So you have a farm that’s certified under SQF. The question is how will it meet the new Produce Safety Rules (PSR) under FSMA?

First of all, you should know that the FSMA Produce Safety Rule does not apply to you if your farm produces products that are:

• rarely consumed raw
• produced for personal or on-farm consumption
• not a raw agricultural commodity
• receiving commercial processing

In general, the Produce Food Safety Rule requirements focus on minimizing the risk of serious adverse health consequences or death from consumption of contaminated produce. In a nutshell, the rule sets procedures, processes and practices for the safe growing, harvesting, packing and holding of fruits and vegetables for human consumption to prevent the introduction of known or reasonably foreseeable biological hazards onto produce.

In North America, SQF is the leading GFSI scheme implemented in food and produce operations. Although most farms have been following Good Agricultural Practices guidance to control food safety risks for quite some time, it is good to know that SQFI has led the way in keeping pace with the changing regulatory requirements of the U.S. As such, the SQF Level 2 Certified Farm under Module 7 of the SQF Code will compare very favourably to the new FSMA Produce Rules.

There are three areas where the SQF Certified Farm will exceed the expectations outlined under FSMA. The first area is in Chillers and Cold Storage safety. The FSMA Produce Safety Rule does not address the complications that can come from trying to maintain proper cold storage. This is more clearly outlined under 7.2.3 of the SQF Code requirements. The second area where SQF is more detailed and stronger is the area of Pest Management. Thirdly, the FSMA Produce Safety Rule does not encourage farmers to follow current GMP rules as appropriate.

In the area of record keeping, both the SQF Certification scheme and the Produce Safety Rule stresses the importance of documentation. FSMA requirements under part 112 requires that your records include:

1. the name and location of your farm
2. actual values and observations observed during monitoring
3. an adequate description (such as commodity name, or the specific variety or brand name of the commodity, and when available, any lot number or other identifier) of covered produce applicable to the record.
4. the location of growing area (for example; a specific field) or other area (for example; a specific packing shed) applicable to the record, and;
5. the date and time of the activity documented.

It’s important to note that although these two standards are not identical, the SQF Certified Farm will exceed or meet most of the requirements under the new FSMA Produce Safety Rule.

dicentra is a professional consulting firm that specializes in addressing all matters related to safety, quality and compliance for all product categories in the health sciences and food industries. We evaluate, implement, and provide all the necessary support for your products and operations to gain market access and build confidence in your brand.