I am not a vegetable farmer. I run a CFIA-licensed (Canadian Food Inspection Agency) mushroom production facility in Brantford, Ontario, under Nature Lion Inc. Mushroom cultivation IS farming — the FDA classifies fresh mushrooms as produce, the substrate is my soil, the growing room is my field — but PSR (the Produce Safety Rule) is not the rule my facility lives under. SFCR (Safe Food for Canadians Regulations) is. I spent a year reading PSR, SFCR Part 6, and the USDA GAP audit checklists because growers kept asking me to translate. Here is what I learned, and what you do this week.
01The four buckets
Are you even covered? The four answers to the PSR question.
PSR stands for Produce Safety Rule, and it lives at 21 CFR Part 112 — the first-ever federal food-safety standard written specifically for farms. It was finalized in November 2015 and has been phased in by farm size ever since. Most of what is online about it was written by lawyers, not farmers, so before anything else: there are exactly four answers to "does PSR apply to my farm?" Three of those four still require you to keep paper. Two of them can be revoked by FDA (the Food and Drug Administration) after an outbreak link. Almost every grower who tells me "I am too small for this" has not actually done the math.
232K
U.S. farms growing produce (USDA NASS 2017 Census of Agriculture). The Produce Safety Rule covers roughly 40,000 of them — the ones above the $25K exemption floor and not growing only "rarely consumed raw" crops.
April 6, 2026
Pre-harvest agricultural water deadline for small businesses ($250,001–$500,000 in average annual produce sales). The compliance date that is hitting most readers right now.
$25K
The full-exemption floor. Average annual produce sales (3-year rolling) under $25,000, inflation-adjusted, and PSR does not apply at all. Above it and the math gets more interesting.
The four buckets, in order:
- 01
Excluded — the rule does not apply, and never did
Three sub-cases. First, produce for personal or on-farm consumption (your kitchen garden, your CSA member's surplus tomatoes). Second, your crop is on FDA's rarely consumed raw list — potatoes, asparagus, beans, beets, sweet and field corn, cranberries, dates, eggplants, figs, ginger, horseradish, lentils, peanuts, pecans, peas, pumpkins, rutabaga, winter squash, sweet potatoes, turnips, water chestnuts, and a handful more. If your entire crop list is on it, you are excluded by crop. Third, your produce is sold to a commercial processor with a documented kill step (canning, distilling, refining into oil or wine or beer) and you provide written disclosure to that buyer. Cultivated mushrooms are NOT on the rarely-consumed-raw list, by the way — they are eaten raw on salads and pizza, so the rule treats them as RAC (raw agricultural commodities) like leafy greens.
- 02
Exempt — under the $25K threshold
Average annual produce sales (not total farm sales) under $25,000 over the most recent 3 calendar years, inflation-adjusted. The arithmetic is on produce sales only, so a livestock farm that sells $5K of sweet corn on the side is exempt on the produce side. You do not need a PSR-compliant plan and you do not get inspected for PSR. You DO need to keep the sales records that prove you are under the threshold, because the inspector who knocks on your door is the one who decides whether your "I am exempt" claim holds. Keep the books.
- 03
Qualified-exempt — modified requirements only
Two tests, both required. First, your average annual FOOD sales (broader category, includes everything you sell — produce, meat, value-added) over the previous 3-year period is under $500,000, inflation-adjusted. Second, more than half of your food sales go to qualified end users: the actual eater (a CSA member, a farmers-market customer), or a restaurant or retail food establishment in the same state, on the same Indian reservation, or within 275 miles of your farm. If you sell mostly to a wholesale distributor or to a buyer 400 miles away, you fail the second test. Qualified-exempt farms still keep records substantiating the exemption, follow the modified disclosure rule (farm name plus complete business address on the label or at the point of purchase), and comply with §§ 112.5 and 112.7. FDA can withdraw a qualified exemption after an outbreak link or a finding of material conduct that would create a public health risk. The exemption is not a permanent shield.
- 04
Fully covered — everything else
If you are not in buckets 1, 2, or 3, you are fully covered. Mandatory compliance with all the applicable subparts (training, hygiene, water, soil amendments, animal intrusion, equipment sanitation, records), state-conducted PSR inspections, and the full 2-year record retention.
