Processors Monthly - January 2014
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Processors Monthly - January 2014

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Western Agricultural Processors Association

Western Agricultural Processors Association
Food Safety
Regulations
FSMA
Truck Rule
ARB

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    Processors Monthly - January 2014 Processors Monthly - January 2014 Document Transcript

    • Newsletter of the Western Agricultural Processors Association January 2014 Industry Calendar January 10 Walnut Show— Yuba City February 17 -19 Pistachio Conference —San Diego February 20 -21 Walnut Board Mtg.— Napa WAPA Staff Roger A. Isom President / CEO roger@agprocessors.org Casey D. Creamer Vice President casey@agprocessors.org Aimee Brooks Director of Regulatory Affairs aimee@agprocessors.org Elda Brueggemann Director of Environmental & Safety Services elda@agprocessors.org Irma Ramirez Safety Assistant irma@agprocessors.org Shana Colby Administrative Assistant shana@agprocessors.org WAPA Office 1785 N. Fine Avenue Fresno, CA 93727 P: (559) 455-9272 F: (559) 251-4471 Processors Monthly Volume 6, Issue 1 Refrigerant Management Program Deadline is March 1, 2014 The deadline for registration is approaching for facilities with refrigeration systems using high global warming potential refrigerants that have a full charge of at least 200 pounds and less than 2,000 pounds. These are designated as "medium-sized" systems under a California state regulation to minimize leaks of environmentally harmful refrigerants. Companies must register their refrigeration system with the California Air Resources Board (ARB) by March 1, 2014, if the single largest system at an individual facility has a full charge of 200 pounds or more of the following refrigerants: chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) or hydrofluorocarbons (HFCs). The online registration and reporting tool, known as the "Refrigerant Registration and Reporting System," or R3, is available at www.arb.ca.gov/rmp-r3. Facilities with smaller refrigeration systems with a full charge of greater than 50 pounds and less than 200 pounds of high global warming potential (highGWP) refrigerant are not required to register until 2016. However, these systems are subject to leak inspection, repair and recordkeeping requirements of the rule in effect now. Facilities with large refrigeration systems with a refrigerant charge of 2,000 pounds or more should already be registered and must continue to submit annual reports to ARB. Failure to register applicable refrigeration systems may result in site inspections, notices of violation and cumulative daily penalties. WAPA Annual Meeting Save the dates and get ready to book your rooms, for WAPA’s best Annual Meeting yet! The 2014 WAPA Annual Meeting will be held on June 19th and 20th at the Monterey Plaza Hotel located on Cannery Row in beautiful Monterey. In addition, WAPA will host its first ever Annual Meeting Dinner at the amazing Monterey Bay Aquarium, in the evening of Thursday, June 19th! This will follow our Annual Golf Tournament, which will be held this year at the Nicklaus Club in Monterey. The Nicklaus Club, formerly the Pasadera Golf and Country Club, is one of the Jack Nicklaus “Signature Clubs” and was originally designed by Nicklaus himself. Rooms are an incredible $199 for what is arguably the best hotel in Monterey! As usual, a quality cast of speakers are being lined up for the event, which promises to be our best yet! Make sure to reserve your rooms early! FDA to Publish Revised Rules on Produce Safety and Preventative Controls FDA Deputy Commissioner for Foods and Veterinary Medicine, Michael Taylor, has announced that FDA will publish revised proposed rule language by early summer 2014 for the Produce Safety Rule and the Preventative Controls Regulations. FDA will accept additional comments only on those sections of the proposed rules that have been revised. In a recent press release Deputy Commissioner Taylor stated “FDA appreciates and takes very seriously the extensive input we have received from produce farmers and others in the agricultural sector on the proposed FDA Food Safety Modernization Act (FSMA) rules on pro-
    • Processors Monthly—Page 2 duce safety and preventive controls for human food, which we published in January 2013. We have made every effort to solicit input on the proposed rules, not only through the standard rulemaking process, but also by participating in more than 150 meetings and by travelling to numerous farms of varying types and sizes from Maine to California. Based on our discussions with farmers, the research community and other input we have received, we have learned a great deal, and our thinking has evolved. Everyone shares the goal of ensuring produce safety, but, as we said at the beginning of the process, the new safety standards must be flexible enough to accommodate reasonably the great diversity of the produce sector, and they must be practical to implement. To achieve this goal, we believe that significant changes will be needed in key provisions of the two proposed rules affecting small and large farmers. These provisions include water quality standards and testing, standards for using raw manure and compost, certain provisions affecting mixed-use facilities, and procedures for withdrawing the qualified exemption for certain farms.” Deputy Commissioner Taylor further stated there may be other revisions as well, but those will be determined after FDA has an opportunity to fully review the written comments that have been submitted. 