GAP/Food Safety for Fruit and Vegetable Growers Wythe Morris Commercial Horticulture/ GAP/ Food Safety Virginia Cooperative Extension

Good Agricultural Practices What is GAP? Good Agricultural Practices 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?

And the difference is… 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 (CSA’s) 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.

Just like your farm business plan, every farm food safety plan is unique and customized to fit your particular farm setup.

Food Safety Modernization Act Tester Hagan Amendment S.510 FSMA Food Safety Modernization Act December 21, 2010 Plus Tester Hagan Amendment S.510 “The new program will take several years to roll out; even longer to become fully effective.”

4/15/2017 GAP Certification Continues to be voluntary until FDA directive (issued 1/4/2013) becomes final later this year. Comment period goes until May 16, 2013. Developed by Wythe Morris, Virginia Cooperative Extension

4/15/2017 GAP Certification Continues to be industry driven although the law is on the books and required compliance is presently being addressed. Developed by Wythe Morris, Virginia Cooperative Extension

Depending on your farm setup… You will need to be… GAP Trained or GAP Compliant or GAP Certified Each step will build on the previous step. This can and will change as your farm business plan changes.

GAP Trained The 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 farm

GAP Compliant 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 required

GAP Certified The Participant: 1. Has requested an audit from a “Third Party” auditing agency and passed the audit

Wholesale Growers, Packers, Distributors GAP Trained GAP Compliant GAP Certified Growers YES Packers Transportation Distribution Processing Remains voluntary and industry driven at this time.

* Must pre-qualify under Tester-Hagan Amendment Direct Marketers GAP Trained GAP Compliant GAP Certified Farmers Markets YES NO* Farm Based Roadside Stands Pick Your Own Community Supported Agriculture * Must pre-qualify under Tester-Hagan Amendment

FSMA Proposed Rule for Produce: Compliance Dates   Average annual value of food sales * Product Grown for Target Consumer GAP Certification Requirement Time to Comply with Audit ** Time to Comply with Water Requirements ** Smallest Farms Less than $25,000 Direct Markets Direct Retail Markets Exempt *** XXX Wholesale Intermediary Buyers YES 4 years 6 years Very Small Businesses Less than $250,000 Subject to Tester Hagan Amendment Partially Exempt *** Small Businesses Less than $500,00 3 years 5 years All other Businesses Over $500,000 Consumer end users 2 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 GAPs

Tester-Hagan Amendment (S.510) Direct Markets- sales directly from farm to consumer without going through a third party buyer. Limited retail and direct markets DM sources must account for greater than 50% of a farm’s sales Sales are conducted within the state or No 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, ctd. 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. CSA’s, 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 State statutory law.”

Developing Your Plan of Action A Plan of Action Manual Helps to ID Hazards Helps to ID Preventive Controls Helps to set up Monitoring Organized system recognized by auditors or other personnel Can move into full certification if needed

Potential Hazards? Sanitation Issues Workers Produce Drinking water Sanitary facilities Hand washing Training Illnesses Accidents and First Aid Produce Manure management Harvest containers and equipment Washing/ sanitation

Are the same items required for all farms? 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.

Examples… Which is correct?

Potential Hazards? Irrigation Types Water Quality Drip Overhead Flooded rows Water Quality Municipal sources Wells Springs Open Sealed Open sources Ponds Streams Reservoir

Potential Hazards? Livestock Management Wildlife Management Location Fencing Access to irrigation water sources Wildlife Management Damages Controls Monitoring

Potential Hazards? Soils Manure/Compost Management Historical Septic systems Flooding Manure/Compost Management Storage Buffer zones Composting procedures Time factors (120 day rule)

Preventive Controls? Good Agricultural Practices Drip irrigation Chemical application and fertigation Crop and field rotations Field assessments Equipment Maintenance Private pesticide license

Preventive Controls? Reducing or preventing contamination Water testing Research Self assessment of our farm Previous land use Aerial photos Standard Operating Procedures Harvesting and Packaging

Monitoring? Traceability System Plant Protection Records One step back One step forward Assigning lot numbers Plant Protection Records

Top 15 Actions To Address GAP/ Food Safety NRV Field Day- Kentland 8/17/2010 Developing Your GAP/ Food Safety Plan of Action Manual Top 15 Actions To Address GAP/ Food Safety 1- Document 2- Document 3- Document 4- Document 5- Document 6- Document 7- Document 8- Document 9- Document 10-Document 11-Document 12-Document 13-Document 14-Document 15- If it is not written down, it did not happen. Developed by Wythe Morris, Virginia Cooperative Extension 36

Direct Marketers… Final Notes for Direct Marketers… Participate in training Develop your farm plan Work your plan and document Stay tuned…

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

Advice to Growers Know what your buyers and packers require in the way of GAP Certification. Find this information out before you grow your crop. Don’t wait until the last minute. If you know you need to be GAP Certified… the process takes reasonable time and effort. Plan ahead!!!

NRV Field Day- Kentland 8/17/2010 Questions? Wythe Morris, ANR Agent Commercial Horticulture/ GAP/ Food Safety Virginia Cooperative Extension morrisw@vt.edu Developed by Wythe Morris, Virginia Cooperative Extension