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How Produce Safety Rules Affect Hydroponic Farming

In the changing world of agriculture, hydroponic farming has emerged as a beacon of progress, offering efficient and renewable ways to grow fresh produce. However, as with any industry, ensuring food safety remains crucial. Enter the Food Safety Modernization Act (FSMA) Produce Safety Rules. Designed to enhance on-farm food safety measures across the United States, these rules have greatly impacted hydroponic farming practices. This blog discusses the basics of FSMA and the effects it has on operations throughout the nation.

What is the Food Safety Modernization Act?

The Food Safety Modernization Act (FSMA) is a law that grants the U.S. Food and Drug Administration (FDA) authority to govern food safety in the United States.

There are seven primary rules of FSMA which focus on prevention of food safety issues and cover the entire food system. These rules include preventive controls for human and animal food, foreign supplier verification programs, accreditation of third-party auditors/certification bodies, sanitary transportation of human and animal food, prevention of intentional contamination or adulteration, and the Produce Safety Rule. It sets guidelines that modernize agricultural regulations.

It has notable protections against the intentional spoilage of food, rules for cleaning practices in production and transportation and suggestions for actions that reduce the risk of bacterial infection of produce.

A FSMA-PSR Training Officer visiting the office of Pure Greens, a container manufacturer in Phoenix, Arizona.
A FSMA-PSR training officer (middle) visits the Pure Greens container farms headquarters in Phoenix.

How is FSMA Different from Other Guidelines?

FSMA, signed into law in 2011, represents a significant shift in how the U.S. government regulates produce safety. It introduced a preventative approach to food safety, with the goal of reducing foodborne illnesses by focusing on preventing contamination.

FSMA contrasts with previous federal guidelines that were focused on responding to food safety issues after they had arisen. FSMA differs from these former federal guidelines in four key ways:

1. Mandatory Regulations

FSMA mandates that the FDA issue regulations for produce safety rather than relying on voluntary industry standards. This gives the FDA more authority to enforce rules and hold producers accountable for ensuring the safety of their products.

2. Preventative Controls

FSMA requires producers to implement preventative controls to reduce the risk of contamination at every step of the supply chain, from growing and harvesting to packaging and transportation.

3. Risk-Based Approach

FSMA requires producers to conduct a hazard analysis and implement measures to control identified risks. This allows producers to focus their resources on the areas with the highest levels of risk.

4. Foreign Supplier Verification Program

FSMA requires importers to verify that their foreign suppliers meet U.S. safety standards. This helps to ensure that imported produce is safe for consumption and is consistent with the quality of American-produced goods.

What is the FSMA Produce Safety Rule (PSR)?

A significant aspect of FSMA is the Produce Safety Rule, which establishes standards for the growing, harvesting, packing and holding produce for human consumption.

The Produce Safety Rule aims to establish standards in these critical areas:

  • Worker training, health and hygiene
  • Agricultural water
  • Biological soil amendments of animal origin (manure)
  • Domesticated and wild animals
  • Equipment, tools and buildings

The FSMA produce rule applies to domestic and imported produce, with some exceptions for certain types of produce and operations already subject to other regulations. If you grow, harvest, pack or hold/cool fresh fruits or vegetables, you may be regulated by the PSR.

Key provisions of the Produce Safety Rule include:

1. Water Quality Standards

The Produce Safety Rule sets specific standards for the quality of water used for farming purposes, including irrigation and washing produce.

2. Worker Training and Employee Health and Hygiene

The Produce Safety Rule requires producers to establish policies and procedures to ensure the health and hygiene of workers handling produce. The PSR requires one supervisor from each farm to complete a Produce Safety Alliance Grower Training Course.

3. Biological Soil Amendments

The rule sets requirements for using biological soil amendments, such as compost and manure, to prevent the spread of pathogens.

4. Equipment, Tools and Buildings

The Produce Safety Rule requires producers to maintain equipment, tools and buildings in a manner that prevents contamination of produce.

5. Recordkeeping

The rule requires producers to maintain certain records related to their food safety practices, to facilitate traceback in the event of a foodborne illness outbreak.

