Presentation Outline• GAP Harmonization presentation

Dave Gombas, Senior Vice President: Food Safety & TechnologyUnited Fresh Produce

• Questions and AnswersModerator: Steve WarshawerFood Safety CoordinatorNational Good Food Network

Produce GAPs Harmonization Initiative

David E. Gombas, Ph.D.David E. Gombas, Ph.D.United Fresh Produce AssociationUnited Fresh Produce Association

September 21, 2010September 21, 2010

United Fresh Global Conference on Produce Food Safety Standards, April 2009

• Over 200 leaders from each stage of the produce supply chain, government, and third-party standard owners and auditors explored the potential value of harmonization and greater alignment of standards

• Produce GAP standards used in various audits in North America seem to be at least 90% the same, providing a clear opportunity for harmonization.

Prior Harmonization Efforts

• Guidance documents (FDA GAPs)• California Leafy Greens Best Practices• Food Safety Leadership Council• SQF 1000 produce standards • GlobalG.A.P• Global Food Safety Initiative (GFSI)

Outcomes From the Conference

The process of bringing key stakeholders together to develop and endorse commodity-specific standards provides a good model for building consensus on general GAP standards.

Harmonization of general GAP standards must be transparent with open communication of intent, progress, and conclusions.

Retailers, foodservice companies, fresh-cut processors, grower-shippers, auditors and standard owners, and government must all be at the table working together.

Outcomes From the Conference

Inclusion of non-food safety standards (environmental, social issues) is a likely obstacle to harmonization, particularly in North America. These issues may need to be addressed separately.

Process to HarmonizationIdentified a small but influential Steering Committee of major industry representatives with the ability to drive broad industry acceptance of common standards:

McDonald’sYum Brands Pro*Act U.S. FoodserviceDardenJack in the Box SyscoSubwayMarkon River RanchDel Monte FreshTaylor Farms

WegmansAholdKrogerLoblawsSafewaySchnucksPublixWalmartFood LionSupervaluCostco14 produce associations

Chiquita Fresh ExpressSun World InternationalDiMare CompanyGreen Giant FreshSunkist GrowersCastellini Co.McEntire ProduceDole Food CompanyThe Giumarra CompaniesTanimura & AntleC.H. Robinson

Vision of Harmonization

Develop a harmonized food safety standard and checklist for GAP audits, and globally-acceptable auditing process, necessary to protect consumers from potential hazards that may contaminate produce at that stage of the supply chain, and that will build efficiencies into the supplier audit process.

One audit by any credible third party, acceptable to all buyers

Scope of work (1)

A single, generic checklist for GAP audits: Focused on food safety practices of pre-farm

gate produce operations (as defined by the scope of the FDA GAPs);

With clearly defined requirements that minimize opportunity for misunderstanding, misinterpretation and “standards creep” by operations and auditors;

Globally recognized, but specifically applicable to North America operations;

Scope of work (2)

Requirements that are risk-based, science-based, attainable, auditable and verifiable;

Considering all microbiological, chemical and physical hazards reasonably likely to occur, consistent with potential hazards addressed in FDA regulatory guidances;

Scalable to all size fresh produce operations; Considerate of regional- and commodity-

specific food safety needs;

Scope of work (3)

Sufficiently non-prescriptive to be accepting of equivalent food safety practices;

Flexible to adapt as science reveals better practices and limits;

Acceptable to a critical mass of customers requiring general produce food safety audits;

Freely accessible by everyone, including any 1st, 2nd or 3rd party auditor.

Technical Working Group

Over 150 stakeholders, representing:• Customers, suppliers, audit companies,

government (FDA and USDA), extension, association staffs;

• A broad scope of fresh produce commodities; • A broad scope of operation sizes; and • A broad scope of producing regions, including

Mexico and Canada. • Open invitation for participation;

no stakeholders excluded

Standard Harmonized from

• CA LGMA• Mushroom GAPs• SENASICA • Silliker• USDA• Tomato Food Safety Audit Protocol• Community Alliance with Family Farmers• California Strawberry Commission

• AFDO Model Code• AIB • CanadaGAP• GlobalG.A.P• SQF 1000

Field Operation/Harvest Audit Standard Draft Now Completed

Categories of the Standard

General Questions • Management Responsibility • Food Safety Plan • Documentation & Recordkeeping • Worker Education and Training • Microbiological Sampling and Testing • Traceability • Recall Program • Corrective Actions • Self-audits

Categories of the Standard

Field Production • Field History and Assessment • Worker Health/Hygiene and Toilet/Handwashing

Facilities • Agricultural Chemicals /Plant Protection Products • Agricultural Water • Animal Control • Soil Amendments

• Vehicles, Equipment, Tools and Utensils

Categories of the Standard

Harvesting • Preharvest Assessment • Water/Ice • Containers, Bins and Packaging Materials • Field Packaging and Handling

• Postharvest Handling Transportation (Field to Packinghouse) • Equipment Sanitation and Maintenance

Post-harvest Operations standard

• General Questions • Produce Cooling • Packinghouse • Transportation (from Packinghouse) • Produce Storage

Fast Facts about the Standard

• 84 audit items• 14 written policies/procedures, such as

– Food safety plan– Traceability and recall programs– Toilet, worker hygiene and health policy– Water management plan

• 14 types of records, including– Training records– Soil Amendments– Agricultural Chemicals– Pre-planting and pre-harvest risk assessments– Microbiological testing (if performed)

What makes it scalable?• Worded to work for family operations as well as

large corporate farms, diverse crop farms as well as single commodity operations

• Allows for “not applicable” • Requires designation of responsibilities, not

dedicated personnel– Allows, does not require, hiring outside

personnel, within the limits of the law• Requirements, documents, records generally

simpler with fewer employees, smaller operations

• Most often instructs auditor to look at practices rather than written procedures or records

Audit Standard

Audit Process

Audit

Audit Process• Operations Committee commissioned to

develop policies and procedures for use of the harmonized standard

• Standard will be freely usable by any audit organization, but must be used consistently

• Market will decide which audit process is most credible, acceptable

Next steps• Complete the Post-harvest Operations audit

standard (Costco, Oct. 21-22)• Schedule “pilot” audits using the draft

standards: – Operation, auditor, customer– Different commodities, different size

operations– Assess what works, what doesn’t, and

make changes to the draft• Develop auditor training tools

What does this mean for you?

• Decreased number of audits– Multiple customers willing to accept the same

audit means fewer audits• Consistent expectations

– Auditors (and customers) using the same standard should be asking the same questions, judging compliance the same way; less “moving target”

• Reduced audit costs– Focus resources on operation,

not on passing the audit of the day

What you can do

• Review the standard and tell us: What’s not clear? What doesn’t work for your operation?

• Use the standard for your own self-audit• Ask your customers – are they involved in

the Initiative? What do they think about it?• Participate. The Initiative was created to

help reduce your audit burden while harmonizing food safety expectations. Make sure it works for you.

Screenshot GHI page

Produce GAPs Harmonization Initiative

Questions?Questions?