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GAP/Food Safety for Fruit and Vegetable GrowersWythe MorrisCommercial Horticulture/ GAP/ Food SafetyVirginia Cooperative ExtensionGoodAgricultural PracticesWhat is GAP?The agricultural/ food industry adopted this acronym to represent those methods and practices considered safe and appropriate to food operations from farm to table.

Have you answered your questions yet?Farming Operations- large or small- are no different from any other business. You must have a business plan in place.What are you growing?

How much do you grow?

How do you harvest?

Do you have needed equipment for your crop?

What is your market?

Commercial Production?Direct Markets?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 (CSAs) 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.And the difference isJust like your farm business plan, every farm food safety plan is unique and customized to fit your particular farm setup.Food Safety Modernization ActDecember 21, 2010PlusTester Hagan Amendment S.510

The new program will take several years to roll out; even longer to become fully effective.

FSMAContinues to be voluntary until FDA directive (issued 1/4/2013) becomes final later this year.Comment period goes until May 16, 2013.

GAP Certification2/18/201314Developed by Wythe Morris, Virginia Cooperative ExtensionContinues to be industry driven although the law is on the books and required compliance is presently being addressed.

GAP Certification2/18/201315Developed by Wythe Morris, Virginia Cooperative ExtensionYou will need to beGAP Trained orGAP Compliant orGAP Certified

Each step will build on the previous step. This can and will change as your farm business plan changes.

Depending on your farm setupThe 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 farmGAP Trained

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 requiredGAP Compliant

The Participant:

1. Has requested an audit from a Third Party auditing agency and passed the auditGAP Certified

GAP TrainedGAP CompliantGAP CertifiedGrowersYESYESYESPackersYESYESYESTransportationYESYESYESDistributionYESYESYESProcessingYESYESYESWholesale Growers, Packers, DistributorsRemains voluntary and industry driven at this time.GAP TrainedGAP CompliantGAP CertifiedFarmers MarketsYESYESNO*Farm Based Roadside StandsYESYESNO*Pick Your OwnYESYESNO*Community Supported AgricultureYESYESNO*Direct Marketers* Must pre-qualify under Tester-Hagan AmendmentFSMA Proposed Rule for Produce: Compliance DatesAverage annual value of food sales *Product Grown forTarget ConsumerGAP Certification RequirementTime to Comply with Audit **Time to Comply with Water Requirements **Smallest FarmsLess than $25,000Direct MarketsDirect Retail MarketsExempt ***XXXXXXWholesaleIntermediary BuyersYES4 years6 yearsVery Small BusinessesLess than $250,000Direct MarketsSubject to Tester Hagan AmendmentPartially Exempt ***XXXXXXWholesaleIntermediary BuyersYES4 years6 yearsSmall BusinessesLess than $500,00Direct MarketsSubject to Tester Hagan AmendmentPartially Exempt ***XXXXXXWholesaleIntermediary BuyersYES3 years5 yearsAll other BusinessesOver $500,000Direct MarketsConsumer end usersYES2 years4 yearsWholesaleIntermediary BuyersYES2 years4 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 GAPsDirect Markets- sales directly from farm to consumer without going through a third party buyer. Limited retail and direct marketsDM sources must account for greater than 50% of a farms salesSales are conducted within the state orNo 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).

Tester-Hagan Amendment (S.510)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

Tester-Hagan Amendment, ctd.

CSAs, 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 Statestatutory law.Tester-Hagan Amendment, ctd.Developing Your Plan of ActionA Plan of Action ManualHelps to ID HazardsHelps to ID Preventive ControlsHelps to set up MonitoringOrganized system recognized by auditors or other personnelCan move into full certification if needed

Sanitation IssuesWorkersDrinking waterSanitary facilitiesHand washingTraining IllnessesAccidents and First AidProduceManure managementHarvest containers and equipmentWashing/ sanitation

Potential Hazards?

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.Are the same items required for all farms?Examples Which is correct?

Irrigation TypesDripOverheadFlooded rowsWater QualityMunicipal sourcesWellsSpringsOpenSealedOpen sourcesPondsStreamsReservoir

Potential Hazards?

Livestock ManagementLocationFencingAccess to irrigation water sourcesWildlife ManagementDamagesControlsMonitoring

Potential Hazards?

SoilsHistoricalSeptic systemsFloodingManure/Compost ManagementStorageBuffer zonesComposting proceduresTime factors (120 day rule)Potential Hazards?

Good Agricultural PracticesDrip irrigationChemical application and fertigationCrop and field rotationsField assessmentsEquipment MaintenancePrivate pesticide license

Preventive Controls?

Reducing or preventing contaminationWater testingResearchSelf assessment of our farmPrevious land useAerial photosStandard Operating ProceduresHarvesting and PackagingPreventive Controls?Traceability SystemOne step backOne step forwardAssigning lot numbersPlant Protection RecordsMonitoring?

Top 15 Actions To Address GAP/ Food Safety1- Document2- Document3- Document4- Document5- Document6- Document7- Document8- Document9- Document10-Document11-Document12-Document13-Document14-Document

15- If it is not written down, it did not happen.Developing Your GAP/ Food Safety Plan of Action ManualNRV Field Day- Kentland8/17/201036Developed by Wythe Morris, Virginia Cooperative ExtensionFinal Notes for Direct MarketersParticipate in trainingDevelop your farm planWork your plan and documentStay tunedDirect Marketers

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

Know what your buyers and packers require in the way of GAP Certification.Find this information out before you grow your crop. Dont wait until the last minute. If you know you need to be GAP Certified the process takes reasonable time and effort. Plan ahead!!!

Advice to Growers

Wythe Morris, ANR AgentCommercial Horticulture/ GAP/ Food SafetyVirginia Cooperative Extensionmorrisw@vt.edu

Questions?NRV Field Day- Kentland8/17/201040Developed by Wythe Morris, Virginia Cooperative Extension