The math, on a napkin
Picture a 30-acre Ontario vegetable farm doing $180K a year, 70% of which is the farmers market and a small CSA, 30% of which is one local grocery chain. Total food sales $180K (under the $500K ceiling, check) and qualified-end-user share is 70% (over the 50% threshold, check). That farm is qualified-exempt under PSR — but it still needs the records substantiating the math, the modified label/point-of-purchase disclosure, and a real plan if the grocery buyer asks. SFCR is the actually-binding rule for that Ontario farm; PSR only matters if the grower exports.
02The live deadline
What changed April 6, 2026 — pre-harvest agricultural water.
PSR has been phased in over a decade. The deadline that is live right now, for most readers, is pre-harvest agricultural water for small businesses under the revised Subpart E. FDA finalized the rewrite in May 2024 after years of industry feedback that the original 2015 testing-frequency-and-numeric-limits framework was unworkable for diverse farms with multiple water sources.
Pre-harvest agricultural water compliance schedule
Large farms (over $500,000 in average annual produce sales): April 7, 2025 (past).
Small businesses ($250,001 to $500,000): April 6, 2026.
Very small businesses ($25,001 to $250,000): April 5, 2027.
Sprouts have an earlier, separate schedule under Subpart M.
Harvest and post-harvest agricultural water (wash water, ice, dump tanks, spray washes) stays under the original prescriptive framework — no detectable generic E. coli per 100 mL in untreated water that contacts covered produce or food-contact surfaces, with monitoring and corrective actions.
The new pre-harvest framework is called the MAWA — short for "agricultural water assessment for pre-harvest agricultural water." Instead of a fixed testing calendar with hard numeric limits, the rule now requires you to perform an annual systems-based assessment that evaluates:
- Your water source (well, surface water, municipal, captured rainwater) and its known sanitary quality
- The distribution system that gets water to your crop (drip, overhead spray, furrow, hand-applied)
- Adjacent land use that might contaminate the source — livestock operations upslope, septic fields, wastewater outflow, wildlife corridors
- Weather and conditions that change the risk (recent flooding, runoff events, drought concentration)
- The way water contacts the crop and how long before harvest
Out of the assessment you identify hazards, decide on corrective measures (treatment, source change, application-method change, longer interval between last irrigation and harvest), and document everything. Testing is one possible input to the assessment — not the gate that determines compliance. The assessment is done annually and any time something material changes (a new well, a new neighbor's operation, a flood event).
This is a bigger lift than it sounds. The 2018 Yuma romaine outbreak (210 cases, 5 deaths, 36 states) was traced to agricultural water from a canal. The fall 2018 Adam Bros. romaine outbreak was traced to sediment in an on-farm reservoir. The 2024 and 2025 Bedner Growers cucumber outbreaks (551 illnesses in 2024 alone, 34 states plus DC) were traced to untreated canal water that matched the outbreak strain. Agricultural water is the most common contamination route in produce outbreaks, and farm-of-origin traceback is what closes those outbreaks. That is why the rule sits where it does.
03What the rule asks for
The subparts you actually have to know.
PSR has subparts A through R (with G, H, and J reserved). You do not need to memorize them, but here are the ones that show up in a real plan and a real inspection.
People
Subpart C + D
Subpart C — Personnel training (§§ 112.21–112.30): at least one supervisor or responsible party from a covered farm must have completed food safety training at least equivalent to the standardized curriculum recognized by FDA. The de facto curriculum is the PSA Grower Training Course (PSA = Produce Safety Alliance, Cornell-developed, FDA and USDA partnered), 7 hours, AFDO (Association of Food and Drug Officials) certificate. Cost runs roughly $120 to $250 all-in depending on state; California growers train free under CDFA funding as of Feb 2025; Idaho is free remote.
Subpart D — Health and hygiene (§§ 112.31–112.33): sick worker policy, handwashing protocol, visitor policy. Acknowledgment signatures at hire and annually thereafter.
