March 10, 2025 • 28 mins
Billy Mitchell, food safety expert, talks with us about food safety audits and commonly asked questions from farmers.
We welcome Billy Mitchell, FSMA Training Coordinator for the National Farmers Union, for a conversation about questions he commonly hears from farmers about food safety.
Tune in to hear about:
- Why food safety certification has become more common
- Is this certification voluntary for certified organic growers and small farms?
- How long it takes to prepare a farm for an audit
- The average cost of a food safety audit
Resources:
Listen to FOG’s food safety-related webinars on our website: https://foginfo.org/food-safety-for-producers/
Learn about the National Farmers Union on their website: https://nfu.org
Find information on food safety on the Produce Safety Alliance website: https://producesafetyalliance.cornell.edu
Due to the ongoing federal funding freeze, we must redirect our efforts to other FOG programs. But we need your help to keep programs like Fresh Take and other FOG initiatives alive!
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Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:02):
Welcome to Florida Organic Growers podcast series
Food Safety for Farmers.
A project funded by the USDANational Institute of Food and
Agriculture Food Safety OutreachProgram, our podcast provides
information on food safetytopics that farmers can use to
better understand how to complywith the Food Safety
Modernization Act regulations.
Thanks for tuning in.
Speaker 2 (00:25):
Welcome everyone.
We're very happy that you canjoin us today.
We're very lucky to have BillyMitchell, who is a training
coordinator for the Food SafetyModernization Act at the
National Farmers Union.
Welcome, Billy, Thanks.
Yeah, I'm glad to be here.
So, Billy, you and I have met.
(00:46):
I've actually been in one ofyour trainings, the one that you
held in Georgia a couple ofyears ago.
So thank you so much forjoining us today when we're
going to be talking about someof the lessons learned from
farmers, as you've been goingaround the country and talking
to farmers about the Food SafetyModernization Act and the FISMA
(01:11):
regulations.
So can you share with us alittle bit about your background
and some of the things that youthink that maybe our audience
would like to learn about?
Speaker 3 (01:23):
Yeah, I'd love to so again.
My name is Billy Mitchell.
I'm the Food SafetyModernization Act, also known as
FSMA, training coordinator atthe National Farmers Union and I
work with a project called theLocal Food Safety Collaborative.
It's a FDA-supportedcooperative agreement and we
provide outreach and educationto and with farmers all over the
(01:44):
country.
So I've just had an incredible,really just about four years at
this job, like that workshop wegot to do together JC at White
Oak Pastures, where we're doingPowerPoints, we're talking about
the laws, we're talking aboutthe rules, but then we're also
on farm in conversation withfarmers, finding out not only
the challenges that they'refacing but also the creative
(02:05):
solutions that they're coming upwith to have cost-effective,
practical produce safetyimplementation on their farm.
And before I had this job doingoutreach and education, I had an
opportunity to farm insideAtlanta and right outside
Atlanta for about seven years,including building just like
this beautiful four and a halfacre urban farm in downtown
(02:26):
Atlanta it used to be right nextto the King Center and just
kind of travel the state ofGeorgia, meeting urban,
peri-urban and rural farmers.
And that has led me to thischance to go to like Florida,
colorado, arizona, vermont andjust see farmers all over the
country and it's just, it's justbeen great.
(02:47):
And then I've also had a chanceto work with people that you
know, like Michelle Daniluk andKeith Schneider from the
University of Florida, who'vereally helped me gain just a
better understanding of thescience behind produce safety,
and then working with peoplelike Jennifer McIntyre at United
Fresh to better understand therules and regulations of gap
audits and like the alphabetsoup that comes with all this
work of like gaps, fisma, psr.
(03:10):
So it's been a good journey andI just learned so much and I
think my biggest takeaway hasreally been that produce safety,
the practices themselves whenthey're implemented well, they
just improve your whole farm.
It often feels like producesafety is a siloed thing or
maybe even the scary thing, butwhen it's done well, it just
(03:32):
helps you run a better smallagricultural business.
It helps create this culture onyour farm where things are just
more positive, they're moreengaging and just have this
better awareness of how the farmis operating.
Speaker 2 (03:45):
And you're absolutely right, I think, by farmers
realizing which I think they do,at least in our experience that
you know the safety of theirproduce is something that they
take seriously and that most ofthem, if not all of them, are
going to always try to do theirbest to provide food to their
(04:10):
customers, or whoever it is thatthey're providing this food to,
that it is safe, that it ishealthy, and then consumers and
all of us can feel sort of, youknow, not only grateful for all
the great work that farmers do,but that we feel like that we
shouldn't really worry about youknow what we're eating or the
state that you know some of thatfood is.
However, I think in ourexperience, some farmers have
(04:34):
told us that they grew up in afarm, they've been farming for
many, many years.
Their parents or theirgrandparents farm, so they know
about farming and they know howto grow food.
But now, with you know, withFEESMA, they're sort of
wondering what's different.
You know they've beenpracticing food safety practices
(04:55):
all their lives, but whatexactly is it different now with
the FEESMA regulations?
And maybe perhaps what are someof the things that they need to
be paying attention to?
Speaker 3 (05:09):
Oh gosh, yeah, that's such a good question because,
especially folks who've grown upfarming, they've always been
following produce safetypractices.
But their parents, theirgrandparents, their family
members were rarely, if ever,asked to prove that they were
following food safety practicesor to get an audit or an
inspection.
And a big part of the reasonthat's changed is we've just had
these big national outbreakswhere just the general public
(05:33):
has been more aware that, whilewe have a very safe food system,
there are risks in the foodsystem.
And you know the Jack in theBox outbreak, which is an
outbreak related to hamburgers.
You know everybody thought howcould a hamburger get you sick?
I mean listeria outbreaksconnected to ice cream.
And for the one that reallyaffected the fresh produce
(05:54):
industry was a spinach outbreakthat happened and that really
motivated consumers to startasking our government you know
what's going on what can we doto reduce risk in this food
system?
