Urban crop production in vertical farms

Departments - Urban Agriculture

Optimizing resource use such as for energy, water, nutrients, and CO2 is essential for the long-term viability of vertical farm systems.

March 26, 2018
Murat Kacira, Neil Mattson, Ryan Dickson and Roberto Lopez

**Fig. 1A**. Hydroponic seedling production in a commercial vertical farm
Photo: Roberto Lopez and Murat Kacira

This article series is from the Resource Management in Commercial Greenhouse Production Multistate Research Project.

Indoor vertical farming systems or plant factories use controlled environment agriculture (CEA) technologies to grow high-value horticultural crops year-round in pre-existing urban warehouses or shipping containers. The internal building of warehouses is most often converted into a growing environment with the goal of achieving higher biomass production compared to outdoor or greenhouse production. The essential components of a vertical farm include multi-layer production shelves, hydroponic, aeroponic, or aquaponic growing systems and sole-source electrical lighting consisting primarily of high-intensity light-emitting diodes (LEDs) (Figs. 1A and B) or fluorescent lamps. However, detailed engineering design fundamentals for heating, ventilation, and air conditioning (HVAC) systems, uniformity of the environment, optimal delivery of carbon dioxide (CO₂), shelf spacing, smart lighting and shelf designs, and interaction of crops and surrounding climate in terms of heat and mass-transfer processes are often overlooked in such retrofits. Optimizing the use of resources such as energy, water, nutrients and CO2 is essential for the long-term viability of vertical farm systems, where energy intensive lighting and HVAC systems can account for close to one third of the overall operational costs. The operational costs and resource use efficiency (defined as the ratio of resource fixed by the produce to resource used by the plant; Kozai, 2013) of multi-tier-based vertical farm systems can be improved by appropriate production system design modifications for key technologies and control strategies while considering the crop-specific minimum environmental requirements such as light intensity and quality, air temperature, velocity and flow pattern, CO₂ and uniformity of these variables.

Many millennial vertical farmers are data-driven and rely on recent technology developments in sensors, environmental monitoring and control, and information and communication technologies. Integrated monitoring and control of the crop and production system and analysis on average account for about 9 percent of a farm workforce’s weekly labor hours (Agrilyst, 2017). It is expected that these technologies will further advance with integration of the diverse set of analytics platforms made available for growers and system operators empowering them to improve production quality and overall resource use efficiency. The technologies that vertical farming operations are most excited about include automation, HVAC, LED lighting systems, smart sensors and data analytics.

Challenges in vertical farming

Several economic challenges make vertical farming a difficult sector to enter and be profitable including both high start-up costs (particularly lighting, vertical growing systems, and sufficient HVAC capacity) and high operating costs (especially energy and labor). In greenhouses, labor is typically the largest production cost followed by energy. In vertical farms, energy costs may be equal to or greater than labor. In a recent survey of CEA operations, 27 percent of vertical farms reported being profitable as compared to 67 percent of greenhouses (Agrilyst, 2017).

In 2016, an energy use simulation was conducted for lettuce production in greenhouses and vertical farms in diverse climates across the U.S. Per unit of lettuce, vertical farms in Minneapolis would require 1.4 to 2.4 times more energy than greenhouse counterparts; while in an arid climate like Phoenix, a vertical farm would require five to 10 times more energy than greenhouses (Harbick and Albright, 2016). Energy use was evenly split between lighting and HVAC systems. Another simulation-based study (Graamans et al., 2018) compared greenhouses vs. vertical farms in the Netherlands, United Arab Emirates, and Sweden in terms of resource use efficiency per unit biomass of lettuce: In all cases, purchased energy (heating plus electricity) used by greenhouses was less than plant factories. Climate made a large difference in the extent of energy savings. In a moderate climate like the Netherlands, greenhouse energy was three times less than the plant factory, while in an extreme northern climate like Sweden, greenhouses used only 15 percent less energy than plant factories. However, beyond energy, it was noted that vertical farm-based production could achieve higher productivity for all other resources (water, CO2, and land area). Currently, energy costs average $8 per square foot production space and represented 25 percent of annual production costs in large vertical farms (Agrilyst, 2017). Therefore, there is further need for research on analysis of resource use efficiencies and to develop resource-conserving environmental control strategies (Fig. 2).

