Fresh Take
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Fresh Take
Farm Food Safety Audits: Lessons Learned from Farmers
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Billy Mitchell, food safety expert, talks with us about food safety audits and commonly asked questions from farmers.
We welcome Billy Mitchell, FSMA Training Coordinator for the National Farmers Union, for a conversation about questions he commonly hears from farmers about food safety.
Tune in to hear about:
- Why food safety certification has become more common
- Is this certification voluntary for certified organic growers and small farms?
- How long it takes to prepare a farm for an audit
- The average cost of a food safety audit
Resources:
Listen to FOG’s food safety-related webinars on our website: https://foginfo.org/food-safety-for-producers/
Learn about the National Farmers Union on their website: https://nfu.org
Find information on food safety on the Produce Safety Alliance website: https://producesafetyalliance.cornell.edu
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Introduction to Food Safety for Farmers
Speaker 1Welcome to Florida Organic Growers podcast series Food Safety for Farmers . A project funded by the USDA National Institute of Food and Agriculture Food Safety Outreach Program , our podcast provides information on food safety topics that farmers can use to better understand how to comply with the Food Safety Modernization Act regulations . Thanks for tuning in .
Speaker 2Welcome everyone . We're very happy that you can join us today . We're very lucky to have Billy Mitchell , who is a training coordinator for the Food Safety Modernization Act at the National Farmers Union . Welcome , Billy , Thanks . Yeah , I'm glad to be here . So , Billy , you and I have met . I've actually been in one of your trainings , the one that you held in Georgia a couple of years ago . So thank you so much for joining us today when we're going to be talking about some of the lessons learned from farmers , as you've been going around the country and talking to farmers about the Food Safety Modernization Act and the FISMA regulations . So can you share with us a little bit about your background and some of the things that you think that maybe our audience would like to learn about ?
Speaker 3Yeah , I'd love to so again . My name is Billy Mitchell . I'm the Food Safety Modernization Act , also known as FSMA , training coordinator at the National Farmers Union and I work with a project called the Local Food Safety Collaborative . It's a FDA-supported cooperative agreement and we provide outreach and education to and with farmers all over the country . So I've just had an incredible , really just about four years at this job , like that workshop we got to do together JC at White Oak Pastures , where we're doing PowerPoints , we're talking about the laws , we're talking about the rules , but then we're also on farm in conversation with farmers , finding out not only the challenges that they're facing but also the creative solutions that they're coming up with to have cost-effective , practical
Billy Mitchell's Background and Experience
Speaker 3produce safety implementation on their farm .
Speaker 3And before I had this job doing outreach and education , I had an opportunity to farm inside Atlanta and right outside Atlanta for about seven years , including building just like this beautiful four and a half acre urban farm in downtown Atlanta it used to be right next to the King Center and just kind of travel the state of Georgia , meeting urban , peri-urban and rural farmers .
Speaker 3And that has led me to this chance to go to like Florida , colorado , arizona , vermont and just see farmers all over the country and it's just , it's just been great .
Speaker 3And then I've also had a chance to work with people that you know , like Michelle Daniluk and Keith Schneider from the University of Florida , who've really helped me gain just a better understanding of the science behind produce safety , and then working with people like Jennifer McIntyre at United Fresh to better understand the rules and regulations of gap audits and like the alphabet soup that comes with all this work of like gaps , fisma , psr . So it's been a good journey and I just learned so much and I think my biggest takeaway has really been that produce safety , the practices themselves when they're implemented well , they just improve your whole farm . It often feels like produce safety is a siloed thing or maybe even the scary thing , but when it's done well , it just helps you run a better small agricultural business . It helps create this culture on your farm where things are just more positive , they're more engaging and just have this better awareness of how the farm is operating .
Speaker 2And you're absolutely right , I think , by farmers realizing which I think they do , at least in our experience that you know the safety of their produce is something that they take seriously and that most of them , if not all of them , are going to always try to do their best to provide food to their customers , or whoever it is that they're providing this food to , that it is safe , that it is healthy , and then consumers and all of us can feel sort of , you know , not only grateful for all the great work that farmers do , but that we feel like that we shouldn't really worry about you know what we're eating or the state that you know some of that food is .
