2. Introduction to Food Safety for Wholesale Success
This unit provides an overview of food safety regulations for agricultural producers and food entrepreneurs.
How can food safety regulations help increase my economic success?
Prevent loss and waste due to improper cooling or storage
Reduce risk from foodborne illnesses and reduce liabilities
Provide access to wholesale markets, where buyers require food safety certifications
What will I learn from this course?
Different types of food safety regulations and how to determine what applies to you
How recordkeeping can increase your marketability
Where to find in-depth training, resources, and support

3. Lesson Outline Overview of food safety regulations
The Good Agricultural Practices (GAP) Voluntary Audit: USDA
Food Safety Modernization Act (FSMA): FDA
State Offices and Contacts
Economic Success
Wholesale Buyer Requirements
Recordkeeping & Profitability
Marketing Safe Products
More Wholesale Resources

4. Part I: Overview of Food Safety Regulations
The Good Agricultural Practices (GAP) Voluntary Audit: USDA
Food Safety Modernization Act (FSMA): FDA
State Offices and Contacts

5. Overview of food safety regulations
Some types of food safety regulations are voluntary.
Example: USDA Good Agricultural Practices (GAP) Certification
Program Details: GAP is a voluntary, preventive program to ensure that you are following accepted food safety protocols for harvesting, handling, washing, cooling, and packing fresh produce. It is not required by USDA, but may be required by your wholesale buyer or distributor.
USDA also maintains Good Handling Practices (GHP) programs for food handlers, GAP for mushrooms, and Harmonized GAP certification programs for some suppliers.
Other types of food safety regulations are required.
Example: Food Safety Modernization Act
Program Details: FSMA is the first update to the U.S. federal laws about food safety in nearly 70 years. FSMA will typically only affect businesses who meet particular revenue levels or sell to particular markets.
Generally, food safety regulations are enforced by the United States Department of Agriculture (USDA) or the Food & Drug Administration (FDA).

6. USDA GAP Certification Process
USDA Good Agricultural Practices (GAP) Voluntary Certification
Guidance that produce growers can use to prevent on-farm contamination of fruits and vegetables
Developed by the USDA in 1985
Voluntary, although more buyers are requiring GAP
Protect your farm business from the economic consequences of food contamination
GAP is focused on prevention of contamination rather than remediation.

7. Basic Principles of GAP
Prevent microbial contamination
Implementation of a Food Safety Program
Follow all applicable laws
Traceability/recordkeeping/documentation
4 W’s +S
Water, Waste, Workers and Wildlife
+ Surfaces

8. GAP Goals: Prevent Likely Sources of Contamination
Biological: Bacteria, Yeast, Molds
Physical: Stone, Glass, Metal, Surfaces
Chemical: Pesticides, Fungicides, Food Allergens
Where does contamination come from?
Water Sources
Unhealthy Employees
Harvest Tools
Dropped produce (bacteria)
Previous Land Use
Neighbor’s farming operations

9. Preparing For GAP Certification
1. Conduct an on-farm risk assessment.
Farm History / Land Use
Worker Health and Hygiene
Restroom and Sewage
Water Sources/Quality (microbial load)
Animals
Manures and Soil Amendments
Equipment and Containers
Product Traceability
OTHER POTENTIAL RISKS:
Harvesting Techniques/ Procedures
Washing and Packing Produce

10. Preparing For GAP Certification
2. Write your food safety plan.
Utilize the On-Farm Risk Assessment
Write Standard Operating Procedures based on current practices (making minimal changes to daily operations).
YOU determine the frequency that you feel you need to document certain risk mitigation strategies.
Do not over-commit – make a feasible plan you can reasonably manage with your current capacity.
Food Safety Plan Templates are available online.
NC Cooperative Extension’s Online Food Safety Plan Course:

11. Preparing For GAP Certification
3. Prepare for the audit: designate a Food Safety Officer.
Responsible person who will ensure compliance with the Food Safety Plan that you have written.
Must be present during the audit.
Can be a shared position amongst owners.
4. Prepare for the audit: gather supporting documentation.
Farm Maps (with field numbers)
Facility Map Overview (keep it simple)
Training Certificates
Water Test Results (within 60 days of audit)
Signage

12. Scheduling a GAP Audit 5. Submit application to Auditing Body.
In North Carolina, the NC Department of Agriculture & Consumer Services Cooperative Grading Service conducts GAP audits.
Provide multiple dates to the auditing body.
Timing is crucial in demonstrating multiple harvest techniques.
Requesting an audit six weeks in advance is recommended.
Cost: USDA mandates that all state auditors charge $92.00 per hour, including travel time. Canvass other farmers in your region who may be pursuing certification to apply for an audit on the same day. Some cost-share programs may also be available to assist you.
Make sure you are fully prepared for the audit – it will be much less expensive if you are able to meet all standards on the first audit visit!

13. Recordkeeping
It is not necessary to duplicate records (i.e., you may keep one set of records that meets both organic certification standards and GAP standards).
Field Map
Land History
Manure Application Records
Compost Monitoring Records
Cleaning Records (equipment, transportation)
Traceability Records

14. During the Audit: Automatic Failure
Falsification of Records
Failure to have a Food Safety Plan or Officer
High presence of rodents or pests
Failure to have water test on file
(Total Coliform & Generic E.coli – quantitative results)
Combining bleach with detergents
Potential wash water hazards (high risk crops)
Any immediate public health risk
Immediate public health risks may include (but are not limited to) raw manure, cows in irrigation water source, birds nesting in packing houses, employees with communicable diseases, and other risks.