And that's kind of what led tothe Food Safety Modernization
Act happening.
Congress passed this act andFDA implements it, and so just
(06:18):
our understanding of risks haschanged, the science has changed
and just the industry haschanged and that can be really
hard for any business,especially a small business,
just to keep up with all thesechanges while you're still just
trying to do the day-to-dayfarming, like, how are you
supposed to pay attention to allthe changes that happen?
(06:39):
And that's why it's soimportant that groups like
University of Florida Extension,florida Organic Growers get out
there and help do outreach andeducation so that growers know
about this, and I think for mostgrowers it's you know.
What FSMA is requiring of them,especially at a smaller scale,
is not that much.
It's an awareness that you'repracticing food safety on your
(07:03):
farm and making sure that youget a refresher, that you learn
those best practices.
Maybe you learn a little bitmore about cleaning and
sanitizing, or you learn moreabout making compost.
Like, is there a way to turnand make your compost that
really reduces the pathogens inthe pile and also helps reduce
things like soil borne diseases?
(07:24):
It also helps reduce thingslike soil borne diseases and
it's growers knowing that.
If somebody asks you what you doon your farm, you know the
language of food safety.
You know to say well, I followgood agricultural practices.
And it also means keeping somepaperwork to show what your
sales are.
So the Food SafetyModernization Act, produce
Safety Rule it really issupposed to be science backed
(07:47):
and scale appropriate, and sofor a lot of growers it's
showing just where you fallunder that rule.
So everybody has to followthose food safety practices.
And by that I mean no one cansell contaminated food into the
food system, you know to, in areally basic way, like nobody
can sell food that has poop onit and, to be quite honest,
nobody wants to do that righteither and so everybody has to
(08:10):
follow those practices.
And then, just depending on thesize of your business, you
might have to keep a couple morerecords to kind of prove that.
But at the end of the day it'sjust awareness of food safety,
knowing the language and reallytaking a class or two to find
out, like, how has the sciencechanged?
How has our understanding ofproduce safety and risk changed
(08:31):
over the past few years?
And what can I do?
Because I care about mycommunity, I care about the
people I'm selling food to, andat the end of the day, farmers
are just always curious and theyalways want to improve.
So you take this food safetyclass just to find out, well,
what's new and what can Iimprove on my farm.
Speaker 2 (08:49):
Find out well what's new and what can I improve on my
farm.
Right, and you mentioned so manyreally important things.
One of the things you mentionedyou know small farmers and these
small farmers, or everyone ingeneral, being sort of familiar
with the language indicating youknow it's sort of an acronyms
(09:11):
and alphabet soup of things thatwe talk about when we're
talking about food safety andthe awareness and keeping
records, so all of those things.
Let me ask you a question.
So in your experience and Iused to run a farmer's market
here in Gainesville and did thatfor several years so most of
the people that come to thefarmer's market are small
farmers and you know they'reselling directly to the
(09:33):
consumers and consumers trustthem and you know they know them
and they're there every week,and so a lot of farmers or
vendors that come to thefarmer's market would ask is
this voluntary?
Is this something that I haveto do?
The farmer's market would askis this voluntary?
Is this something that I haveto do?
I think you have, in part,answer that question, but can
(09:54):
you maybe talk a little bitabout some of the things that
those that are selling directlyto consumers and maybe selling a
farmer's market need to beaware of, as you stated.
Speaker 3 (10:04):
Yeah, sure, and maybe we'll start with that alphabet
soup of acronyms.
Sure, and maybe we'll startwith that alphabet soup of
acronyms.
I think that that is wherethere's a little bit of
confusion.
So there's gaps, goodagricultural practices, and
that's something that farmersshould be following.
That's what helps us create asafe and vibrant food system.
And then a lot of growers willask me do I need a gap audit?
(10:27):
And that's when somebody comesout to your farm and they kind
of review your paperwork, theywatch your practices and they
ask you a bunch of questions.
And that's a really like abuyer driven thing.
And I would say 99.99% of smallfarmers do not need to get gap
audited.
They don't need to pay someoneto come out to their farm and
(10:49):
see what's going on andespecially, there's rarely a
farmer's market, a restaurant, aCSA, a small co-op who's
requiring that audit, even likea farm to school program.
But there's certainly a benefitto growers.
Almost all those audits areactually free online.
So if you Google the USDA gapaudit or the USDA harmonized gap
(11:13):
audit, you can see what thoseaudits look like and you can
even do a self audit where youprint it out and you walk around
your farm and you just askyourself those questions and it
kind of helps.
You know that you're probablyalready meeting a lot of the
industry standards and a fewthings that growers can really
do, even if you're not gettingan audit.
But some of the best goodagricultural practices to follow
are checking in with youremployees and having a
(11:36):
conversation about the fact thatwe come to work in clean
clothes.
We wash our hands so we don'tcontaminate things.
You know, if you're sick, don'tcome into work.
You talk about cleaning andsanitizing, and like a really
small thing with cleaning andsanitizing is that it's a
four-step process.
You always got to clean first,kind of like you always brush
(11:57):
your teeth before you usemouthwash.
But most sanitizers are a sprayand walk away sanitizer and a
lot of small growers spray theirsanitizers and then just wipe
it off, and so it ends up nothaving the time to do what it
needs to do to help improve yourfood safety, and so sometimes
there's just little things likethat, like training your
employees to spray and walk awaywith that sanitizer and a real
(12:22):
easy one that's a big one thatyou can do to get ahead of huge
problems is just an annual watertest.
It's checking in with somebodygetting your water tested just
to make sure that there's nobacteria issues within your
drinking water.
But I mean, jc, you're right forthose growers that you used to
get to work with at the farmer'smarket, they don't need to be
(12:44):
audited, but it certainlybenefits them to like follow
those practices and they can dotiny things like make a five
page food safety plan, becausesometimes a school might be
really interested in just doingone purchase from a small farmer
and that school will bedelighted to know that that
farmer can provide them with afood safety plan.
