• FDA published a draft guidance to help farmers and educators develop or select alternate curricula to meet the training requirements of the Produce Safety Rule mandated by the Food Safety Modernization Act (FSMA). As our readers may know, the Produce Safety Rule establishes science-based minimum standards for the safe growing, harvesting, packing, and holding of produce grown for human consumption.
  • Part of the Produce Safety Rule requires that at least one supervisor or responsible party from a covered farm successfully complete food safety training at least equivalent to that received under standardized curriculum recognized as adequate by the FDA. The draft guidance recognizes version 1.1 of the standardized curriculum developed by the Produce Safety Alliance (PSA) as adequate for the standardized curriculum in 21 CFR 112.22(c) – Subpart C, Personnel Qualifications and Training of the Produce Safety Rule.
  • Covered farms, however, are not required to use the standardized curriculum and may use alternate curricula. The draft guidance provides recommendations on the factors that should be considered when developing or selecting an alternate curriculum training.
  • Stakeholders may submit comments on the draft guidance until October 2, 2019. Keller and Heckman attorneys are well-versed in FSMA and the Produce Safety Rule requirements and are available to assist interested parties in preparing comments for submission to FDA. For assistance, please email: fooddrug@khlaw.com