Author: Stepheni Norton, San Diego Regional Food Safety Specialist
FSMA is serious business, so we have a few disclaimers before we dig in.
- Advice provided here is meant for QUALIFIED EXEMPT 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.
- ATTN – If your sales outlets have changed during COVID and you are concerned about a potential change in your farm status, read our blog post on the temporary enforcement discretion on sales to qualified end users
YOU’RE QUALIFIED EXEMPT, NOW WHAT
Qualified exempt farms must comply with modified FSMA requirements, which includes establishing and keeping certain records, prominently displaying your farm name and business address and growing, harvesting, packing, and holding your crops in a sanitary and safe way. Failing to do these things, can mean the withdrawal of your Qualified Exemption status.
Do not worry, you are (most likely) already doing these things, you just need to document it.
Qualified Exempt Status Record
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 (e.g. in 2020 you should have these records for the 2017, 2018, and 2019 seasons. In 2021, you replace the 2017 records with the 2020 ones, so you still have records from the most recent three year time frame)
Record Tool Tip: Run a report from your credit card processing or accounting system. Make sure to filter out non produce items (tours, events, value added products, etc) and attach to your Annual Assessment.
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
- Annual Sales Report
Record Retention: Keep for a rotating 3 years (e.g. in 2020 you should have these records for the 2017, 2018, and 2019 seasons. In 2021, you replace the 2017 records with the 2020 ones, so you still have records from the most recent three year time frame)
Record Tool Tip: Use Page 1 of our Annual FSMA Assessment form, from Blog Post 1
Displaying Farm Name
FSMA requires your farm name and complete business address must be disclosed “prominently” on the produce package label or at the point of purchase. So that, in case of an outbreak, the produce can quickly be traced back to the farm source.
Purpose: to document the farm where the produce was grown.
Must Include:
- Name of your farm
- Complete business address of your farm
Acceptable Methods:
- Label on packaging
- Posters or signs at farm stand
- Post card or document included in packaging
- Electronic notice on your website for internet sales
Tool Tip: Add your complete farm address to your farmers market sign, print and display at your farm stand, add it to your credit card receipts.
Sanitary & Safe Practices
Regardless of your farm’s status, you are required to take appropriate measures to assure your produce is not adulterated – grown or harvested in such conditions that it is unfit for food; or prepared, packed, or held under insanitary conditions whereby it may have become contaminated with filth.
If adulterated produce causes and an outbreak of foodborne illness that is directly linked to your farm, or if FDA determines it is necessary to protect the public health and prevent or mitigate an outbreak based on conduct or conditions associated with your farm or produce, your qualified exemption may be withdrawn.
So, although FSMA does not require farms to create a written farm food safety plan, CAFF believes the best way for a farm to document that they have sanitary and safe practices is to have a written plan.
Purpose: to document your sanitary and safe practices.
Should Include:
- Name of your farm
- Complete business address of your farm
- Description of your farm
- Contact information
- Risk assessment of practices and conditions on the farm that can impact food safety
- Description of practices that the farm undertakes to reduce risks
Record Retention: review and update at least annually to reflect any changes in practices on your farm
Record Tool Tip: Use the CAFF Simplified Food Safety Plan Template or if you are Certified Organic, use your Organic Systems Plan.
Need help setting up your records or creating a farm food safety plan? Contact your location CAFF Regional Food Safety Specialist (scroll to bottom of page for contact info).
RECORD KEEPING REMINDERS
- Paper or electronic record keeping are acceptable.
- Do not recreate the wheel.
- You can use the records you already keep, just add the detail required by FSMA.
- You can use free templates
- Record must be stored on the farm.
- Records may be stored off farm if they are readily accessible
- Electronic records are considered to be onsite if they are accessible from a computer at your farm.
- Off season when your farm is closed, records can be stored off farm.
- Records must be readily accessible (accessible within 24 hours for official review)
- Financial Records must be kept and retained as long as necessary to support the farm’s status, usually a rotating 3 years.