(13:04):
So if the parents ask, they cansay oh yeah, we buy from small
farmers who follow goodagricultural practices.
They don't get audited becausethey're small.
We can visit their farm and seewhat they're doing.
But they did provide us alittle bit of paperwork just as
assurance.
Speaker 2 (13:20):
What about, in your experience, certified organic
growers who are already keepinga lot of records as it pertains
to their certification?
Would a lot of these certifiedorganic farmers require a food
safety certification on top ofthe organic certification they
(13:44):
already have?
Speaker 3 (13:46):
That's such a good question and it's kind of like
it's complicated and it depends.
So these food safety auditsalmost always come down to your
buyer.
They're almost always buyerdriven.
You know it's not mandatory,you could walk away from that
buyer, but it kind of feelsmandatory.
The nice thing is that if you'realready certified organic,
(14:08):
probably one of the harderthings about food safety audits
is just building the recordkeeping habits Because often the
practices are already in place.
If you're certified organic,you've already built those
habits around record keeping andthere will be quite a few
records that can cross over,like your soil amendment records
, any cleaning and sanitizingrecords that you keep.
(14:30):
But it's really going to be aconversation between you and
your buyer and if you're asmaller local farm working with
a smaller local regional buyer,you can ask them if they just
want to come out to your farm,spend the day with you, see your
farm like, find out why theyreally want and need that audit.
(14:50):
But at the end of the day it'sthere.
There's no hard or fast answerthere.
Unfortunately, just beingcertified organic won't get you
out of a food safety auditbecause there are some things in
a food safety audit that justaren't captured in that NLP
audit?
Speaker 2 (15:07):
Yeah yeah, and thank you for explaining that so well,
because that is a question, asI was saying, that we get often
from some of the certifiedorganic farmers that we interact
with.
So being certified is great toall those certified organic
farmers listening.
But and again Billy was justsaying, find out more why your
(15:31):
buyer, instead of requiring youto have that food safety
certification you know what aresome of the reasons behind that,
and perhaps a lot of the stuffthat you're already doing shows
that you're complying with someof those regulations but will
not get you out of it.
They really do want thatcertification, out of having
that food safety certification.
Speaker 3 (15:52):
One other thing I guess I should just say is that
if a buyer asks you for a gapaudit, you want to go ahead and
ask them which one.
So there's no universal gapaudit.
So they could be talking abouta USDA gap audit, a harmonized
gap audit, a primus gap audit.
So before you, as a grower, gothrough all the work to pay for
(16:14):
and pass an audit, make surethat you're paying for and
passing the one that your buyerwants.
So you really just want to makesure you're on the same page.
Speaker 2 (16:23):
Yeah, that's such a good tip and thank you so much
for sharing that with us.
Tip, and thank you so much forsharing that with us.
It seems that many of theoutbreaks that we've heard about
and you sort of alluded to themin the beginning come from,
perhaps, large-scale farms andperhaps these are not as common
in small farms, or maybe I'mmistaken about that.
(16:43):
But do small-scale farmers needto show that they're compliant
with these food safetyregulations, and what are some,
maybe some of the tips that youwould like to share with us,
when people might think thatfarmers, small farmers, can also
just be just as risky aslarge-scale farms?
Speaker 3 (17:03):
Right, oh gosh, that's such a good.
It's such a complicatedquestion.
So I think the one thing wejust have to recognize is that,
just like pathogens don't care,they don't care if you're a
small farm, they don't care ifyou love your community and you
love your produce.
Pathogens are just there.
They're there on small farms,they're there on big farms, and
(17:28):
also outbreaks can be hard totrace.
Part of the reason that we hearabout them mostly from big
farms is those are big, headline, attention grabbing things and
they affect a ton of people.
But there's a lot of foodborneillnesses in our country that
just don't get tracked.
You know, there's a lot of usmaybe even folks listening to
(17:48):
this who we've probably gotten afoodborne illness before, like.
I've gotten one I think it wasfrom a grocery store.
I've gotten one that I thinkwas from a restaurant, but I
just kind of had a bad day athome and I didn't go to the
hospital, I didn't report it.
So a lot of that stuff getsunderreported and there have
been a couple outbreaks thathave been linked back to farmers
(18:12):
markets.
But maybe something that's alittle more impactful is that
there have just been some reallyfoodborne illness outbreaks
related to, just like churchesor family dinners.
Like these things do happen ona really small scale, they just
don't make it into the reallybig new systems.
(18:34):
And really, at the end of theday, I think we all don't want
to be that small farm or thatfarmer's market that breaks the
mold.
We don't want to be the onethat becomes the big thing.
And there there is this greatpodcast called farmer to farmer
and Chris Blanchard who hostedit and passed away a few years
ago.
He was just a big believer infood safety and one of the
(18:56):
reasons he was is because he, inhis opinion and I share this
our local food system is both soresilient but also so fragile.
He would, you know, worriedthat an outbreak might get
traced back to a farmer's marketand the farmers wouldn't be
prepared to say we follow goodagricultural practices, they
(19:17):
wouldn't be prepared to takesteps to help mitigate that risk
.
Instead they would just say,well, no, no, you know, food
safety is just a big farm thingand we didn't have to follow
those practices.
And then it would just be in thenews Local farmers market gets
people sick or local farm getspeople sick, and the messaging
would just be all over the placeyeah, even if they haven't,
(19:37):
even if it feels like a big farmproblem, you know, we do just
know that small all farmers careabout their community.
But as small farmers like atthat farmers market you got to
manage in Gainesville we areseeing those folks face to face.
We are building such strongpersonal relationships with them
, and what I've seen at farmer'smarkets is that folks who start
(19:59):
to get sick, people who areimmunocompromised and you can't
look at somebody and tell thatthey're immunocompromised they
really start going to farmersmarkets too.
So people who are already at ahigher risk are coming to
smaller farmers because theytrust our quality and they want
to lead healthy lives, and sothat's just another motivator
that, even if we're not seeingthe outbreaks linked to us, we
(20:21):
know, like you said, that ourcustomers trust us, and so it's
a real at least for me, a realstrong motivator to do the right
thing and follow thesepractices.
