Food Safety Certification for Aquaponics under the FSMA And HACCP; Summary:
The most important thing to know: To the best of our knowledge, we are the only one of the myriad “commercial aquaponics trainers” who teach our students how to get Food Safety certification for aquaponics. This includes FSMA GAP certification (Food Safety Modernization Act, Good Agricultural Practices), HACCP certification (Hazard Analysis and Critical Control Points), packinghouse certification, processing facility certification, and cold storage certification.
It seems strange to us that anyone would label their course a “commercial aquaponics” course if they couldn’t teach you how to legally sell more than $25,000 per year of produce per year (under the FSMA law) as we can, or how to get twice as much for your organically certified produce (click here to find out more about organic certification requirements) as we can.
Legal Requirements: As of February 2016, any agricultural producer (such as an aquaponics farmer) must have FSMA GAP certification (Food Safety Modernization Act, Good Agricultural Practices) to legally operate, unless you sell less than $25,000 worth of produce a year. This allows you to only sell whole heads of produce in a bulk box, gives you the lowest possible price for your produce, and extremely limits who you can sell to.
Additional Certification for profitability: There is an additional certification called GMP HACCP (Good Manufacturing Practices, Hazard Analysis and Critical Control Point). This is an optional certification; meaning it is not required by law. But there’s something more important to know about this certification. With it, the door is open for an agricultural producer to sell relatively valuable packaged, washed, cut, and otherwise manufactured products directly to the major retailers such as the Big Box stores (Costco, Sam’s Club, Target), as well as directly to all other retailers such as Albertson’s, Ahold Delhaize, Kroger’s, and Whole Foods, who now require this certification in their vendors. More and more outlets are now requiring this certification in their vendors.
Without GMP HACCP certification, this door is closed. You simply can’t sell some of the more profitable products such as lettuce and salad mixes and other types of aquaponic products. You can’t make pestos or salsas, salad or lettuce mixes, or wash your produce. You can’t even package individual items in bags or clamshells. Think twice before deciding that this certification isn’t necessary for your business to succeed.
The future? There are now Farmer’s Markets in California (Los Angeles area) that require California State Food Safety certification for all their vendors. This is just a guess, but them requiring FSMA GAP certification next is not a big jump from that. And then requiring GMP with HACCP for their vendors of prepared foods such as lettuce mixes and so on will not be a big jump either.
Finally: Just as the FSMA moved from being a set of recommendations in 2009 to being a law now, we feel that these HACCP requirements will move from being a profitable option to being a law at some point in the future. These certifications are really about providing safe food to the community around you; something we all agree is important. Why not be ready now?
What is the Food Safety Modernization Act (FSMA)?
Current Food Safety Laws dictate that everyone has a role in ensuring safe food from field to fork. The Food Safety Modernization Act (abbreviated as FSMA, and pronounced “FIZZ mah”) is the first major overhaul of our nation’s food safety practices since 1938. It includes new regulations that govern fresh produce direct from the field, and produce from facilities that process food for people to eat. This means it represents some big changes to our food system – and following these laws will be extremely important for your success.
FSMA gives the Food and Drug Administration broad new powers to prevent food safety problems, and to detect and respond to food safety issues. To do so, FSMA authorizes new regulations for farmers who grow certain kinds of fresh produce as well as for certain facilities that process food for human consumption. The regulations focus on addressing food safety risks from microbial pathogen contamination (e.g., Salmonella, E. coli O157:H7, and Shigella).
Specifically, FSMA requires FDA to establish new regulations for:
- Standards for produce production (Produce Rule), and
- Food safety measures for facilities that process food for human consumption (Preventive Controls Rule).
Why Does it Matter?
Food safety matters because the risk of foodborne illness — that is, the risk of getting sick or even dying from food contaminated with pathogens such as E. coli — is largely preventable by good food safety measures applied at every step from farm to fork. Examples of good measures include hand washing and keeping foods at the right temperature. However, it’s not as simple as requiring all farms and facilities to meet identical safety requirements. Depending on the complexity of the supply chain, types of produce grown, and the kinds of practices the growing facility implements, different kinds of farms and facilities face different types of risks when it comes to contamination that could cause illness. As an aquaponics facility, you must address potential risks associated with your method of food production to the satisfaction of the auditor and certifying organization.
Where Did FSMA Come From?
Due to a rise in major outbreaks of foodborne illnesses and increasing bioterrorism concerns after 9/11, both Congress and the Obama Administration proposed new food safety measures in 2009 that expanded food safety regulations to the farm level. Previously, food safety regulatory oversight was focused mainly on the processing, food handling, and manufacturing sectors – areas shown to be of highest risk for foodborne pathogen contamination.
What Happened Next?
The Food and Drug Administration (FDA) started the lengthy process of implementing the Food Safety Modernization Act (FSMA). The FDA enacted FSMA – passed by Congress into actual rules and regulations – in November of 2015. This means that the FSMA Rule is now law. So, the question is, how can you best adhere to this new law?
FSMA Audits Legally Required For Your Aquaponic Operation:
The greenhouse FSMA audit must be performed one time each year, and is divided into sections that correspond to areas of potential contamination risk in your operation. These areas include:
- Ground history;
- Adjacent land use;
- Pest Control;
- Foreign material control;
- Growing media;
- Fertilizer/crop nutrition;
- Irrigation/water use;
- Plant protection;
- Employee hygiene; and
- Food biosecurity
A harvest crew audit (see below for details) will be performed at the same time as the greenhouse audit module in order to assess areas of potential contamination risk in the harvesting operation.