2014 Food Safety Training Classes: WAPA and AIB International are once again partnering to bring you food safety training for tree nut processing facilities! This year’s schedule is as follows: HACCP Workshop – March 5-6, 2014 HACCP Assessments – April 14-15, 2014 BRC Introduction, Interpretation, and Implementation – March 25-26, 2014 In the “HACCP Workshop”, participants will learn to organize Prerequisite Programs to meet the requirements for food safety. You will also learn to identify the three types of hazards (Biological, Chemical, and Physical). Participants will have the opportunity to get their questions answered by an industry expert and to develop a complete HACCP Manual specific to their plants through practical workshops. In the “HACCP Assessments” participants will:      workshops. Learn to manage change, including evaluation of potential, affiliated food hazards when revisions to equipment, raw materials, and/or process parameters are made. Learn new strategies to ensure that your HACCP Program remains effective. Finally, AIB International’s BRC Certification seminar provides the tools necessary to understand and implement a BRC Food Safety system in your facility from the auditor’s perspective. Learning objectives include:     Develop, implement, and maintain programs that meet the BRC Audit Standard Recognize the BRC Standard program links and how the interact given specific scenarios Create specific records and procedures Perform management tasks required by specific clauses The classes will be held at the Association offices, located at 1785 N. Fine Ave in Fresno. Hotel rooms are located close by at the Picadilly Inn – Airport. Class cost is $425 each for members, and $475 for nonmembers. However, the class cost goes down if you register for more than one class and if you register early! Look for details to be mailed directly to you in January, or sign up and register online! WAPA Testifies at ARB Truck Rule Workshop! WAPA President/CEO Roger Isom spoke out against the proposed changes to the California Air Resources Board’s Heavy Duty On-road Vehicle Regulation (aka The Truck Rule), saying the proposed changes don’t go far enough! ARB is currently proposing changes to the rule designed to lessen and/or delay the impact of the current rules. The proposed changes include:    Re-opening the opt-in period to register existing low mileage agricultural vehicle extension Re-opening the opt-in period to register for the existing PM phase-in requirements Increase the thresholds for the low-use exemption for trucks that are operated a total of less than 5,000 miles per year Expand “NOx exempt” areas to include additional counties including Butte County! Revisit the HACCP preliminary tasks and seven principles with an updated perspective.  Discuss physical, chemical, and microbiological hazards of current importance. Acquire practical auditing experience for evaluating Isom specifically stated that the proposed changes to the HACCP systems implementation through interactive NOx exempt areas were too limited and placed unfair ad-
    • Processors Monthly—Page 3 vantages on farmers in the San Joaquin Valley. Isom also commented that the extensions on the filter requirements would do nothing for individual owner/operators and small fleet owners that simply can’t afford a diesel particulate filter (DPF) especially when the filter costs more than the truck is worth! Finally, Isom blasted the ARB for the filter requirements in general emphasizing the repeated problems with retrofit filters, including over 100 trucks in ARB’s own Proposition 1B program where there was not a single truck that could be found with a “working filter.” Isom also asked why ARB was doing a survey to fleet owners asking if the filters worked or not, to which ARB indicated that the survey was unauthorized and that a new one will be going out in early spring. Isom requested that the survey be conducted by a “unbiased“ third party to get to the truth. WAPA continues to press ARB on one of the most costly and impactful rules for its members to comply with, and encourages all of its members to weigh in now on the impact of the truck rule and cost of compliance! Sixth Rule Proposed under FSMA addresses Protection against Adulteration FDA is set to publish a proposed rule on Protecting Food against Intentional Adulteration. This is the sixth proposed rule under the Food Safety Modernization Act (FSMA) and would require large food businesses, both domestic and foreign, to have a written defense plan that addresses possible areas of vulnerability in their operations and requires steps to prevent adulterations that could result in large-scale public harm. FDA has highlighted general activities where adulteration is most likely to occur:     bulk liquid receiving and loading; liquid storage and handling; secondary ingredient handling mixing and similar activities. Each facility would then address these points of