Points analysis of the USDA GAP Audit Checklist

To assist farmers in passing a USDA GAP certification, I determined which categories of the USDA GAP audit checklist have the most impact on the final score. Questions in each part (General, Part 1,2,3 and 4) were placed in categories such as equipment/containers, water/ice, facilities/storage, animals/pests, product handling, worker health and hygiene, bathroom and handwashing, traceability, sewage/waste, transportation, manure, and land history.

In Table 1, questions from all parts (General, Part 1, 2, 3 and 4) are ranked into categories and points were tallied. Each question number is labeled with a color to identify what action should be taken (as defined by the USDA GAP checklist):

  • Record, red  (a record is required to be kept showing an action was taken)
  • Policy, blue (a policy/SOP must be documented in the food safety plan in order to show conformance to the question)
  • Document, black (a document is required to show conformance to the question. May be a combination of a policy and a record indicating that an action was taken)
  • Observation, green

Each question number is listed in the appropriate value column:

  • 5 points
  • 10 points
  • 15 points

In Tables 2-6, each individual part has the questions divided into ranked categories. The points for each category are broken down into which action needs to be taken: record, policy, document or observation.

We encourage any comments/responses to this analysis of the USDA GAP audit.


Agritourism and Food Safety Webinar

On Wednesday, December 14th, I participated in a webinar about Food Safety Education and Planning for Agritourism Providers. This webinar was hosted by Ben Amsden from Plymouth state university center for rural partnerships, and Lisa Chase and Londa Nwadike from University of vermont extension and focused on discussing risk management and food safety practices for those involved in agritourism activities. Most of the farmers in our project participate in agritourism events such as U-pick operations, farms stands, and community supported agriculture, and they have asked questions about how to deal with the health and hygiene practices of patrons.

The first part of the webinar focused on risk, seeking advice on risk management, and developing a risk management plan. Most farmers are familiar with general or product liability insurance however other plans are available can that cover special events, the premises, and physical damage. The second half of the webinar discussed food contamination, the impact of foodborne illness, and risk-based food safety principles. It is important to discuss issues with your employees like how to influence patrons to employ good hygiene practices when coming on your farm. The proper placement of signage and availability of  sanitary facilities will encourage patrons to follow good hygiene practices on the farm.

Agritourism is not normally discussed when talking about on-farm food safety but this is a significant source of revenue for some farming operations. This reminds me that each farm is different with different inputs (water, animals, workers, and patrons) requiring the assessment of risk on each individual farm and the development of risk reduction strategies that meet the needs of the farm.

Please find the recorded webinar, Powerpoint slides, and other resources at Agritourism:A Web-Based Resource for Farmers

Fresh produce safety for small scale intensive vegetable and fruit producers workshop

On November 12, Dr. Chris Gunter and I presented at the 26th annual Sustainable Agriculture Conference hosted by the Carolina Farm Stewardship Association. Our presentation, “Fresh produce safety for small scale intensive vegetable and fruit producers” discussed good agricultural practices (GAPs) and the opening markets project. Attendants ranged from small farmers to representatives from industry groups. At the beginning of the workshop, attendants participated in a hazard identification exercise reporting possible hazards on their farms and determining practical risk reduction strategies.

Here are the presentations.

GAPs the basics

Opening Markets

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Let’s talk GAPs…

Last week, I drove out to Pittsboro, NC to guest lecture at Central Carolina Community College (Pittsboro campus) in the Advanced organic crop production class. This class is part of the Sustainable Agriculture program which provides training in organic farming methods and technical skills. I was asked to speak with the class about good agricultural practices, the USDA GAP/GHP audit, and review the Opening markets project. Most of the students either own their own farm or work on a farm in the area. At the beginning of the lecture students raised their concerns regarding the cost of audits and food safety practices in general. One student asked, “Why aren’t audits performed by Cooperative Extension agents – for free?” My answer is, there could be a conflict of interest if the educators in the community also administered the audits. Beyond this salary and travel costs would still have to be paid for the agents – increase in tax dollars and/or cost recovery. And then there are liability issues. For example, PrimusLabs, who inspected the cantaloupe farm and facility associated with the recent listeria outbreak, is being sued by the victims and their families.

The presentation lasted an hour and a half with a majority of the time spent on class discussion. There is a lot of interest in good agricultural practices and the opening  markets project particularly understanding the GAP requirements and overall process. Here is the presentation.