Harvest Crew Audit
A ‘harvest crew’ is defined as a crew of harvest personnel under common management. The harvest crew FSMA audit is performed periodically during the harvest season, and is divided into sections that correspond to areas of potential contamination risk in your harvesting operation. These areas include:
- Employee safety
- Employee hygiene
- Harvest practices
- Food security
PLEASE NOTE: The above two audits are relatively simple, and are the bare minimum required by the FSMA for you to sell any produce whatsoever. These two audits, when passed, will allow “one cut in the field”, and do not cover any “value-added” processing. In other words, if this is the only certification you have, you are only allowed to put entire heads of produce into a box for sale; no cutting, washing, bagging or putting individual items in clamshells, or other preparation is allowed.
This creates the lowest value product, which is a major reason for procuring the next certifications for GMP (Good Manufacturing Practices) with HACCP (Hazard Analysis and Critical Control Points):
GMP, HACCP Audits, And Certification For Profitability:
GMP stands for Good Manufacturing Practices; which is the FSMA certification required for any facility that washes, cuts, bags or puts in clamshells, or otherwise processes vegetables. Most wholesalers and Big Box stores such as Costco have additional requirements above and beyond the FSMA GMP to insure food purity and safety. HACCP certification is one important and commonly required certification that falls into this category.
HACCP is an acronym that stands for Hazard Analysis and Critical Control Points. HACCP is a method to help identify and evaluate the processes that control food safety issues. Essentially, HACCP helps to identify
- What can go wrong in your food production process?
- What physical, microbiological, chemical and other risks are there to our food production process?
- How to control our process so that it doesn’t go wrong.
- If it does go wrong, what happens then? How do we fix it? A documented plan must be in place.
For example, Costco has additional requirements for produce vendors that are dedicated to making sure their members are protected from food-borne illness as well as making sure that Costco is adequately shielded from liability; HACCP procedures help reassure Costco (and other “Big Box” stores) that their “deep pockets” are adequately protected.
Why Bother With GMP And HACCP Certification?
- It’s a smart business decision: the difference in gross income between selling relatively valuable prepared and packaged produce and having to dump bulk whole-head produce on the market (because you lack HACCP certification) can easily be half your total yearly gross income. That’s nothing to sneeze at, or to ignore in your business plan.
- In addition, satisfying these additional HACCP requirements goes a long way towards protecting you and your investors from legal liabilities. In the event of a claim, it will be easier to show that the problem could not have originated from your facility if the pertinent HACCP records and log books are available and up-to-date. The simple records required by FSMA do not include the detailed information HACCP records do, and do not cover this possibility adequately. It would be easier to claim that you were negligent, only operating the facility under the “minimum” FSMA legal requirements.
Average HACCP audit requirements for produce vendors:
Packinghouse Audit with HACCP
A “packinghouse” is where whole, uncut commodities are prepared and packed for commercial distribution after being subjected to processes such as sorting, washing, weighing, etc.
The packinghouse audit must be performed at least once per year. The audit is comprised of three main sections; a Good Manufacturing Practices section, a Food Safety File Requirements section and a HACCP section, with questions that assess the your food safety program. This audit includes:
- Pest control;
- Employee hygiene practices
- Food biosecurity
- All other operational practices and documentation as they relate to food safety.
Processing Audit with HACCP
To sell anything but whole, uncut produce in boxes, you need the processing audit HACCP certification; this covers you for preparing things like bagged or clamshelled head products, cut vegetables, lettuce and salad mixes, and items like uncooked pestos and salsas. The processing audit is performed at a minimum of once per year. The processing audit questions are used to assess the facility’s food safety program as it applies to Good Manufacturing Practices under 21 CFR, part 110, and relevant parts of the Food Code, 2001 (FDA/USPHIS), including HACCP requirements.
The audit is comprised of three main sections: Good Manufacturing Practices, Food Safety File Requirements, and HACCP. The audit encompasses the areas of:
- Pest control;
- Employee hygiene practices;
- Food biosecurity
- All other operational practices and documentation as they relate to food safety including HACCP plans.
Cooling/Cold Storage with HACCP
A ‘cooling/cold storage facility’ is where product is temporarily stored prior to distribution in order to maintain the proper temperature. Pre-cooling processes (ice injectors, Hydrovac, pressure cooling, etc.) may also be used in the harvest operations.
The cooling/cold storage audit must be performed at least once per year. The cooling/cold storage audit questions are used to assess your food safety program as it pertains to cooling and cold storage. The audit is comprised of three main sections; Good Manufacturing Practices, Food Safety Requirements, and HACCP.
The audit encompasses the areas of:
- Pest control;
- Employee hygiene practices; and
- All other operational practices and documentation as they relate to food safety. Food biosecurity is also addressed.
PLEASE NOTE: These audits require standard operating procedures (SOPs) to be in place for a minimum of 90 days before the audit can take place. Therefore, it is critical that one part of your production area be brought online as soon as possible, to put SOPs in place and begin their documentation.
In order to do this kind of processing, you will also need to pass your local State Health Department food preparation facility certification, which is far less stringent than these certification requirements. This mostly consists of additional paperwork and a visit by a State Health Department inspector once a year or so.