Automation in vertical farming

While indoor production may lend itself to increased automation (vs. field production), the nature of vertical farming (multi-layered production) appears to make it difficult to automate. Processes that in 2-D greenhouses (moving plants to the production space, respacing, sorting, and harvesting) are more time-consuming and labor-intensive in 3-D. For example, accessing crops for maintenance, monitoring, and pulling for harvesting typically requires added labor time through use of ladders or scissors lift in vertical farming (Fig. 3). Thus, automation and robotics systems need to be integrated for such operations.

**Fig. 1B**. Lettuce production at the University of Arizona Controlled Environment Agriculture Center Urban Agriculture Vertical Farm Research, Teaching and Outreach Facility
Photo: Roberto Lopez and Murat Kacira

Nutrient management in vertical farms

Indoor vertical farming operations take advantage of technology and automation to improve production efficiencies. This includes optimization of the root-zone (in terms of pH, fertilizer nutrients and dissolved oxygen) to produce high-quality crops and reduce nutrient waste. However, managing nutrients in vertical farming does not have to be high-tech or complicated. In addition, common nutrient management techniques used in greenhouse hydroponic and container crop production also apply to vertical farming.

Measuring electrical conductivity (EC) and pH in the rootzone are common methods for monitoring crop fertility. EC refers to the concentration of total nutrients surrounding roots, where greater EC values indicate a greater nutrient supply. pH refers to acidity or basicity in the root zone (where pH 7 is neutral), which influences the solubility and availability of nutrients for uptake. For most crops, nutrients are adequately available at pH 5.6 to 6.4. Multiple factors interact and can influence nutrients and pH during vertical farming production. For strategies on managing these factors, check out our previous Produce Grower article, “Edible crop species differ in their pH effect in hydroponics,” at bit.ly/2CNsGUk

In addition to measuring root-zone pH and nutrient levels, growers should periodically conduct detailed nutrient analyses on both the applied nutrient solution and plant tissue using a commercial lab. This helps growers check their own in-house pH and EC measurements, and verify that they are supplying individual nutrients in the correct amounts. Tissue nutrient analyses provide information on the amount of nutrients the plants are taking up, which helps growers adjust their fertilizer program for optimal plant growth and diagnose nutritional problems. Visual inspection of plants to diagnosis nutrient and other disorders remains important in plant factories but can be difficult under sole-source LED lighting. For example, under narrow waveband red and blue light, plant surfaces appear pink or purple. Some lights have a human vision feature to turn OFF red/blue light and turn ON white (broad-spectrum) light to inspect plants, or operators use special glasses with green lenses to see plants with natural colors. Computer vision systems can help enhancing plant inspection for growth, health monitoring and environmental control purposes and as an integral part of needed automation and robotics applications.

**Fig. 2**. Computer simulation analysis of climate (e.g. air velocity and temperature) uniformity in a vertical farm system (Zhang and Kacira, 2017)
Graphic: Murat Kacira

Future prospects

Vertical farming can meet consumer demand for high-quality, nutritious, chemical-free, and locally grown horticultural crops. Due to high production costs, there should be additional benefits delivered by sole-source lighting and CO₂ enrichment (such as phytochemical, nutrient or color enhancement). Research and development to improve labor and energy-use efficiency as well as increased uniformity of the growing environment will be important to address industry viability/profitability. Further, there is an increasing demand by the vertical farm industry for an educated/experienced workforce who understand both the biology and engineering of controlled environment crop production systems. Because the industry is young, the workforce has largely come from related industries without prior experience specifically in indoor climates. Therefore, it’s critical to maintain and further grow controlled environment agriculture-based research, educational, and extension/outreach programs offered by higher education institutions to meet the industry’s demands.

