Though it took Kim Butz just under six months to assemble a harmonized U.S. Department of Agriculture GAP food safety plan for her employer, once finished, it cost Red Earth CSA of Kempton, Pennsylvania, more than $30,000 in facility improvement costs to achieve compliance. – USDA’s GAP-GHP Program

The harmonized plan is the tougher of the two compliance standards within USDA’s GAP-GHP program. GAP-GHP stands for Good Agricultural Practices-Good Handling Practices and is a voluntary on-farm inspection program designed to assess and prevent food-borne contamination risks.

Butz told growers who attended a February Pennsylvania Association of Sustainable Agriculture-sponsored workshop on harmonized food safety plans one of the reasons why their community-supported ag (CSA) enterprise chose the harmonized option was because one of the farm’s wholesale clients told them they needed one in place by summer’s end to continue to do business. This is nothing new; many of the industry’s larger farmers undergo as many as 10 audits required by their customers.

The large majority of U.S. grocery stores require GAP-GHP audits to do business, said Beth Oleson, food safety director of Produce Food Safety Services in LaGrange, Georgia. Produce Food Safety Services is part of the Georgia Fruit and Vegetable Growers Association.

“Of the larger, more established grocery chains, I would say 100 percent are there,” Oleson said. “But once you start getting into the smaller, more regional grocery store chains, I would say 75 percent or more are requiring it.”

The practice has been ongoing since 1999, she said. Food retailers have been the major impetus behind demanding food safety audits from farmers (see sidebar). At face value, inspecting a farm to determine what steps its owners must take to reduce food-borne disease vectors can be beneficial.

But what about farms selling commodities to more than one wholesaler or grocery chain? What if all of their customers demanded they submit to separate independent audits? That’s exactly what is happening and has been since 1999.

Another reason Red Earth CSA chose the harmonized option was the compliance schedule released by the U.S. Food and Drug Administration for the Food Safety and Modernization Act (FSMA). The CSA must be FSMA audit-ready by Jan. 26, 2018.

A harmonized GAP-GHP food safety plan is virtually the same as compliance with FSMA. “FSMA was created using the GAP-GHP program as a model,” said Judy Martin, Pennsylvania Department of Agriculture Food Safety Division assistant director.

Passed by Congress in 2011, FSMA creates an on-farm/ in-plant reporting and inspection process aimed at reducing the incidence of food-borne illness. All farms covered by the law – large and small – must be in compliance by Jan. 26, 2024.

The Act applies to all farm commodities. However, there are exemptions based on such things as commodity consumption, marketing methods and annual sales.

For example, FSMA applies only to produce consumed raw, which provides potato growers not involved in processing an exemption. Dairy farmers who ship milk directly to processors are exempt; however, those who produce dairy products with their milk are not.

No non-exempt commodities will reach consumers without having passed through a “kill-step.” Kill-steps include canning, cooking or irradiation.

The Produce Safety Rule and the Preventive Controls Rule – another FSMA rule that applies to farming – brings very little new regulation to growers, said Oleson. “There were never any regulations about on-farm handling; there were just suggestions and guidelines. Now we have federal regulations and all of these things are based on GAP and GHP.”

Diving in

No stranger to federal regulation, Butz spent years working as a compliance officer for a liquid petroleum and natural gas firm. She also spent nearly 25 years in food service as a manager and chef and grew up on a small farm.

The Common Market’s end-of-summer deadline demanded immediate action. “I just dove into this,” she said. “There is a ton of information about how to navigate the GAP-GHP system on the internet.”

Her search took her to material developed by Penn State University. “It was easy to follow, used a lot of good examples and it had templates to help you figure out what information the FDA wants,” she said.

Red Earth’s food safety plan focuses on the pre- and post-harvest activities in four locations: its nursery, equipment shed, pack house and fields. Butz created lists of the necessary tasks, what had to be purchased, crew they needed to hire and what reports had to be written for GAP compliance.

