Not Covered ≠ No Paperwork
By: Stepheni Norton, San Diego Regional Food Safety Specialist
Last Updated: March 19th, 2020
Basic record keeping to prove you’re not covered farm status.
FSMA is serious business, so we have a few disclaimers before we dig in.
- Record keeping advice provided here is meant for NOT COVERED FARMS
- If you need help determining your status, read our “THE 1 THING EVERY FARM MUST DO” blog post.
- Although tools are mentioned here, CAFF does not endorse or recommend any specific platform.
PROOF IS IN THE PUDDING…PAPERWORK
Even though you are not required to comply with all of FSMA, you are still required to prove your status, AKA A NOT COVERED FARM. This “proof” includes records you (most likely) already keep with just a few minor additions.
If you’re claiming the full exemption because you only grow rarely consumed raw crops than you need these records:
Annual Crop Plan
Record Purpose: to show you only grow crops that are on the FDAs rarely consumed raw list.
Record Must Include:
- Name of your farm
- Location of your farm
- Planting Year
- Crop and Varietal
- Location of growing area
- Be signed and dated
Record Retention: Keep for 2 years
Record Tool Tip: Copy your plot plan and seed order list.
If you’re claiming the full exemption because you have sold less than an average $27,528 gross produce sales over the last three years than you need to these records:
Annual Sales Report and Related Receipts
Record Purpose: to show your gross produce sales.
Record Must Include:
- Name of your farm
- Location of your farm
- Date of transaction (for receipts)
- Date of Report (for report)
Record Retention: Keep for a rotating 3 years
Record Tool Tip: Run a report from your accounting system. Make sure to filter out non produce items (tours, events, value added products, etc).
All farms claiming an exemption should review their status annually and have that record:
Annual Assessment
Record Purpose: a written record reflecting that you have performed an annual review and verification of your farm’s status.
Record Must Include:
- Name of your farm
- Location of your farm
- Attestation of your review
- Be signed and dated
Record Retention: Keep for a rotating 3 years
Record Tool Tip: Use Page 1 of our Annual FSMA Assessment form.
RECORD KEEPING REMINDERS
- Paper or electronic record keeping are acceptable.
- Record must be stored on the farm.
- Electronic records are considered to be onsite if they are accessible from a computer at your farm.
- Off season when your farm is closed, they can be store off farm.
- Records must be readily accessible (accessible within 24 hours for official review)
- Don’t recreate the wheel. You can use the records you already keep, just add the detail required by FSMA.
Need help setting up your records? Contact your location CAFF Regional Food Safety Specialist.