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A Suggestion To Improve The Draft GAP

Jim Prevor’s Perishable Pundit, January 30, 2007

Here at the Pundit we’ve emphasized that all this attention to form in terms of how industry food safety standards will get developed should be secondary to substance: What are the food safety standards going to be?

As we mentioned in Draft GAP Plan Shows Great Improvement … And Need For More Input , the draft GAP standards circulating for spinach, lettuce and other leafy greens are not as strong as they could be. In fact, as we mentioned in our Pundit’s Letter To The Signatories Of The Buyer-led Food Safety Initiative, the draft GAPs are significantly weaker than the current practices of Fresh Express, the biggest player in the fresh-cut salad business.

As part of our efforts to improve the draft GAPs we’ve offered a $500 honorarium to the person who presents us with the best single idea for an improvement for the draft GAPs. We’ve been talking to many food safety experts and, most, look at the Fresh Express standards and say that they are pretty comprehensive and that given the limits of our current scientific understanding, most experts seem to feel that the industry is unlikely to do much better than just adopting those standards wholesale.

Yet several are working on certain suggestions.

Today, Roy Costa of Environ Health Associates offers his proposal, which is an attempt to help the industry achieve food safety on a more cost-effective basis by suggesting a risk assessment for each field.

It is a sensible idea. Every field in every place does not require the same regimen. Roy proposes to grade farms with a risk assessment of high, medium or low and then adjust the testing plan for each field based on the risk assessment grade:

Good Agricultural Practices Document Review
and Recommendations
“Documenting a Risk Based Approach
to Applying GAP Metrics/Standards”

Proposed GAP Standards and Metrics

A risk assessment can improve the setting of standards and make them more acceptable to the fresh produce industry and more effective when applied. Farmers can determine risk fairly easily if they can identify threats to crop safety, and analyze and quantify the current level of protection. In such an analysis, it is possible to assign a risk value to farms based on existing conditions. Such values provide an additional validating step by providing a risk based system for applying the standards.

We can define a threat as any situation, condition or activity that brings hazards such as microbial pathogens closer or in contact with crops. Farmers can evaluate threats including nearness to cattle operations, size of the cattle operation, contiguous land, up slope/down slope topography, evidence of wildlife intrusion into crops, distance to manure and composting, prevailing weather patterns such as prevailing wind, biological and chemical quality of watercourses, drainage patterns on the farm or nearby, and susceptibility to flooding.

Farmers then document the controls: fences, berms, flood control, well construction, and the protection of water bodies used for irrigation and other safety measures that are in place now.

By analyzing threats and controls, investigators can assign numeric values and classify farms into three risk categories:

Risk Categories: High, Medium and Low

We propose a system of classification of farms based on risk assessment, a system that classifies farms into high, medium and low risk. The classifications proposed are subject to change as better science or regulations come into full effect. But what initial classification could provide are logical methods for applying testing regimens and timetables for compliance, with farmers applying the most critical and immediate interventions, testing, etc., to farms in the high-risk category and less stringent timetables for compliance and preventive measures to those classified low risk.

You can read Roy’s suggestion here. His Curriculum Vitae here.

Many thanks to Roy for taking his time to try to help the industry. His idea of risk assessment might allow the industry to be ultra-rigorous where required but not waste money on unnecessary tests.

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