USDA Farmers to Families Food Box Purchases Program Food Safety Requirements

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vcc

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Apr 24, 2020, 5:06:01 PM4/24/20
to Food Systems Leadership Network COVID-19 Response Group

Can anyone clarify this language in the Emergency- Master Solicitation for Commodity Procurement included with the USDA Farmers to Families Food Box Purchases Program RFP released today? Does this mean all suppliers must meet these requirements or only those "sourced from storage"?


"(f) In order to facilitate the expedited purchases of commodities and address the challenges with conducting audits of fruits and vegetable that are sourced from storage; AMS will allow greater flexibility to verify food safety requirements. Suppliers must meet one of the following:
(1) USDA Good Agricultural Practices/Good Handling Practices audit conducted by a USDA-AMS auditor.
(2) Global Food Safety Initiative (GFSI) benchmarked certification program audits (GlobalGAP, SQF, Primus GFS, CanadaGAP)."


Thank you!

-- 
Oak Hawk
Value Chain Coordinator
SE Indiana Farm Connect
v...@foodandgrowers.com

Nikki Seibert

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Apr 26, 2020, 3:39:29 PM4/26/20
to vcc, Food Systems Leadership Network COVID-19 Response Group
This is the same question we have. I've reviewed the documents and cannot determine if by "Supplier" they could be talking about the food hub AND/OR the farmers. 

Hopefully we can interpret ourselves (food hubs/distributors) at the suppliers  I know this would make a HUGE difference for most folks. 

Nikki 

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Oak Hawk

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Apr 26, 2020, 3:46:32 PM4/26/20
to Nikki Seibert, Food Systems Leadership Network COVID-19 Response Group

Thanks, Nikki! Unfortunately, the NSAC blog referenced in a previous post suggests that GAPs will be a notable exception to the policy of specifications being mutually agreeable between the contractor and the non-profits they are working with. I don't know if this is a conversation to have with USDA and how much flexibility there is going forward, so any input there would be greatly appreciated. We've been encouraging producers to work towards GAPs to increase market access, but as I'm sure many of you all experience this can often be a long-term conversation. We have quite a ways to go in SE Indiana.

Fingers crossed I guess!

Oak

Debra Tropp

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Apr 26, 2020, 4:01:51 PM4/26/20
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My educated guess, and it is only a guess, is that the food hub/aggregator would suffice as the "supplier", since the RFP referrers to "offerors" (suppliers) and "contractors" (distribution agents at final point of distribution). But I suppose we may be able to get more clarification tomorrow during the Wallace webinar.
Examples of "flexibilities" officially disclosed by USDA thus far related to food distribution seem to include labeling flexibilities related to COOL (posted below) and procurement flexibilities (related to Federal acquisition policies)
Hope this is helpful:
Debbie

USDA Announces Labeling Flexibilities to Facilitate Distribution of Food to Retail Locations

April 13, 2020

The U.S. Department of Agriculture (USDA) Agricultural Marketing Service (AMS) is committed to providing flexibilities to support the nation’s food supply and will continue to take steps to meet challenges due to the COVID-19 national emergency.

USDA is exercising enforcement discretion for a temporary period to provide labeling flexibilities to the Country of Origin Labeling (COOL) requirements and allow the re-distribution of food products intended for foodservice to be sold in retail establishments.

COOL is a labeling law that requires retailers to notify their customers with information regarding where certain foods originated. Covered commodities include muscle cut and ground meats: lamb, goat, and chicken; wild and farm-raised fish and shellfish; fresh and frozen fruits and vegetables; peanuts, pecans, and macadamia nuts; and ginseng. Ordinarily, commodities subject to COOL requirements are not required to include a country of origin or method of production label when distributed to foodservice, but the labels are required when these foods are sold at retail establishments.