Water + soil
Subpart E + F
Subpart E — Agricultural water (§§ 112.40–112.50): the MAWA for pre-harvest (above), plus the original prescriptive framework for harvest and post-harvest water. No detectable generic E. coli per 100 mL in untreated water contacting covered produce or food-contact surfaces.
Subpart F — Biological soil amendments (§§ 112.51–112.60): raw manure, manure tea, fish emulsion, bone meal, table waste, and composted versions of all of the above. Raw manure has a deferred interval — FDA originally proposed 9 months and 45 days, deferred in the 2015 final rule, and currently does not object to growers following the USDA National Organic Program standard: 120 days between raw manure application and harvest for crops whose edible portion contacts the soil, 90 days where it does not. Validated compost (Process A: turned aerobic, 131 degrees Fahrenheit or above for 15 days minimum, 5 turnings; or Process B: static aerated, 131 for 3 days or more) has no required wait. Most diversified growers eventually move to validated compost just to avoid the 120-day timing trap.
Animals + equipment
Subpart I + L
Subpart I — Domesticated and wild animals (§§ 112.81–112.84): intrusion observation, no-harvest decisions when there is evidence of significant animal activity. Date-stamped photos and signed determinations are the record an inspector will look for.
Subpart L — Equipment, tools, buildings, sanitation (§§ 112.121–112.140): cleaning and sanitation of food-contact surfaces (harvest containers, dump tank liners, brush rollers, conveyor belts, packing tables), maintenance records, pest control. This is where on-farm packing operations attract the most inspector attention.
Records
Subpart O
Subpart O — Records (§§ 112.161–112.167): minimum 2-year retention. Electronic records explicitly allowed (including offsite). Each record needs date and time, location, product identity, and the person who performed the activity. Signatures required on sick-worker policy acknowledgments, qualified-exempt documentation, and annual training records. This is the working surface a digital system replaces with structured, time-stamped, exportable records — same content, no manual binder rebuild on inspection day.
A few more for reference: Subpart M covers sprouts (the strictest sub-regime in the whole rule, with its own compliance schedule), Subpart K covers growing-harvesting-packing-holding more broadly, and Subparts P/Q/R cover variances, enforcement, and the procedure FDA uses to withdraw a qualified exemption.
04USDA GAP
PSR vs USDA GAP — which one your buyer actually wants.
This is where most growers get tangled. PSR is federal regulation, enforced by state Departments of Agriculture under cooperative agreements with FDA. GAP stands for Good Agricultural Practices, and it is a voluntary, buyer-driven certification program audited by USDA AMS (Agricultural Marketing Service) or by private bodies. PSR is the floor; GAP is what most large produce buyers actually demand on top of it.
USDA AMS audits four variants:
- 01
USDA GAP and GHP
The basic audit. Aligns with FDA recommendations. Often sufficient for regional grocers and foodservice distributors. (GHP = Good Handling Practices, the post-harvest companion to GAP.)
- 02
Harmonized GAP
Recognized by FDA as PSR-aligned. One audit that satisfies both your federal compliance demonstration and your buyer's certification ask.
- 03
Harmonized GAP Plus+
The only USDA GAP audit recognized as GFSI-equivalent (GFSI = Global Food Safety Initiative — the international benchmarking organization whose recognition is what large global retailers ask for) AND PSR-aligned. An extra $250 annual maintenance fee on top of the audit cost. For most wholesale-bound SME growers, this is the cheapest path to broad market access.
- 04
GroupGAP
The group-of-growers option. Multiple small or mid-size farms share the audit cost under a coordinated quality management system. Designed specifically for the cooperative and small-farm segment.
Cost reality, since nobody publishes this clearly. USDA's hourly audit rate in 2024–2025 is roughly $132 to $163 per hour depending on state, billed for audit time plus travel time plus report-writing time. A typical small-farm USDA GAP audit (under 30 acres, one site) lands at $900 to $1,600 all-in. One tracking study I read pegged the average at $925 for very small farms. Harmonized GAP Plus+ adds the $250 annual maintenance fee on top. GlobalG.A.P. (the international counterpart, required by some retail chains, European-owned grocers, and most export markets) runs $1,500 to $5,000+ for a single-site farm with a 3-to-6-month timeline from initial assessment to certificate.
