The Food Safety Modernization Act (FSMA) and Produce Safety Rule (PSR) Grant Manager at the Arizona Department of Agriculture, Joseph T. Oddo, was hired by the Department after a 30-career with Eagle Produce LLC. Dba Martori Farms. During his tenure at Martori Farms, Oddo was responsible for Food Safety and Human Resources and developing and maintaining the Food Safety Program utilizing third-party auditors under the Primus GFS scheme. With over 60 audits performed (9 annually) achieving scores over 90% during that time, Oddo was also recruited to train workers thru the H2-A guest worker program.

His current responsibilities include the training, education, and outreach regarding the Produce Safety Rule. As stakeholders become compliant trained and educated his responsibility will include inspection.

Mr. Oddo’s insights highlight the high points of Senate Bill 1063: Produce Safety Rule; State Administration. Just signed into law by Arizona’s Governor Ducey, the bill allows the Arizona Department of Agriculture to assume primary enforcement of the Produce Safety Rule. 

Produce Safety Rule requirements can be applied to the “backyard grower” as well as large producers. Key requirements include the testing of the water used in operations, whether soil amendments are applied, animal intrusion, worker training, cleaning, and sanitation. These requirements can be applied to all farm sizes and types.

Arizona Agriculture: What impact will SB 1063, the Produce Safety Rule, have on the fresh fruit and vegetable industry here in Arizona and California?

Oddo: Currently many of the large growers in Arizona and California have food safety plans in place and are audited through either 3 rd party audits or the Leafy Greens Marketing Agreement (LGMA). Compliance with the Produce Safety Rule is now federal law which establishes minimum food safety standards nationwide. This imposes and equitably places all required growers, harvesters, packers, and holders on the same minimal standard for food safety. Consumers will be able to have confidence that whether they buy from a small or large producer that the minimal standards for food safety are being met. Those stakeholders who currently do not have food safety plans in place will need to invest the time and expense to adapt their companies to the new standards. The Arizona Department of Agriculture (AZDA) can and will provide the education and training necessary to ensure all companies who request these services can come into compliance with the new Produce Safety Rule.

Arizona Agriculture: Does the Produce Safety Rule take a proactive approach to food safety? Are you pleased with FDA’s effort in trying to reduce foodborne illness?

Oddo: The Produce Safety Rule takes the approach to “educate before you regulate.” This is evidenced by the initial steps of determining a farm inventory and offering the voluntary On Farm Readiness Review. Arizona will be one of the first states to offer the training required to deliver this non-regulatory review of a farms readiness for inspection, which has been delayed until mid-2019. Additionally, AZDA has delivered the Produce Safety Alliance “Grower Training Class,” a stakeholder requirement, to over 150 people and Produce Safety Rule training to over 200. These programs are all proactive approaches to complying with the Produce Safety Rule.

The FDA had a massive undertaking in trying to come up with a food safety standard that would be applicable to all “Farms” nationwide. Additionally, the task of educating and inspecting all the stakeholders in each state was more than the FDA could take on. As a result, grants were offered to the states to fund the delivery of the Training, Outreach, Education and final inspection of the Produce Safety Rule. While at times slow, the FDA’s efforts to curb foodborne illness thru local control was a major step in reducing the risk of foodborne illness outbreaks.

Arizona Agriculture: Arizona is now working to authorize the AZDA, rather than the FDA, to take on primary responsibility for Produce Safety Rule inspections. How does this help the cause?

Oddo: Localized control of the training, education, and inspections will allow for an increase in the supervision of all components of the Produce Safety Rule. It will allow for the development of working relationships between AZDA and all stakeholders improving the quality and development of food safety plans to ensure compliance with the Produce Safety Rule. Non-compliance issues can be resolved quickly thus averting and minimizing the risks associated with foodborne illness outbreaks. Consumers will have improved access to the understanding and confidence that locally grown produce is meeting the standards of the Produce Safety Rule.

Arizona Agriculture: Beyond legislation and self- imposed food safety standards, how else can we help consumers understand our food safety standards?

Oddo: Consumers by in large expect that when produce is purchased at a retail outlet or farmers market it is safe to eat. There is a lack of understanding of the food safety steps taken by the grower, packer, harvester, or holder of that produce to maintain food safety standards. The fact is that through the whole supply chain when it comes to produce there is not a 100% certainty that foodborne pathogens have been eliminated. The key is to educate the public through as many sources possible that handling practices in the home can be the best defense against foodborne illness. The retail outlets and farmers markets can help in the distribution of information to the public about cleaning and storing produce in the home prior to consumption. The combination of the Produce Safety Rule standards being maintained through the supply chain and safe handling and storage within the home will greatly reduce the risks of foodborne illness.

Arizona Agriculture: As the leafy greens market grows, can our food safety standards scale?  In other words, can these food safety standards adapt to large and small farming operations?

Oddo: One of the challenges the FDA had was to develop the Produce Safety Rule so that it could be applied to farming operations regardless of size or geographic location. The key requirements of the Produce Safety Rule can be applied to the “backyard grower” as well as the major nationwide producers. Additionally, the Produce Safety Rule requires compliance from the holder (coolers) of produce where the size can vary yet the key requirements remain the same. These key requirements include the testing of the water used in operations, whether soil amendments are applied, animal intrusion, worker training and cleaning and sanitation. These requirements can be applied across all stakeholder operations. The focus is to train and educate stakeholders on how to apply these requirements in their individual operations.

Arizona Agriculture: Talk to us about the industry’s training efforts and how workers adapt to the training.

Oddo: Currently AZDA and the Arizona Leafy Greens Marketing Agreement provide training in GHP/GMP (Good Handling Practices/Good Manufacturing Practices) and Food Safety Training according to the compliance measures described in the LGMA. AZDA has hired two trainers whose specific responsibility is to provide ongoing training to stakeholders requiring compliance under the Produce Safety Rule. To date, AZDA has developed a questionnaire and mailed to over 500 farms and has had direct contact with over 200 farms. We’ve delivered direct Produce Safety Rule training to over 200 people in Yuma in both English and Spanish. And, we’ve developed a power-point presentation, brochure, and webinar to be delivered to County Health Directors and the Food Marketing Association.

Inspections will not begin until 2019 so all efforts are being directed to the outreach, training, and education on the Produce Safety Rule. The response from both industry and the public has been positive with the consensus that public safety is the priority.

Arizona Agriculture: I know industry uses farm tours to enlighten influencers and others about your food safety practices, but what else are you doing to teach consumers about the industry’s dedication to food safety?

Oddo: Currently AZDA has focused its efforts on ensuring that those responsible for compliance under the Produce Safety Rule receive the proper training leading to compliance. Articles have been published in the Local First Arizona newsletter and Arizona Farm Bureau’s publications, and AZDA has changed its website to include information available to the public on the Food Safety Modernization Act and Produce Safety Rule. Through the introduction of SB1063, local representatives will understand the Produce Safety Rule having the ability to inform constituents. AZDA intends to provide brochures to retail outlets and farmers markets for public distribution.    

Simply having this conversation with you and our farmers and ranchers will help continue to inform on an issue that is important to all of us.

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