Important FSMA terms and the Produce Safety Rule.

What Requirements Does FSMA Put on Hydroponic Farms?

The routes of contamination the FDA considered for covered produce under the Produce Safety Rule apply to hydroponic farming. Covered produce grown in hydroponic systems is subject to the same potential for contamination from agricultural water, although the risk differs between traditional and hydroponic production.

Traditional farms can experience the spread of contaminated food. Hydroponic farms often use a closed loop watering system, replacing the solution regularly. In particular, the FDA recommends that hydroponic farmers closely monitor the pH and nutrient levels of their water to prevent the growth of harmful pathogens.

What Farms Are Exempt from the Produce Safety Rule?

While food safety is crucial for all farms producing food for human consumption, the Produce Safety Rule regulation only applies to some farms. Your farm or operation may receive an exemption from the Produce Safety Rule. Exemptions are awarded by the Arizona Department of Agriculture annually and farms must submit an exemption application by Oct. 1 each year.

The following are exemptions farms could qualify and submit an application online for:

1. Process Exempt and Rarely Consumed Raw Exemption

Agricultural commodities that are considered Rarely Consumed Raw or products that are sent to further processing which will include a kill step, both of which will eliminate any pathogens present on the produce therefore the produce would not be regulated or fully exempt from the Produce Safety Rule.

2. Micro Exemption

Another full exemption from the Produce Safety Rule would be awarded if the farm has less than $25,000 in average annual produce sales and/or services rendered over a three year basis. Read more here.

3. Qualified Exemption

If you sell your food locally, you may be able to earn a qualified exemption for your farm. Farms can earn a qualified exemption if the farm’s previous three year average food sales are less than $500,000 and sell more than half of their produce to “qualified end-users.”

Qualified End-Users include:

  • The consumers of the food (not a business); or
  • A restaurant or retail store located in the same state or reservation as the farm or within 275 miles of the farm.
A FSMA-PSR training officer visits Pure Greens container farms and talks Produce Safety Rules.
Controlled Environment Agriculture (CEA) elements in container farms enhance efficiency in maintaining cleanliness. Separate handling spaces can help ensure that no produce has been contaminated.

These growers must comply with minimal labeling requirements and maintain records to prove they meet them. A food packaging label is required. Farms must prominently display on the food packaging label the name and the complete business address of the farm where the produce was grown. If there is not a packaging label, then the farm must openly display, at the point of purchase (i.e. at a farmers’ market), the name and complete business address of the farm where the produce was grown either on a poster, sign or placard.

For internet sales, the farm must include a notice on the sale web page.

Container Farm Advantages

Container Farms have key advantages in meeting FSMA Produce Safety Rules and maintaining a clean growing environment from production to distribution. These benefits include:

Easier to Clean

When meeting FSMA requirements for traditional farms, the sheer area of the growing space can make it difficult to maintain clean standards. If you have several acres of property, you might have contamination and not know it.

Easier to Monitor

Because container farms are more compact, monitoring growing conditions and making quick changes to maintain a clean space is easy. Elements of Controlled Environment Agriculture (CEA) can make this process more efficient. Temperature and humidity are two factors that, if not controlled, can lead to microbial growth. In container farms, monitoring systems can immediately notify growers if any environmental element drops or rises above what’s expected. That allows growers to act quickly to ensure safety standards like those in FSMA.

Provides a Secure Shelter

The inside of a shipping container farm, showing the grow trays, grow lights and air circulation system.
Container farms have advantages in meeting FSMA rules and maintaining a clean growing environment. Most notably, container farms offer precise monitoring for a variety of environmental factors and are easier to maintain and clean than traditional farming practices.

Traditional farming methods are often subject to factors such as natural disasters, pests and disease. These factors can impact crop yields and ruin food safety. Conversely, container farms provide a safe and secure environment for crops to grow, free from external affects.

Learn More

Interested in learning more about container farming or the Produce Safety Rules? Contact us today to learn more about how a Pure Greens farm might help you enhance your farming production and give you more control over the growth of your crops.

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