company’s policies, legal rights and responsibilities. This team should develop an inspection plan/procedure in writing and conduct drill inspections so that when an inspector shows up at your door, everyone knows what to do. Before an actual inspection takes place, an inspector should present credentials, a notice of inspection and discuss the nature of the inspection. At the time of the inspection, the inspector will want to observe all activities conducted and performed on your operation that are covered by the PSR. If the inspector sees anything of concern, he or she should discuss it with you immediately and provide regulatory reference and scientific rationale to support such concerns. Any corrective actions that you commit to will be documented. At the end of the inspection, the inspector should summarize any discussions you had during the inspection, answer any questions you may have, discuss any follow-up steps, and provide your team with a copy of the inspection report. Western Growers has an Inspection Manual that provides information and suggested guidelines for members to follow during food regulatory inspections. This manual can be accessed at www.wga.com/resources Self-Assessments and On-Farm Readiness Reviews View preparing for a PSR inspection as an opportunity to conduct a self-audit of your food safety program activities, procedures, documentation, and record systems. WG has produced a PSR self-audit checklist along with an illustrated PS Rule Implementation Guide that is available to members on our website www.wga.com/fsma. This resource provides you with an opportunity to self-assess your operation. Also, in 2017 the FDA released four guidance documents to help those subject to the PS Rule to establish and implement the required
practices and procedures. These guidance documents culminated in the October 2018 release of a comprehensive Draft Guidance to Industry: Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption and Draft Guidance for Industry: Guide to Minimize Food Safety Hazards of Fresh-cut Produce . This document is open for comments and we welcome your thoughts and careful review. Any comments can be submitted to us by March 30, 2019, or to the FDA by the comment deadline of April 22, 2019. Industry guidance can assist you in assessing your operation. In addition, you could also request a non-regulatory On-Farm Readiness Review (OFRR). These are designed to help growers better understand what to expect from an actual PRS inspection. An OFRR is a voluntary, on-site assessment of your operation’s food safety and good agricultural practices coordinated by your state department of agriculture. OFRRs provide you with an opportunity to learn about the applicability of the rule to your operation and to ask questions. Western Growers has a dedicated OFRR website page that includes videos and additional information to better understand how OFRRs work and how to request one (www.wga.com/ofrr). In conclusion, being prepared is a must to deal successfully with the upcoming PSR inspections. If you have assembled an inspection team, have inspection procedures in place and have assessed your operation regarding PSR requirements, you are better prepared ahead of any PSR inspection. Nevertheless, it is not too late if you have not addressed inspection preparedness. We encourage you to use tools and resources available to you. Please contact WG’s Science and Technology staff for assistance or if you have any questions about this matter.
36 Western Grower & Shipper | www.wga.com JANUARY | FEBRUARY 2019
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