To facilitate the distribution of food to retail establishments from suppliers that have inventory on hand that is labeled for use in restaurants, effective April 20, 2020, and for a period of 60 days, AMS will not take enforcement action against the retail sale of commodities that lack an appropriate country of origin or method of production label, provided that the food does not make any country of origin or method of production claims. Once the 60-day period has ended, COOL designations will once again be required at covered retail establishments.

By allowing this labeling flexibility, food can be diverted from restaurants to retail, ensuring that this food is made available to families around the country and helping restaurants and their suppliers access additional markets, such as grocery stores, that are currently experiencing greater demand. These actions are in line with similar labeling flexibilities allowed by the Food and Drug Administration and USDA Food Safety and Inspection Service.

For further information contact Trevor Findley, Deputy Director, Food Disclosure and Labeling Division, (202) 997-9720, or by email at trevor....@usda.gov. For more information on enforcement of COOL visit the AMS website: https://www.ams.usda.gov/rules-regulations/cool.

From the RFP: 

The Government intends to use FAR Part 18 flexibilities when appropriate for this solicitation.   AMS/CPP intends to contract with regionally located contractors that would supply a preapproved portfolio of fresh fruit, vegetable, dairy, and or meat products (see CLIN item schedule below).  The intent is to strategically contract with multiple entities with the goal of targeted coverage across the United States.  The contracted entities would conduct food distribution supply chain activities to get USDA procured food to Americans impacted by COVID 19.  
 


To view this discussion on the web visit https://groups.google.com/d/msgid/FSLNcovidresponse/CABemdzUPLsGrq9AQ_CSOhaKPVonMYjhGHFNwppTbLbkGHBzyaQ%40mail.gmail.com.


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Debra Tropp
Principal, Debra Tropp Consulting
5325 Strathmore Avenue
Kensington, MD 20895
Twitter: @dtropp

Cook, Leah

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Apr 27, 2020, 8:19:24 AM4/27/20
to Nikki Seibert, Debra Tropp, vcc, Food Systems Leadership Network COVID-19 Response Group
Hi folks,

It's worth mentioning that a food hub could be GAP/GHP certified under Part 6: Wholesale Distribution Center/Terminal Warehouse scope.

The majority of the requirements of the audit are practices a food hub would already be required to meet in order to comply with the federal Current Good Manufacturing Practices (now in 21 CFR Part 117). This means the on-ramp to audit readiness may be shorter for a food hub than for a farm who may not have the same starting baseline for the documentation requirements.

The very first question in Part 6 is:

"All companies that supply fresh produce are required to have passed a third party audit verification of GAP and/or GHP."

The question is worth 15 points, but is not mandatory to pass the audit. The intention is certainly for distribution warehouses to be sourcing from GAP/GHP certified farms, but if your operation can afford not to get those 15 points, you could potentially pass the audit and get certified as the food hub 'supplier for this program. It would remain to ask the USDA if they'd be fine accepting the food hub's certification as a supplier vs the farm's.

Right now the USDA is continuing to prioritize first time auditees for the GAP/GHP program. Field work is continuing for all of us doing USDA produce work.

How your state is implementing things may vary, but here in Maine we are fulfilling all audit requests in a timely manner and we're seeing quick processing of audits from the USDA reviewers at the moment.

Hope this helps and adds to the conversation...

Thanks,
Leah Cook
Maine Department of Agriculture, Conservation & Forestry


From: fslncovi...@googlegroups.com <fslncovi...@googlegroups.com> on behalf of Debra Tropp <debra...@gmail.com>
Sent: Sunday, April 26, 2020 4:01:34 PM
To: Nikki Seibert <ni...@witmeetsgrit.com>
Cc: vcc <v...@foodandgrowers.com>; Food Systems Leadership Network COVID-19 Response Group <FSLNcovi...@googlegroups.com>
Subject: Re: [FSLNcovidresponse] USDA Farmers to Families Food Box Purchases Program Food Safety Requirements
 

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Atwell, Elizabeth

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Apr 28, 2020, 11:07:55 AM4/28/20
to Cook, Leah, Nikki Seibert, Debra Tropp, vcc, Food Systems Leadership Network COVID-19 Response Group

Good morning -

 

We reached out to USDA yesterday for clarity on this question and received the following guidance:

Farmers are suppliers in this arrangement, and they will need to have GAP or GFSI-benchmarked audits. It will be the responsibility of the contractor to make sure that the product is coming from farms under GAP or GFSI-benchmarked certification.

