October 27, 2015
Since 2010, the U.S. Department of Agriculture’s Agricultural Marketing Service (AMS) has been partnering with the Wallace Center at Winrock International to pilot a group food safety certification option called GroupGAP.
USDA recently previewed the planned expansion of the GroupGAP pilot to a full program, which will become available nationwide in the spring of 2016. According to AMS Administrator Anne Alonzo, “transitioning the GroupGAP pilot to a full program will increase the ability of small and mid-sized growers to obtain food safety certification, thereby improving market access opportunities throughout the produce industry.”
Why Group Certification?
It has become increasingly commonplace for buyers to require their suppliers, like farms, to demonstrate adherence to certain food safety practices. AMS, through the Specialty Crop Inspection Division, already offers an audit service for farms interested in obtaining GAP certification (GAP stands for “good agricultural practices”) to meet that market requirement.
Under the existing USDA GAP model, each farm is audited individually for compliance with an industry-recognized food safety standard. With GroupGAP, a group of farms come together and collaboratively develop a quality management system for the entire group through a central organizing entity, like a producer cooperative, aggregator, or food hub that serves as an intermediary between the farmers and institutional or wholesale buyers. Through the central entity, qualified individuals internally audit the participating farms. AMS audits both the group quality management system, and directly audits a percentage of the farms at random.
GroupGAP offers benefits to farmers and buyers alike. For farmers, it provides access to peer learning and other training opportunities; it supports and encourages collective sharing of risk, equipment, and other knowledge resources; and it opens up new markets. In turn, by aggregating groups of producers through the central entity, GroupGAP benefits buyers looking to meet growing consumer demand by purchasing from a broader base of local producers with a verifiable commitment to food safety.
GroupGAP and FSMA
FDA and USDA have indicated their intention that USDA GAP will align with new federal requirements under the Food Safety Modernization Act (FSMA), so that farmers who are certified through USDA GAP and GroupGAP – and their buyers – will have the confidence that they are satisfying FSMA’s regulatory requirements.
As FDA prepares to finalize the FSMA rule governing produce safety, increasing attention has been placed on the role of third party audits in FDA’s implementation strategy. FDA has indicated that it will look to food safety certification as a compliance indicator as it focuses its limited implementation and inspection resources.
However, it is critical that FDA not place out-sized reliance on third party audits as a way of alleviating their regulatory responsibility. Third party audits are costly and burdensome to administer, disproportionately so for smaller operations, and for that very reason in FSMA Congress explicitly prohibits FDA from requiring farms from having to hire a third party to verify compliance with the rules. The proposed Produce Rule does not require audits, but if FDA’s compliance strategy for farms leans so heavily on third party audits that they become de facto requirements, then the spirit of the law has been ignored. The final Produce Rule is expected to be released in early November.
NSAC has long emphasized that training and education play crucial roles in successful FSMA implementation, and should also factor significantly in FDA’s determination of how to focus its implementation resources. Not only must there be accessible and affordable certification options for those farms that chose to voluntarily undergo food safety certification, but training and education must also be affordable and accessible to farms of all types and sizes.