Speaker 2 (20:30):
I couldn't agree more .
So what about if a farmer doeschoose, whether it's because
their buyer is requiring it andthey're now considering to seek
food safety certification?
Can you tell us in yourexperience, how long does it
take to one prepare the farm foran actual food safety audit?
(20:51):
How long would it take for themto obtain that valid
certificate, and perhaps even ifyou know, what is the average
cost of these types of audits?
So things like again threethings how to prepare your fund
for the audit, how long will ittake for them to obtain their
(21:13):
certification, and perhaps thecost of these audits.
Speaker 3 (21:17):
Yeah.
So that really the firstquestion how to prepare.
I think one of the best ways toprepare it is to find out what
audit either you want to getbecause you're just motivated to
do it.
You know, I think there's a lotof certified organic farms who
do this where they don't reallyhave buyers requiring it, but
they're just motivated to getthat certification and prove to
(21:39):
their customers, and so youmight just be motivated to get a
food safety audit.
And so the first thing you wantto do is go online and find
that audit.
I mean, that's one of the nicethings is that there should be
no surprises audit day, so youmight go to the USDA GAP website
and download the audit and do aself audit.
(21:59):
So just go through it line byline, question by question, you
know, and circle the ones thatdon't make any sense, so that
they can call you JC, or theycan call me, or they can call
Michelle Daniluk and say I'mtrying to figure this out, but I
just don't understand thisquestion.
And you can also circle thethings that you need to do and
most of the time it's reallysome like new paperwork systems
(22:21):
that you're going to create andthen maybe potentially a couple
of new practices as well andwith those audits you can score
yourself so you can see what youshould be getting on audit day,
and I think that will reallyhelp you as a grower, know where
you're at.
But then how long is it goingto take me as a grower to
(22:43):
prepare for this?
So if you go through that selfaudit and you're keeping zero
paperwork on your farm right now, you're probably going to want
like three to six months toreally build those paperwork
systems, because it's just veryhard to start doing 30 brand new
records the next day.
You know you might want toidentify like three new records
a week over the course of acouple of months to really build
(23:06):
up all those skills, becausewhile you're doing the paperwork
, all the other farming stuffrain events, customers canceling
, employees, calling in sick allthat stuff is going to happen.
So best way to prepare isdownload the audit and and audit
yourself or get like one ofyour employees to audit you and
that way your employees start tounderstand the motivations
(23:29):
because you're going to have tomake some changes to your farm
and so that way everybody's onthe same page.
Why are we making these changes?
Why is it important and thatwill help you figure out how
long, because there are somepeople who can call an auditor
and a month later knock thataudit out, but probably most
people who've never been auditedbefore.
You want to give yourself aminimum three months, but maybe
(23:52):
even six months just to feel itout.
And that last question how muchdoes it cost?
It kind of depends on the auditthat you're going to get and
even things like how far awaydoes your auditor live, because
some auditors, some auditschemes, you'll be charged for
(24:12):
their travel as well.
I would say we like generallysee it between $600 and $1,200,
which is kind of a wide range,but it can certainly be even
more expensive than that, and sothe best thing to do is, once
you find out what audit you'regoing to get, you'll also be
able to figure out who doesthose audits in your area and
(24:34):
just give them a ring Start tobuild that relationship.
Let them know you're interestedand let them know that you want
to be able to prepare for itand start saving, and they can
give you a general cost estimate.
Speaker 2 (24:46):
Wow, you've shared so much with us today.
We again can't thank you enough.
One of the things that I thinkwe can take with us is that food
safety certification in mostcases is buyer-driven.
If the buyer, if thatrestaurant, if that place that
(25:11):
you have farmers, the potentialto sell your product, whether it
be a school, again, arestaurant, sort of a bigger
organization is requiring it.
You know that's something thatyou can consider.
I think you mentioned that youknow over 90% of the small
farmers out there probably don'tneed a gap audit necessarily,
(25:36):
but you know there's things that, when they're considering this,
that they can do to find outwhether or not a gap audit is
something that they can use.
They can visit the and is thisthe FDA website or USDA website
where they can find out a lot ofthis information.
Speaker 3 (25:55):
Yeah, that's a really good point.
So there's the USDA gap audits.
So if you just Google USDA gapit'll pop up.
And then there's also the FDA'sFood Safety Modernization Act
and they have differentrequirements.
One thing if you're just reallywondering, well, what's the FDA
(26:15):
asking, there's this greatgroup called the Produce Safety
Alliance the acronym is PSA andon the Produce Safety Alliance's
website they have this requiredrecords document.
So what records does the FDArequire if you're going to get
an inspection?
And I think most growers arekind of pleasantly surprised.
You know you hear the FDA andyou probably are thinking it's
(26:39):
going to be like 50, 100 records.
You're thinking it's going tobe a lot of paperwork.
But if you look at thatrequired records document you'll
see that they're really justnot that many records and
they're really practical ones.
You know, writing down whatyour employee training was, if
you're making compost piles,tracking the temperature, which
I imagine a lot of the organicgrowers are already doing.
(27:00):
But so for those audits, usdaGAP website is one good place to
go, the United Fresh HarmonizedGAP resources and for FDA FISMA
inspections, a nice place tostart is with the Produce Safety
Alliance.
They've really taken the leadon education around the country
and there's probably a lot ofgrowers who have taken that
course.
If you sat in on an eight-hourPowerPoint course with lots of
(27:24):
food safety information, thatwas the Produce Safety Alliance
grower training.
Speaker 2 (27:28):
Right, well, thank you again, billy.
We really appreciate your timeand sharing with us so much
really useful information To allof our listeners.
We hope that you cancontinually join us to get more
information about food safety.
To understand food safety, youcan check out our website for
(27:49):
new upcoming episodes on thistopic as well as upcoming
webinars.
Please sign up to receive ourupdates through our mailing list
and you feel free to alsosubmit your questions on our
website.
