GAPs: Purpose, Requirements, Implementation and Certification Process Juan Anciso, Ph.D., Associate Professor and Extension Vegetable Specialist Texas AgriLife Extension Service

What does GAPs mean? GAPs is an acronym for Good Agricultural Practices

Good Agricultural Practices or GAPs are basic environmental, health and sanitary practices that aid in the production of safe fruits and vegetables. Purpose

GAPs Facts Prevention is Key! 100% control of microorganisms is impossible Strategy is to reduce the risk System of accountability Most of the practices are common sense Main change will be Farm Safety Plan/Manual and record keeping

Recent Issues 2011, Listeria monocytogenes on cantaloupe -- unknown, facility with environmental samples 2008, Salmonella St. Paul on Peppers -- contaminated irrigation water 2006, E. coli 0157:H7 on Spinach -- spinach crop contaminated by wild hogs or cattle feces

Why do we need GAPs? Every year, about 76 million cases of foodborne illnesses result in an estimated: 325,000 hospitalizations 3,000 needless deaths Economic losses between $10-83 billion

Why do we need GAPs in produce? According to the FDA, from 1996 to 2007 there were 72 reported outbreaks of foodborne illness associated with 20 fresh produce commodities. 5 Commodities = 76% Of Outbreaks from 1998 to 2008 All Lettuce26% Tomato19% Cantaloupe16% Herbs (parsley)11% Green Onions4% Note: The above table may not account for all outbreaks from 1998 to Total of 72 outbreaks were reported.

Are GAPs required by law? Not mandatory by law today Will become legally binding once FDA comes out with a rule since the Food Safety Modernization Act. Exemption of selling at least 50% through direct marketing and making less than $500,000 Mandatory by most large retailers

Requirements Have a Food Safety Plan/Manual Have a Designated Food Safety Person Standard Operating Procedures in place Employee Trainings on Hygiene once a year Documents Records (logs) Microbial Water Testing 3 rd Party Audit

Implementation (easy) Develop a Food Safety Plan/Manual. -- we can develop one for you -- or go online and develop one yourself ( Designate a person in charge of Food Safety -- either yourself or someone -- display the Name and Phone number.

Implementation (hard) Most of these things are probably already being done but not written. The main part of implementation will be keeping logs and records of everything you do for food safety. In addition to having routine trainings with employees to keep them up to date. Passing the 3 rd Party GAPs certification audit.

Certification/Audit Process Before you attempt a 3 rd party audit: Go through a training (online – agrilifefoodsafety.tamu.edu $40) Go through a check list to make sure all necessary processes are in place and all required documentation is available Have at least 3 months of records Will want to come during production time

Third Party GAPs Auditors USDA NSF-Davis Fresh Primus SQF – Safe Quality Food Institute Food Safety Net Services SCS – Scientific Certification Systems

Third Party GAPs Audit Success Do not need a perfect score to pass the audit. Passing the audit is good for one year standing. Texas Department of Agriculture has a program for those successfully passing the audit and attending an approved TDA training the applicants can get upto $750 reimbursement.

Food Safety Modernization Act ‘‘SEC STANDARDS FOR PRODUCE SAFETY. ‘‘(a) PROPOSED RULEMAKING.‘‘(1) IN GENERAL.— ‘‘(A) RULEMAKING.—Not later than 1 year after the date of enactment of the FDA Food Safety Modernization Act, ……..shall publish a notice of proposed rulemaking to establish science-based minimum standards for the safe production and harvesting of those types of fruits and vegetables, …….that are raw agricultural commodities for which the Secretary has determined that such standards minimize the risk of serious adverse health consequences or death. ‘‘(B) include, with respect to growing, harvesting, sorting, packing, and storage operations, science-based minimum standards related to soil amendments, hygiene, packaging, temperature controls, animals in the growing area, and water;

Food Safety Modernization Act The amendment includes the following requirements for exemption: 1. Producers must have annual gross sales less than $500,000. This includes all subsidiaries and affiliates of a business. 2. Producers must sell more than half their products directly to consumers (including at farmers markets) or to local restaurants and retailers that in turn sell directly to consumers. 3. FDA has authority to withdraw an exemption from a farm or facility associated with a foodborne illness outbreak. 4. The distance from a facility or farm that is eligible to be a “qualified end-user” was reduced to 275 miles.

Texas Senate Bill 81 A BILL TO BE ENTITLED AN ACT relating to food safety. BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF TEXAS: SECTION 1. Section (a), Health and Safety Code, is amended to read as follows: (a) A person is not required to hold a license under this subchapter if the person is: (1) a person, firm, or corporation that only harvests, packages, or washes[, or ships] raw fruits or vegetables for shipment at the location of harvest;

Do You Need to be GAP Certified on your Produce Operation? Exemption of selling at least 50% through direct marketing and making less than $500,000 FDA comes out with the Rules – Probably audits will not be mandatory but Food Safety Plans will be. Education, Education, Education will probably be Mandatory.