References

Agrilyst. 2017. State of indoor farming. https://www.agrilyst.com/stateofindoorfarming2017

Graamans, L., E. Baeza, A. van den Dobbelsteen, I. Tsafaras, C. Stanghellini. 2018. Plant factories versus greenhouses: Comparison of resource use efficiency. Agricultural Systems, 160: 31-43.

Harbick, K. and Albright, L.D. 2016. Comparison of energy consumption: greenhouses and plant factories. Acta Hortic. 1134, 285-292.

**Fig. 3**. A scissors lift is used to access crops on upper levels in a commercial plant factory.
Photo: Neil Mattson

Kozai, T. 2013. Resource use efficiency of closed plant production system with artificial light: Concept, estimation and application to plant factory. Proceedings of the Japan Academy, Series B, Physical and Biological sciences, 89: 447-461.

Ying, Z. and M. Kacira. 2017. Analysis of environmental uniformity in a plant factory using CFD analysis. Presented at GreenSys 2017-International Symposium on New Technologies for Environment Control, Energy-Saving and Crop Production in Greenhouse and Plant Factory, August 20-24, Beijing, China.

Acknowledgements

Financial support was received from the USDA National Institute of Food and Agriculture, Multistate Research Project NE-1335: Resource Management in Commercial Greenhouse Production. Murat is a professor at the University of Arizona (mkacira@email.arizona.edu), Ryan is an extension professor/specialist at the University of New Hampshire (Ryan.Dickson@unh.edu), Neil is an associate professor and extension specialist at Cornell University (neil.mattson@cornell.edu) and Roberto is an assistant professor and floriculture/controlled environment specialist at Michigan State University (rglopez@msu.edu).

The role of wood substrates in controlled environment vegetable and fruit production systems

Features - Production

Growers can choose from a variety of wood components.

March 1, 2018
Brian E. Jackson

**Fig. 1.** Wood substrates and substrate components can be processed/engineered in different ways to produce different materials with specific physical and chemical properties.
Photo: Brian E. Jackson

The increase in soilless culture production of greenhouse vegetables, fruits and other consumables continues across the globe. As this rise continues, much research has been and is currently being conducted on suitable, alternative, economical, recyclable, disposable and efficient substrate materials to maximize crop yield and production efficiency. While the use of “soilless” organic and inorganic materials is not new to the industry, there is more interest in alternative materials now than ever before. Traditional (and successful) substrate components have included materials like rockwool, expanded clay aggregates, Growstones, perlite, pumice, Oasis cubes, coconut coir, peat moss and rice hulls. Another material that has been investigated is wood products (fiber, chips, sawdust, shavings, etc.). The goal of this article is to provide some background information and historical context to the development and use of wood substrates for controlled environment cropping systems. More detailed information about specific issues, potentials, advantages and disadvantages of using wood substrate materials will follow in the near future.

**Fig. 2.** Many trials in Europe and North America have evaluated the potential of using wood substrates in the production of many vegetable and fruit crops.
Photo: Brian E. Jackson

Wood fiber’s history

First developed in Europe in the early 1980s for the production of ornamental crops (floriculture and nursery), wood fiber has also been tested and trialed for vegetable and fruit production since the early 1990s. There are a variety of different wood components that have been commercialized over the years, many of which can have very different visual properties as well as physical and chemical properties (Fig. 1). To date, there have been more than 30 different types of wood substrate materials (components) developed, tested, and some commercialized in Europe and North America.

The idea of using wood materials can be alarming to many growers as we have been taught, or experienced, that there can be negative outcomes to growing plants in a non-composted fresh wood material. Research has shown that wood from softwood species (conifers) is better suited for use in plant growth systems because generally speaking, they do not break down (decompose) as fast as hardwoods, contain fewer phytotoxic chemicals than hardwoods, and they are located geographically around the world near horticultural production sites. Some conifer species studied in previous vegetable crop trials have included Pinus tadea, P. palustris, P. sylvestris, P. pinaster, Picea glauca, Picea abies, and Larix decidua.