 

We believe that additional details on the food safety requirements of this program will be covered during the USDA webinar happening today at noon ET.  Details below:

 

Pre-Proposal USDA Farmers to Family Food Box --- April 28th at 12 ET-- The conference will be held via zoom @ https://www.zoomgov.com/j/1602561314

Or join by phone: Dial(for higher quality, dial a number based on your current location):

                              US: +1 669 254 5252  or +1 646 828 7666

                              Webinar ID: 160 256 1314

                              International numbers available: https://www.zoomgov.com/u/aeqHEnRZIO

 

Hope this information helps!

Elizabeth

 

 

From: fslncovi...@googlegroups.com <fslncovi...@googlegroups.com> On Behalf Of Cook, Leah
Sent: Monday, April 27, 2020 8:19 AM
To: Nikki Seibert <ni...@witmeetsgrit.com>; Debra Tropp <debra...@gmail.com>
Cc: vcc <v...@foodandgrowers.com>; Food Systems Leadership Network COVID-19 Response Group <fslncovi...@googlegroups.com>
Subject: Re: [FSLNcovidresponse] USDA Farmers to Families Food Box Purchases Program Food Safety Requirements

 

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Wes King

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Apr 28, 2020, 11:41:26 AM4/28/20
to Atwell, Elizabeth, Cook, Leah, Nikki Seibert, Debra Tropp, vcc, Food Systems Leadership Network COVID-19 Response Group
Hi all - One small detail to add that wasn't clear to me originally but has been clarified and confirmed that GroupGAP certification will be acceptable. 

To view this discussion on the web visit https://groups.google.com/d/msgid/FSLNcovidresponse/BN8PR01MB55088AFAE09BD4D803A9983D82AC0%40BN8PR01MB5508.prod.exchangelabs.com.


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National Sustainable Agriculture Coalition (NSAC)
110 Maryland Ave. NE, Ste. 209
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andyollove

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Apr 28, 2020, 6:28:32 PM4/28/20
to Food Systems Leadership Network COVID-19 Response Group
Hi all,

These food safety requirements are obviously a disqualifying factor in directing these potential contracts to small amazing farmers. In California for example there are only around 200 GAP certified or Group Gap farms. Would folks in this group be interested in putting out a rapid-fire petition advocating for the relaxing of food safety certificate requirements? Would people sign on?

Ayano Jeffers-Fabro

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Apr 28, 2020, 6:43:40 PM4/28/20
to andyollove, Food Systems Leadership Network COVID-19 Response Group
I would be down to sign

me ka lōkahi (in unity),

Ayano "Aya" K. Jeffers-Fabro
Project Manager, East Oakland Grocery Cooperative
Program Associate, Sunol AgPark Education Program

Ua mau ke ea o ka `āina i na `opio - The life of the land is perpetuated by the youth
If you want to go fast, go alone. If you want to go far, go together. - African Proverb


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This discussion group is maintained by the Wallace Center at Winrock International for educational and informational purposes only the Wallace Center is not responsible for the opinions and information posted on this site by others; postings represent the viewpoint of the writer and are not endorsed by the Wallace Center. Wallace Center disclaims all warranties with regard to information posted to this group, whether posted by the Wallace Center or any third party. In no event shall the Wallace Center be liable for any special, indirect, or consequential damages or any damages whatsoever resulting from loss of use, data, or profits, arising out of or in connection with the use or performance of any information posted to this group.
 
