Group Food Safety Audits May Help Prepare You For The Produce Rule

To be in compliance with the Food Safety Modernization Act (FSMA) — the Produce Safety Rule in particular — and meet requirements of buyers, you may very well need to verify you are using Good Agricultural Practices (GAPs) by undergoing third-party verification audits. Of course, these audits create an additional expense and, to some growers, a financial burden.

Ken Petersen

Ken Petersen

To help lift some of the weight for the small- and mid-size grower who may need to undergo an audit to sell produce in the marketplace, a “group audit” effort is in the works. This new program is known as the USDA Agricultural Marketing Service (AMS) Group Certification option for GAP certification, or Group GAP.

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The pilot program for Group GAP was started in 2012 when AMS was approached by the Wallace Center, a nonprofit organization working with farmers across the country and the food hubs, which are defined as an organization managing the distribution and marketing of food from local and regional producers.

American Vegetable Grower caught up with Ken Petersen, chief of the Fruit and Vegetable Program’s Audit Services Branch, USDA AMS, to discuss the concept of group audits and how they may benefit your operation as you implement food safety practices on your farm and prepare for the Produce Safety Rule, which is expected to be released in October.

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1. USDA’s AMS currently offers audits via USDA GAPs and Good Handling Practices (GHPs) Audit Verification Program. How will the group audit fit in with other USDA offerings and when will it be available?

Petersen: This is going to be an additional option for any size farm, but in particular it works well for small- to medium-size producers who are looking to gain market access. We are excited about the pilot program we conducted the last couple of years and are looking forward to next spring when we will unveil it as a full program offering.

Our current GAPs program was a one-audit-per-farm system, which works well for a lot of people, but small groups like co-ops and food hubs, were looking for other options to reduce the cost of audits. [The Wallace Center] got in touch with the AMS administrator and other representatives from the agency and asked us to explore some other options for certification.

2. What constitutes a “group” as it pertains to group audits?

Petersen: We have tried to define group as a general term to be as inclusive as we could. There are some certification bodies that define it as a legal business entity, and we wanted to avoid that so groups that really wanted to come together and work together didn’t have to become a legal entity and deal with those issues.

So we define a group as any group of producers that agree to operate within an established business model that have the operational resources to support and implement a quality management system.

3. What are USDA’s requirements for the group audit?

Petersen: When a group decides it wants to go through group certification, it works with us and the Wallace Center. The process begins by writing a quality management plan. We loosely follow the ISO 9001 standard for quality management systems (QMS). [A QMS is defined as a collection of processes focused on accomplishing objectives to meet customer requirements.]

In general, the process looks at who will be responsible for the group, identifies your food safety plan, and determines who is responsible for each task. For example, if the group is working collectively, farmer X is going to be in charge of doing the internal audits and farmer Y is in charge of training. This is all part of the process for implementing that plan.

Another thing that needs to be addressed is: What are the penalties to the group if someone is not complying? If the group goes out and does an internal audit on one of its members and [that member is] not in compliance, what are the corrective actions that are necessary? We are looking for there to be a robust system in place [for each group] that addresses how it will manage the program and ultimately that the group is performing internal audits of all its members.

4. What are the main requirements to be involved in a group audit?
Petersen: Each participant would still have to implement food safety practices on his farm, but he doesn’t have a lot of the overhead issues he would have to deal with if he had to write his own food safety plan. The farmer can use the group’s food safety plan so he can concentrate on the business of growing produce. Someone at the group level will handle [the food safety plan] and will disseminate that information to each grower.

As part of the group’s system, we come in and audit the group, meaning whatever that central entity is [the core group in charge of the plan], to make sure they have implemented their quality management system and that they have done internal audits of all of their members. In addition, we will audit a percentage of the actual growers in the group just as a verification that the growers have implemented the food safety program that was specified by the group.

Plus, the group has to operate under a business model. There has to be someone who is taking charge of the group. Whether it is the co-op or the food hub, packinghouse, or whatever that entity is, they are ultimately responsible for the Group GAP system.

5. In general, what are the cost savings to the small grower if he opts to be group audited?

Petersen: We have been looking at the whole issue of cost savings and the benefits of group certification and we haven’t finalized specific numbers yet, but the benefit of group certification allows for the growers in the group to share resources and pool resources so they can better meet their needs rather than a group of 100 growers all doing their own food safety training and hiring a food safety specialist.

From a pure audit cost standpoint, if you have a group of 100 growers who were paying for individual certifications versus the group certification, they are seeing a tremendous cost savings on economy of scale.

6. How does the program fit in with being in compliance with the Produce Safety Rule?

Petersen: AMS has been involved with FDA on FSMA and the Produce Safety Rule, in particular. We meet with FDA on a fairly regular basis, and recently we formed a working group that is essentially benchmarking our USDA GAPs program to the requirements of the Produce Safety Rule, once that is final and published.

7. What is the plan going forward to increase awareness about the program?

Petersen: We are developing our communication strategy and we have been doing a lot of outreach. We hosted several webinars earlier this year that were geared toward small- and medium-size farms. We also do field visits to state and regional growers where we have been talking about group certification. Plus, the Wallace Center, with its reach to food hubs, has been touting this project, as well.

To view an USDA AMS video on third-party audits for specialty crops, go to bit.ly/IntrotoUSDASCI.

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