**Fig. 3.** Wood fiber produced with twin-screw extrusion can be easily used (typically blended with peat moss) in loose-fill containers for vegetable production.

Previous research with wood fiber substrates has been conducted on many vegetable crops in containerized or hydroponic systems including cucumber, tomato, peppers, cabbage, melons, herbs, squash, strawberries, cane berries and blueberries. These vegetable/fruit trials have spanned the globe as researchers in the United States, Canada, Spain, Poland, England, Germany, Belgium, South Korea and Mexico (as well as others) have contributed to our current understanding of the potential in wood-based substrates for crop production. Research has investigated using 100 percent wood substrates for crop production (Fig. 2) as well as blends of wood components to peat moss, bark or coconut coir.

Wood substrates currently on the market (commercialized) are primarily made by one of three main processes: 1) single or twin screw extrusion; 2) twin disc refiners; or 3) hammer mills. Each machine type and process is unique, therefore the wood fiber produced is unique. The differences among the different materials include fiber size and thickness, sterility/chemical properties, and varying abilities to be compressed, handled and blended with other materials. Companies who sell wood substrates should be able to provide the technical assistance to utilize and manage their specific product in one’s own production system. The structure and properties of different engineered wood fibers may also facilitate better or more specific usage in different cropping systems, loose-filled containers or troughs compared to compressed blocks or slabs, for example (Figs. 3 and 4).

**Fig. 4.** A more fibrous and compressible wood fiber produced from a disc refining process may be suitable for pressed bales, blocks or sleeves for hydroponic crop production systems.
Photo: Brian E. Jackson

When considering the switch to organic substrates or the switch to wood fiber in your production system, there are many variables to consider. As more intensive research is conducted, our understanding of how wood may be an option for you will become more certain. As of now, some potential advantages of wood substrate materials may include 1) organic in nature and OMRI (Organic Materials Review Institute) listed; 2) locally available to substrate manufacturers and growers, which could limit or lower transportation costs; 3) recyclable; 4) and disposable. Much remains to be learned about using wood components in our production systems, but the perceived advantages and potential are believed by many to be well worth their investigation and consideration.

Brian is an associate professor and director of the Horticultural Substrates Laboratory at NC State University. He can be reached at Brian_Jackson@ncsu.edu. More information about wood substrates can be viewed here

Q&A: Meet the original Produce Mom

Departments - Consumer Corner

Lori Taylor turned a side project into a full-time career and passion centered around fresh fruits and vegetables.

March 1, 2018
Chris Manning

Originally, The Produce Mom was Lori Taylor’s pet project at the Indianapolis Fruit Company. In her marketing position, Taylor developed the digital brand to help her then-employer improve its produce branding and play up produce’s importance in a healthy diet.

“There was not a comprehensive resource for consumers or produce industry professionals to learn about all of the different [options] in the produce department,” she says. “And I’m a mom in my real life. I wanted to learn more about the produce department, and I was hungry for a solution.”

Three years ago, however, the vision she saw for The Produce Mom became more than what the Indianapolis Fruit Company envisioned. So, Taylor bought the brand from the company and struck out on her own, eventually renaming it The Produce Moms. Below, she answers questions about the company’s evolution, its mission and the #ProduceChallenge.

Produce Grower: Why did you change the name from The Produce Mom to The Produce Moms?

Lori Taylor: It was inspired by Mark Zuckerberg’s recent mission statement update at Facebook. Facebook changed its mission statement to put an emphasis on communities to build a better world. And when I read that, I thought, ‘We are in a position where we built a community and it’s united under the passion of fresh fruits and vegetables. We are also excited about introducing our two [new] produce moms. One is Candice, who has been recognized as one of America’s top African-American food bloggers. We are also bringing in Tara, who is a fitness instructor and dietician. They represent what I am not.

