Good Agricultural Practices and Good Handling Practices Audit Verification Program

Helping produce farmers, packers, and distributors meet buyers’ food safety certification requirements

In the late 1990s, many schools, grocers, and wholesalers began to demand that producers undergo third party food safety audits. To provide a standard food safety audit system for producers, packers, and distributors, the U.S. Department of Agriculture (USDA) (in partnership with other 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). GAP and GHP certifications can help to open new markets to producers, packers, and distributors seeking to sell to schools, grocers, wholesalers, and others that require third party food safety certifications.

Learn More About GAP and GHP:

Program Basics

The USDA’s Agricultural Marketing Service (AMS) runs the GAP and GHP audit program. There are several types of verification audits, including the following:

  • GAP: Observes best practices of on-farm production and harvesting of produce to verify that the operation works to reduce the contamination of fresh fruits and vegetables
  • GHP: Observes best practices of packing, storing, and distributing produce to ensure the operation works to reduce the contamination of fresh fruits and vegetables
  • Harmonized GAP and GHP: Aligns the GAP and GHP audits with the Food Safety Modernization Act (FSMA) Produce Safety Rule to show to buyers that they are implementing the rule’s requirements
  • Group GAP: Creates an internal auditing program for small and medium sized farms. Farms can share resources and costs of the audits and create an audit program that works best for them
  • H-GAP Plus+: Combines an H-GAP audit with the standards recognized by the Global Food Safety Initiative (GFSI)

Certification from this program does not guarantee that the product is free from microbial contamination or compliant with FDA food safety regulations, but verifies that the grower or handler 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 has licensed AMS or state department of agriculture employees who conduct GAP and GHP audits. There are four distinct types of audits that may be applicable to an operation:

  • An initial audit, which is an announced audit that verifies the farm or facility’s compliance with the requirements. A GAP and GHP certification is valid for one year from the date of the initial audit
  • An unannounced verification visit, which is conducted at some point following a successful initial or follow-up audit
  • A follow-up audit, which is performed when either an initial audit or unannounced verification visit reveals that a farm or facility is not meeting the program requirements
  • Group internal producer audits, which is performed as part of an internal Group-GAP audit

The GAP and GHP audit is divided into the following sections, each of which covers a specific portion of the supply chain:

  • General Questions (which cover overarching food safety issues)
  • Part 1 – Farm Review
  • Part 2 – Field Harvesting and Field Packing Activities
  • Part 3 – House Packing Facility
  • Part 4 – Storage and Transportation
  • Part 6 – Wholesale Distribution Center/Terminal Warehouse
  • Part 7 – Preventive Food Defense Procedures

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 and so is not included here. 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 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, a farmer 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.

For H-GAP, the four main scopes of the audit are:

  • General Questions
  • Field Operations and Harvesting
  • Post Harvest Operations
  • Logo Use

The General Questions scope is required; one or both of the Field Operations and Harvesting and/or the Post-Harvest scopes are also required. The Logo scope must be completed for any operations using the USDA GAP and GHP logos on packaging and other materials. The H-GAP checklist is available here.

GroupGAP goes through GAP & GHP or H-GAP audits together, as a group. The group develops a shared Quality Management System (QMS), which includes the GAP or GHP requirements. Then, the audit is conducted for the entire group. The group conducts internal audits of all group members and USDA also performs an annual audit of the Group’s QMS and audits for some, but not all, of the groups individual operations. This is a great way to share the costs of audits and to use the group’s QMS to create consistent results for all group members. For more information on GroupGAP, check out the User Guide.

Eligibility

Produce suppliers throughout the U.S. production and supply chain are eligible to be GAP and GHP certified – including individual farms as well as packing houses.

The Program in Action

Thousands of operations have been certified under GAP and GHP audit program since its inception, and many have seen expanded access to wholesalers, schools, and grocery chains as a result. 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.

How to Apply and Program Resources

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 audit fee is a $108 per hour (plus round trip travel) for an auditor’s time for any audit or audit-related visit. Therefore, the overall cost of the audit can vary 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.

For at least 2019, and possibly future years, farmers in 16 states will be able to go through an H-GAP or H-GAP Plus+ audit at no cost: Connecticut, Delaware, Hawaii, Maine, Maryland, Massachusetts, Nevada, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Utah, Vermont, West Virginia and Wyoming. Producers in these states will receive an automatic credit for the cost of these audits.

For more information see:

Program History, Funding, and Farm Bill Changes

In October 1998, 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 – provided 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, 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.

GAP and GHP was established under existing agency authority and therefore does not require reauthorization in any legislation. AMS uses non-appropriated funds (i.e. user fees) to administer the program and therefore does not require Congressional appropriations.

In 2011, AMS added a Harmonized Food Safety Standard for Produce into the GAP and GHP audit programs with the goal of better aligning them with the new FSMA requirements for produce farms. AMS created a new combined checklist for Harmonized GAP (H-GAP) audit in 2018 with the intent of aligning the H-GAP audit standards with the FSMA Produce Safety Rule regulated by FDA.

Also, in 2016, AMS implemented a GroupGAP audit program to make it more a more cost-effective and practical process for small and medium sized growers.

Last updated in August 2019.

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