Then, she assembled her work crews to get them on board with the project. “We had trainings, we talked, we shared ideas, we started a team,” Butz said. “After every project was completed, you could see the enthusiasm building and the sense of pride that everyone was starting to exhibit.”

Some old, some new

USDA wants its food safety plans to accurately depict a farm’s workflow from seed to shipment. In addition, growers must assess their farm’s contamination risks and devise solutions to pass a federally mandated, on-premise inspection.

The period spent bringing Red Earth to an audit-ready condition was, for the most part, spent eliminating clutter from the four operational centers.

The equipment shed was a study in accumulated disorder. “Wherever somebody walked into the equipment building with something, was where it landed,” Butz said, “and that’s where it stayed until somebody came in, picked it up and put it somewhere else.”

She and her crew swept in and installed shelves, put fresh stone down on the floor and laid pallets on top of the stone. “A lot of what happened in the equipment shed was making it food-safe,” she said.

For example, if a tractor out in a field blows a hydraulic line, it sprays hydraulic fluid all over the immediate area. “That’s all contaminated product now,” Butz said. “Not only are we going to lose the crop, but we’re also going to have an impact on the soil and on the water. So what could we do to minimize that?”

She switched the farm over to biodegradable, hydraulic fluid as well as food-safe lubes for all their equipment. It is a standard Red Earth applies to “anything that comes into contact with the food we ship,” she said.

They also hired a part-time mechanic whose job it is to maintain the farm’s vehicles and equipment to assure it does not cause or contribute to any kind of contamination.

Pack house rules

The crew scrubbed and sanitized walk-in refrigerators and food contact surfaces. They also installed a Dosatron system in the pack house for sanitization and built a new wash table. Then they began packing their CSA member boxes with plastic liners.

GAP-GHP requires a separate break structure for employees to wash hands and store their belongings. The CSA bought a shed with washing facilities, installed some used lockers, and added some picnic tables, a coffeemaker and a microwave oven.

“Our workers really like it,” said Butz. “They call it their cantina. We all eat lunch together in there.”

Some GAP requirements required them to hire contractors. The pack house needed a new concrete pad out front and all buildings needed drainage to channel water away from the structures. They also hired contractors to put up additional portable toilets and hand-washing stations, and for pest control and water testing.

Program execution

Although her work crews pushed forward on cleanup and construction, Butz was back in her office assembling the report.

The finished product fills a heavy-duty, three-ring notebook.

Everyone at Red Earth CSA undergoes food safety training. Butz said she uses flipcharts provided by Penn State. “New employees are trained on their first day of employment,” she said.

Each area has its own training program covering various aspects of produce production, harvest and processing. Workers are trained, not only on best management practices, but also on how to deal with contamination events.

In addition, each location has logs hanging on clipboards employees must fill out to record their activities. There are maintenance logs, well logs, food safety training logs, soil amendment application logs and sanitizer logs, to name a few.

The audit

With a complete report, training programs in place and running, and facilities improved, Red Earth CSA was ready for its audit. Butz submitted her request online on the Pennsylvania Department of Agriculture website.

“Your auditor will call ahead to set the audit up and go over the dates and times,” said Butz.

Their audit began with a plan review, which includes a review of all logs and documentation. The auditors walked the fields, reviewed the maps Butz prepared of the farm’s water system and inspected its nursery, greenhouse and high tunnels.

They questioned the field and pack house crews as well as the equipment and delivery truck drivers to assess work knowledge and their understanding of food safety practices. The inspectors evaluated restrooms and hand-washing facilities. There were also temperature checks in the walk-ins.

In the end, Pennsylvania Department of Agriculture inspectors noted only three issues Red Earth had to address: They needed a contractor log, a Porta-John log and to record the pest control technician’s and the pest control company’s license numbers.

“After the audit, the entire crew was ecstatic, celebratory and felt a major sense of accomplishment,” said Butz.

Too Many Audits

On the verge of the Food Safety and Modernization Act’s (FSMA) commencement, farm organizations are waging a familiar battle. Non-farm groups seek to increase the amount of regulation growers must comply with in order to bring their commodities to market.

