (812) 886-0198 or jsmonroe@purdue.edu if you have any questions concerning food safety training. I am available to discuss training issues and to assist with any on-farm training needs that you may have.

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