Craig Kawamura (Systems Consulting) - Comment

In the record keeping section, what is the specific record keeping requirements? For example, is non-editable time-stamping a required to prevent fraudulent documentation? What information are you looking for in the records. Will you come out with a checklist of all the food safety requirements, rather than a large, wordy document that is difficult for growers to follow, or disseminate? Consultants, such as our company, can help growers build a food safety plan. Many registrants already have a food safety plan in place. How will they know there food safety plan is in compliance? Is it required to have a food defense plan in place also? Who, where, and when do these plans need to be submitted?