Speaker 2However , I think in our experience , some farmers have told us that they grew up in a farm , they've been farming for many , many years . Their parents or their grandparents farm , so they know about farming and they know how to grow food . But now , with you know , with FEESMA , they're sort of wondering what's different . You know they've been practicing food safety practices all their lives , but what exactly is it different now with the FEESMA regulations ? And maybe perhaps what are some of the things that they need to be paying attention to ?
Speaker 3Oh gosh , yeah
Food Safety Evolution and FSMA Basics
Speaker 3, that's such a good question because , especially folks who've grown up farming , they've always been following produce safety practices . But their parents , their grandparents , their family members were rarely , if ever , asked to prove that they were following food safety practices or to get an audit or an inspection . And a big part of the reason that's changed is we've just had these big national outbreaks where just the general public has been more aware that , while we have a very safe food system , there are risks in the food system . And you know the Jack in the Box outbreak , which is an outbreak related to hamburgers . You know everybody thought how could a hamburger get you sick ? I mean listeria outbreaks connected to ice cream . And for the one that really affected the fresh produce industry was a spinach outbreak that happened and that really motivated consumers to start asking our government you know what's going on what can we do to reduce risk in this food system ? And that's kind of what led to the Food Safety Modernization Act happening . Congress passed this act and FDA implements it , and so just our understanding of risks has changed , the science has changed and just the industry has changed and that can be really hard for any business , especially a small business , just to keep up with all these changes while you're still just trying to do the day-to-day farming , like , how are you supposed to pay attention to all the changes that happen ? And that's why it's so important that groups like University of Florida Extension , florida Organic Growers get out there and help do outreach and education so that growers know about this , and I think for most growers it's you know .
Speaker 3What FSMA is requiring of them , especially at a smaller scale , is not that much . It's an awareness that you're practicing food safety on your farm and making sure that you get a refresher , that you learn those best practices . Maybe you learn a little bit more about cleaning and sanitizing , or you learn more about making compost . Like , is there a way to turn and make your compost that really reduces the pathogens in the pile and also helps reduce things like soil borne diseases ? It also helps reduce things like soil borne diseases and it's growers knowing that .
Speaker 3If somebody asks you what you do on your farm , you know the language of food safety . You know to say well , I follow good agricultural practices . And it also means keeping some paperwork to show what your sales are . So the Food Safety Modernization Act , produce Safety Rule it really is supposed to be science backed and scale appropriate , and so for a lot of growers it's showing just where you fall under that rule . So everybody has to follow those food safety practices .
Speaker 3And by that I mean no one can sell contaminated food into the food system , you know to , in a really basic way , like nobody can sell food that has poop on it and , to be quite honest , nobody wants to do that right either and so everybody has to follow those practices . And then , just depending on the size of your business , you might have to keep a couple more records to kind of prove that . But at the end of the day it's just awareness of food safety , knowing the language and really taking a class or two to find out , like , how has the science changed ? How has our understanding of produce
Record-keeping and Small Farm Requirements
Speaker 3safety and risk changed over the past few years ? And what can I do ? Because I care about my community , I care about the people I'm selling food to , and at the end of the day , farmers are just always curious and they always want to improve . So you take this food safety class just to find out , well , what's new and what can I improve on my farm .
Speaker 2Find out well what's new and what can I improve on my farm .
Speaker 2Right , and you mentioned so many really important things .
Speaker 2One of the things you mentioned you know small farmers and these small farmers , or everyone in general , being sort of familiar with the language indicating you know it's sort of an acronyms and alphabet soup of things that we talk about when we're talking about food safety and the awareness and keeping records , so all of those things .
Speaker 2Let me ask you a question . So in your experience and I used to run a farmer's market here in Gainesville and did that for several years so most of the people that come to the farmer's market are small farmers and you know they're selling directly to the consumers and consumers trust them and you know they know them and they're there every week , and so a lot of farmers or vendors that come to the farmer's market would ask is this voluntary ? Is this something that I have to do ? The farmer's market would ask is this voluntary ? Is this something that I have to do ? I think you have , in part , answer that question , but can you maybe talk a little bit about some of the things that those that are selling directly to consumers and maybe selling a farmer's market need to be aware of , as you stated .
