Routine Inspections are beginning! Here’s what you need to know.

If you have already been inspected by MDARD for FSMA, you will be inspected in the next 3-5 years. Don’t fret! Here are some insider tips.

The Produce Safety Rule (PSR), part of the Food Safety & Modernization Act (FSMA), establishes minimum regulatory requirements you must follow and will be inspected to regarding your on-farm produce safety practices. There are some exemptions, but for those of you who sell primarily wholesale, grow “covered”, or usually consumed-raw, produce, and make over $30k per year in gross produce sales, then you have probably been inspected under the FSMA PSR in the last 6 years.

And… you will be inspected again! The MI Department of Agriculture and Rural Development (MDARD) is now moving into their “routine” inspection phase. In other words, the farms who fit within the above criteria that have already received their initial inspection will now be receiving a routine inspection which is like an initial inspection, but some key differences are described below. This is assuming you are still produce farming and meeting the sales criteria above, similar to when you received your initial inspection.

What does it mean to receive a routine inspection? How does an initial inspection look different from a routine inspection?

While an initial inspection takes a more educational approach with a report documenting discussion points, a routine inspection will include violations documenting farm food safety practices that are not in compliance with the PSR. You should address any notes from the initial inspection before the routine inspection.  If an inspector observes practices that are not in compliance with the PSR There are two categories of violation criticality, core and priority. A core violation/observation is a practice that does not pose an imminent health risk, but must be corrected as soon as possible, and definitely before the next routine inspection. A routine inspection will likely occur every 3-5 years.

Priority observations are more serious, as they pose a serious imminent public-health risk. If priority violations are unable to be corrected during the inspection, a follow-up visit by MDARD will be required to verify correction. The timing of the follow-up inspection can range from a few weeks to the following season, depending on the violation and time of year.  If you still do not correct the observation by then, the next visit accrues a $60 re-inspection fee, beginning a progressive enforcement strategy until the issue is fixed and verified by MDARD.

We (I) do not want any “observations”/violations to happen– for your sake and the consumers! So, here are some tips to make sure you are dotting the i’s and crossing the t’s before a routine inspection:

• Look at your initial inspection notes before your routine inspection. The MDARD inspector would have sent you a copy via mail or email, in case you did not take your own! If you can’t find it, you can reach out to a current inspector to send you a copy of your previous report.

• Call your local produce safety technician. Technicians are a free, confidential, voluntary resource. They can help prepare you for an inspection and have cost-share dollars available in case there are any changes needed that require some capital. Find your local technician here!

• Take an updated water test if you have not already. Even if you use municipal water, make sure you have the latest, publicly available test records on hand. An annual water sample is required for non-public water sources that you use for harvest or post-harvest purposes, including activities such as handwashing, equipment cleaning and sanitizing, or produce washing.

• Maintain your required records. An inspector will ask to see the following in writing:

  • Worker training records: who was trained, on what topics, which includes personnel illness policy, training date, supervisor initials.

  • A personnel policy includes: symptoms of foodborne illness that employees must monitor for and not handle food with, and when can workers return to work.

• Produce Safety Alliance Grower Training Certificate. If you can’t find yours, contact Phil Tocco.

• Records of water test(s), as applicable, and an annual water system inspection.

• Cleaning and sanitizing records: what piece of equipment was cleaned and sanitized, who cleaned and sanitized it (initials), when/date, and supervisor initials.

  • Shortcut: you can have an SOP stating HOW to clean and sanitize certain food contact surfaces and equipment, and state in the record that SOP #/xyz was followed. This avoids having to write the cleaning and sanitizing process on the cleaning record itself and makes it easier for employees to fill out!

• If you use compost:

  • A record verifying temperature, time, and number of turnings OR

  • A certification letter/record from the composting company states they are doing their due diligence to make sure the compost has reached a number of turnings, time, temperature.

An important note: be able to justify why certain practices work for your operation, and that they still achieve food safety. The PSR utilizes a non-prescriptive approach for many practices. For example, if you use “batch” or recirculated water to wash produce, what is your process in determining when that water needs to be changed? Why that method? Can you justify that this process works for you AND aligns with the Produce Safety Rule? The PSR states that you must “visually monitor” and “maintain and monitor the temperature” of such water to “maintain its safe and adequate sanitary quality and minimize the potential for contamination…” (§112.45(d)). As you can see, it can be vague!

If there are questions or needed assistance relating to any practice changes, or notes from your initial inspection, please contact your local technician! They can help define what food safe practices can look like for your operation, just in time for your routine inspection.

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Article by Morgan Anderson, Produce Safety Technician