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Marion Murphy

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Apr 28, 2020, 6:48:43 PM4/28/20
to andyollove, Food Systems Leadership Network COVID-19 Response Group
Yes I believe this a very important step to unearth creative,  out of the box methodologies to insure no farmer is left stranded without support to grow ti a market as they have been so often.  Food Maps (subject on the call tomorrow) could help with documentation of which farmers are growing which food crop to match them with those most in need.  Thank you for the opportunity to participate in the discussion.  

From: fslncovi...@googlegroups.com <fslncovi...@googlegroups.com> on behalf of andyollove <andyo...@freshapproach.org>
Sent: Tuesday, April 28, 2020 4:28:32 PM
To: Food Systems Leadership Network COVID-19 Response Group <FSLNcovi...@googlegroups.com>
Subject: [FSLNcovidresponse] Re: USDA Farmers to Families Food Box Purchases Program Food Safety Requirements
 

Jared Mast

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Apr 28, 2020, 6:50:08 PM4/28/20
to Marion Murphy, Food Systems Leadership Network COVID-19 Response Group, andyollove
I sent to our local congresswoman.

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Jared Mast
Executive Director
Greater Easton Development Partnership
325 Northampton Street
Easton, PA 18042
610-250-2078 (office)

Elizabeth Bowman

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Apr 28, 2020, 7:18:40 PM4/28/20
to Jared Mast, Marion Murphy, Food Systems Leadership Network COVID-19 Response Group, andyollove
I would sign and circulate.  

Elizabeth Bowman
----------------------------------
Director, Farmers' Market Operations
Sustainable Economic Enterprises of Los Angeles (SEE-LA)


To view this discussion on the web visit https://groups.google.com/d/msgid/FSLNcovidresponse/CAN-m-qM4MKEcxaiC2c-ABEFuO69U%3DMGrAKFGbm5t0tTboGGKHA%40mail.gmail.com.

leslee pate

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Apr 28, 2020, 8:17:17 PM4/28/20
to Elizabeth Bowman, Jared Mast, Marion Murphy, Food Systems Leadership Network COVID-19 Response Group, andyollove
I would sign and share as well. 

Leslee Dixon Pate

__\\

On Apr 28, 2020, at 4:18 PM, Elizabeth Bowman <eliz...@see-la.org> wrote:



Ronnette Gonsalves

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Apr 28, 2020, 8:19:35 PM4/28/20
to Elizabeth Bowman, Jared Mast, Marion Murphy, Food Systems Leadership Network COVID-19 Response Group, andyollove
Aloha, 
Our group would also sign and circulate. Big Island Hawaii 

Ronnette Gonsalves 
BWOP 
Bodacious Women of Pahoa 
Food Pantry Hub Puna Hi.


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Mariya Strauss

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Apr 28, 2020, 8:36:01 PM4/28/20
to Ronnette Gonsalves, Elizabeth Bowman, Jared Mast, Marion Murphy, Food Systems Leadership Network COVID-19 Response Group, andyollove
Farm Alliance of Baltimore would sign and share as well. It is disappointing that small urban producers cannot participate.

To view this discussion on the web visit https://groups.google.com/d/msgid/FSLNcovidresponse/3E0CF682-30CA-4E67-A12A-ACC6979F8F8E%40gmail.com.


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Mariya Strauss
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Farm Alliance of Baltimore
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Farm Alliance of Baltimore is Charity 17360314 in the Baltimore City United Way campaign.

Jared Mast

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Apr 28, 2020, 8:38:05 PM4/28/20
to Mariya Strauss, Elizabeth Bowman, Food Systems Leadership Network COVID-19 Response Group, Marion Murphy, Ronnette Gonsalves, andyollove
would a first goal be to extend the response period while some of this gets worked out? 