Speaker 3Yeah , sure , and maybe we'll start with that alphabet soup of acronyms . Sure , and maybe we'll start with that alphabet soup of acronyms . I think that that is where there's a little bit of confusion . So there's gaps , good agricultural practices , and that's something that farmers should be following . That's what helps us create a safe and vibrant food system . And then a lot of growers will ask me do I need a gap audit ? And that's when somebody comes out to your farm and they kind of review your paperwork , they watch your practices and they ask you a bunch of questions . And that's a really like a buyer driven thing . And I would say 99.99% of small farmers do not need to get gap audited . They don't need to pay someone to come out to their farm and see what's going on and especially , there's rarely a farmer's market , a restaurant , a CSA , a small co-op who's requiring that audit , even like a farm to school program . But there's certainly a benefit to growers . Almost all those audits are actually free online . So if you Google the USDA gap audit or the USDA harmonized gap audit , you can see what those audits look like and you can even do a self audit where you print it out and you walk around your farm and you just ask yourself those questions and it kind of helps . You know that you're probably already meeting a lot of the industry standards and a few things that growers can really do , even if you're not getting an audit .
Speaker 3But some of the best good agricultural practices to follow are checking in with your employees and having a conversation about the fact that we come to work in clean clothes . We wash our hands so we don't contaminate things . You know , if you're sick , don't come into work . You talk about cleaning and sanitizing , and like a really small thing with cleaning and sanitizing is that it's a four-step process . You always got to clean first , kind of like you always brush your teeth before you use mouthwash . But most sanitizers are a spray and walk away sanitizer and a lot of small growers spray their sanitizers and then just wipe it off , and so it ends up not having the time to do what it needs to do to help improve your food safety , and so sometimes there's just little things like that , like training your employees to spray and walk away with that sanitizer and a real easy one that's a big one that you can do to get ahead of huge problems is just an annual water test . It's checking in with somebody getting your water tested just to make sure that there's no bacteria issues within your drinking water .
Speaker 3But I mean , jc , you're right for those growers that you used to get to work with at the farmer's market , they don't need to be audited , but it certainly benefits them to like follow those practices and they can do tiny things like make a five page food safety plan , because sometimes a school might be really interested in just doing one purchase from a small farmer and that school will be delighted to know that that farmer can provide them with a food safety plan . So if the parents ask , they can say oh yeah , we buy from small farmers who follow good agricultural practices . They don't get audited because they're small . We can visit their farm and see what they're doing . But they did provide us a little bit of paperwork just as assurance .
Speaker 2What about , in your experience , certified organic growers who are already keeping a lot of records as it pertains to their certification ? Would a lot of these certified organic farmers require a food safety certification on top of the organic certification they already have ?
Speaker 3That's such a good question and it's kind of like it's complicated and it depends . So these food safety audits almost always come down to your buyer . They're almost always buyer driven . You know it's not mandatory , you could walk away from that buyer , but it kind of feels mandatory .
Speaker 3The nice thing is that if you're already certified organic , probably one of the harder things about food safety audits is just building the record keeping habits Because often the practices are already in place . If you're certified organic , you've already built those habits around record keeping and there will be quite a few records that can cross over , like your soil amendment records , any cleaning and sanitizing records that you keep . But it's really going to be
GAP Audits vs. Required Practices
Speaker 3a conversation between you and your buyer and if you're a smaller local farm working with a smaller local regional buyer , you can ask them if they just want to come out to your farm , spend the day with you , see your farm like , find out why they really want and need that audit . But at the end of the day it's there . There's no hard or fast answer there . Unfortunately , just being certified organic won't get you out of a food safety audit because there are some things in a food safety audit that just aren't captured in that NLP audit ?
Speaker 2Yeah yeah , and thank you for explaining that so well , because that is a question , as I was saying , that we get often from some of the certified organic farmers that we interact with . So being certified is great to all those certified organic farmers listening . But and again Billy was just saying , find out more why your buyer , instead of requiring you to have that food safety certification you know what are some of the reasons behind that , and perhaps a lot of the stuff that you're already doing shows that you're complying with some of those regulations but will not get you out of it . They really do want that certification , out of having that food safety certification .
Speaker 3One other thing I guess I should just say is that if a buyer asks you for a gap audit , you want to go ahead and ask them which one . So there's no universal gap audit . So they could be talking about a USDA gap audit , a harmonized gap audit , a primus gap audit . So before you , as a grower , go through all the work to pay for and pass an audit , make sure that you're paying for and passing the one that your buyer wants . So you really just want to make sure you're on the same page .
