SONIA SALAS | DIRECTOR, SCIENCE & TECHNOLOGY SCIENCE & TECHNOLOGY
Are You Prepared for the Produce Safety Rule Inspections? The Food Safety Modernization Act (FSMA) expanded the U.S. Food and Drug Administration’s (FDA) inspectional authority and imposed many new requirements. Do you know what to do if a Produce Safety Rule (PSR) inspector knocks on your door?
PSR regulatory inspections are around the corner! They are set to begin in the spring of 2019. In most states (including Arizona, California, Colorado and New Mexico), inspections will be conducted by your state department of agriculture under a cooperative agreement with FDA. Because prior notice to a company of an impending inspection is not required, you may not receive it. If an inspector contacts you to schedule an inspection, respond promptly as unresponsiveness will likely result in an unannounced inspection. Unless there is an urgent matter,
inspectors will generally seek to inspect during normal business hours. In addition, an inspection has the weight of the law behind it; the inspector is specifically there to check for regulatory noncompliance. Noncompliance could lead to enforcement as simple as a follow-up inspection or as severe as operational shutdowns, penalties/fines, criminal investigations, and under the worst-case scenario, imprisonment. PSR inspections will be prioritized based on operational size, where the operations are located, and which commodities are grown and/or handled. Inspections will involve verbal questions, records reviews and observations of covered activities. Record reviews will cover training, biological soil amendments of animal origin, food contact surface cleaning and sanitizing, water related records, and documentation related to exemptions that apply to your operation. PSR inspections represent new territory for growers and regulators and add uncertainty as to what to expect. Being prepared in advance will go a long way to helping you feel confident when faced with your first PSR inspection. Fortunately, there are tools and resources available to accomplish this. There are three aspects you should consider: 1) assembling an inspection team, 2) requesting an On Farm Readiness Review (OFRR); and, 3) utilizing industry resources. fundamental. An inspection team is commonly formed by a minimum two employees and it is best if headed by a senior level company representative. One person should be designated as the main contact and another one designated to take notes. An inspection team is responsible for greeting the inspector, participating in the opening conference, accompanying the food inspector during the inspection, providing documentation, answering questions and participating in the closing conference. The inspection team should be familiar with the PSR requirements and be responsible for understanding your Assembling an inspection team Having an inspection team and procedure in place is
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JANUARY | FEBRUARY 2019
Western Grower & Shipper | www.wga.com
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