Again, billy, thank you so muchfor joining us today.
We really appreciate you beingwith us today.
Speaker 3 (28:07):
Yeah, thank you, this was really fun.
I appreciate it.
Speaker 1 (28:15):
Thank you for tuning in.
Visit our Food Safety forFarmers podcast page on our
website, wwwfoginfoorg, to findmore information about episodes
and webinars.
Subscribe to our email list forupdates and submit any
questions you may have aboutfood safety.
Welcome to Florida Organic Growers podcast series
Food Safety for Farmers.
A project funded by the USDANational Institute of Food and
Agriculture Food Safety OutreachProgram, our podcast provides
information on food safetytopics that farmers can use to
better understand how to complywith the Food Safety
Modernization Act regulations.
Thanks for tuning in.
Speaker 2 (00:25):
Welcome everyone.
We're very happy that you canjoin us today.
We're very lucky to have BillyMitchell, who is a training
coordinator for the Food SafetyModernization Act at the
National Farmers Union.
Welcome, Billy, Thanks.
Yeah, I'm glad to be here.
So, Billy, you and I have met.
(00:46):
I've actually been in one ofyour trainings, the one that you
held in Georgia a couple ofyears ago.
So thank you so much forjoining us today when we're
going to be talking about someof the lessons learned from
farmers, as you've been goingaround the country and talking
to farmers about the Food SafetyModernization Act and the FISMA
(01:11):
regulations.
So can you share with us alittle bit about your background
and some of the things that youthink that maybe our audience
would like to learn about?
Speaker 3 (01:23):
Yeah, I'd love to so again.
My name is Billy Mitchell.
I'm the Food SafetyModernization Act, also known as
FSMA, training coordinator atthe National Farmers Union and I
work with a project called theLocal Food Safety Collaborative.
It's a FDA-supportedcooperative agreement and we
provide outreach and educationto and with farmers all over the
(01:44):
country.
So I've just had an incredible,really just about four years at
this job, like that workshop wegot to do together JC at White
Oak Pastures, where we're doingPowerPoints, we're talking about
the laws, we're talking aboutthe rules, but then we're also
on farm in conversation withfarmers, finding out not only
the challenges that they'refacing but also the creative
(02:05):
solutions that they're coming upwith to have cost-effective,
practical produce safetyimplementation on their farm.
And before I had this job doingoutreach and education, I had an
opportunity to farm insideAtlanta and right outside
Atlanta for about seven years,including building just like
this beautiful four and a halfacre urban farm in downtown
(02:26):
Atlanta it used to be right nextto the King Center and just
kind of travel the state ofGeorgia, meeting urban,
peri-urban and rural farmers.
And that has led me to thischance to go to like Florida,
colorado, arizona, vermont andjust see farmers all over the
country and it's just, it's justbeen great.
(02:47):
And then I've also had a chanceto work with people that you
know, like Michelle Daniluk andKeith Schneider from the
University of Florida, who'vereally helped me gain just a
better understanding of thescience behind produce safety,
and then working with peoplelike Jennifer McIntyre at United
Fresh to better understand therules and regulations of gap
audits and like the alphabetsoup that comes with all this
work of like gaps, fisma, psr.
(03:10):
So it's been a good journey andI just learned so much and I
think my biggest takeaway hasreally been that produce safety,
the practices themselves whenthey're implemented well, they
just improve your whole farm.
It often feels like producesafety is a siloed thing or
maybe even the scary thing, butwhen it's done well, it just
(03:32):
helps you run a better smallagricultural business.
It helps create this culture onyour farm where things are just
more positive, they're moreengaging and just have this
better awareness of how the farmis operating.
Speaker 2 (03:45):
And you're absolutely right, I think, by farmers
realizing which I think they do,at least in our experience that
you know the safety of theirproduce is something that they
take seriously and that most ofthem, if not all of them, are
going to always try to do theirbest to provide food to their
(04:10):
customers, or whoever it is thatthey're providing this food to,
that it is safe, that it ishealthy, and then consumers and
all of us can feel sort of, youknow, not only grateful for all
the great work that farmers do,but that we feel like that we
shouldn't really worry about youknow what we're eating or the
state that you know some of thatfood is.
However, I think in ourexperience, some farmers have
(04:34):
told us that they grew up in afarm, they've been farming for
many, many years.
Their parents or theirgrandparents farm, so they know
about farming and they know howto grow food.
But now, with you know, withFEESMA, they're sort of
wondering what's different.
You know they've beenpracticing food safety practices
(04:55):
all their lives, but whatexactly is it different now with
the FEESMA regulations?
And maybe perhaps what are someof the things that they need to
be paying attention to?
Speaker 3 (05:09):
Oh gosh, yeah, that's such a good question because,
especially folks who've grown upfarming, they've always been
following produce safetypractices.
But their parents, theirgrandparents, their family
members were rarely, if ever,asked to prove that they were
following food safety practicesor to get an audit or an
inspection.
And a big part of the reasonthat's changed is we've just had
these big national outbreakswhere just the general public
(05:33):
has been more aware that, whilewe have a very safe food system,
there are risks in the foodsystem.
And you know the Jack in theBox outbreak, which is an
outbreak related to hamburgers.
You know everybody thought howcould a hamburger get you sick?
I mean listeria outbreaksconnected to ice cream.
And for the one that reallyaffected the fresh produce
(05:54):
industry was a spinach outbreakthat happened and that really
motivated consumers to startasking our government you know
what's going on what can we doto reduce risk in this food
system?
And that's kind of what led tothe Food Safety Modernization
Act happening.
Congress passed this act andFDA implements it, and so just
(06:18):
our understanding of risks haschanged, the science has changed
and just the industry haschanged and that can be really
hard for any business,especially a small business,
just to keep up with all thesechanges while you're still just
trying to do the day-to-dayfarming, like, how are you
supposed to pay attention to allthe changes that happen?