Speaker 2Yeah , that's such a good tip and thank you so much for sharing that with us . Tip , and thank you so much for sharing that with us . It seems that many of the outbreaks that we've heard about and you sort of alluded to them in the beginning come from , perhaps , large-scale farms and perhaps these are not as common in small farms , or maybe I'm mistaken about that . But do small-scale farmers need to show that they're compliant with these food safety regulations , and what are some , maybe some of the tips that you would like to share with us , when people might think that farmers , small farmers , can also just be just as risky as large-scale farms ?
Speaker 3Right , oh gosh , that's such a good . It's such a complicated question . So I think the one thing we just have to recognize is that , just like pathogens don't care , they don't care if you're a small farm , they don't care if you love your community and you love your produce . Pathogens are just there . They're there on small farms , they're there on big farms , and also outbreaks can be hard to trace . Part of the reason that we hear about them mostly from big farms is those are big , headline , attention grabbing things and they affect a ton
Organic Certification and Food Safety
Speaker 3of people .
Speaker 3But there's a lot of foodborne illnesses in our country that just don't get tracked . You know , there's a lot of us maybe even folks listening to this who we've probably gotten a foodborne illness before , like . I've gotten one I think it was from a grocery store . I've gotten one that I think was from a restaurant , but I just kind of had a bad day at home and I didn't go to the hospital , I didn't report it . So a lot of that stuff gets underreported and there have been a couple outbreaks that have been linked back to farmers markets . But maybe something that's a little more impactful is that there have just been some really foodborne illness outbreaks related to , just like churches or family dinners . Like these things do happen on a really small scale , they just don't make it into the really big new systems .
Speaker 3And really , at the end of the day , I think we all don't want to be that small farm or that farmer's market that breaks the mold . We don't want to be the one that becomes the big thing . And there there is this great podcast called farmer to farmer and Chris Blanchard who hosted it and passed away a few years ago . He was just a big believer in food safety and one of the reasons he was is because he , in his opinion and I share this our local food system is both so resilient but also so fragile . He would , you know , worried that an outbreak might get traced back to a farmer's market and the farmers wouldn't be prepared to say we follow good agricultural practices , they wouldn't be prepared to take steps to help mitigate that risk . Instead they would just say , well , no , no , you know , food safety is just a big farm thing and we didn't have to follow those practices .
Speaker 3And then it would just be in the news Local farmers market gets people sick or local farm gets people sick , and the messaging would just be all over the place yeah , even if they haven't , even if it feels like a big farm problem , you know , we do just know that small all farmers care about their community .
Speaker 3But as small farmers like at that farmers market you got to manage in Gainesville we are seeing those folks face to face . We are building such strong personal relationships with them , and what I've seen at farmer's markets is that folks who start to get sick , people who are immunocompromised and you can't look at somebody and tell that they're immunocompromised they really start going to farmers markets too . So people who are already at a higher risk are coming to smaller farmers because they trust our quality and they want to lead healthy lives , and so that's just another motivator that , even if we're not seeing the outbreaks linked to us , we know , like you said , that our customers trust us , and so it's a real at least for me , a real strong motivator to do the right thing and follow these practices .
Speaker 2I couldn't agree more . So what about if a farmer does choose , whether it's because their buyer is requiring it and they're now considering to seek food safety certification ? Can you tell us in your experience , how long does it take to one prepare the farm for an actual food safety audit ? How long would it take for them to obtain that valid certificate , and perhaps even if you know , what is the average cost of these types of audits ? So things like again three things how to prepare your fund for the audit , how long will it take for them to obtain their certification , and perhaps the cost of these audits .
Speaker 3Yeah . So that really the first question how to prepare .
Small Farms and Food Safety Risks
Speaker 3I think one of the best ways to prepare it is to find out what audit either you want to get because you're just motivated to do it . You know , I think there's a lot of certified organic farms who do this where they don't really have buyers requiring it , but they're just motivated to get that certification and prove to their customers , and so you might just be motivated to get a food safety audit . And so the first thing you want to do is go online and find that audit .
