Food Safety Magazine-June/July2013

ticularly to reduce the paperwork burden at small operations. However, the Operations Committee recognized that misinterpretation and disputes in interpretation of these requirements would still happen and recommended formation of a committee that would be responsible for ongoing review of disputes and interpretation of the intent of the standards.

Therefore, a Calibration Committee was formed, compris-ing representatives of various audit organizations that intended to use the Harmonized Standards and representatives of various commodity growers and buyers (Figure 3). By bringing as many audit organizations as possible to the table and adding subject matter experts in different growing and handling practices, the goal is to further harmonize auditors’ interpretations of what is expected at an audited operation: what practices are “compliant” with the intent of the Harmonized Standards; what practices are not; and how auditors are to react when they see practices they believe may represent a public health risk. The committee’s responsibilities are to 1) develop the official training materials for auditors on how to interpret the intent of the standards and 2) participate to resolve real-time disputes in interpretation of the standards. Importantly, it is not the committee’s responsibility to train auditors how to audit; that task remains the responsibility of the individual audit organizations.

Coordinated by United Fresh, the volunteer members of

the Calibration Committee have had their work cut out for them: They’ve evaluated dozens of dispute questions and developed consensus responses to each; they developed training slides for each requirement in the Field Operations and Harvesting standards, including hundreds of possible scenarios of what an auditor might see, often drawn from the dispute questions, and how the auditor should react to and judge what he or she sees; and they offered two Train-the-Trainer workshops in 2012 for auditors and auditees alike—one at Costco headquarters in Issaquah, WA, the second at the USDA National Agricultural Library in Beltsville, MD. Thanks to the generous support of several of the Calibration Committee member organizations, both workshops were offered at no fee to attendees, and both were filled with over 70 attendees each. The participating audit organizations, including USDA, Equicert and some who are GlobalG.A.P. and SQF certification bodies, subsequently began training their auditors, greatly increasing the capacity for operations to have an audit performed to the Harmonized Standards.

Harmonized Standards and the FSMA Rules. At this writing, FDA had just published its proposed rules for Produce Safety and Preventive Controls for Human Food. The scope of the Produce Safety proposed rule is the same as the 1998 FDA GAPs Guide and the Harmonized Standards: the growing, harvesting and on-farm handling of fresh produce. While

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