FSMA vs.

GAP: A Side by Side Comparison for Produce

Presented by: Leah Cook, January 2019

Records & Documentation Requirements

FSMA: Produce Safety Rule
Subpart & Supervisor Review,
Topic Areas Record Requirements Date, & Initial
Section
Must include written disclosure
Subpart A
with shipped product saying that No supervisor review
Section
product is not adequately treated needed.
112(b)(2)
to reduce pathogens.
COMMERCIAL PROCESSING
EXEMPTIONS Must get written assurances from
Subpart A your customer that they or their
No supervisor review
Section subsequent customer will perform
needed.
112.2(b)(3) commercial processing to
adequately reduce pathogens.
Supervisor review and
Subpart A Must maintain sales records and
signature needed;
Section records demonstrating eligibility
except on sales
112.7(b) for qaulified exemptions.
receipts.
QUALIFIED EXEMPTIONS
Must perform and record annual
Subpart A
review and verification of Supervisor review and
Section
continued eligibility for qualified signature needed.
112.7(b)
exemption.
If you want to use alternate
methods not listed in the PSR, you
Subpart B must establish and maintain
ALTERNATIVES TO ANY No supervisor review
Section documentation of scientific data or
SUBPARTS needed.
112.12( c ) info that supports a conclusion
that your methods provide an
equal measure of protection.
All required personnel trainings
Subpart C
must be recorded and records Supervisor review and
Section PERSONNEL TRAINING
must include: dates, topics signature needed.
112.30(b)(2)
covered, and personnel trained.
Must record observations and
inspection findings of water
Subpart E
WATER SYSTEM system inspections: at the No supervisor review
Section
INSPECTION beginning of the growing season, needed.
112.50(b)(1)
as appropriate, but at least
annually.

**PAGE 1 OF 3**

MAINE DEPARTMENT OF AGRICULTURE, CONSERVATION & FORESTRY

 FSMA vs. GAP: A Side by Side Comparison for Produce
Presented by: Leah Cook, January 2019

Records & Documentation Requirements

FSMA: Produce Safety Rule
Subpart & Supervisor Review,
Topic Areas Record Requirements
Section Date, & Initial
Subpart E
AGRICULTURAL WATER Must keep analysis reports of all Supervisor review and
Section
ANALYSES agricultural water tests. signature needed.
112.50(b)(2)
Must establish and keep records of
Subpart E
all scientific data or info used to No supervisor review
Section
support the adequacy of your needed.
112.50(b)(3) AGRICULTURAL WATER water treatment methods.
TREATMENTS
Subpart E
Must keep records of results of Supervisor review and
Section
water treatment monitoring. signature needed.
112.50(b)(4)
Must keep establish and keep
records of all scientific data or info
Subpart E
used to support microbial die-off No supervisor review
Section
or removal rates used to support needed.
112.50(b)(5)
time intervals used to achieve log
AGRICULTURAL WATER reductions of E. coli.
APPLICATION / DIE-OFF
INTERVALS Must keep records of actions you
take if ag water does not meet
Subpart E
quality standards, including Supervisor review and
Section
records of any time intervals or signature needed.
112.50(b)(6)
other reduction treatments
applied.
Must maintain annual
Subpart E documentation of results or
No supervisor review
Section PUBLIC WATER SUPPLY certificates of compliances from
needed.
112.50(b)(7) public water systems supplying
your water.
Must establish and maintain
documentation of scientific data or
Subpart E
ALTERNATIVES TO WATER info that supports a conclusion No supervisor review
Section
REQUIREMENTS that your alternative methods needed.
112.50(b)(8)
provide an equal measure of
protection.

**PAGE 2 OF 2**

MAINE DEPARTMENT OF AGRICULTURE, CONSERVATION & FORESTRY

 FSMA vs. GAP: A Side by Side Comparison for Produce
Presented by: Leah Cook, January 2019

Records & Documentation Requirements

FSMA: Produce Safety Rule
Subpart & Supervisor Review,
Topic Areas Record Requirements
Section Date, & Initial
Must keep records of any
Subpart E
statistical analytical methods you No supervisor review
Section WATER ANALYSIS METHODS
use in lieu of the methods in the needed.
112.50(b)(8)
PSR to evaluate water results.
Must have annual documentation
Subpart F that the process used to treated
No supervisor review
Section biological soil amendments of
needed.
112.60(b)(1) animal origins is scientifically
TREATED BIOLOGICAL SOIL
valid and process is monitored.
AMENDMENTS OF ANIMAL
ORIGIN FROM 3RD PARTY
Must have annual documentation
SUPPLIERS
Subpart F biological soil amendments of
No supervisor review
Section animal origins were handled
needed.
112.60(b)(1) appropriately to minimize risk of
re-contamination.
Must keep documentation that
Subpart F BIOLOGICAL SOIL
process controls (time, Supervisor review and
Section AMENDMENTS OF ANIMAL
temperature, turnings) were signature needed.
112.60(b)(2) ORIGIN TREATED ON-FARM
achieved.
Must establish and keep records of
Subpart L dates and methods of cleaning and
EQUIPMENT CLEANING AND Supervisor review and
Section sanitizing equipment used in
SANITATION signature needed.
112.140(b)(2) covered harvesting, packing, or
holding activities.

**NOTE: Requirements for written assurances from

COMMERCIAL PROCESSING customers have been delayed
another 2 years to: January 26, 2021.**

**NOTE: ALL WATER requirements are currently under

review and compliance deadlines delayed.**

**PAGE 3 OF 3**

MAINE DEPARTMENT OF AGRICULTURE, CONSERVATION & FORESTRY