(06:39):
And that's why it's soimportant that groups like
University of Florida Extension,florida Organic Growers get out
there and help do outreach andeducation so that growers know
about this, and I think for mostgrowers it's you know.
What FSMA is requiring of them,especially at a smaller scale,
is not that much.
It's an awareness that you'repracticing food safety on your
(07:03):
farm and making sure that youget a refresher, that you learn
those best practices.
Maybe you learn a little bitmore about cleaning and
sanitizing, or you learn moreabout making compost.
Like, is there a way to turnand make your compost that
really reduces the pathogens inthe pile and also helps reduce
things like soil borne diseases?
(07:24):
It also helps reduce thingslike soil borne diseases and
it's growers knowing that.
If somebody asks you what you doon your farm, you know the
language of food safety.
You know to say well, I followgood agricultural practices.
And it also means keeping somepaperwork to show what your
sales are.
So the Food SafetyModernization Act, produce
Safety Rule it really issupposed to be science backed
(07:47):
and scale appropriate, and sofor a lot of growers it's
showing just where you fallunder that rule.
So everybody has to followthose food safety practices.
And by that I mean no one cansell contaminated food into the
food system, you know to, in areally basic way, like nobody
can sell food that has poop onit and, to be quite honest,
nobody wants to do that righteither and so everybody has to
(08:10):
follow those practices.
And then, just depending on thesize of your business, you
might have to keep a couple morerecords to kind of prove that.
But at the end of the day it'sjust awareness of food safety,
knowing the language and reallytaking a class or two to find
out, like, how has the sciencechanged?
How has our understanding ofproduce safety and risk changed
(08:31):
over the past few years?
And what can I do?
Because I care about mycommunity, I care about the
people I'm selling food to, andat the end of the day, farmers
are just always curious and theyalways want to improve.
So you take this food safetyclass just to find out, well,
what's new and what can Iimprove on my farm.
Speaker 2 (08:49):
Find out well what's new and what can I improve on my
farm.
Right, and you mentioned so manyreally important things.
One of the things you mentionedyou know small farmers and these
small farmers, or everyone ingeneral, being sort of familiar
with the language indicating youknow it's sort of an acronyms
(09:11):
and alphabet soup of things thatwe talk about when we're
talking about food safety andthe awareness and keeping
records, so all of those things.
Let me ask you a question.
So in your experience and Iused to run a farmer's market
here in Gainesville and did thatfor several years so most of
the people that come to thefarmer's market are small
farmers and you know they'reselling directly to the
(09:33):
consumers and consumers trustthem and you know they know them
and they're there every week,and so a lot of farmers or
vendors that come to thefarmer's market would ask is
this voluntary?
Is this something that I haveto do?
The farmer's market would askis this voluntary?
Is this something that I haveto do?
I think you have, in part,answer that question, but can
(09:54):
you maybe talk a little bitabout some of the things that
those that are selling directlyto consumers and maybe selling a
farmer's market need to beaware of, as you stated.
Speaker 3 (10:04):
Yeah, sure, and maybe we'll start with that alphabet
soup of acronyms.
Sure, and maybe we'll startwith that alphabet soup of
acronyms.
I think that that is wherethere's a little bit of
confusion.
So there's gaps, goodagricultural practices, and
that's something that farmersshould be following.
That's what helps us create asafe and vibrant food system.
And then a lot of growers willask me do I need a gap audit?
(10:27):
And that's when somebody comesout to your farm and they kind
of review your paperwork, theywatch your practices and they
ask you a bunch of questions.
And that's a really like abuyer driven thing.
And I would say 99.99% of smallfarmers do not need to get gap
audited.
They don't need to pay someoneto come out to their farm and
(10:49):
see what's going on andespecially, there's rarely a
farmer's market, a restaurant, aCSA, a small co-op who's
requiring that audit, even likea farm to school program.
But there's certainly a benefitto growers.
Almost all those audits areactually free online.
So if you Google the USDA gapaudit or the USDA harmonized gap
(11:13):
audit, you can see what thoseaudits look like and you can
even do a self audit where youprint it out and you walk around
your farm and you just askyourself those questions and it
kind of helps.
You know that you're probablyalready meeting a lot of the
industry standards and a fewthings that growers can really
do, even if you're not gettingan audit.
But some of the best goodagricultural practices to follow
are checking in with youremployees and having a
(11:36):
conversation about the fact thatwe come to work in clean
clothes.
We wash our hands so we don'tcontaminate things.
You know, if you're sick, don'tcome into work.
You talk about cleaning andsanitizing, and like a really
small thing with cleaning andsanitizing is that it's a
four-step process.
You always got to clean first,kind of like you always brush
(11:57):
your teeth before you usemouthwash.
But most sanitizers are a sprayand walk away sanitizer and a
lot of small growers spray theirsanitizers and then just wipe
it off, and so it ends up nothaving the time to do what it
needs to do to help improve yourfood safety, and so sometimes
there's just little things likethat, like training your
employees to spray and walk awaywith that sanitizer and a real
(12:22):
easy one that's a big one thatyou can do to get ahead of huge
problems is just an annual watertest.
It's checking in with somebodygetting your water tested just
to make sure that there's nobacteria issues within your
drinking water.
But I mean, jc, you're right forthose growers that you used to
get to work with at the farmer'smarket, they don't need to be
(12:44):
audited, but it certainlybenefits them to like follow
those practices and they can dotiny things like make a five
page food safety plan, becausesometimes a school might be
really interested in just doingone purchase from a small farmer
and that school will bedelighted to know that that
farmer can provide them with afood safety plan.
(13:04):
So if the parents ask, they cansay oh yeah, we buy from small
farmers who follow goodagricultural practices.
They don't get audited becausethey're small.
We can visit their farm and seewhat they're doing.
But they did provide us alittle bit of paperwork just as
assurance.
Speaker 2 (13:20):
What about, in your experience, certified organic
growers who are already keepinga lot of records as it pertains
to their certification?
Would a lot of these certifiedorganic farmers require a food
safety certification on top ofthe organic certification they
(13:44):
already have?
