The need to conduct a hazard analysis (HACCP) is part of the current Good Manufacturing practices (GMPs) that you (unless you fit into an exemption) should have to follow. These requirements are both related to, but also in addition to, anything that you might have to do specific to the Food Safety Modernization act (FSMA). You can reference Federal regulations 21 CFR 117 for more information about the GMPs.
As for FSMA, the first thing to figure out is what rules you may fall under:
1.) Are you a farm and don't otherwise process the food? If so, unless you fit into one of the exemptions they have, you would fall under FSMA's Produce Safety rule.
2.) If you somehow process the food, then (again unless you fit within one of the exemptions), you would fall under the FSMA's Preventive Controls rule.
It comes down to what you do with the fruit. To be considered a farm, you cannot process the fruit further. The FDA defines that through what they call a "raw agricultural commodity". Basically, this is their way of saying what you can do to the fruit before they consider it food processing. Look at Federal Food, Drug, and Cosmetic act (Sec 201 r) for that definition or this link: https://www.ecfr.gov...5#se21.1.1_1227 for more information about that.
It is very confusing. If you can be more specific about what you do with the food (grower, fresh pack, bake/cook, etc), people could probably help here more. Another option would be to talk with a local University AG extension agent about what you do and they can help you understand what you must adhere to and what training you may need. They are paid to help you, so use them. I've always found them to be responsive.
I would make sure that before you do anything, you understand what you have to do, so you aren't worrying about something you don't have to.
I hope that this helps somehow.
Anyway, good luck,
Todd
Edited by tsebring, 22 May 2019 - 03:57 PM.