15. Additional Resources, State Offices and Contacts
The NC Growing Together Project (NCGT), with partners NC Cooperative Extension (NCCE), NC State University (NC State), and the Carolina Farm Stewardship Association (CFSA), sponsors one- and two-day workshops across the state to assist farms in achieving GAP certification:
CFSA offers free one-on-one consultations:
For a comprehensive list of upcoming GAP training events, visit
NCGT’s Guide to Cost-Share Programs & GAP Assistance
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GAP Workshop Manual (NCGT & CFSA)
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USDA GAP&GHP Online Resources
Several resources are available for learning more about GAP and the voluntary USDA audit process.

16. Food Safety Modernization Act
The U.S. Food and Drug Administration (FDA) has published an update to the Food Safety Modernization Act (FSMA), which includes rules for various types of food producers.
Although the official federal guidance on these rules has not yet been released, some resources are available now for producers and food facilities who wish to determine whether they will be subject to the new guidelines.*
The law was signed on January 4, 2011, but has not been enforced yet. The federal government, through FDA, has been developing guidance on how to enforce the new regulations and who is subject to them.
The update to the existing food safety legislation is the first in more than 70 years, and shifts the focus of food safety enforcement away from responding to contamination and towards prevention efforts.
*As of September 1, 2017

17. Food Safety Modernization Act
Exemptions:
Farms selling less than $25,000 per year over a three-year average
If produce is not consumed raw
Those growing only for personal consumption
What counts as raw?

18. Food Safety Modernization Act
You may be covered fully or with modified requirements:
Some types of processing can kill pathogens, which may mean you are not subject to full requirements
Depending on whether you qualify as a small business and who your end users are, you may not be subject to full requirements
More info:

19. FSMA: Additional Resources, State Offices and Contacts
NCGT’s FSMA Resources & NSAC Flowchart
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NSAC Guidance on FSMA Impacts: Produce
content/uploads/2016/09/FSMA-PRODUCE-RULE-FINAL.pdf
NSAC Guidance on FSMA Impacts: Facilities
content/uploads/2016/09/FSMA-FACILITIES-FINAL-.pdf
FDA’s Page on FSMA
NC Cooperative Extension FSMA Guides, Area Agent Contacts, and Training Events:
FSMA: Additional Resources, State Offices and Contacts

20. Part II: Economic Success
Wholesale Buyer Requirements | Recordkeeping & Profitability
Marketing Safe Products | More Wholesale Resources

21. Wholesale Buyer Requirements
Wholesale produce buyers & institutional purchasing agents are enthusiastic about helping farmers understand postharvest needs.
They see value in:
Educating growers
Providing packing information
Extending shelf life
Often, buyers will attend training workshops and other events to help clarify needs for wholesale handling and packing, meet farmers, and assist in the education of growers interested in selling into wholesale markets.
Regardless of whether your farm sells wholesale or direct-to-consumer, postharvest handling methods can increase shelf life and provide valuable marketing tools for your farm!

22. Wholesale Buyer Requirements
Consumers are demanding local products, and wholesalers are trying to meet this demand by supporting small farms in the wholesale market.
Many small farms, however, represent a risk to the wholesale buyer or distributor.
If farms do not demonstrate safe handling practices, the buyer’s risk of loss, poor shelf life, or liability for foodborne diseases increased.
As a result, even though USDA does not require GAP certification, many buyers have their own requirements for their vendors.
Logistics
Shelf Life
Grading, Sorting, and Packing
Communication
Warehouse Space
Reduced Liability and Risk

23. Recordkeeping & Profitability
The recordkeeping for most food safety programs is not an undue burden. Most of these records are similar to those needed for a comprehensive business plan, a loan application, or applications for grants or cost-share programs to help with farm costs.
Consistent recordkeeping is one of the most important things a farm business can do. It’s tedious, but it provides invaluable information on losses, harvests, and trends, as well as a shield against liability that arises from problems with food safety along the supply chain.
Best of all, proper recordkeeping can help you identify risks and inefficiencies early, reducing overall costs, lowering insurance premiums, and preventing catastrophic contamination events.

24. Marketing Safe Products
Even in direct markets, safety is a priority for the consumer.
As more consumers become aware of the risks of food contamination, your safety practices become a marketing tool – even at the farmers’ market.
A premium product demands a premium price.
Buyers are willing to pay more for products that they know are safe.
Wholesale buyers are more likely to take you seriously – and negotiate with you seriously – if they know that you take food safety and liability seriously.

25. More Wholesale Resources
NCGT’s “For Producers” Resources (including vendor contacts, market channel selection, certifications and training, postharvest handling resources, wholesale pricing, and more)
Cornell University Extension Small Farms Program
NC Cooperative Extension
Center for Environmental Farming Systems
Dozens of resources are available to help producers who are prepared to move into wholesale markets, from state and national resources.

26. Next Steps https://www.ces.ncsu.edu/local-county-center/
Contact your local Extension agent first. They can help you navigate what food safety regulations apply to you and where to access the resources you need.