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.

The decision tool for determining which FSMA rules to follow is provided in Fawell’s presentation, “Which FSMA Rules Apply to Me?” which can be found online at www.Almonds.com/FoodSafetySymposium, where you will also find all of the presentations at this year’s symposium.