Food Safety Magazine - June/July 2013

PRODUCE
ticularly to reduce the paperwork burden at small operations.
However, the Operations Committee recognized that misinterpretation
and disputes in interpretation of these requirements
would still happen and recommended formation of a
committee that would be responsible for ongoing review of
disputes and interpretation of the intent of the standards.
Therefore, a Calibration Committee was formed, comprising
representatives of various audit organizations that intended
to use the Harmonized Standards and representatives of
various commodity growers and buyers (Figure 3). By bringing
as many audit organizations as possible to the table and adding
subject matter experts in different growing and handling
practices, the goal is to further harmonize auditors’ interpretations
of what is expected at an audited operation: what practices
are “compliant” with the intent of the Harmonized Standards;
what practices are not; and how auditors are to react
when they see practices they believe may represent a public
health risk. The committee’s responsibilities are to 1) develop
the official training materials for auditors on how to interpret
the intent of the standards and 2) participate to resolve realtime
disputes in interpretation of the standards. Importantly,
it is not the committee’s responsibility to train auditors how
to audit; that task remains the responsibility of the individual
audit organizations.
Coordinated by United Fresh, the volunteer members of
the Calibration Committee have had their work cut out for
them: They’ve evaluated dozens of dispute questions and developed
consensus responses to each; they developed training
slides for each requirement in the Field Operations and Harvesting
standards, including hundreds of possible scenarios of
what an auditor might see, often drawn from the dispute questions,
and how the auditor should react to and judge what he
or she sees; and they offered two Train-the-Trainer workshops
in 2012 for auditors and auditees alike—one at Costco headquarters
in Issaquah, WA, the second at the USDA National
Agricultural Library in Beltsville, MD. Thanks to the generous
support of several of the Calibration Committee member
organizations, both workshops were offered at no fee to attendees,
and both were filled with over 70 attendees each. The
participating audit organizations, including USDA, Equicert
and some who are GlobalG.A.P. and SQF certification bodies,
subsequently began training their auditors, greatly increasing
the capacity for operations to have an audit performed to the
Harmonized Standards.
Harmonized Standards and the FSMA Rules. At this writing,
FDA had just published its proposed rules for Produce Safety
and Preventive Controls for Human Food. The scope of the
Produce Safety proposed rule is the same as the 1998 FDA
GAPs Guide and the Harmonized Standards: the growing,
harvesting and on-farm handling of fresh produce. While
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64 F o o d S a f e t y M a g a z i n e