Speaker 3I mean , that's one of the nice things is that there should be no surprises audit day , so you might go to the USDA GAP website and download the audit and do a self audit . So just go through it line by line , question by question , you know , and circle the ones that don't make any sense , so that they can call you JC , or they can call me , or they can call Michelle Daniluk and say I'm trying to figure this out , but I just don't understand this question . And you can also circle the things that you need to do and most of the time it's really some like new paperwork systems that you're going to create and then maybe potentially a couple of new practices as well and with those audits you can score yourself so you can see what you should be getting on audit day , and I think that will really help you as a grower , know where you're at . But then how long is it going to take me as a grower to prepare for this ? So if you go through that self audit and you're keeping zero paperwork on your farm right now , you're probably going to want like three to six months to really build those paperwork systems , because it's just very hard to start doing 30 brand new records the next day . You know you might want to identify like three new records a week over the course of a couple of months to really build up all those skills , because while you're doing the paperwork , all the other farming stuff rain events , customers canceling , employees , calling in sick all that stuff is going to happen . So best way to prepare is download the audit and and audit yourself or get like one of your employees to audit you and that way your employees start to understand the motivations because you're going to have to make some changes to your farm and so that way everybody's on the same page .
Speaker 3Why are we making these changes ? Why is it important and that will help you figure out how long , because there are some people who can call an auditor and a month later knock that audit out , but probably most people who've never been audited before . You want to give yourself a minimum three months , but maybe even six months just to feel it out . And that last question how much does it cost ?
Speaker 3It kind of depends on the audit that you're going to get and even things like how far away does your auditor live , because some auditors , some audit schemes , you'll be charged for their travel as well . I would say we like generally see it between $600 and $1,200 , which is kind of a wide range , but it can certainly be even more expensive than that , and so the best thing to do is , once you find out what audit you're going to get , you'll also be able to figure out who does those audits in your area and just give them a ring Start to build that relationship .
Preparing for Food Safety Certification
Speaker 3Let them know you're interested and let them know that you want to be able to prepare for it and start saving , and they can give you a general cost estimate .
Speaker 2Wow , you've shared so much with us today . We again can't thank you enough . One of the things that I think we can take with us is that food safety certification in most cases is buyer-driven . If the buyer , if that restaurant , if that place that you have farmers , the potential to sell your product , whether it be a school , again , a restaurant , sort of a bigger organization is requiring it . You know that's something that you can consider . I think you mentioned that you know over 90% of the small farmers out there probably don't need a gap audit necessarily , but you know there's things that , when they're considering this , that they can do to find out whether or not a gap audit is something that they can use . They can visit the and is this the FDA website or USDA website where they can find out a lot of this information .
Speaker 3Yeah , that's a really good point . So there's the USDA gap audits . So if you just Google USDA gap it'll pop up . And then there's also the FDA's Food Safety Modernization Act and they have different requirements . One thing if you're just really wondering , well , what's the FDA asking , there's this great group called the Produce Safety Alliance the acronym is PSA and on the Produce Safety Alliance's website they have this required records document . So what records does the FDA require if you're going to get an inspection ?
Speaker 3And I think most growers are kind of pleasantly surprised . You know you hear the FDA and you probably are thinking it's going to be like 50 , 100 records . You're thinking it's going to be a lot of paperwork . But if you look at that required records document you'll see that they're really just not that many records and they're really practical ones . You know , writing down what your employee training was , if you're making compost piles , tracking the temperature , which I imagine a lot of the organic growers are already doing . But so for those audits , usda GAP website is one good place to go , the United Fresh Harmonized GAP resources and for FDA FISMA inspections , a nice place to start is with the Produce Safety Alliance . They've really taken the lead on education around the country and there's probably a lot of growers who have taken that course . If you sat in on an eight-hour PowerPoint course with lots of food safety information , that was the Produce Safety Alliance grower training .
Speaker 2Right , well , thank you again , billy . We really appreciate your time and sharing with us so much really useful information To all of our listeners . We hope that you can continually join us to get more information about food safety . To understand food safety , you can check out our website for new upcoming episodes on this topic as well as upcoming webinars . Please sign up to receive our updates through our mailing list and you feel free to also submit your questions on our website . Again , billy , thank you so much for joining us today . We really appreciate you being with us today .
Speaker 3Yeah , thank you , this was really fun . I appreciate it .
Speaker 1Thank you for tuning in . Visit our Food Safety for Farmers podcast page on our website , wwwfoginfoorg , to find more information about episodes and webinars . Subscribe to our email list for updates and submit any questions you may have about food safety .