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Nathan A Adams IV is a Partner in Holland & Knight's Tallahassee office
On Jan. 26, 2018, farms that sold an average of more than $500,000 in produce during each of the past three years were required to comply with the FDA Food Safety Modernization Act (FSMA). Requirements include standards for worker training, health and hygiene, domesticated and wild animals, and equipment decontamination and cleaning. Sprout growers already have had to meet the requirements specific to them. Microbial standards and testing for agricultural water are on hold. Also pending are standards related to the risk of contamination from the use of raw manure as fertilizer. The department also has announced that it will exercise enforcement discretion as it relates to preventive controls requirements for operations that do not fit within the farm definition because they conduct certain activities not included within the definition (e.g., coloring raw agricultural commodities) or do not meet the ownership requirement to be a secondary activities farm (e.g., some packinghouses).
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