So the operator decision tree, simplified:
- Direct-to-consumer only (farmers market, CSA, roadside stand): you probably do not need GAP. Your buyers are eaters, not auditors.
- Local restaurants, regional foodservice: maybe USDA GAP basic, maybe nothing. Ask each buyer.
- Grocery chains, foodservice distributors, school districts, hospitals: almost certainly GAP. Harmonized GAP Plus+ is usually the cheapest path that satisfies multiple buyers from one audit.
- Export, large global retailers: GlobalG.A.P. or equivalent.
“
One buyer wants Harmonized GAP. One wants GlobalG.A.P. The CSA just wants me to "have a food safety plan." Three different paper trails for the same lettuce, and I am the one growing it AND writing them.
”Composite — diversified vegetable grower, 40 acres, three buyer types
The reason this is software-shaped: the four GAP variants overlap heavily with each other and with PSR, but the audit checklists ask the same questions in different formats. A single structured plan that maps to all of them — same answer once, exported into the format each auditor expects — is the entire point.
05FSMA 204
FSMA 204 traceability — coming July 2028, start the lot codes now.
The third layer on top of PSR and GAP is FSMA 204 — short for the FSMA Food Traceability Rule (FSMA = Food Safety Modernization Act, the 2011 law under which PSR was written). FSMA 204 was finalized in November 2022. The original compliance date was January 20, 2026; FDA extended it by 30 months in August 2025, so the new deadline is July 20, 2028.
FSMA 204 applies to foods on the Food Traceability List (FTL). For produce farms, the foods on the FTL that matter are: fresh leafy greens, fresh-cut leafy greens, fresh-cut produce, cucumbers, fresh herbs, peppers, fresh sprouts, fresh tomatoes, melons, and tropical tree fruits. (The list also covers shell eggs, nut butters, soft and semi-soft cheeses, ready-to-eat deli salads, crustaceans, and bivalve molluscan shellfish, none of which are farm-side for most produce growers.)
Why this hits produce farms uniquely: for raw agricultural commodities, the farm IS the first receiver, the originator of the supply-chain trace. There is no upstream entity to push the work onto. The CTEs (Critical Tracking Events) that apply at the farm level:
- 01
Harvesting
Removing the RAC (raw agricultural commodity) from the field.
- 02
Cooling
Active temperature reduction before initial packing — hydrocooling, forced-air, room cooling, vacuum cooling for leafy greens.
- 03
Initial packing
First packing of the RAC. If you pack on-farm into the box that goes to the buyer, this is yours.
- 04
Shipping
Sending the lot to another covered entity (a distributor, a processor, a retailer).
For each CTE, you have to capture the KDEs (Key Data Elements): a Traceability Lot Code (TLC) that uniquely identifies the lot, the date and time, quantity and unit of measure, location identifier, and the downstream receiver. And you have to be able to share that data with FDA within 24 hours of a request. A spreadsheet on the office laptop does not survive that timeline. Neither does a binder full of harvest sheets. A digital system that captures the KDEs at the point of activity — at harvest, at the cooler, at the packing line, at the loading dock — is what gets that traceback done before the outbreak grows.
The exemption interaction is clean: farms not covered under PSR are also exempt from FSMA 204, and farms with $25K or less in produce sales are exempt from both. The $25K floor doubles as both exemptions. If you are above it, plan now — building a lot-coding habit takes a season, not a weekend.
06Canadian growers
For Canadian growers — SFCR Part 6.
If your farm is in Canada, the binding rule is SFCR — the Safe Food for Canadians Regulations, SOR/2018-108 — not PSR. Fresh fruit and vegetable businesses fall under SFCR Part 6, regulated by CFIA. The structure parallels PSR in many places but the triggers and language are different.
- 01
SFC licence trigger
You need an SFC (Safe Food for Canadians) licence if you import, export, or send fresh fruits and vegetables inter-provincially (across a provincial border). Intra-provincial growers and harvesters who sell only within their own province generally do not need an SFC licence — but they are still bound by other applicable food safety law. The minute you ship a case of Ontario carrots to a Quebec distributor, you trigger.
