Clarification and Guidance Regarding Produce Safety Rule Letter and Questionnaire Sent to Winegrape Growers. 

Many California winegrape growers received a letter and questionnaire from the California Department of Agriculture (CDFA), dated Feb. 11, concerning forthcoming compliance activities related to the federal Produce Safety Rule (PSR).  The letter and questionnaire — which asks about growers’ annual average sales, produce safety training, a food safety plan and a food safety audit scheme – have caused confusion among winegrape growers since winegrapes used for processing into wine are exempt from the PSR.  CAWG worked with Congress to secure this exemption.

CAWG contacted a CDFA official responsible for promoting California growers’ compliance with the PSR to gain clarification on the issue.  As a result of that effort, CAWG believes growers who only grow winegrapes may elect to provide a more limited response to the questionnaire.

Growers of winegrape varieties that are grown, harvested and used solely for wine and receive commercial processing may choose to only provide their name, farm name, work phone, cell phone, email and a list of winegrape varieties produced.  CDFA advised CAWG that a winegrape grower may simply list on the questionnaire the winegrape varieties produced.

However, a winegrape grower who also grows other commodities covered under the PSR should fill out the questionnaire in full.  Generally, covered commodities would include those commodities that are consumed fresh or that fail to receive processing that reduces risks of illness from microbial hazards (i.e., bagged salads, fresh unpasteurized juice, etc.).  For more information on covered commodities visit CDFA’s Produce Safety Program website.

If you grow grapes that are recognized as having use as fresh table grapes or raisins, then you should fill out the questionnaire in full.  The winegrape exemption from the PSR only applies to grape varieties recognized as of a wine-type.  So, Thompson seedless, which has historically been used for multiple purposes, would not be an exempt wine-type variety under the PSR.

The congressional exemption secured by CAWG for winegrapes was included in the conference report for H.J. Res 31, which was signed into law by President Trump on Feb. 15.  That exemption reads as follows (underline added):

SEC. 758. None of the funds made available by this or any other Act may be used to enforce the final rule promulgated by the Food and Drug Administration entitled “Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption,” and published on November 27, 2015, with respect to the regulation of the production, distribution, sale, or receipt of grape varietals that are grown, harvested and used solely for wine and receive commercial processing that adequately reduces the presence of microorganisms of public health significance.

Published with permission by CAWG.

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