Speaker 3 (13:46):
That's such a good question and it's kind of like
it's complicated and it depends.
So these food safety auditsalmost always come down to your
buyer.
They're almost always buyerdriven.
You know it's not mandatory,you could walk away from that
buyer, but it kind of feelsmandatory.
The nice thing is that if you'realready certified organic,
(14:08):
probably one of the harderthings about food safety audits
is just building the recordkeeping habits Because often the
practices are already in place.
If you're certified organic,you've already built those
habits around record keeping andthere will be quite a few
records that can cross over,like your soil amendment records
, any cleaning and sanitizingrecords that you keep.
(14:30):
But it's really going to be aconversation between you and
your buyer and if you're asmaller local farm working with
a smaller local regional buyer,you can ask them if they just
want to come out to your farm,spend the day with you, see your
farm like, find out why theyreally want and need that audit.
(14:50):
But at the end of the day it'sthere.
There's no hard or fast answerthere.
Unfortunately, just beingcertified organic won't get you
out of a food safety auditbecause there are some things in
a food safety audit that justaren't captured in that NLP
audit?
Speaker 2 (15:07):
Yeah yeah, and thank you for explaining that so well,
because that is a question, asI was saying, that we get often
from some of the certifiedorganic farmers that we interact
with.
So being certified is great toall those certified organic
farmers listening.
But and again Billy was justsaying, find out more why your
(15:31):
buyer, instead of requiring youto have that food safety
certification you know what aresome of the reasons behind that,
and perhaps a lot of the stuffthat you're already doing shows
that you're complying with someof those regulations but will
not get you out of it.
They really do want thatcertification, out of having
that food safety certification.
Speaker 3 (15:52):
One other thing I guess I should just say is that
if a buyer asks you for a gapaudit, you want to go ahead and
ask them which one.
So there's no universal gapaudit.
So they could be talking abouta USDA gap audit, a harmonized
gap audit, a primus gap audit.
So before you, as a grower, gothrough all the work to pay for
(16:14):
and pass an audit, make surethat you're paying for and
passing the one that your buyerwants.
So you really just want to makesure you're on the same page.
Speaker 2 (16:23):
Yeah, that's such a good tip and thank you so much
for sharing that with us.
Tip, and thank you so much forsharing that with us.
It seems that many of theoutbreaks that we've heard about
and you sort of alluded to themin the beginning come from,
perhaps, large-scale farms andperhaps these are not as common
in small farms, or maybe I'mmistaken about that.
(16:43):
But do small-scale farmers needto show that they're compliant
with these food safetyregulations, and what are some,
maybe some of the tips that youwould like to share with us,
when people might think thatfarmers, small farmers, can also
just be just as risky aslarge-scale farms?
Speaker 3 (17:03):
Right, oh gosh, that's such a good.
It's such a complicatedquestion.
So I think the one thing wejust have to recognize is that,
just like pathogens don't care,they don't care if you're a
small farm, they don't care ifyou love your community and you
love your produce.
Pathogens are just there.
They're there on small farms,they're there on big farms, and
(17:28):
also outbreaks can be hard totrace.
Part of the reason that we hearabout them mostly from big
farms is those are big, headline, attention grabbing things and
they affect a ton of people.
But there's a lot of foodborneillnesses in our country that
just don't get tracked.
You know, there's a lot of usmaybe even folks listening to
(17:48):
this who we've probably gotten afoodborne illness before, like.
I've gotten one I think it wasfrom a grocery store.
I've gotten one that I thinkwas from a restaurant, but I
just kind of had a bad day athome and I didn't go to the
hospital, I didn't report it.
So a lot of that stuff getsunderreported and there have
been a couple outbreaks thathave been linked back to farmers
(18:12):
markets.
But maybe something that's alittle more impactful is that
there have just been some reallyfoodborne illness outbreaks
related to, just like churchesor family dinners.
Like these things do happen ona really small scale, they just
don't make it into the reallybig new systems.
(18:34):
And really, at the end of theday, I think we all don't want
to be that small farm or thatfarmer's market that breaks the
mold.
We don't want to be the onethat becomes the big thing.
And there there is this greatpodcast called farmer to farmer
and Chris Blanchard who hostedit and passed away a few years
ago.
He was just a big believer infood safety and one of the
(18:56):
reasons he was is because he, inhis opinion and I share this
our local food system is both soresilient but also so fragile.
He would, you know, worriedthat an outbreak might get
traced back to a farmer's marketand the farmers wouldn't be
prepared to say we follow goodagricultural practices, they
(19:17):
wouldn't be prepared to takesteps to help mitigate that risk
.
Instead they would just say,well, no, no, you know, food
safety is just a big farm thingand we didn't have to follow
those practices.
And then it would just be in thenews Local farmers market gets
people sick or local farm getspeople sick, and the messaging
would just be all over the placeyeah, even if they haven't,
(19:37):
even if it feels like a big farmproblem, you know, we do just
know that small all farmers careabout their community.
But as small farmers like atthat farmers market you got to
manage in Gainesville we areseeing those folks face to face.
We are building such strongpersonal relationships with them
, and what I've seen at farmer'smarkets is that folks who start
(19:59):
to get sick, people who areimmunocompromised and you can't
look at somebody and tell thatthey're immunocompromised they
really start going to farmersmarkets too.
So people who are already at ahigher risk are coming to
smaller farmers because theytrust our quality and they want
to lead healthy lives, and sothat's just another motivator
that, even if we're not seeingthe outbreaks linked to us, we
(20:21):
know, like you said, that ourcustomers trust us, and so it's
a real at least for me, a realstrong motivator to do the right
thing and follow thesepractices.
Speaker 2 (20:30):
I couldn't agree more .
So what about if a farmer doeschoose, whether it's because
their buyer is requiring it andthey're now considering to seek
food safety certification?
Can you tell us in yourexperience, how long does it
take to one prepare the farm foran actual food safety audit?
(20:51):
How long would it take for themto obtain that valid
certificate, and perhaps even ifyou know, what is the average
cost of these types of audits?