- 02
DRC membership
The Fruit and Vegetable Dispute Resolution Corporation. Since SFCR took effect January 15, 2019, anyone buying, selling, importing, or exporting fresh fruit and vegetables inter-provincially or internationally must be a DRC member in good standing, unless specifically exempt. The DRC handles commercial disputes (rejected loads, payment disagreements) under a binding arbitration framework.
- 03
PCP requirement
Licensed FFV (Fresh Fruits and Vegetables) businesses, plus growers and harvesters for export or inter-provincial trade, have needed a documented PCP (Preventive Control Plan) since January 15, 2020. The PCP is the Canadian equivalent of a HACCP-based food safety plan, with mandatory sections for traceability, recall, and complaints baked in. Records are kept for the full retention window specified in the regulation.
- 04
Bilingual labeling
Consumer-facing packaging must be in English and French. CFIA enforces.
From my own facility
My CFIA inspector at the Brantford facility audits against my PCP every six months. He pulls a random month of records, walks the production area with the PCP in hand, and asks "show me the entry that matches what I am looking at." The system has to make that retrieval fast or the inspection becomes a 90-minute archaeology dig through three-ring binders. The CFIA bar and the PSR bar are different chapters of the same reflex. Inspectors do not change. Records do.
07What is in the plan
What a real farm food safety plan actually contains.
This is the question I get most. Synthesized from the PSA, Cornell, Penn State, Rutgers, MSU, and UMass templates I have worked through, a real farm food safety plan has 11 sections. Best-in-class plans run 40 to 80 pages with all the SOPs and maps attached. Most operators land at 25 to 40 pages.
- 01
Farm description and scope
Legal name, address, parcels and fields with map, crops grown and methods (conventional, organic, transitional), buyers and markets (direct, wholesale, processor), employee count, activities covered by the plan.
- 02
Food safety policy and responsibility
A short written policy. Designated supervisor (the PSA-trained person), backup supervisor, signatures.
- 03
Worker training and health
Training records (PSA certificate, on-farm refresher topics, new-hire onboarding). Sick-worker policy. Visitor policy. Handwashing protocol. Map showing handwashing facility and restroom locations relative to fields and pack areas.
- 04
Land use and pre-season assessment
Field history (what grew there before, what amendments went on). Adjacent land risks — livestock operations, wastewater, septic fields, flood zones. Animal intrusion observation procedure. No-harvest decision tree.
- 05
Agricultural water
Source identification with a distribution map. The annual MAWA assessment for pre-harvest. Testing schedule for harvest and post-harvest water. Corrective action procedure if a test fails.
- 06
Soil amendments
Type, source, treatment status, application dates per field. Application-to-harvest intervals (120-day or 90-day per NOP if raw manure, no wait if validated compost).
- 07
Harvest, packing, holding
Container cleanliness, equipment cleaning schedule, food-contact surface sanitation. Packhouse environmental monitoring where applicable. Pest control program.
- 08
Traceability
Lot code system (a common pattern: harvest date plus field plus crop). The path each lot takes from field through pack to shipped. Mock recall procedure.
- 09
Records
All required logs, 2-year retention per Subpart O, with explicit electronic-record provisions if you use them.
- 10
Corrective action and recall procedure
What happens when a sample fails, when a complaint comes in, when a buyer rejects a load. Recall team contacts. Notification timelines.
- 11
Verification
Internal audits, annual mock recalls, management review of the plan.
The structure looks heavy on paper. In practice, once it is built, it is also the document you hand the GAP auditor, the document you hand the FDA inspector (or the state PSR inspector), the document you hand the CFIA inspector if you are Canadian, and the document you attach when the wholesale buyer sends a vendor compliance packet. Build it once, export it many ways.
08The build
What the farm build of HACCPlan does.
None of this is generic compliance software with a "farms" label glued on. Each piece exists because a real grower needed it and asked.
- 01
Farm Food Safety Plan builder
Pre-loaded with the 11-section structure above, the relevant PSR subparts mapped to each section, and the SFCR PCP layout as a Canadian alternative. One document, not 12 templates pieced together from extension websites.
