Update on GAP audit snafus
Editor’s note: This article is from the archives of the MSU Crop Advisory Team Alerts. Check the label of any pesticide referenced to ensure your use is included.
During this first year of USDA GAP audits in the fruit industry, the learning curve has been steep. However, many growers have passed their audits successfully. Those growers that have been through the USDA GAP audit process have helped us construct the following pointers based on their experiences. We hope this continued collaboration will result in further audit success. Due to the differences in GAP manual organization, these suggestions are listed under the section names utilized by the USDA GAP and GHP Audit Verification Checklist.
Implementation of a food safety program
Maps. Indicate on your maps how you or your farm workers identify the individual blocks. For example, if you have an aerial photo, simply identify (whether it is by number or name) each block. You can simply handwrite the information on the picture/document. This step is an important part of satisfying Questions G1 and G2 and is also important for Part 5 – Traceback.
Worker health and hygiene
Farm policies checklist. A grower had a file of his signed Spanish farm policy pages in a file folder, but when the auditor looked at the file folder he could not understand the policy pages as he was not fluent in Spanish. Growers should make sure to include a copy of the English version of the policies as well the Spanish version to ensure the auditor knows what the checklist or policy the workers were signing includes.
Field Harvest Visitor Policy. Growers should instruct the auditor to follow the guidelines set up in the Field Harvest Visitor Policy, which may include washing hands before beginning the inspection. The auditor may be looking for this request and you will be demonstrating your Visitor Policy (G7).
Field sanitation facilities. Wording in this section of the food safety plan should be amended to define how often the facilities are serviced (cleaned, pumped out, etc.) to satisfy Question G10.
Product contamination from blood/body fluids. At this time, there is variability between MACMA and MSU manuals on this point, but the policy wording should include the following verbiage “destroy the product, clean any equipment, and remove/replace any clothing that may have been contaminated” in order to satisfy Question G13.
Manure and municipal biosolids
If your farm does not use manure or municipal biosolids (Option C as defined in the USDA Audit), include a policy in the plan that states that no manure or biosolids are utilized in order to satisfy Question 1-22. Remove the other pages under this tab that reference Options A or B.
Field harvesting and transportation
Light bulbs and glass. Clear packing tape placed across the light bulbs would be considered taking steps to satisfy Question 2-9 and protect the produce in case of breakage.
Be sure to include a completed bin/tank tag as an example - a blank tag will not work. All bins should be tagged in the field or before they leave the farm as part of your policy for “traceback.” You should include a policy for traceback as well as a mock recall procedure (an example of a mock recall can be found in the MSU USDA GAP manual under the Traceability Policy). Include this policy or a similarly crafted policy in the manual that fits your operation.