So things like again threethings how to prepare your fund
for the audit, how long will ittake for them to obtain their
(21:13):
certification, and perhaps thecost of these audits.
Speaker 3 (21:17):
Yeah.
So that really the firstquestion how to prepare.
I think one of the best ways toprepare it is to find out what
audit either you want to getbecause you're just motivated to
do it.
You know, I think there's a lotof certified organic farms who
do this where they don't reallyhave buyers requiring it, but
they're just motivated to getthat certification and prove to
(21:39):
their customers, and so youmight just be motivated to get a
food safety audit.
And so the first thing you wantto do is go online and find
that audit.
I mean, that's one of the nicethings is that there should be
no surprises audit day, so youmight go to the USDA GAP website
and download the audit and do aself audit.
(21:59):
So just go through it line byline, question by question, you
know, and circle the ones thatdon't make any sense, so that
they can call you JC, or theycan call me, or they can call
Michelle Daniluk and say I'mtrying to figure this out, but I
just don't understand thisquestion.
And you can also circle thethings that you need to do and
most of the time it's reallysome like new paperwork systems
(22:21):
that you're going to create andthen maybe potentially a couple
of new practices as well andwith those audits you can score
yourself so you can see what youshould be getting on audit day,
and I think that will reallyhelp you as a grower, know where
you're at.
But then how long is it goingto take me as a grower to
(22:43):
prepare for this?
So if you go through that selfaudit and you're keeping zero
paperwork on your farm right now, you're probably going to want
like three to six months toreally build those paperwork
systems, because it's just veryhard to start doing 30 brand new
records the next day.
You know you might want toidentify like three new records
a week over the course of acouple of months to really build
(23:06):
up all those skills, becausewhile you're doing the paperwork
, all the other farming stuffrain events, customers canceling
, employees, calling in sick allthat stuff is going to happen.
So best way to prepare isdownload the audit and and audit
yourself or get like one ofyour employees to audit you and
that way your employees start tounderstand the motivations
(23:29):
because you're going to have tomake some changes to your farm
and so that way everybody's onthe same page.
Why are we making these changes?
Why is it important and thatwill help you figure out how
long, because there are somepeople who can call an auditor
and a month later knock thataudit out, but probably most
people who've never been auditedbefore.
You want to give yourself aminimum three months, but maybe
(23:52):
even six months just to feel itout.
And that last question how muchdoes it cost?
It kind of depends on the auditthat you're going to get and
even things like how far awaydoes your auditor live, because
some auditors, some auditschemes, you'll be charged for
(24:12):
their travel as well.
I would say we like generallysee it between $600 and $1,200,
which is kind of a wide range,but it can certainly be even
more expensive than that, and sothe best thing to do is, once
you find out what audit you'regoing to get, you'll also be
able to figure out who doesthose audits in your area and
(24:34):
just give them a ring Start tobuild that relationship.
Let them know you're interestedand let them know that you want
to be able to prepare for itand start saving, and they can
give you a general cost estimate.
Speaker 2 (24:46):
Wow, you've shared so much with us today.
We again can't thank you enough.
One of the things that I thinkwe can take with us is that food
safety certification in mostcases is buyer-driven.
If the buyer, if thatrestaurant, if that place that
(25:11):
you have farmers, the potentialto sell your product, whether it
be a school, again, arestaurant, sort of a bigger
organization is requiring it.
You know that's something thatyou can consider.
I think you mentioned that youknow over 90% of the small
farmers out there probably don'tneed a gap audit necessarily,
(25:36):
but you know there's things that, when they're considering this,
that they can do to find outwhether or not a gap audit is
something that they can use.
They can visit the and is thisthe FDA website or USDA website
where they can find out a lot ofthis information.
Speaker 3 (25:55):
Yeah, that's a really good point.
So there's the USDA gap audits.
So if you just Google USDA gapit'll pop up.
And then there's also the FDA'sFood Safety Modernization Act
and they have differentrequirements.
One thing if you're just reallywondering, well, what's the FDA
(26:15):
asking, there's this greatgroup called the Produce Safety
Alliance the acronym is PSA andon the Produce Safety Alliance's
website they have this requiredrecords document.
So what records does the FDArequire if you're going to get
an inspection?
And I think most growers arekind of pleasantly surprised.
You know you hear the FDA andyou probably are thinking it's
(26:39):
going to be like 50, 100 records.
You're thinking it's going tobe a lot of paperwork.
But if you look at thatrequired records document you'll
see that they're really justnot that many records and
they're really practical ones.
You know, writing down whatyour employee training was, if
you're making compost piles,tracking the temperature, which
I imagine a lot of the organicgrowers are already doing.
(27:00):
But so for those audits, usdaGAP website is one good place to
go, the United Fresh HarmonizedGAP resources and for FDA FISMA
inspections, a nice place tostart is with the Produce Safety
Alliance.
They've really taken the leadon education around the country
and there's probably a lot ofgrowers who have taken that
course.
If you sat in on an eight-hourPowerPoint course with lots of
(27:24):
food safety information, thatwas the Produce Safety Alliance
grower training.
Speaker 2 (27:28):
Right, well, thank you again, billy.
We really appreciate your timeand sharing with us so much
really useful information To allof our listeners.
We hope that you cancontinually join us to get more
information about food safety.
To understand food safety, youcan check out our website for
(27:49):
new upcoming episodes on thistopic as well as upcoming
webinars.
Please sign up to receive ourupdates through our mailing list
and you feel free to alsosubmit your questions on our
website.
Again, billy, thank you so muchfor joining us today.
We really appreciate you beingwith us today.
Speaker 3 (28:07):
Yeah, thank you, this was really fun.
I appreciate it.
Speaker 1 (28:15):
Thank you for tuning in.
Visit our Food Safety forFarmers podcast page on our
website, wwwfoginfoorg, to findmore information about episodes
and webinars.
Subscribe to our email list forupdates and submit any
questions you may have aboutfood safety.
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