Harmonized GAP Standards
Contact water includes water used for irrigation and should be potable.
Photos by Sally Colby.
Walsh, who has been involved in postharvest for close to 40 years, says that the 1990s brought a shift from using more chemicals in agriculture to using fewer. However, some of the changes in practices led to more contamination in fruit. “We had problems with organic apple juice that was contaminated with E. coli O157:H7,” he noted, “and raspberries that were contaminated with cyclospora, a human parasite, coming in from Guatemala.”
Audits are becoming more widely used to address these issues and to monitor food safety in all aspects of production.
“Everything that everyone does in food safety goes back to a document created by the U.S. Food and Drug Administration in 1998 – a guide to minimize foodborne illness contamination in fresh fruits and vegetables,” Walsh explained. “Everything we do ties back to that guide, including the words good agricultural practices (GAP).”
Walsh noted that over the past 14 years, numerous third-party auditing companies have been developed to determine whether products are up to certain standards. The top three private auditors include ., PrimusLabs and the Global Food Safety Initiative (GFSI). Government audit programs include the USDA-AMS and the new USDA Harmonized GAP audit.
The development of USDA harmonized standards is a direct response to audit fatigue – the result of larger growers having to go through multiple audits to meet standards. Walsh explained, “The USDA Harmonized audit is a system that puts all of the guidelines together. In the older audits there was a point system. What we learned from the Jensen Farms melon problem is that you could pass an audit and still have things that need to be corrected.”
One of the components of harmonization is moving away from a point system and toward corrective action. “If you’re being audited, you still have to have a passing grade for each section on the audit,” said Walsh, “but it’s based on passing a certain number of questions. For the question[s] that you don’t pass, there are corrective actions required or immediate action needed. For noncompliant areas, they’ll come back and make sure you correct and document it.”
The harmonized standards include two sections: production and harvest, and postharvest farmgate. They also require a mock recall and a plan to move toward GFSI certification.
Growers could fail the old USDA audit in several ways, but now the list includes nine specific infractions. Automatic failures on a harmonized audit include: falsification of records; no written food safety plan; no one to oversee the written plan; presence of an immediate food safety risk; presence or evidence of excessive pests (rodents, insects); and unsafe employee practices – all of which were failures on the old audit.
New infractions include: lack of traceability program in place; no demonstrated (mock) recall program; and not making required corrective action. Walsh said, “Corrective action required (CAR) means that you’ve passed the audit, but we see something that needs to be corrected. Immediate corrective action (ICR) means that the audit is not passable because something must be done immediately. The auditor will not tell you how to correct it; they’ll just tell you that it has to be corrected.”
New harmonized USDA standards include planning and implementing a mock recall.
Walsh says that one of the newest aspects of food safety inspection includes microbiological testing, specifically water testing. “The FDA says, ‘water should be appropriate for its intended use.’ There’s no more frustrating statement,” he said. Testing focuses on determining the presence of the non-environmental, generic form of E. coli that is in the intestinal flora of warm-blooded animals.
When it comes to water testing, Walsh said that it’s important to understand the definition of contact water, which is water that actually touches the crop. “Contact water might be what’s in the dump tank at the packinghouse, overhead irrigation for crops, or water that is mixed with pesticides. In general, contact water should be potable, or drinkable, water. That’s tricky, because in many cases you’re using surface water that isn’t potable,” he explained.
Water samples are easy to collect, but must be sent to the lab within 24 hours of collection. “E. coli will multiply in warm water,” said Walsh, “so your numbers may be worse if the sample remains at room temperature. Refrigeration won’t kill the bacteria; it will stop the bacteria at whatever the number was at collection.”
For water sampling, use a sterile 100-milliliter bottle to collect the sample, complete the label, refrigerate if there will be a delay in sending, and send as soon as possible.
To collect a well water sample, allow the water to run for about five minutes prior to collection. For a pond water sample, stir the water gently to mix the warm surface layer with the cooler lower layer, but don’t disturb the bottom mud. Always take care not to touch the inside of the container or the cap, which can contaminate the sample.
Wells should be tested once at the beginning of the year. Surface water should be tested three times: at planting (to determine baseline numbers), at peak use and at harvest. Farms that use city water can obtain current water records from the municipality.
The overall goal of improving GAP standards is to reduce audit fatigue so growers can concentrate on achieving food safety, rather than worrying about passing an audit. For more information on the program, visit www.ams.usda.gov/AMSv1.0/GAPGHPAuditVerificationProgram.
The author is a frequent contributor and freelance writer who farms and raises Great Pyrenees in south-central Pennsylvania. Comment or question? Visit www.farmingforumsite.com and join in the discussions.