Official Food Safety Plans Guidelines 8 Main Areas: Water Manure and Municipal Biosolids Worker Health and Hygiene Sanitary Facilities Field Sanitation Packing Facility Sanitation Transportation

Principle # 1 Prevention of microbial contamination of fresh produce is favored over reliance on corrective action once contamination has occurred. Don’t use a Band-Aid, prevent problems instead!!

Principle # 2 To minimize microbial food safety hazards in fresh produce, growers, packers, and shippers should start and use GAPs and GMPs in those areas that they have control over.

Principle #3 Fresh produce can become microbiologically contaminated at any point along the farm-to-table food chain. The major source of microbial contamination with fresh produce is associated with human or animal feces.

Principle #4 Whenever water comes in contact with produce, its quality dictates the potential for contamination. Minimize the potential for microbial contamination from water used with fresh produce.

Principle #5 Practices using animal manure or municipal bio-solid wastes should be managed closely to minimize the potential for microbial contamination of fresh produce.

Principle #6 Worker hygiene and sanitation practices during production, harvesting, sorting, packing, and transport play a critical role in minimizing the potential for microbial contamination of fresh produce.

Principle #7 Follow all applicable local, state, and federal laws and regulations Follow corresponding laws, regulations, or standards for operators outside the U.S. for agricultural practices

Principle #8 Traceback, recordkeeping, documentation Accountability at all levels (farm, packing, distribution center and transport operation is the key to a successful food safety program. Qualified personnel and effective monitoring ensures program functions correctly.

Major Points of GAPs Food Safety (common sense) Prevention ( animal and human fecal matter) Sanitation Worker hygiene KEEP RECORDS of worker training and GAPs practices employed Anything WATER comes into contact with can become contaminated

Water Concerns Water must be potable (<2 generic E. coli/100mls, drinking quality ) for all post-harvest uses: – Hygiene of workers – Washing produce – Transporting – Cooling – Processing Temperature Difference - Not greater than 10 degree F

Why Rinsing and Sanitizers do not clean produce or eliminate the risk of a microbial contamination? Clean Greens Study - Looked at microbiological quality of produce (arugula, cilantro, parsley, spinach, mustard greens, collards, dill, and cantaloupe) from field to loading on truck. Johnston et. al Journal of Food Protection 68: Various researchers looking at washing produce with 200 ppm chlorine Texas A&M study looking at various sanitizers

Water and Produce Sampling Scheme Field Crop Produce sample collected Water sample collected Wash Tank Rinse Packaging Distribution Produce manually removed from field bins Produce rinsed with water (Anti- microbial agent may be added) Produce packed into boxes and top-iced Conveyor belt

Parsley Total Aerobic Bacteria E. coli Total Coliforms Total Enterococcus

Cantaloupe Total Aerobic Bacteria E. coli Total Coliforms Total Enterococcus

Other Studies using 200 PPM Chlorine vs. Water Rinse CommodityPathogen Log reduction Water 200 ppm chlorine CilantroE. coli O157:H CantaloupeSalmonella CantaloupeE. coli O157:H CantaloupeSalmonella Brussels sprouts Listeria monocytogenes TomatoesSalmonella0.01.2

Texas A&M Spinach Study TreatmentLog Reduction E. Coli O157:H7Salmonella Water Wash0.7de Ozonated Water 30 min. 0.6cde1.0cde Chlorine dioxide gas 30 min. 0.7e0.3e Chlorine dioxide gas 1 hr. 0.7de0.6de Ozonated Water 15 min. 1.1c0.9c Calcium Hypochlorite 200ppm, free chlorine 1.0cde0.7cde Peroxyacetic Acid1.1cd0.8cd Lactic Acid2.7a2.3a

Take Home Message on Disinfectants and Washing 1.A reduction of 0.5 log to a 2 log of pathogens on produce surface. About a 50% to 99% reduction. A kill step is often defined as a 5 log reduction or % reduction. 2.Disinfection does have antimicrobial effects and are important to prevent the wash water to remain sanitized. 3.Prevention of a contamination event is the first line of defense rather than trying to clean-up or remove these pathogens with aqueous sanitizers.

Helpful Links GAPs information and for-sale items Family Farm food safety and GAPs Plans Texas GAPs online training cfm?id=797 Texas AgriLife Food Safety Website AgriLife Food Safety App Apple App Store Texas GAPs and GHPs Food Safety Training Curriculum Extension Publication B-6244 ($10) Resources and Events Produce Safety Meat Safety Poultry Safety Pathogens Hygiene and Handwashing > > > > > > AgriLife Food Safety