Please note that the Grassroots Guide has not yet been updated to reflect changes made by the 2018 Farm Bill, which was passed and signed into law in December 2018. We are in the process of updating the Guide and expect to publish an updated version in the spring of 2019. In the meantime, please use this guide for basic information about programs and important resources and links for more information, but check with USDA for any relevant program changes made by the 2018 Farm Bill. Also, check out our blog series covering highlights from the new farm bill.
In the late 1990s, many schools, grocers, and wholesalers began to demand that producers undergo third party food safety audits. Farmers and consumers have a vested interest in growing and eating safe food. To provide a standard food safety audit system for producers, packers, and distributors, USDA and various inspection and standardization agencies developed the Good Agricultural Practices (GAP) and Good Handling Practices (GHP) Audit Verification Program. The GAP and GHP program is a voluntary, user-fee funded independent audit program offered to the produce industry to verify that fresh fruits and vegetables are produced, packed, handled, and stored according to food safety practices that minimize the risks of microbial food safety hazards. The audits are based on recommendations from the U.S. Food and Drug Administration (FDA) and open up new markets for producers, packers, and distributors seeking to sell to schools, grocers, wholesalers, and others that require food safety certification.
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In October 1998, the U.S. Food and Drug Administration (FDA) issued a guidance document for the fresh fruit and vegetable industry that provided general guidelines for reducing the risk of contamination of fresh produce by microbial organisms. The FDA’s document – Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables – provides information about high-risk areas for contamination and how to avoid or minimize such contamination. Shortly after the release of the FDA guide, many wholesale and foodservice buyers began requiring their suppliers to undergo third party food safety audits.
In response to numerous requests from the fruit and vegetable industry, USDA’s Agricultural Marketing Service (AMS) and the Association of Fruit and Vegetable Inspection and Standardization Agencies (AFVISA) developed an audit-based program to verify compliance with the FDA guide. AMS conducted a pilot project in 2001 and then formally implemented the GAP and GHP program in 2002.
Certification from the program does not guarantee that the product is free from microbial contamination but verifies that the participant has taken proactive measures to reduce the risk of contamination. GAP covers on-farm production and harvesting practices while GHP covers packing, storage, and the distribution of crops. The responsibility for product safety and the continued observance of best practices rests with the operation producing and handling the fresh product.
Though FDA is the federal agency with regulatory authority for fresh fruits and vegetables, it is licensed AMS or state department of agriculture employees who conduct GAP and GHP audits. There are three distinct types of audits that may be applicable to an operation:
The GAP and GHP audit is divided into the following sections, each of which covers a specific portion of the supply chain, including:
Generally, a GAP audit consists of Parts 1 and 2 and applies to producers while a GHP audit consists of Parts 3 and 4 and applies to packing houses. Part 5 is no longer in use. Part 6 covers a wholesale distribution center or terminal warehouse for GHP. Part 7 covers steps taken to protect product from intentional contamination. The General Questions section is a mandatory accompaniment for every other section in an audit (except for a Part 7-only audit).
The mandatory General Questions section requires a food safety program (including a food safety manual), traceability program, and a recall program (including documented evidence of having completed at least one mock recall prior to the audit). It also covers worker health and hygiene and pesticide or chemical use. The food safety manual is a written document that covers all aspects of the growing and handling process. The plan indicates what steps and procedures the operation will take to reduce the risks of contamination by identified chemical, physical, or microbial hazards.
The audit is performed by an auditor who uses a GAP and GHP audit checklist to score the food safety performance of the operation. The audit checklist also defines when documents are required and what type of documentation is necessary. The audit checklist is available on the GAP and GHP website. To pass any scope, you must earn at least 80 percent of the points available in each applicable section. Operators can choose to have a single crop or multiple crops included in the same audit. Once an operation has successfully met the requirements of the audit, it will receive a USDA certificate and have its information listed on the USDA website. The certificate is good for one year, unless the operation fails an unannounced verification audit.
Produce suppliers throughout the production and supply chain are eligible to be GAP and GHP certified.
Thousands of operations have been certified under GAP and GHP, expanding their access to wholesalers, schools, and grocery chains. A spreadsheet (searchable by products sold, location, or company name) listing all currently certified operations can be found on USDA’s Companies that Meet USDA GAP&GHP Acceptance Criteria page.
For example, Good Natured Family Farms (GNFF) of Kansas City, Missouri, is an alliance of more than 150 family farms who pooled their resources in 2009 to help members attain GAP certification and continue selling to two major buyers in the area – SYSCO and Chipotle – who began to require GAP certification. As a result of their collective effort, USDA partnered with GNFF in 2010 to pilot a Group GAP certification process, the report on which can be found here via the Wallace Center: Group GAP Pilot Project Report and Assessment.
Because food safety practices and certifications can be expensive for small farmers, Group GAP certification processes are being developed in which a “recognized entity” maintains an internal quality management system designed to implement, monitor, and ensure implementation of Good Agricultural Practices among the group’s farms. GAP auditors then externally audit this system. Group GAP certification was first developed internationally and is now being piloted domestically.
Producers, packers, and distributors must submit a request to schedule an audit at least two weeks in advance of their anticipated audit date by contacting their local USDA inspection office, which can be found on USDA’s GAP and GHP information page. A copy of one’s food safety manual must be submitted in one’s request to schedule an audit. The operation being audited must also provide the auditor with a point of contact for its food safety officer, who must be present at the time of the inspection and know the operation’s food safety practices in detail. A Participation Agreement outlining the expectations of the operation and USDA in performing the audit must be submitted prior to the audit.
Currently the fee is a $92.00 per hour fee (including travel time) for an auditor’s time for any audit or audit-related visit plus a $50 USDA administrative fee. Thus, the overall cost of the audit varies significantly based on the travel time required to get to the farm. The Opening Markets Project at North Carolina State University, which tracked the GAP certification process for 12 small farms (less than 30 acres in production) in the state, found that the average cost of the audit was $925.
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GAP and GHP was established in 2002 under existing agency authority and therefore does not require reauthorization in any legislation. AMS uses non-appropriated funds to administer the program and it therefore does not require Congressional appropriations.
Last updated in October 2014.