How to get to Audit day…

The ultimate goal of the project is to prepare the participating farms to pass a USDA GAP certification. USDA GAP auditors are a 3rd party  (what that means is they are independent of both the organization being audited and any customers of the organization). They can offer resources to point you in the right direction to receive the guidance you need. Good resources for producers as they get ready for an audit are local extension agents, university representatives, or other farmers.

To schedule an audit in NC, complete and send this form (Request form) to NCDA&CS marketing division grading services along with your proposed audit dates (4 weeks in advance at the minimum) and a copy of your food safety manual. Before the audit day, the auditor needs to know the type of audit requested (USDA GAP audit, Harmonized food safety standard, Tomato audit protocol (T-GAP), Leafy greens audit (LGMA), and Identity Preservation Audit ; parts desired to be completed of the USDA GAP/GHP audit (Part 1&2 to be completed for GAP portion, Part 3&4 to be completed for GHP portion, Part 6 is for wholesale distribution centers, and Part 7 is for preventative food defense procedures) and reviewed your food safety manual; and, any previous audits completed. All crops the participant requests to be audited must be in production.

When the auditor arrives, the auditor will confirm with the farm the type of audit and parts to be completed, and attain records and documentation.

The audit will begin with the general questions and all parts have to pass the general questions. There will be an automatic fail if there is a high likelihood of product being contaminated, high presence of rodents or pests, observation of employee non-compliance with health and hygiene policy, or if you don’t have a food safety manual or food safety officer.

During the audit, the auditor will observe processes on the farm, including proper signage, availability of bathroom and handwashing facilities, and conditions of containers and storage, etc.

The auditors will confirm that employees are complying with standard operating procedures and policies. At times the auditor will need to review records even though the audit does not call for it. The audit will be stopped immediately if the farmer is found to have falsified records – automatic failure. Upon completion of the audit a report will be available. This report contains a completed checklist with score sheet and corrective actions. Auditors will write comments for all questions answered No or N/A.

Before the auditor leaves they will discuss the audit findings and the farmer will be able to discuss corrective actions. The auditor will also ask about the seasonality of the business so they can make arrangements for the follow-up or unannounced visit. This is important when auditing multiple crops so that the auditor can see as many things in production/harvest as possible.

In addition to an administrative cost of $50, the audit fees are $92/hour. The fees cover time on site for conducting the audit, travel time and preparatory time.

This summarizes the main things that many farmers will encounter as they get to the stage of an actual audit.  This project’s participating farmers are compiling materials and scheduling their USDA GAP audits, many for the spring.

GAP Audit Worksheet

Throughout this project, our participants are encouraged to make self diary entries discussing certain food safety topics and the GAP certification process. One of the reoccurring themes discussed by participants in their self diaries is the difficulty they have in comprehending and navigating the audit verification sheet.  This confusion causes participants to feel frustrated. In an effort to make the USDA GAP audit more manageable, I’ve put together a GAP audit worksheet that separates the audit content into three sections, Records (logs), Policy/Documents, and Observations.

There are three forms of in which an auditor will be determining conformance on page 3 of the USDA GAP Audit.  They are record, policy, and document. A record will show an action was taken (Records (logs) column in worksheet). A policy or standard operating procedure will be documented in the food safety plan (Policy/Documents column in worksheet). A document can be a combination of a policy in the food safety manual and a record showing an action was taken (These are indicated by # in Policy/Documents column in the worksheet). Thus documents can be a combination of a policy and a record. In the USDA GAP audit, there are several instances where an auditor will need to observe to determine compliance (Observations column in the GAP Audit worksheet document). We encourage any comments/responses to this GAP audit worksheet.

Signs, Signs, Signs…

Recently a farmer asked me, ‘where can I get signs for my farm?’ I responded, ‘I am not sure.’ I have one farmer ordering their signs so they can personalize them for their farm. But no one else has asked me this question. So I decided to performed several internet searches and this is the result. My boss recommended Home Depot so that is where I started.

Home Depot – no smoking sign

Safetysign.com – all kinds of signs

Compliancesigns.com – handwashing signs

Healthcaresigns.com – handwashing signs

Justbathroomsigns.com – bathroom signs

Emedco.com – handwashing signs

Staples.com – policy signs