If you’re a walnut or pistachio grower or huller, the Produce Safety Rule (PSR), part of the Food Safety Modernization Act (FSMA), is likely on your radar. With inspections becoming more common, understanding what to expect during a PSR inspection and how to prepare effectively can help minimize disruptions and ensure a smooth inspection process.

What are Produce Safety Rule Inspections?

PSR establishes science-based minimum standards for the safe growing, harvesting, packing, and holding of fruits and vegetables intended for human consumption. PSR inspections are conducted to assess whether farms are implementing the required practices and standards to reduce the risk of contamination from pathogens such as E. coli, Salmonella, and Listeria, which can cause serious foodborne illnesses. These inspections are usually carried out by state departments of agriculture or other designated agencies in cooperation with the U.S. Food and Drug Administration (FDA).

What to Expect During an Inspection

Notification and Scheduling

In most cases, farms will receive advance notice of an upcoming inspection. However, unannounced inspections can also occur, particularly if there have been previous compliance issues or a foodborne illness outbreak linked to the farm.

Arrival and Introduction

Upon arrival, the inspector will introduce themselves as a California Department of Food and Agriculture (CDFA) Produce Safety inspector and present their FDA credentials. They will provide an overview of the inspection process and outline what they will be looking for during their visit.

Initial Walkthrough

The inspection typically begins with a walkthrough of the farm. The inspector will observe the general conditions of the fields, equipment, and facilities, paying close attention to areas that could impact produce safety, such as water sources, equipment sanitation, and worker hygiene practices.

Review of Practices and Records

Inspectors will review your farm’s practices and documentation related to key areas of PSR, including:

Worker Training and Health

Inspectors will verify that all employees handling produce have received proper training on health and hygiene practices and are protocols for handling illnesses and injuries:

• Are your food safety rules posted or communicated to visitors?

• How are sick employees handled? (Reassign position or sent home?)

Agricultural Water

The quality and management of water used for the farm’s processes will be closely examined, in particular for E.coli. Inspectors will check water testing records, where applicable, to ensure compliance with the required standards. Although for walnut folks, items apply such as:

• Is there a water-changing schedule in place for float tank water?

• Ensure water used for hulling is potable.

• Ensure water wells have backflow prevention.

However, agricultural water management must also meet both harvest and postharvest requirements. Preharvest water is any water used in the production phase, such as irrigation, pesticide application or frost control, whereas postharvest water refers to any water that comes in contact during and after the crops are harvested and any water used on food contact surfaces. This includes during washings, cooling, cleaning food contact equipment, cleaning bins and/or packaging, handwashing water and processing.

One key requirement for postharvest water is there be no detectable generic E. coli in the water that directly contacts the product in postharvest stages. To help mitigate those risks, ensure:

• Annual water assessments are conducted once annually for preharvest agricultural water.

Soil Amendments

If your farm uses manure or compost, the inspector will review your treatment and application methods to ensure they meet safety guidelines.

Wildlife and Domesticated Animals

Inspectors will assess measures taken to prevent contamination from animals, animal intrusion and managing animal access to growing areas. However, the FDA does not require removing wildlife habitats, fencing around crops, or creating bare ground buffers between crops and habitats.

This is especially important for tree nut farms. Practicing and implementing preharvest assessments for your farm is beneficial:

• Walk or drive the ranch and area surrounding water sources look for anything abnormal such as broken fences, significant amounts of animal fecal matter, animal carcasses, security breaches, signs of trespassing, etc. that may be a food safety or security risk.

Equipment, Tools and Buildings

The inspector will evaluate the cleanliness and maintenance of equipment, tools, and buildings to ensure they do not pose a risk of contamination. You want to prepare to discuss how you clean and sanitize your equipment, especially harvest equipment. Ensure that:

• You have all documentation of cleaning and sanitizing activities such as procedures and schedules for cleaning harvest equipment, bathrooms and/or toilet facilities (including portable toilets) and tools.

• Hand-washing facilities are available and adequately stocked.

Discussion and Feedback

After completing the inspection, the inspector will discuss their findings, provide feedback on areas where your farm is meeting the requirements and highlight any areas of concern that need to be addressed.

Documentation of Findings

The inspector will document their findings in a report, which you will receive. If any non-compliance issues are identified, you may be given a timeframe to make the necessary corrections.

How to Prepare for a Produce Safety Rule Inspection

Stay informed

Food safety guidelines can change, so staying informed is key. The FDA and state agriculture departments offer several resources to help you stay informed. Western Agricultural Processors Association (WAPA) assists its tree nut industry members in compliance with the Produce Safety Rule.

Develop and maintain records

Keep detailed records of all practices, including water testing, worker training, soil amendment use, etc. WAPA has helped members develop food safety plans, including logs to help maintain detailed records.

Conduct self-audits

Having regular reviews of your farm’s practices can help identify potential issues before an official inspection and allow you to make corrections proactively. WAPA, in conjunction with CDFA, coordinated multiple free Regional On-Farm Readiness Reviews for farms to learn about what to expect during an inspection.  These reviews included mock inspections, covered topics on food safety practices and harvest and postharvest requirements, along with a great opportunity to ask specific questions to CDFA.

Train your team and self

Under PSR, it is required that there is an individual who has completed an FDA-approved Produce Safety Rule Grower Training or equivalent. Provide regular training sessions and reminders about health and hygiene practices, safe equipment use and other critical areas. WAPA helps provide training on safe equipment use in the agricultural community.

Maintain Cleanliness and Organization

Keep your farm, equipment and facilities clean as appropriate and organized. Clean and sanitize, as necessary, tools, equipment and surfaces that come into contact with produce to minimize contamination risks.

Prepare for Questions

Be prepared to answer questions from the inspector about your farm’s practices and how you comply with PSR. WAPA can assist members and be onsite during the inspection.

Create an Inspection Plan

Develop a plan for handling an inspection. Designate a competent individual to accompany the inspector, provide requested documents and answer questions.

Remember, an inspection is an opportunity to improve and demonstrate your commitment to food safety. With the right preparation, you can ensure that your farm is always ready for an inspection.