PG: How have The Produce Moms been able to challenge common misconceptions about fresh produce?

LT: We did a $10 produce [buying] challenge to show people the affordability of produce with Kroger. We made it a game. I had to buy one fruit, one vegetable and one organic item [with $10] and, as the series went on, we were able to take it a step further and include one locally grown item. It was a three-month long series on Facebook Live and that series drove the point home.

PG: Back when you were still The Produce Mom, the brand was known for the produce challenge, a monthly calendar that challenges people to eat a different produce item each day. What was the inspiration behind it?

LT: Approximately four years ago, we started the produce challenge, and it was inspired by my Facebook friends sharing things like the squat challenge, the plank challenge or the sit-up challenge. It was very much inspired by the fitness industry and things fitness industry influencers were doing to have people do one specific action. Each challenge came with positive messaging, too — stuff like ‘start a new healthy habit today.’ I participated in them myself, saw them rise in popularity and on social media and thought, ‘Wow, we need that in produce. We should be encouraging people to try all of the varieties in the produce section.’

For more information, visit theproducemom.com

This interview was edited for style and clarity.

Keeping up with the cold chain

Features - Equipment & Technology

New methods for removing heat from produce and packaging is extending the shelf life of fresh greens and other produce.

March 1, 2018
Neil Moran

Growing the highest-quality product is the first order of business in any greenhouse food production facility. However, what happens during the postharvest cold chain period is what will ensure the product will end up on the dinner table as fresh as the day it was picked. New methods for removing heat from produce and packaging is extending the shelf life of fresh greens and other produce.

Leading the way at lef Farms

lef Farms, a company that opened in 2016 in Loudon, N.H., is supplying fresh, hydroponically grown greens to an increasingly larger base of customers in New England. It is owned by Pleasant View Gardens, a company that has been selling ornamental plants for about 40 years. The company’s president and CEO, Henry Huntington, had been looking for a way to diversify when he went into the produce-growing business, says Bob LaDue, VP and COO, a former greenhouse consultant and Cornell-educated horticulturist. Instead of using existing facilities at Pleasant View, they constructed a 75,000-square-foot standalone growing facility with a cooler big enough to handle any future plans of expansion.

Now, lef Farms has found a way to approximately double the shelf life of its lettuce, Pak choi and other greens. This is allowing the company to expand its market to all of the New England states and New York, according to Donald “DJ” Grandmaison, sales and marketing manager at lef Farms.

LaDue and Huntington have examined the cold chain methods growers have used over the years. They have helped lef Farms come up with some innovations in chilling and packaging that LaDue says are “game-changer[s].”

“A lot of what I was seeing was people harvesting these products either in a greenhouse or head house at the temperature they were growing,” LaDue says. “Then [they were] putting it in a plastic bag or clam shell — some type of container — and then putting those in a box, sealing the box up, palletizing them, wrapping them up in shrink wrap and putting it in the cooler to cool off.” The product would then end up in a cooler waiting for pickup; the insulation in the packaging would do an effective, but unfortunately counterintuitive, job of trapping warm air inside the packaging.

“Some of my work at Cornell was to put temperature-recording devices inside the packaging, then pack them in the core of the pallet and put them in the cooler,” says LaDue, who managed a greenhouse growing operation at the university for 13 years. “We found out it could take several days for the products in the middle of the pallet to get cooled to the proper temperature. Meanwhile, you’ve lost a lot of shelf-life potential.”

LaDue says when the greens are cut in the dark, they still go through the process of respiration, consuming oxygen and releasing carbon dioxide. This normal cycle is what leads to eventual spoilage. This process can be slowed down by keeping the temperature cool around the product while still allowing respiration to take place.

