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Looking at the 36-page USDA Good Agricultural Practices Audit Verification Checklist, you’re sure to experience some trepidation. Flipping through the pages, you’ll see that to receive basic U.S. food-safety GAP certification, your farm will be scored on restroom facilities, first-aid policies, irrigation-water testing protocols, condition of harvesting equipment, pest-control programs … and the list goes on.
Whether or not you’re are aiming for GAP certification—a requirement usually driven by wholesale purchasers—the guidelines set forth for the audit are largely common-sense food-safety measures that farms of all sizes should implement anyway. Getting the certification simply ensures you and your customers that these guidelines are actually followed.
To minimize your intimidation of the process, follow this basic outline to prepare for and survive a GAP audit.
Step 1: Create a Farm Food-safety Plan
Creating a food-safety plan for your farm is the first step toward GAP certification. The GAP audit follows the Food and Drug Administration’s “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables.” It’s not light reading, but it outlines the thinking behind standard food-safety requirements and can help you better understand the need for a food-safety plan.
Information is available online and through your local cooperative extension office to get you on a path to creating a food-safety plan. Industry consultants and fellow farmers are excellent resources, as well.
“I think it’s always a good idea to get somebody else onto your farm to take a critical look at your operation—and not just for food safety,” says Chris Blanchard, owner of Rock Spring Farm in Decorah, Iowa, who frequently hosts food-safety workshops through his farm-consulting business Flying Rutabaga Works. “Farmers who are extremely busy and on a short timeline might really benefit from working with a consultant.”
Step 2: Request a GAP Audit
With plan in place, fill out a USDA Request for Audit Services form, and submit it to the GAP auditing organization closest to your farm.
“Auditor location in proximity to the farm is a critical factor to take into consideration, especially when cost includes the auditor’s time to travel to the farm,” says Gretchen Wall, Produce Safety Alliance coordinator at Cornell University. PSA is a collaboration between Cornell University, FDA and USDA that helps farmers understand and implement food-safety practices.
According to United Fresh, a trade association for businesses that work with fresh produce, USDA GAP auditors’ time is billed at $92 per hour per auditor, including travel time.
“USDA has been great about scheduling audits for multiple growers in one area or visiting when they are on farms for other reasons to cut down on costs,” Wall says.
Step 3: Perform a Self-audit
Once your audit request is submitted, you should hear back from the agency within 48 hours. Ask for a copy of the agency’s GAP audit paperwork to guide you through preparation for your audit inspection.
“Self-audits are a great way to prepare for a real audit,” Wall says. “Farmers can ensure they are able to meet the requirements before the auditor visits the farm. This helps save time and money for both parties; there should be no surprises if you complete a self-audit before the auditor arrives.”
Don’t cut yourself any slack when walking through the audit paperwork.
“Answer the questions honestly. And make sure your bathrooms are clean—that’s the first place your inspector will visit,” Blanchard adds.
Step 4: Be Open and Flexible During the Audit
On the day of the inspection, each inspector has his own way of doing things—within the parameters of the GAP program, of course—so it’s difficult to say how long you should expect an audit to last. The timeframe will also depend on the size and complexity of your operation. (Blanchard’s GAP audit took four hours.) You want to have your food-safety manager present (this might be you), and if you have employees, make them available to speak with the auditor, too. Have your food-safety plan and records ready, and be able to explain your record-keeping system.
The auditor will run through the GAP checklist, assigning each question a point value—a maximum of 5 to 15 points, depending on the weight of the question—and making notes. United Fresh outlines several conditions that result in an automatic “unsatisfactory” rating, including an immediate food-safety risk, rodents or excessive pests, employee practices jeopardizing produce safety, falsification or lack of records, and not having someone responsible for a food-safety program.
The auditor can explain GAP audit procedures and answer questions about the reasoning behind requirements, but he is not allowed to give advice or offer consultation on improvements.
Step 5: Wait for Results, and Reapply if Necessary
After the auditor completes his report, it is reviewed by an auditing supervisor, and you will be notified if you passed or were delinquent in certain areas. There is no GAP penalty for not passing the inspection; you simply try again after you’ve corrected the things the auditor found to be insufficient. Although, Blanchard points out, failing an audit can be a problem if you’re selling to a vendor who requires GAP certification.
The GAP certification process is a big undertaking, but it can have financial returns for your farm by opening up new markets that require this food-safety benchmark. Use the resources available to you to help in your preparation. Online resources, such as Family Farmed’s On-Farm Food Safety Project and Get GAP Certified, as well as your peers, can aid you in developing a plan that will improve food safety for your customers and your own family.
About the Author: Freelance writer Lisa Munniksma is concerned about food safety from a farmer’s and a consumer’s point of view. Follow her as she learns about sustainable living, agriculture and food systems around the world at www.freelancefarmerchick.com.