- 02
Pre-harvest MAWA workspace
The annual agricultural water assessment, broken into the four input categories (source, distribution, adjacent land, conditions). Year-over-year comparison so you can see what changed and document why your corrective measures changed with it. Lab results from harvest and post-harvest water tests attached to the same record set.
- 03
Soil amendment tracker
Field-by-field application records. Treatment status (raw, validated compost via Process A or B, treated otherwise). Auto-calculated wait-period reminders so you do not accidentally harvest 100 days after raw-manure application instead of 120.
- 04
Worker training tracker
PSA certificate storage with expiry tracking. New-hire onboarding workflow with the sick-worker and visitor policy acknowledgments wired in. Refresh reminders for the annual training cycle.
- 05
Animal intrusion and no-harvest log
Date-stamped photo capture from the field. Signed determinations on no-harvest decisions. The record an inspector will reach for under Subpart I.
- 06
Equipment cleaning and sanitation log
Per-zone cleaning schedules — pack table, dump tank, conveyor, harvest containers, cooler interior. SOP-linked logs so the cleaner is checking against the written procedure, not their memory.
- 07
GAP audit prep workspace
Pre-audit gap analysis aligned to the current USDA GAP, Harmonized GAP, and Harmonized GAP Plus+ checklists. Export your farm food safety plan in the format each auditor expects. Saves the consultant fee or the all-night-before-the-audit panic.
- 08
FSMA 204 KDE capture
Traceability Lot Code generation at harvest. KDE capture at the four farm-side CTEs (harvesting, cooling, initial packing, shipping). Built so the 24-hour FDA traceback request is a query, not a frantic search through harvest sheets.
- 09
Mock recall engine
Run a real mock recall through your actual records. Identify which lots went to which buyers in the FDA-expected window. Shareable PDF of results for your buyer or auditor.
- 10
Qualified-exempt math worksheet
Three-year sales rolling average. Qualified-end-user share calculator (with the 275-mile distance check). Auto-generates the documentation packet you keep on file to substantiate the exemption claim.
- 11
Bilingual records for Canadian growers
Plan, logs, and labels in English and French. Satisfies CFIA's bilingual labeling requirement and the documentation language requirements for an SFCR-audited PCP.
09The outbreak record
The outbreaks that shaped the rule.
You do not have to be told why this matters; the cases say it themselves.
Recent produce outbreaks — what FDA traced and what it cost
Jensen Farms cantaloupe (2011, Listeria): 148 illnesses across 28 states, 33 deaths, median patient age 81, 99% hospitalization. Traced to a recently-installed used wash-line system that pooled water and accumulated soil. The highest-fatality produce outbreak in modern U.S. history.
Yuma romaine (spring 2018, E. coli O157:H7): 210 cases, 5 deaths, 36 states. Strain traced to agricultural water from a canal in the Yuma growing region. This outbreak drove the Subpart E rewrite.
Adam Bros. romaine (fall 2018, E. coli O157:H7): Strain found in sediment within an on-farm agricultural water reservoir, with whole-genome-sequencing match to patient isolates.
Bedner Growers cucumbers (2024 and 2025, Salmonella): Florida grower. Untreated canal water matched the outbreak strain. 551 illnesses across 34 states plus DC in 2024 alone. A second outbreak in 2025. FDA Warning Letter Nov 17, 2025.
Grimmway Farms organic carrots (2024, E. coli O121:H19): Multistate, deaths reported. Reminder that organic certification and food safety certification are different documents.
The pattern: agricultural water is the most common route. Farm-of-origin traceback closes outbreaks fast. That is exactly what the current rule structure is built around.
“
The 2020 imported-enoki Listeria outbreak — 48 illnesses, 36 in the U.S. and 12 in Canada, traced to one Korean exporter, FDA Import Alert 99-23, simultaneous CFIA recalls — is why my facility tests our growing-room environment for Listeria the way a leafy-greens farm tests its irrigation reservoir. Different crop, identical reflex. Substrate is my soil. Growing room is my field. The Brill chapter on cultivation hazard analysis (Mushroomology, Chapter 29, 2026) is where I wrote that argument down.
”My own facility, on the mushroom angle
10Starter logs
Where to start — free templates while you build the plan.