“We want to keep that environment around the leaves balanced to a normal oxygen/carbon dioxide ratio,” LaDue says. “We looked at a lot of different options. Instead of packaging in the head house, we would conveyor the raw product into the cooler, cut it, mix it, weigh it, bag it and palletize it; it was quite different from anything that was being done anywhere worldwide.”

The company also looked at every aspect of the way the product was being packaged before it shipped. He said they worked with a packager to come up with a laser-perforated packaging that allows for this normal exchange of gases. They also box up the greens in boxes that are more open than traditional boxes. And instead of securing all of the boxes on the pallet with a thick shrink wrap, they use a thinner wrap that he says “spider webs” around the boxes, keeping them from falling off the pallet, but also allows for necessary air flow.

LaDue says the product takes about five minutes from the time it is cut until it is bagged and ready to ship. It is then moved on pallets into a sealed chamber and onto a truck, thus avoiding shocking the product.

“We’ve really gone a long way towards quickly and effectively getting rid of the heat from the crop, and it’s working really well,” he says. (Editor's note: Read more about the operation here)

Keeping it fresh at NatureFresh

NatureFresh Farms, purveyors of greenhouse bell peppers, cucumbers and tomatoes, has also made a sizable investment in a heat-reducing storage facility, in addition to technology to provide computerized labor management. These investments allow the company to manage both labor and cooling.

Founded in 1999, NatureFresh is a well-known grower in the industry who supplies fresh produce to all of Canada and as far south as Florida and Texas as well as the Central and Eastern U.S. Each year, they trial over 300 varieties of vegetables, selecting the ones they feel have the best flavor and shipping quality.

“All our commodities are consolidated within our new modern distribution center we officially opened in August 2017,” says Ray Wowryk, director of business development at NatureFresh, based in Leamington, Ontario, Canada. He says that the facility is equipped with advanced high-efficiency pre-coolers that remove heat prior to packaging or market distribution.

“Precooling is key to maximize shelf life,” Wowryk says. “Providing ideal storage commodity-specific temperature and humidity is key also.”

The company utilizes technology to monitor the state-of-the-art packaging and storage facilities they invested in.

“Adding modern equipment and updating packaging machines along the application and robotics improved overall efficiency and handling,” Wowryk says.

Monitoring of the product and surrounding environment doesn’t end when it leaves the distribution center. “There are a number of temperature monitors used for recording temperature during transportation,” Wowryk says. “Most retailers request specific brands supported by their food safety program. All provide the key data required to identify any breaks in the cold chain.”

Neil Moran is a horticulturist and freelance writer and copywriter for the green industry. greenindustrywriter.com

Follow the Rule

Features - Food Safety

The Produce Safety Rule is in effect — here’s what it means for growers.

March 1, 2018
Lisa Jo Lupo

With the Produce Safety Rule of the Food Safety Modernization Act (FSMA) now in effect for many produce growers, the last few months have seen a number of updates and communications from the U.S. Food & Drug Administration (FDA). The following is an overview of some of the most significant ones and what they mean to growers.

Readiness reviews

As of Jan. 26, the first general compliance date of the Produce Safety Rule (PSR) took effect — are you ready? If not, take heart. Not only do small and very small establishments still have a year or two (respectively) to comply, but the FDA is giving all produce growers a bit of a reprieve — committing to a program to “educate before and while we regulate,” as it has done with other rules of FSMA.

This means that the FDA will not begin PSR inspections until 2019, instead conducting On-Farm Readiness Reviews. This enables growers to have their operations and practices assessed for compliance and take corrective action before being held to regulatory action of non-compliance. With the rule establishing enforceable safety standards for the production and harvesting of produce for the first time, the FDA recognizes that growers have not previously been subject to such oversight. This does not mean that growers won’t be expected to meet produce safety requirements, but the FDA will use the extended compliance time to provide training and develop guidance development and outreach.

In September 2017, the FDA also proposed a rule that would extend the compliance dates for the agricultural water requirements by two to four years for produce other than sprouts. The extension was proposed to allow time for the FDA to review and revise the standards to increase the feasibility and practicability for farmers, while still ensuring public health.

