April 5, 2016
After three years in pilot stage the U.S. Department of Agriculture’s (USDA) Agricultural Marketing Service (AMS) this week announced that GroupGAP, a new certification option ideal for small and mid-sized farms, will be available nationwide.
GAP (short for “good agricultural practices) certification is a USDA audit program through which producers can demonstrate their compliance with food safety requirements to purchasers and retailers. Historically, GAP certification has been out of reach for many small and mid-sized farms and beginning and socially disadvantaged farmers because of the price. GroupGAP provides a long-awaited alternative option, wherein grower groups, farmer coops, and food collaboratives can share the certification cost by pooling together.
Under the traditional USDA GAP model, each farm is audited individually for compliance with industry-recognized food safety standards. Under the GroupGAP model, a group of farmers can come together and collaboratively develop a quality management system through a central organizing entity, like a producer cooperative or food hub, which serves as an intermediary between the farmers and institutional or wholesale buyers. Through the central entity, qualified individuals internally audit the participating farms. AMS’s role in Group GAP is to audit both the group quality management system a well as directly auditing a percentage of the farms at random.
For farmers and growers alike, group certification provides access to a myriad of benefits. By working in a collective, farmers have expanded opportunities for peer learning and training, collectively share risk, equipment, and other knowledge resources, and can gain access to new markets. In turn, GroupGAP benefits buyers by aggregating groups of producers through a central entity. This helps buyers to meet growing consumer demand for food with verifiable commitments to food safety and growing standards by pooling broad bases of local producers who meet those standards.
What does GroupGAP have to do with FSMA?
Producers have typically sought GAP certification in order to access markets where such certification is required. Today, growers are under added market pressure to obtain food safety certifications because of the Food and Drug Administration (FDA)’s new food safety rules; established through the Food Safety Modernization Act (FSMA). FDA has made it clear that while audits are not required under the new rules, private audits will nevertheless play a role in FDA’s compliance strategy for the new food safety rule for produce farmers.
The National Sustainable Agriculture Coalition (NSAC) has long cautioned against FDA’s outsized reliance on third party audits as indicators of compliance. Such audits often represent significant costs and burdens to smaller farms, which is why FSMA explicitly prohibits FDA from requiring farmers to pay for audits to verify compliance with the rules.
While NSAC remains in opposition to any de facto regulatory requirement that farmers pay for auditing as part of their food safety requirements, we do applaud the emergence of GroupGAP as a strong alternative option for farmers seeking food safety certifications. We would encourage farmer cooperatives, food hubs, and other similar collaborative growing arrangements to consider this option.
We are also pleased that AMS is currently working with FDA on a joint GAP review project, which will review the alignment of the USDA GAP program (including GroupGAP) to FSMA’s requirements. Following review, USDA GAP and GroupGAP would undergo any necessary modifications so that they provide at least the same baseline requirements as FSMA. These revisions are expected to be in place before the final compliance implementation date in the FSMA Produce Rule.
Want to learn more?
The USDA offers several resources for potential GroupGAP applicants, including a handy user’s guide and a fact sheet for growers. The GroupGAP User’s Guide explains how to apply and participate in a GroupGAP, offers details on both the pre-application and application processes, and clarifies initial responsibilities of the USDA and participating groups. The Guide also asks preliminary questions to help producers decide whether GroupGAP is appropriate for their operation.
Some questions for producers to consider are:
For producer groups who decide to join, the AMS Specialty Crops Inspection Division will visit sites to ensure compliance, perform spot checks to verify appropriate on-farm implementation, and offer an analysis of the group’s system of oversight.
The USDA will be offering several Internal GroupGAP Auditor Training Courses, including AMS Fundamentals of Auditing and Produce GAPs Harmonized Food Safety Standard Auditor Training. The produce-specific GAP course will be offered twice, in Salt Lake City, UT on April 20-22, and in Fredericksburg, VA on May 11-13.
To apply for a GroupGAP audit service, producers must complete a 1-page application, available here. For wholesalers and distributors interested in requesting audit service, an agreement for participation is available here.
You can also learn more via the Introduction to GroupGAP guide, offered by the Wallace Center, an NSAC member organization.