If you are not ready to commit to software, start with the logs you can fill out today. These are the same cleaning and temperature templates I use at my Brantford facility — the cooler temp log, the per-zone cleaning record, and the sanitation rotation transfer cleanly to on-farm pack operations. Cold storage of harvested produce is a cold-chain problem and the same kind of log catches the same kind of problem.
Free starter logs for on-farm packing and cold storage
Free, ungated. Fillable on a tablet or computer in any PDF viewer. Print blank and fill on a clipboard. No account needed.
These are general-purpose templates, not the PSR-specific water assessment or soil amendment forms. The PSR-specific records live inside the farm food safety plan builder in the app. The point of starting with paper is to get the habit of writing it down at the time you did it — not at 9 PM Friday filling in the whole week.
11Getting started
What the first 30 days on HACCPlan look like for a farm.
A realistic onboarding for a single-site farm runs roughly like this. Multi-site or co-op operations add a setup week.
- 01
Days 1 to 3 — coverage math
Run the four-bucket decision. Document the 3-year produce sales average. If you are qualified-exempt, calculate the qualified-end-user share. Pull the rarely-consumed-raw list against your crop list. End of day 3 you know which bucket you are in and the records you need to keep prove it.
- 02
Days 4 to 10 — the plan skeleton
Generate the farm food safety plan starter. Add your farm description, field map, crops, buyers. Designate the PSA-trained supervisor (and book the training if no one is trained yet). Write or import the sick-worker and visitor policies. Sign acknowledgments for current employees.
- 03
Days 11 to 20 — water and soil amendments
Build the source-and-distribution map. Run the first MAWA pre-harvest assessment for each water source. Schedule harvest and post-harvest water tests if you do not have current results on file. Log every soil amendment that has gone on a field in the current production cycle, with treatment status and date.
- 04
Days 21 to 30 — operations and traceability
Set up the harvest log with a lot-coding scheme (most farms use harvest date + field + crop). Run one practice harvest through the system end to end — from harvest log to cooler entry to pack record to shipping. Hand the result to your wholesale buyer or a friendly auditor as a sanity check. If you are aiming for a USDA GAP audit, schedule it now for 60 to 90 days out.
By day 30 you should be able to run a mock recall on a real lot from last week and trace it from the field to the buyer in under 30 minutes. If you can, the system is working. If you cannot, that is what month two cleans up.
Start with the farm food safety plan
Generate your farm food safety plan free — Produce Safety Rule and SFCR Part 6 supported
Free tier covers one farm food safety plan, the four-bucket coverage math, the worker training tracker, and the core temperature and cleaning logs. Paid tiers add the MAWA workspace, soil amendment tracking, GAP audit prep, FSMA 204 KDE capture, and the mock recall engine.
Email required to save your plan. No credit card. No upgrade prompts during the free tier.
Footnotes
1.21 CFR Part 112 (Produce Safety Rule) — full text — ecfr.gov
2.FDA — FSMA Final Rule on Pre-Harvest Agricultural Water (May 2024) — fda.gov
3.FDA — Exemptions Relevant to Produce Farms — fda.gov
4.FDA Fact Sheet — Rarely Consumed Raw Produce — fda.gov
5.AFDO — PSA Grower Training Course — afdo.org
6.USDA AMS — GAP and GHP Audit Services — ams.usda.gov
7.USDA AMS — Harmonized GAP and Harmonized GAP Plus+ — ams.usda.gov
8.FDA — FSMA 204 Food Traceability Final Rule + 2025 Compliance Extension — fda.gov
9.CFIA — Fresh Fruits and Vegetables Regulatory Requirements — inspection.canada.ca
10.CDC — Yuma Romaine E. coli O157:H7 Outbreak (Spring 2018) — cdc.gov
11.FDA — Salmonella Cucumbers Outbreak Investigation (2024 and 2025, Bedner Growers) — fda.gov
12.FDA — Listeria monocytogenes Enoki Mushrooms Outbreak (March 2020) — fda.gov
Andrew Langevin·CFIA-licensed facility, Brantford ON· Published 2026-06-04· 13 min read· Wikidata Q139112497