State partnerships

Not only does the rule bring new federal standards to growers, it extends FDA’s regulatory responsibility in a new direction. That is, prior to FSMA, FDA was not responsible for the inspection of farms, including the 8,750 greenhouse vegetable and 673 greenhouse fruit and berry growers (according to the latest USDA Census of Agriculture in 2012). This fact, along with other FSMA-increased inspection responsibility for domestic and foreign food facilities, means stretching the already resource-limited agency beyond its limits.

To alleviate this resource shortage, the FDA has partnered with the states in various ways to incorporate their on-farm expertise. A first collaboration was developed soon after the issuance of the PSR final rule in 2015: the Produce Safety Network. This network of produce safety experts, located throughout the country and coordinated by the FDA, was created to enable focus on the diversity of state and regional growing practices while ensuring consistency where appropriate.

The FDA also has been working with the National Association of State Departments of Agriculture (NASDA). Not only is NASDA helping plan and carry out implementation of the rule, but growers can expect to see state representatives with or instead of FDA investigators on the readiness reviews and inspections.

“FDA has long held that state partnerships are necessary to help the food industry understand and achieve the new requirements of FSMA, particularly for the Produce Safety Rule,” said David Acheson, president of The Acheson Group and former FDA associate commissioner of foods. “This is primarily because the states have a long history of successfully working with their farming communities,” he said.

Grower assistance

While the FDA’s inspection reprieve and state partnerships are assisting in the general roll-out of the new requirements, growers are likely to also have very specific and individual questions and needs. It was for just such questions that the FDA introduced the Technical Assistance Network (TAN), an online resource for inquiries related to the FSMA rules, programs and implementation strategies.

Along with a link through which questions can be asked, the TAN website includes answers to common questions submitted through the network and FDA-developed FAQ pages. Both are grouped by topic. The questions submitted to TAN are answered by FDA information specialists or subject matter experts, “based on the complexity of the question,” the site states. While the agency commits to responding to inquiries as soon as possible, it also states that “response times may vary, due to complexity of question and the volume of inquiries we receive.”

According to data in the TAN Inquiries Report, only about 10 percent (734) of the 7,280 submitted questions through November 2017 related to the PSR. Additionally, as of January 2018, the common questions/popular topics page does not yet include a PSR section. We would, however, expect PSR-related questions in the TAN to increase as growers continue to work toward full compliance of this rule.

There is, in fact, a post on a Michigan State University Extension (MSUE) webpage which discusses a TAN response to a question regarding the PSR exemption for growers who sell more than half their gross sales to a qualified end user. While the rule defines a qualified end user as the consumer of a local food, restaurant, or retail establishment, the discussion states that it was unclear whether a food hub would be considered a qualified end user and if so, under what conditions.

“We now definitely know some food hubs do not count as qualified end users under the FSMA Produce Safety Rule,” the MSUE post says, stating that the TAN response “indicated that food hubs with a farm-to-business model are unlikely to meet the definition of qualified end user, while those with a farm-to-consumer business model may meet the definition.” Excerpting from the TAN response, it adds, “Sales to the food hub would only be sales to a ‘qualified end-user’ if the food hub fits the definition of a retail food establishment or a restaurant, and meets the location requirements.”

The FDA also is continuing to provide PSR assistance through guidance documents, with the most recent being those focused on Small Entity Compliance; Considerations for Determining Whether a Measure Provides the Same Level of Public Health Protection as the Corresponding Preventive Controls Requirement; and FDA Enforcement Discretion for some aspects of certain rules, including the PSR. In late January, the agency also updated its PSR webpage with current information on the rule’s requirements, compliance dates, training, technical assistance, and other resources.

For more information, see the FDA’s communication on:

On-Farm Readiness Reviews

State Partnerships bit.ly/2GdMt2h; bit.ly/2nc0cP4

TAN