1. GAP/Food Safety for Fruit and Vegetable Growers
Wythe Morris
Commercial Horticulture/ GAP/ Food Safety
Virginia Cooperative Extension

2. Good Agricultural Practices
What is GAP?
Good Agricultural Practices
The agricultural/ food industry adopted this acronym to represent those methods and practices considered safe and appropriate to food operations from farm to table.

3. Have you answered your questions yet?

4. Farming Operations- large or small- are no different from any other business. You must have a business plan in place.

5. What are you growing?

6. How much do you grow?

7. How do you harvest?

8. Do you have needed equipment for your crop?

9. What is your market?

10. Commercial Production?
Direct Markets?

11. And the difference is…
Direct Markets- those markets where product moves from the farm directly to the consumer. Example, Farmers Markets, Farm Roadside Stands, Pick Your Own, Consumer Supported Agriculture (CSA’s) and now restaurants and retail food establishments under new FDA Directive.
Commercial Production- those markets where product (mainly in larger quantities) moves through intermediate steps such as harvest, packing, transportation and distribution before it gets to the consumer.

12. Just like your farm business plan, every farm food safety plan is unique and customized to fit your particular farm setup.

13. Food Safety Modernization Act Tester Hagan Amendment S.510
FSMA
Food Safety Modernization Act
December 21, 2010
Plus
Tester Hagan Amendment S.510
“The new program will take several years to roll out; even longer to become fully effective.”

14. 4/15/2017
GAP Certification
Continues to be voluntary until FDA directive (issued 1/4/2013) becomes final later this year.
Comment period goes until May 16, 2013.
Developed by Wythe Morris, Virginia Cooperative Extension

15. 4/15/2017
GAP Certification
Continues to be industry driven although the law is on the books and required compliance is presently being addressed.
Developed by Wythe Morris, Virginia Cooperative Extension

16. Depending on your farm setup…
You will need to be…
GAP Trained or
GAP Compliant or
GAP Certified
Each step will build on the previous step.
This can and will change as your
farm business plan changes.

17. GAP Trained The Participant:
1. Has a working knowledge of Good Agricultural Practices
2. Has identified known hazards related to their farm operation
3. Has developed a “plan of action” to address and monitor food safety related hazards on their farm

18. GAP Compliant The Participant:
1. Has implemented the plan of action that they have written and designed for their farm/business operation
2. Is keeping and continues to keep records and documents as required

19. GAP Certified The Participant:
1. Has requested an audit from a “Third Party” auditing agency and passed the audit

20. Wholesale Growers, Packers, Distributors
GAP Trained
GAP Compliant
GAP Certified
Growers
YES
Packers
Transportation
Distribution
Processing
Remains voluntary and industry driven at this time.

21. * Must pre-qualify under Tester-Hagan Amendment
Direct Marketers
GAP Trained
GAP Compliant
GAP Certified
Farmers Markets
YES
NO*
Farm Based Roadside Stands
Pick Your Own
Community Supported Agriculture
* Must pre-qualify under Tester-Hagan Amendment

22. FSMA Proposed Rule for Produce: Compliance Dates
Average annual value of food sales *
Product Grown for
Target Consumer
GAP Certification Requirement
Time to Comply with Audit **
Time to Comply with Water Requirements **
Smallest Farms
Less than $25,000
Direct Markets
Direct Retail Markets
Exempt ***
XXX
Wholesale
Intermediary Buyers
YES
4 years
6 years
Very Small Businesses
Less than $250,000
Subject to Tester Hagan Amendment
Partially Exempt ***
Small Businesses
Less than $500,00
3 years
5 years
All other Businesses
Over $500,000
Consumer end users
2 years
* based on average of previous three years
** from date of Final Rule published in Federal Register
*** Direct marketers are still required to have training and comply with GAPs

23. Tester-Hagan Amendment (S.510)
Direct Markets- sales directly from farm to consumer without going through a third party buyer.
Limited retail and direct markets
DM sources must account for greater than 50% of a farm’s sales
Sales are conducted within the state or
No greater than 275 mile radius of the home farm.
Farm produces less than $500,000 of product over the combined previous three years (Must be documented and verified).
Required to prominently and conspicuously display, at the point of purchase, the name and business address of farm or facility where the food was manufactured (produced).