Stefanie Vogley-Hauck

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Apr 28, 2020, 8:45:45 PM4/28/20
to Mariya Strauss, Ronnette Gonsalves, Elizabeth Bowman, Jared Mast, Marion Murphy, Food Systems Leadership Network COVID-19 Response Group, andyollove
Also found out that small veteran nonprofits (AMVETS, VFW, Legion posts) with a homebound veteran food distro program also do not qualify. One of Ohio's AMVETS posts has been delivering more than 100 meals a day. Over 1000 meals in 2 weeks. Trying to see if there are any resources out there to help supply the program. 

They also have no land in which to grow their own food. 

Stefanie Hauck
AMVETS Department of Ohio

To view this discussion on the web visit https://groups.google.com/d/msgid/FSLNcovidresponse/CAKniXTbyVCEJhtHrjjFLqYK%2BiGdiDU6AdpDGzgwH1Za1e%3D8EkQ%40mail.gmail.com.

Chester Williams

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Apr 28, 2020, 10:07:02 PM4/28/20
to Marion Murphy, andyollove, Food Systems Leadership Network COVID-19 Response Group
ABC2 and the GROW K Food council in North Carolina will sign 

In The Spirit Of Community

Chester B. Williams, CEO
A Better Chance A Better Community (ABC2)

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On Apr 28, 2020, at 6:48 PM, Marion Murphy <mmu...@growyourownmeal.org> wrote:



Dalila Boclin

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Apr 29, 2020, 12:46:26 PM4/29/20
to Chester Williams, Marion Murphy, andyollove, Food Systems Leadership Network COVID-19 Response Group
Hello, 

Did the USDA ever provide a response to or acknowledgement of this petition? Any further clarity on the issue?

To view this discussion on the web visit https://groups.google.com/d/msgid/FSLNcovidresponse/44109E47-A6BF-4E14-88E7-C47D44053EAD%40abc2nc.org.


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mobile: 862.452.8759 | dal...@freshfarm.org 

 

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Erika Rincon

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Apr 29, 2020, 12:49:22 PM4/29/20
to Dalila Boclin, Chester Williams, Marion Murphy, andyollove, Food Systems Leadership Network COVID-19 Response Group
Hello,

Is there a petition circulating? If so could someone link me to it? 

Thank you! 
Erika Rincon

To view this discussion on the web visit https://groups.google.com/d/msgid/FSLNcovidresponse/CAEft1z%3DvsvLMQQCkLksfDvmtV74gbh_Mzc4Q6NhQzhRmvaxFvg%40mail.gmail.com.


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National Young Farmers Coalition

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Andy Ollove

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Apr 29, 2020, 12:52:32 PM4/29/20
to Erika Rincon, Dalila Boclin, Chester Williams, Marion Murphy, Food Systems Leadership Network COVID-19 Response Group
Hi all,

I was the one who floated the idea yesterday but honestly haven't been able to get to it as I'm working on our application. I did however reach out to a food safety expert in California to get their read on it and this is the encouraging response I got:

I do not see anywhere specifically in the RFP that states specific food safety requirements for vendors (aka farms). On page 13 (vendor capability information checklist), under the first section, number 2 there's mention of facility registration number with FDA. This is required for food processing facilities that are not selling at least 50.1% of their food directly to consumers. 

On that same page in the middle section it says, "If applicable, audits are completed." I'm guessing that many of the farms you're referencing they want to source from would be fully or partially exempt from the federal Food Safety Modernization Act (fully exempt farms gross less than $28,075 annually in produce sales and partially exempt farms have to gross less than $561,494 annually in all food sales + sell at least 50.1% of their sales directly to consumers via farmers markets, CSAs, etc). Given that many (all?) of the farms that they want to source from in this RFP are fully or partially exempt from FSMA, you could make the argument that they should not have to have completed a GAP audit because the federal law doesn't even require them to have to get a FSMA Inspection. You could also add that farms that do not have GAP audits can provide some written attestation that they are producing their crops in accordance with California's direct market farmers good agricultural practices guidelines (all direct market farmers in CA are supposed to be implementing these practices that are listed in the "easy print for English" hyperlink at the top of that page). 

