School nutrition operators should ensure that fresh produce is purchased from reputable suppliers that adhere to the FDA's Current Good Manufacturing Practices (cGMPs). School nutrition staff involved in purchasing activities should visit their fresh produce distributor at least annually to observe their food safety practices, inspect facilities, and ask questions regarding the food safety requirements for their suppliers. Consider organizing the site visit with other school district purchasing staff or purchasing cooperative members to reduce the number of visits to the facility. To be considered a reputable supplier, all facilities should be properly licensed and in compliance with local, state, and federal food safety regulations.
We outline specific food safety policies and practices to observe, which will help you ask questions on your visit to ensure you have confidence in the fresh produce distributor’s food safety program. While the focus is fresh produce distributors, many of the food safety policies and practices are also applicable to other types of food distributors.
Planning a Distributor Visit
As a current or potential buyer, we recommend you visit your produce distributor's warehouse at least once a year to observe their food safety practices and documentation of those practices, specifically:
- receiving and storing;
- cleaning and sanitizing;
- employees’ health and hygiene;
- employees’ food safety training;
- and the recall and traceability program.
Some common terms and language used by distributors and other wholesalers, which may help you communicate more effectively are:
- Backhaul
Product is picked up from suppliers after delivering product to customers. This process improves transportation efficiency by delivering product and picking up product to return to the distribution center in one trip. For example, Vendor A may deliver fresh produce and other supplies to its customers and take back fresh produce to the distribution center from Farm A at the end of the route.
- Chain of Custody
The documentation of a food item showing each step in the process: acquisition, transfer, handling, and disposition.
- Clean
Visually free of dust, dirt, food residues and other debris.
- Good Condition
Close to the original condition of an item or piece of equipment; good condition and not in disrepair.
- Current Good Manufacturing Practices (cGMPs)
In September 2015, the FDA modernized the cGMPs and established them in new Part 117 (21 CFR Part 117), along with new requirements for hazard analysis and risk-based preventative controls which were issued as part of the implementation of the FDA Food Safety Modernization Act (FSMA).
- Good Agricultural Practices (GAPs) and Good Handling Practices (GHPs)
Best practices to verify that fruits and vegetables are produced, packed, handled, and stored in the safest manner possible to minimize risks of microbial food safety hazards.
HACCP plans are written documents based on HACCP principles specific to a facility that identify procedures to be followed to prevent foodborne illness.
- Hazard Analysis Critical Control Points (HACCP) and HACCP Plans
A preventative system to reduce the risk of foodborne illness through appropriate food handling, monitoring, and record keeping.
- Repacking
Sorting and packaging of product to meet a customer’s specifications such as color of tomatoes, ripeness of avocados, and/or packaging of product into smaller amounts.
- Trace Back and Trace Forward Ability
Trace back ability is the ability to trace the produce one step back in the chain of custody. For example, Vendor A would track fresh produce back to the distribution center, which in turn can identify their source of product. This information is needed in the event of a recall or food borne illness outbreak.
Trace forward ability is the ability to trace the produce one step forward in the chain of custody.
Read about the food safety practices to expect from your fresh produce distributor and what to observe and discuss while visiting.
Additional Resources
- OSHA's Agricultural Operations Standards
- EPA's Basic Information about Pathogens and Indicators in Drinking Water
- FDA's Guidance for Industry: Food Producers, Processors, and Transporters: Food Security Preventive Measures Guidance
- FDA's Guidance for Industry: Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables
- USDA AMS's GAP & GHP Audit information