Kentucky Ag News
The reality of GAP certification: The UK experience
University of Kentucky College of Agriculture, Food and Environment
LEXINGTON, Ky. - Many farmers have heard of GAP – Good Agricultural Practices – but few have any experience with the program. The purpose of this short article is to help farmers (and those who work with farmers) understand more about the GAP system in particular and food safety practices and audits in general. We’ll share the recent practical experience of University of Kentucky Horticulture Farm’s GAP audit and certification.
Why should a farmer even care about GAP? One answer is that it incorporates principles of food safety. GAP is a set of practices for farmers to use to reduce the risk of foodborne disease. There are two levels of GAP “certification” for farmers. One is certification that training has occurred and the other more rigorous level is the third-party GAP audit. A third-party GAP audit can be done by the U.S. Department of Agriculture or by an auditor licensed by the USDA Agricultural Marketing Service.
Market access is what drives most farms to get a third-party GAP audit. Wholesalers, distributors, and retailers want to provide safe food and limit their liabilities. One of their liability limiting strategies is to require the producers they buy from to verify that they use good practices. So, farmers who want access to these markets will need to get a third-party GAP audit even though there is no current regulatory requirement for them to do so. (This will change for medium and larger operations when the new Food Safety Modernization Act regulations are released later this year.)
The UK Horticulture farm has about 30 acres of certified organic land in its total acreage. Because UK Dining Services did not have a local supplier of some produce products, it approached the Sustainable Ag program and offered to buy some products until local farms could fill the gap. But, since UK Dining and its procurement partners require GAP third-party audit certification, that meant that we would need to get a third-party GAP audit.
Dr. Mark Williams, Horticulture Department faculty member and organic program manager, made arrangements with the USDA, and an audit was scheduled for June 5. A key element of a successful audit is good preparation. Because this part of the farm is certified organic, good records covering water, chemical and fertilizer use (yes, organic farms do use chemicals and fertilizers), and field histories are maintained.
The GAP audit has seven total sections, but only the relevant ones are evaluated. Since in our situation there is no wholesale distribution center, we could skip section 6. The audit investigated our practices such as water sources, animal access to fields, worker sanitation, storage cleanliness and temperatures, and traceability. The auditor used a straightforward Audit Verification Checklist.
The audit was not an unpleasant experience. The USDA auditor spent from 9 a.m. to 2 p.m. on the farm. She explained that, while this was an audit, it would also be a “conversation” about the practicalities of the practices being assessed. As a result, the audit was a useful learning experience. At the end, she gave us a draft response indicating that we had probably passed – which was confirmed two days later. We learned that an audit is not even close to a visit to the dentist office.
The Kentucky Department of Agriculture has extensive GAP materials and helps administer a cost share program to partially offset the cost of an audit, and will conduct mock audits to help managers prepare. Our audit cost about $2,000 (the cost of the auditor’s time and travel expenses), but for Kentucky farmers, it would be reduced by the KDA/Kentucky Horticulture Council cost share program.
If you want to learn more about GAP audits and the Food Safety Modernization Act regulations, help is on the way. In the near future, we’ll have a workshop at the UK Horticulture Farm in Fayette County. A session is also being planned for the January 2016 Fruit and Vegetable Conference, and written materials and training sessions for farmers and agents are being designed.
This article was written by Lee Meyer, agriculture economist at the University of Kentucky College of Agriculture, Food and Environment, and Mark Williams, a horticulture professor at UK. The article first appeared in the July 29 edition of Economic and Policy Update.