24. Tester-Hagan Amendment, ctd.
Requires documentation that demonstrates that the owner, operator, or agent in charge of the facility:
Has identified potential hazards associated with the food being produced
Is implementing preventive controls to address the hazards
Is monitoring the preventive controls to ensure that such controls are effective

25. Tester-Hagan Amendment, ctd.
CSA’s, Farmers Markets, Roadside Stands, PYO are all considered retail food establishments under S.510 and regulated by state and local agencies i.e. licensed by locality and state health departments. S.510 “NO PREEMPTION-Compliance with this subsection shall not relieve any person from liability at common law or under State statutory law.”

26. Developing Your Plan of Action
A Plan of Action Manual
Helps to ID Hazards
Helps to ID Preventive Controls
Helps to set up Monitoring
Organized system recognized by auditors or other personnel
Can move into full certification if needed

27. Potential Hazards? Sanitation Issues Workers Produce Drinking water
Sanitary facilities
Hand washing
Training
Illnesses
Accidents and First Aid
Produce
Manure management
Harvest containers and equipment
Washing/ sanitation

28. Are the same items required for all farms?
Because the same audit questions are asked of all farms, the questions are the same but, the answers are customized to fit your farm situation as described in your Farm Food Safety Plan of Action Manual.
The method that one farmer may use to comply with a question may be different than another farmer.
Both may still be correct responses and both will receive credit for the question.

29. Examples… Which is correct?

30. Potential Hazards? Irrigation Types Water Quality Drip Overhead
Flooded rows
Water Quality
Municipal sources
Wells
Springs
Open
Sealed
Open sources
Ponds
Streams
Reservoir

31. Potential Hazards? Livestock Management Wildlife Management Location
Fencing
Access to irrigation water sources
Wildlife Management
Damages
Controls
Monitoring

32. Potential Hazards? Soils Manure/Compost Management Historical
Septic systems
Flooding
Manure/Compost Management
Storage
Buffer zones
Composting procedures
Time factors (120 day rule)

33. Preventive Controls? Good Agricultural Practices Drip irrigation
Chemical application and fertigation
Crop and field rotations
Field assessments
Equipment Maintenance
Private pesticide license

34. Preventive Controls? Reducing or preventing contamination
Water testing
Research
Self assessment of our farm
Previous land use
Aerial photos
Standard Operating Procedures
Harvesting and Packaging

35. Monitoring? Traceability System Plant Protection Records One step back
One step forward
Assigning lot numbers
Plant Protection Records

36. Top 15 Actions To Address GAP/ Food Safety
NRV Field Day- Kentland
8/17/2010
Developing Your GAP/ Food Safety Plan of Action Manual
Top 15 Actions To Address GAP/ Food Safety
1- Document
2- Document
3- Document
4- Document
5- Document
6- Document
7- Document
8- Document
9- Document
10-Document
11-Document
12-Document
13-Document
14-Document
15- If it is not written down, it did not happen.
Developed by Wythe Morris, Virginia Cooperative Extension 36

37. Direct Marketers… Final Notes for Direct Marketers…
Participate in training
Develop your farm plan
Work your plan and document
Stay tuned…

38. What if I decide to expand and sell produce in wholesale quantities?

39. Advice to Growers
Know what your buyers and packers require in the way of GAP Certification.
Find this information out before you grow your crop.
Don’t wait until the last minute. If you know you need to be GAP Certified… the process takes reasonable time and effort. Plan ahead!!!

40. NRV Field Day- Kentland
8/17/2010
Questions?
Wythe Morris, ANR Agent Commercial Horticulture/ GAP/ Food Safety Virginia Cooperative Extension
Developed by Wythe Morris, Virginia Cooperative Extension