Food Safety: Answers and Updates
FOR FRUIT AND VEGETABLE CROPS
By Juli Ogden and Ben Marchant / The Farm Plan LLC
At The Farm Plan, we provide many farmers with on-site audit support. In my opinion, one of the most important pieces of advice I can give farmers is ‘learn to work with your auditor’. No matter if this year will be your 1st certification, or
your 10th, following some simple steps makes the audit process simpler and easier for everyone. First, let’s define what food safety is – in this context, we’re
referring to raising a crop in a safe and sustainable manner that will not harm consumers. This is obviously in everyone’s interest to show the professionalism and commitment to producing safe crops within our industry, as well as broadening the base of the retailers willing to purchase our product.
An audit can be intimidating. The thought of a potentially unfriendly stranger poking around until they find something so that they can say ‘Gotcha!’ is in the minds of many farmers. Fortunately, the reality is somewhat different. The auditor is there to do a job, and they receive no special consideration for passing or ‘failing’ a farmer. Their goal, simply, is to move through an audit checklist as efficiently as they can. If they need to spend additional time to answer the questions completely, they will use it, and conversely if the opportunity exists to finish the audit earlier than scheduled because the farm is in obvious compliance without the need to dive deep, then they will be glad to finish up a little earlier. It’s in your best interest to be as organized as possible, ready to show compliance against each control point.
Auditors have different personalities. They are typically drawn from the industry they audit or have spent time learning your industry. Different auditors will have different ideas and there will be some, though hopefully minimal, variation between them. One auditor may mark a control point ‘compliant’, and the next year a different auditor will mark it ‘non-compliant’. It happens, and while it’s OK to ask questions and challenge a finding, keep things polite and professional. For you, a non-compliance might feel like a personal affront to the hard work you put in day in, day out, but to the auditor ‘it’s just business’ as they say. If you can show additional data that might sway the auditor, ask if that would help them reconsider their finding. And if not, it’s better not to argue. Seek a second opinion once the audit is complete.
It is your right to challenge an audit finding. While I don’t recommend arguing every finding raised by the auditor, if you have a genuine concern that the finding does not reflect your compliance with the control point, you should contact the certifying body (CB) employing the auditor. Again, professionally and politely provide your data and show how you comply with the control point. This check and balance won’t always go in your favor, though, and if it doesn’t it’s often best to just move on. There is a further escalation available for very serious issues, such as auditor misconduct and fraud, but we’ll cover that another time.
For the most part, your auditor will be happy to be at your operation. They will have questions, and often genuine interest in how you do things. They may have a passion for food, food safety, and educating those around them. While there are rules precluding auditors from being overly familiar with your operation, depending on the standard, you can request the same auditor 3 or 4 years in a row before you are required to have a new auditor. Scheduling conflicts may not always allow this, but CB’s will do their best to honor your request. As mentioned, some auditors see things differently, or you may just feel more comfortable with a certain auditor. The consistency from year to year may ease your concerns.
Prior to your audit, it’s a good idea to contact the auditor. If that is not possible contact the representative at the CB to obtai
nthe list of documents the auditor will request, and in which order they prefer to see things. Having your documents organized the way the auditor prefers relieves stress and shows that your farm is organized, getting you off to a good start. When your auditor arrives on-site, treat them like a respected supplier. Have them sign-in and ask if they would like to conduct the physical inspection prior to the paperwork. This small change in schedule will allow the auditor to see the answer to many control points, and once inside they will be able to mark the question ‘OK’ without conversation, saving everybody time.
And please remember that there is always help available, you do not have to go through it alone if you do not want to.
- CROPS FOR PROCESSING: This new GLOBALG.A.P. standard simplifies rules for crops slated to be frozen, juiced, used to make pre-cooked meals and other types of processing. www.thefarmplan.com/GGcfp.
- FSMA PRODUCE SAFETY RULE Add-On: This additional GLOBALG.A.P. module may be requested for your audit. This is not mandatory and does not replace a FSMA Inspection but, according to GLOBALG.A.P. trainers, “may decrease the likelihood of your farm being inspected”. Expect more change in the future. See www.thefarmplan.com/FSMApsr.
- FSMA Compliance and Water Testing Rules: These remain in a state of flux. See new rules compliance target date chart at www.thefarmplan.com/FSMAdates.