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Draft GAP Plan Shows Great Improvement…
And Need For More Input

Jim Prevor’s Perishable Pundit, January 17, 2007

United, PMA and WGA — with the help of many in the industry — have been hard at work drafting the revised version of the Good Agricultural Practices (GAP) document for spinach and leafy greens.

The current version of the GAP document in force in the industry can be found here.

The current version, published in April 2006, has been widely criticized as being watered down and non-specific. So, for example, when looking at an issue such as animal encroachment, the current version gives a vague list of “things to consider,” so you will get lines like this:

If unusually heavy wildlife pest activity or evidence of wildlife pest activity occurs (e.g., presence of wildlife feces), consider whether or not to harvest affected portions of the field.

What standards to use in one’s consideration? When would it be OK to harvest and when not? The current GAP document is silent on these issues.

A team of top people in the industry has developed a draft to be used as the core of the new Good Agricultural Practice document for spinach and leafy greens. You can read the draft here.

We’re posting the draft in the hope that the many readers we have with interest and expertise in this area will review it and contribute your thoughts on how it can be made better. This includes the many experts outside the U.S. who deal with such matters.

Last time the associations drafted this document, it was really “inside-baseball.” Barely anyone outside of the government and the industry even noticed.

This time, however, we can count on withering scrutiny of this document once it is published. And we are not just talking about scrutiny in the trade; consumer media, consumer advocacy groups and others will be analyzing this as well.

In order to encourage thorough analysis of the document, PerishablePundit.com will offer $500 to the person or persons who write the Pundit with the best single suggestion for how to improve the GAP draft. The Pundit may not always be correct, but our judgment is still final — at least on this competition.

Our quick take:

The document is filled with much more specific requirements, procedures and “decision trees” — or “go/no go” analysis — in making various decisions such as should you use this water or harvest this crop.

There are a lot of specific numbers — 20 feet from the edge of a pond, 500 feet from the edge of a concentrated animal feeding operation, no raw manure on the land for a year, etc., but also an acknowledgement that most of the specific numbers have no real scientific basis.

Without doubt, it is a much more thorough document than the existing one, and those involved should all get a round of applause for helping the industry.

At the same time, it seems immensely difficult for farmers to follow. This is a problem because if it is too hard to follow, it won’t be followed.

There is a continuing reference indicating that if various procedures aren’t followed, the product can’t be marketed as “ready-to-eat produce.” This is a little unclear but seems to leave open the door to selling it as raw produce — head lettuce instead of fresh-cut lettuce. We can’t see how that will fly with consumers.

We are a little concerned that too much depends on growers acting against their economic interest. For example, in one of the decision trees, it asks this question:

If animal intrusion is suspected (i.e., a broken fence, but no tracks due to recent rain), food safety assessment should be performed by qualified personnel. The following information is important to make a decision regarding remedial and corrective actions:

  • Type of animal
  • Extent of intrusion
  • Crop area affected

Can remedial action be formulated that controls or eliminates the identified risk?

If the answer is no, the decision tree says:

Production block should not be marketed as ready-to-eat commodity.

The idea is fine but the temptation for a farmer to not notice something is pretty strong.

The draft also makes a lot of requirements for document and record storage but no actual procedure to make sure that these documents are available 24/7/365.

From a marketing perspective, we are concerned that the rules are so complex that consumers won’t be able to appreciate them and so they won’t build public confidence in the way simple rules might be interpreted: all fields must be fenced, no manure of any type, etc.

Yet these concerns, though real, are quibbles. This is a giant step ahead for the industry. Tom Stenzel, President and CEO of United Fresh, Bryan Silbermann, President of PMA and Tom Nassif, President and CEO of Western Growers Association, deserve an enormous hand for shepherding the industry to this point.

Now let us all, working together, take it even higher. We want great ideas from around the world to help make our fresh produce supply as safe as it can be. Read over the document and you can send your ideas to us through any of the e-mail addresses on the site or by clicking right here.

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