GAP, which stands for “Good Agricultural Practices,” is a farm certification program run by USDA. Many small farmers feel GAP is not accessible to them, either from a cost perspective or because USDA built the program with much larger farms in mind. Recently, USDA rolled out something called “GroupGAP,” which is supposed to be friendlier to smaller farms by allowing them to apply for GAP as a group. But, is it any better?
Our intern, Clare Healy, spent the whole summer doing research to find out. The bulk of her research went towards just understanding the cost of each, which took months of research and phone calls to sort out. Because there are so many factors that affect the cost, we have compiled her research into one easy to read and adjust graph. (Thanks to Nick Henry and Greg Epstein for handling the math part of this creation.)
Graph of GAP versus GroupGAP (click on the image below to view)
After that, Clare tracked down a few farms that got certified with GAP and some in GroupGAP. Below are two testimonials from each.
GAP (Individual): Blue Sky Farms, Litchfield Park, Arizona.
Farm background: Blue Sky Farms has been growing fruits and vegetables on their 35 acres for twenty years.
The representative from Blue Sky Farms (BSF) reported no challenges to GAP certification. Previous certification experience includes Organic certification; the farmers for Blue Sky are currently seeking dual certification under Hazard Analysis Critical Control Point (HACCP). BSF was reimbursed 75% of their auditing costs through the Arizona Department of Agriculture (ADA). The BSF representative recalls the auditing cost at roughly $1,000, with around $700 being reimbursed by the ADA. She added that certification definitely felt worth it, as food safety is a big concern, and she would recommend the process to other growers.
GroupGAP: Upper Peninsula Food Exchange GroupGAP Pilot, various locations in the Upper Peninsula, Michigan.
Group background: Farmers growing fruits and vegetables on six or fewer acres; average farming or personal gardening experience is 15 years; average total gross income of $6,000-10,000.
Challenges: Of the sixteen initial farms involved in the Upper Peninsula Food Exchange GroupGAP pilot, ten completed the program and subsequently became GroupGAP certified. Some farmers expressed apprehension and concern over the costs of GroupGAP for their small group if state or partnering organizational subsidies were to be removed. Farmers also expressed feeling overwhelmed by steps to certification and the amount of paperwork needed. According to the Upper Peninsula Food Exchange:
“Record keeping (a necessary daily activity to stay in compliance) was most noted as a significant challenge of GroupGAP; farmers noted the significant amount of time and effort needed for keeping records and updating them as well as customizing log books. Most found that the actual practices were in line with what they were already doing but necessitated some minor and in some cases time-consuming changes. The group also felt pressure to not let their fellow participant farmers down. While this was a worry, the group pressure also acted as an insurance method to keep each participating farm in daily compliance, adhering to food safety manual and QMS policy.”
Successes: All group members reported feeling at the forefront of preparedness in food safety protocol. Additionally, they felt more safe and supported in the group structure, and came to depend on one another.
For More Information
There is much more information readily available online regarding GroupGAP experiences; if you would like to contact an individually GAP certified farm for more information please see the database of GAP certified growers.
For more information, including a webinar of GroupGAP testimonials, visit the National Good Food Network.
The FDA’s revised Food Safety Modernization Act (FSMA) establishes “…science-based minimum standards for the safe growing, harvesting, packing, and holding fruits and vegetables grown for human consumption.”
While FSMA has meaningful implications for food safety regulations, it does not apply to every farm in the U.S. This document provides a brief overview of the produce categories covered by FSMA and the act’s exemptions. If you are more visually oriented, take a look at the super intuitive flow chart at the bottom of the page, which will tell you right away whether you have to abide by FSMA or not.
Both the flow chart and the information below were put together by our policy intern, Clare Healy.
The six produce-related categories of FSMA application are as follows:
- Agricultural Water: Water Quality and Testing. Certain water used with growing and harvesting must be tested for the average amount and variability of E coli. Testing requirements vary based on type of water used (i.e. ground water, surface water, municipal water).
- Biological Soil Amendments: Raw Manure and Stabilized Compost. There must be a 120 day interval between the application of raw manure to soil and crops that will contact that soil, and a 90 day interval for crops that will not contact the soil. Stabilized compost must be applied in a form that minimizes the risk of contact with crops before or after application.
- Sprouts: Irrigation water must be tested for certain pathogens, and pathogen tests must be negative before sprouts enter the marketplace. The growing, harvesting, packing and holding environment of sprouts must be tested for Listeria or Listeria monocytogenes.
- Domestic and Wild Animals: All farms must visually examine crops and fields/growing areas for contamination by animals. If significant contamination is found the area should be clearly marked, and crops may need to be forfeited.
- Worker Training and Health and Hygiene: Supervisors and farm workers handling produce and/or food-contact surfaces must be trained in proper hygiene practices, and implement hygienic practices, like hand and food-surface washing. Those who are ill or have a contagious infection should not have contact with farm’s produce or food-contact surfaces.
- Equipment, Tools and Buildings: There must be appropriate, secure, and clean storage of farm tools that come into contact with produce, as well as maintenance and cleanliness of other equipment.
FSMA Does not apply to:
- Fruits, vegetables, and grains that are not raw commodities, or that are rarely consumed raw. A complete list of “rarely consumed raw” foods can be found on pages 4-5 of Key Requirements: Final Rule on Produce Safety, cited at the end of this document.
- Produce consumed on-farm or as personal farm consumption.
- Farms that within the past three-year period from FSMA implementation have an average annual value of produce sold amounting to equal or less than $25,000.
In order to be eligible for qualified exemption, without meeting the exemptions above, a farm must meet the following two requirements:
- During the previous three-year period the farm’s average food sales must be less than $500,000; and
- During the previous three-year period the farm’s sales to “qualified end-users”—consumers and/or restaurant or retail food establishment located in the same state or Indian reservation as the farm, or no further than 275 miles away, must be greater than sales to all other markets combined.
For more information, including list of “Rarely Consumed Raw” crops, FSMA compliance dates, details on qualified exemptions, variances, and more, please see Key Requirements: Final Rule on Produce Safety.
We do the policy work we do for the sake of making change, but it’s also nice to get recognized every once in a while. For that reason, we were honored to learn that we were nominated for not one, but two “Common Ground” awards. Put together by the Metropolitan Pima Alliance, “Common Ground recognizes community leaders, projects and events with successful collaboration for the overall benefit of the community.”
The two projects were are being recognized for are:
- The advocacy we did around urban agriculture, which eventually led to the successful passing of an updated zoning code that is garden, farm, and urban ag-friendly.
- The advocacy we did around school gardening, which led to the State Health Department making their school garden guidelines more friendly towards the use of compost, rainwater, and other things.
After making the final round, we were asked to present to the selection committee, which we did last Thursday, July 28. To be nominated and get to present in the final round alone is an honor; hopefully one of our projects wins an award!
We spent much of the early part of 2016 doing advocacy on House Bill 2518 (see page 4, line 11), which sought to make school garden food automatically approved for use in the cafeteria. We’re happy to announce that the bill was passed, and signed by the governor! Thanks to those of you who responded to our calls (via facebook and e-blast) to call your representatives and ask for its passage.