Today, there are business interests pressuring the Food and Drug Administration to apply rules from a federal law that has yet to take effect. “One of the things we are battling right now is buyer organizations, both wholesale and retail, restaurant chains and brokerage firms are trying to push for FSMA compliance, ahead of its scheduled introduction,” said Beth Oleson, food safety director of the Georgia Fruit and Vegetable Growers Association’s Produce Food Safety Services.

Oleson and her two co-workers act as consultants to farmers nationwide who are either about to undergo an audit or have just finished one. They also run a number of training programs for farmers and plan to continue this activity once FSMA kicks off.

Non-farm interests demand audits at a time when FDA has yet to release its FSMA state enforcement officer training programs, much less its guidelines for enforcing the Act’s rules.

Some wholesalers or distributors send their own food safety inspectors to farms equipped with their audit checklist. Farmers who sell to multiple customers can be audited with one specific branded audit, all saying their particular branded audit is the prerequisite for a business relationship.

“If that business is worth it, then you implement that brand of an audit,” said Oleson.

Some retailers also send their own people to the farm to conduct a second-party audit. “A farmer who services several large customers may have to submit to three to five branded audits, plus three to five store audits, that’s the equivalent of 10 audits per year,” she noted.

“They are asking the same questions, they are looking at the same documents. The cost is exorbitant.”

Indeed, audits are not cheap. Pennsylvania Department of Agriculture Fruit/Vegetable- Ag Commodity Program Supervisor Brenda Sheaffer told growers at a recent on-farm workshop her agency will charge $92 an hour for FSMA audits, including travel time.

Faced with the same dilemma about six years ago, European countries created a set of audit standards called the Global Food Safety Initiative (GLFSI). The idea was to certify the best of the audits to reduce the number in the marketplace.

This benchmark’s usage spread to this country and is recognized as the highest audit standard. However, GLFSI-benchmarked audits go beyond food safety.

“It is still considered a food safety audit but it also looks at sustainability, pesticide usage, land preservation, business practices as well as employee welfare,” Oleson said.

None of those things are bad things, she said, but none of them are about food safety. “There has been a lot of audit-sprawl; audit creep has begun.”

FSMA will not end the practice of marketdriven audits; however, some farmers in some states will get some relief. Pennsylvania, for example, will offer its growers up to a $400 cost-share for FSMA audits.

Pennsylvania Department of Agriculture inspectors made unannounced follow-up visit to determine Red Earth had acted on the three issues they raised in the audit, Butz warned.

Butz’s work has positioned Red Earth CSA to enjoy a smooth transition from harmonized GAP-GHP certification to FSMA. The question, however, is when FDA will be ready to launch.

FDA has yet to release its guidelines for the rules, said Oleson. “We can read the rules. But FDA always comes out with guidelines. Those guidelines give insight as to what the regulations mean, how we can comply with them and what some of the acceptable alternatives might be.”

At presstime, the agency had yet to release inspector training information as well.

In the meantime, states were preparing for the commencement of education, training and audits. Of all the states contacted, Pennsylvania seemed to be in the best state of preparedness for FSMA compliance.

While it has only two inspectors, presently, both have significant experience conducting GAP-GHP audits. State farm groups and the Pennsylvania Department of Agriculture have held a number of educational meetings for growers in various locations around the state to help them understand what lies ahead for them under FSMA.

In addition, Penn State Extension has posted a large selection of information for growers on how to navigate the food safety plan process and ensuing audits.

Georgia’s Department of Agriculture was waiting on a bill that has passed the Senate but not the House to give state food safety personnel authority to perform audits on farms. At presstime, Georgia had hired two FSMA inspectors. Similarly, they have hired an outreach director recently.

The California Department of Food and Agriculture will hire three “senior environmental scientists,” the title they use to describe food safety inspectors, as well as an analyst and office technician, this year. Over the next three fiscal year, the department plans to hire eight more environmental scientists.

Until FDA releases FSMA guidelines and inspector training programs, all states and growers can do is wait, and attempt to educate themselves on what lies ahead.