vulnerability in their operations and then identify actionable steps to mitigate the risk of intentional adulteration. In addition, facilities will be required to write their own food defense plan that would include:        Actionable process steps, Focused mitigation strategies Monitoring Corrective Actions Verification Training Record Keeping FDA is proposing the new requirements would be in effect 60 days after the final rule is published. However, smaller businesses are granted extensions based on total annual sales, employees, and other factors yet to be specified. The rule does not apply to farms or facilities not required to register under section 415 of the FD&C Act. The proposed rule was published in the Federal Register on December 24, 2013, allowing the public to review it and submit comments until March 31, 2014. WAPA continues to follow FSMA updates closely and this update is no exception. AgSafe to offer Worker Protection Standards and Hazard Communications AgSafe will be offering their Safety Essentials workshop that includes both Worker Protection Standards and Hazard Communication courses. These courses are excellent opportunities to continue effective safety programs, brush up with new skills and learn new requirements. The Worker Protection Standards class is designed for supervisors, crew leaders, and workers and teaches where and how workers may come into contact with pesticides, how workers can protect themselves from exposure, signs and symptoms of poisoning from pesticides including first aid procedures, restricted entry intervals, postings, warnings, pesticide use reports, protection from employer retaliation and much more. This class is held from 8:00 AM-12:00 PM. The second course offered is Hazard Communications from 1:00 PM-4:00 PM. The course is ideal for managers and supervisors and aims to teach them state and federal regulations requirements, including requirements for a hazard communication plan, and will review the Global Harmonization System and documentation and training. The courses can be taken individually or together. Classes are available in both English and Spanish. Cost per class is $20 for members and $30 for Non-Members. A $10 late fee will be assessed for those that register less than 5 days prior to the event. Questions can be directed to AgSafe at 209-526-4400 or safeinfo@agsafe.org. Registration is available on their website at www.agsafe.org by selecting their calendar and choosing the event you would like to Location Date attend. The Bakersfield, CA 01/16/2014 courses will Salinas, CA 02/06/2014 be offered in Fresno, CA 02/11/2014 five different Oxnard, CA 02/12/2014 locations: Santa Maria, CA 02/13/2014
    • Western Agricultural Processors Association 1785 N. Fine Avenue Fresno, CA 93727 PRESORTED STANDARD US POSTAGE PAID FRESNO, CA PERMIT NO. 2201 Happy New Year! State Releases Updated Comprehensive Water Reliability and Ecosystem Restoration Plan The Bay Delta Conservation Program, which aims to restore ecosystem health and secure reliable water supplies for California has been released for formal public review. In addition to stabilizing water deliveries from the Delta, the plan details the recovery of 56 species of plants, fish and wildlife over the 50 year life plan. These “co-equal goals” were delineated by the Legislature in the 2009 Delta Reform Act. The 9,000 page plan and its corresponding Environmental Impact Report/ Environmental Impact Statement have undergone several revisions since the administrative drafts that were released last spring and summer. Some revisions include: analysis and hundreds of public meetings. The plan describes 22 separate conservation measures that are administered by CDWR, operator for the SWP and the U.S. Bureau of Reclamation, operator of the CVP. The plan aims at providing these entities with a stable regulatory environment that works towards the recovery of imperiled fish species. Only in the last paragraph of the State’s press release is any real mention of the water users that so desperately need a workable plan. It states that water users (Southern California, the Santa Clara Valley, and the  Changes to the alignment of the conveyance tunnels for a San Joaquin Valley) will bear most of the costs of the smaller environmental footprint plan, including the new intakes and tunnels which will  Details that ensure the critical adaptive management proctotal around $16 billion. The public review draft of the ess accurately measures species recovery BDCP is available at www.baydeltaconservationplan.com.  Detailed changes on how the plan would be governed Also available is guidance for comments and a schedule  Tools and funding available to support adaptive manageof public meetings. Comments will be gathered until April ment if more Delta water is needed 14, 2014. WAPA will be actively involved in commenting  Additional design criteria and operational constraints for on the plan and attending public meetings as to address proposed Delta intake  Additional measures to further protect the greater sandhill our concerns with the proposed plan, including avoiding crane, giant garter snake, and saltmarsh harvest mouse damaging impacts to our ag economy, ag jobs, and busiThe BDCP has been developed through seven years of ness climate.