Scott Monroe

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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. The water testing component of the produce rule requires growers to regularly test irrigation water. While a previous article dealt with water testing requirements, I’ve received questions as to exactly who is required to test water. As a result, I wanted to review the steps in determining whether or not one is held to the water testing requirement. The first step is to determine if you are covered by the produce rule. An excellent flowchart to help determine coverage may be found at http://www.fda.gov/downloads/Food/GuidanceRegulation/FSMA/UCM472499.pdf. If you’re gross produce sales averaged $25,000 or less in the last three years or you are growing produce for your own personal consumption only, then your farm is[Read More…]


The Food Safety Modernization Act Produce Rule addresses many issues with regard produce food safety. One issue not addressed is the issue of biological soil amendments of animal origin (i.e. manure). When issuing the rule, the Food and Drug Administration (FDA) chose to leave blank those portions of the rule dealing with the required interval between manure application and harvest of covered crops pending a comprehensive risk assessment by the agency. FDA has initiated its comprehensive risk assessment process by publishing a request for scientific data, information, and comments in the Federal Register on March 4. There will, most likely, be other requests for comments as FDA investigates the issue and incorporates its findings into the produce rule. The entire request, along with instructions for submitting comments, can be found at https://www.federalregister.gov/articles/2016/03/04/2016-04712/risk-assessment-of-foodborne-illness-associated-with-pathogens-from-produce-grown-in-fields-amended  


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[Read More…]


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.  Those growers who are covered by the rule will have from 2-4 years, depending on farm size (defined by gross sales), to be in compliance. All growers will then receive an additional 2 years to comply with the water testing component of the rule. The water testing component of the produce rule requires growers to regularly test irrigation water. Growers irrigating with surface water (ponds, lakes, streams, ditches) are required to collect and test 20 samples over a two-year period in order to establish a baseline. Once the baseline is established, 5 samples[Read More…]


In November 2015 the Food and Drug Administration (FDA) published the final version of Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption, otherwise known as the Produce Rule, in the Federal Register. Sixty days later, in January 2016, the rule became law.  The Produce Rule is one of several new regulations mandated by the Food Safety Modernization Act (FSMA), which was signed into law in January 2011. I have had many growers ask whether or not they are covered by this new rule. FDA has put out an excellent flow chart to help determine coverage.  It can be found online at http://www.fda.gov/downloads/Food/GuidanceRegulation/FSMA/UCM472499.pdf. When determining coverage, there are some key questions that growers should ask: What is the value of my produce sales? Growers whose produce sales have averaged $25,000 or less for the past three years are not covered by this rule. What crops am[Read More…]


​There are certain questions within our culture for which there are simply no good answers. For example, how many times have we heard the classic question, “If a tree falls in a woods and there’s no one to hear it, does it still make a sound?” One question I’ve been asked recently, for which the answer is equally elusive, is “How long must I wait to grow vegetables after applying manure to the field?” With the 2015 season quickly winding down, it will soon be time to start making plans for next year’s crops. Part of those plans will undoubtedly include the question of manure use. While manure is a good source of plant nutrients and organic matter, it may also contain human pathogens that can be transferred onto fresh fruits and vegetables. After manure is applied to a field, the bacterial community in the manure changes as it adapts[Read More…]


​Recently the USDA announced the addition of a new third-party auditing service that will be available through the Ag Marketing Service (AMS). The service, called “GroupGAP”, will be available in the spring of 2016. The expansion of the service follows multi-year piloting and testing of the program. Under the GroupGAP program, independent farms may organize under a central entity, such as a food hub or grower cooperative, to create a food safety system. Participating farms are responsible for collectively developing food safety practices and collecting required documentation. Entities will also be responsible for providing their own internal auditing services. They will also participate in an external audit by USDA-AMS Specialty Crops Inspection Service. Growers marketing through food hubs, cooperatives, produce auctions, or other collective entities may benefit from this program. The full press release and details from USDA may be found at http://blogs.usda.gov/2015/10/22/groupgap-program-brings-new-market-opportunities-for-farmers/.


Note that the Wabash River is visible through the break in the trees.

​With the record-setting rainfall we’ve seen over the past month, flooding of fields is very widespread (Figure 1). Fields that have experienced flooding present growers with difficult management choices. Flooding is defined (per FDA) as the “flowing or overflowing of a field with water outside a grower’s control.” Flooding is associated with streams, creeks, or ponds that overflow their banks and cannot be controlled. The FDA considers food contacted by flood water to be “adulterated” and not fit for human consumption. Due to microbial and other concerns, produce cannot be harvested and sold into the public food supply once it contacts flood water. Frequently, only a portion of a field is affected by flooding. If only part of a field is affected and flood water contacts the edible portion of the crop, growers should manage the contaminated crop so that it does not affect uncontaminated crops. To protect uncontaminated crops,[Read More…]


​Purdue University and the Illiana Watermelon Association (IWA) are offering food safety audit cost-share programs to Indiana fruit and vegetable growers this year. Funds for the programs come from a grant from the Indiana State Department of Agriculture through the USDA Specialty Crops Block Grant Program. Through the Purdue program, Indiana fruit or vegetable growers who receive passing scores on their third party food safety audits are eligible for reimbursement of 40% of their audit cost, up to a maximum of $400 per farm. Through the Illiana Watermelon Association program IWA members may receive reimbursement for 75% of an audit cost (up to  $1,500) if a preferred audit-provider is used, or 60% (up to $1,200) if a non-preferred provider is used. Producers of any fruit or vegetable wishing to take advantage of the IWA program may join the IWA. To apply for cost-sharing, complete and return the appropriate application by[Read More…]


​As we approach the 2015 growing season, produce food safety continues to be an important issue.  This year, why not make it one of your goals to create a “culture” of food safety on your farm?  Below are some things you can do to get started on that goal during the winter months:Review (or get started on) your written food safety plan. Winter is an excellent time to review your written food safety plan.  As you review the plan, ask yourself if all policies and procedures are written in such a way that they are easily understood.  Review any areas, such as hand washing, documentation, etc., that presented particular challenges for the farm, to see if expectations can be clarified or if procedures can be simplified. Make sure policies and procedures are available in the appropriate languages. As we see an ever-increasing level of diversity in our labor force, it[Read More…]