On the FAQs page for the RFP there's two on food safety and the 2nd one mentions being in compliance with state, federal, and local food safety laws, which a farm would be if they were exempt/partially exempt from FSMA and implementing general good agricultural practices (but haven't had a formal GAP Audit). So what I suggested above is aligned with how they answered that FAQ. 

If there is specific language in the RFP or elsewhere that I missed on food safety requirements or certifications please point out to me where that is and I'll see if I can "translate" it into what that actually means in reality.
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Andy Ollove | Food Access Program Manager
Fresh Approach: Making Healthy Food More Accessible in the Bay Area

Oak Hawk

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Apr 29, 2020, 12:55:57 PM4/29/20
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Hi Andy,

The language that prompted my original concern is on page 24 of the RFP Attachment 1 Emergency Acquisition MSCP, section (f):

"(f) In order to facilitate the expedited purchases of commodities and address the challenges with conducting audits of fruits and vegetable that are sourced from storage; AMS will allow greater flexibility to verify food safety requirements. Suppliers must meet one of the following:
(1) USDA Good Agricultural Practices/Good Handling Practices audit conducted by a USDA-AMS auditor.
(2) Global Food Safety Initiative (GFSI) benchmarked certification program audits (GlobalGAP, SQF, Primus GFS, CanadaGAP).

(i) USDA-AMS reserves the right to conduct onsite or remote validation audits of any vendor."

Andy Ollove

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Apr 29, 2020, 2:07:09 PM4/29/20
to Oak Hawk, Food Systems Leadership Network COVID-19 Response Group
Okay, updated very pessimistic read from the same person, which leaves us back where we started.

The USDA GAP/GHP Audit is the most basic audit out there, so it's possible some of the farms you're considering sourcing from could pass it (they'll probably have to get a bunch of paperwork done aka farm food safety plan and training records and likely change some of their practices). You can request a GAP/GHP Audit here. To my knowledge AMS and the California Department of Food and Agriculture in CA are only conducting GAP Audits for newly applying farms. If a farm already has a GAP Audit and is up for their annual renewal of their audit and in person audit those have been delayed currently and audit certificates (that are normally only valid for a 12 month timeframe) have been extended.

I imagine that it'll probably be a slow process for a farm to get newly audited -- there's probably a backlog of audits and everything is getting done slower. So that could be helpful for a farm to have enough time to get everything in place in time for an audit in a few weeks (vs. a few days). CAFF is available for some remote assistance via phone and email with helping explain to growers how to do this but honestly unless the farmer is already somewhat knowledgeable about food safety and motivated to figure this out I imagine it's going to be really challenging for a farmer (that's already juggling everything else right now) to get an audit completed very fast. I wonder if a farm has at least initiated the process and doesn't necessarily have their audit completed prior to selling product through this program if that could work?

I mean like I said it'll probably take some time to get their Audit scheduled so they could at least say they are in the process of getting a GAP Audit. I guess that would fall on Fresh Approach and the folks filling out the application on whether you all want to include farms that are doing that. Another thing to keep in mind is that a USDA GAP/GHP Audit will probably cost a farm $1,000-1,500 in direct costs, so I honestly wouldn't recommend that you have farms pursue getting a GAP Audit unless they'll be selling a significant amount of product to this program. Otherwise the extra time, cost, and headache is sadly just not worth it. If you know you have a handful of farms that you could buy significant amounts of produce through and those farms are big-scale production (for a small farm) than it could make sense for them to go through the hops to get this in place to be able to sell to the program. If it was just going to be a few one off purchases that likely it doesn't make sense. You can search for farms that already have a GAP Audit here, maybe there's some you didn't realize that had it that you could partner with?

To view this discussion on the web visit https://groups.google.com/d/msgid/FSLNcovidresponse/fc99a569-f929-5c58-d9e0-60e5325043ae%40foodandgrowers.com.
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