The Almond Board of California (ABC) held its 18th annual Food Quality and Safety Symposium in Modesto recently with a keen focus on providing almond industry members with information and resources to help them comply with upcoming rules in the Food Safety Modernization Act (FSMA).
For handlers with more than 500 employees and subject to the Preventive Controls rule, the compliance period begins this September, while other operations have up to three years before compliance is mandatory.
The California almond industry has a long history of creating and implementing food safety programs to the extent that much of FSMA is not new to us because we have been building the foundation for many years.
Growers will find that many of the requirements under the Produce Safety rule are very similar to the ABC’s “Good Agricultural Practices for Almond Growers,” and handlers who operate under standard third-party auditing programs, including the Global Food Safety Initiative (GFSI), will find that they are already very close to compliance with the Preventive Controls rule.
Which rules apply?
Knowing which rules will impact a specific operation requires a close look at the categories and the qualifications that place an individual or company into a specific category.
Whether you are an almond grower, a huller-sheller, a handler or a processor, you may be surprised to learn that all four of these categories could also be considered a “farm” under FSMA rules.
As we learned from symposium speaker Elizabeth Fawell, who with colleagues at consulting firm Hogan Lovells developed a decision tool for almond industry members to determine which FSMA rules apply to their operation, the key factors that influence the type of operation you have include: location (proximity to an orchard); ownership structure; company size; and activities performed (growing, hulling-shelling, handling, manufacturing).
Engaging in multiple activities may mean that you are regulated under the Produce Safety rule for some activities and under Preventive Controls for other activities.
For instance, if you’re a huller-sheller or a processor who meets the definition of a farm, then you would have to comply with the Produce Safety Rule, which applies to food intended for consumption in the U.S. plus produce for export.
Another rule, Preventive Controls for Animal Food, applies to the almond industry for hulls used as an animal feed. An exemption to this rule would be granted if the hulls are consumed on the farm where the almonds are grown, or if growers who meet the “farm” definition do not engage in hull processing.