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Understanding GAPs

Jim Prevor’s Perishable Pundit, November 24, 2008

Our piece, Pundit’s Mailbag — Wegmans Responds to ‘Double Standard’ Allegation, raised the issue of the meaning and reliability of GAPs or Good Agricultural Practices. In search of a better understanding of GAPs, we turned to Trevor Suslow, who is an Extension Research Specialist at UCDavis.

We sometimes think of Dr. Suslow as the Kevin Bacon of the produce industry. Just as Kevin Bacon seems as the very epicenter of the movie industry to those who play "Six Degrees of Kevin Bacon" — where one finds that everyone in cinema is connected to Kevin Bacon typically in four or fewer links — so it seems that every commodity group can be connected to each other by a study conducted by Trevor Suslow. Among other things he is, along with Linda Harris, Associate Director WIFSS, UCDavis, the national GAP coordinator for California.

Trevor SuslowSo we asked Dr. Suslow three questions we had about GAP standards. He was kind enough to let us share his insights with the industry at large:

You pose some very timely and important questions. We spend a good deal of time with diverse groups trying to facilitate dialogue and contribute to science-based information transfer.

Clearly there are no simple answers, and every response requires elaborate qualifications and caveats to provide caution against over-generalization within such a diverse and dynamic industry.

However, I will strive to be uncharacteristically concise to get the gist of my understanding and impressions. Please recognize that where ‘facts’ are few or contradictory, I will be sharing opinion and perspective based on personal observation and experience.

1) Does it mean a lot to be audited to GAP standards? My understanding is that GAP varies dramatically from place to place. Every state has its own GAP, does every county?

GAP programs remain predominantly guidance documents to assist growers and handlers in satisfying expectations of prerequisite programs that are the foundation for more detailed and comprehensive food safety systems. There is a diversity of GAP programs and standards but they do have a high degree of commonality as they tend to plagiarize each other. There is an even greater diversity of emphasis and detail among GAP programs in approaching verifiable standards or specified limits.

Where science or empirical (but well–founded) industry experience fails to provide a data-based control limit or criteria, the resultant GAP guidance tends to be highly variable, worded for convenience, and lacks teeth. Equally, some GAP audit criteria seem to be developed more around what can easily be scored or checked off than what has the greatest potential for prevention and risk reduction.

Comparative reviews of GAP programs have been conducted and the ones that are judged as superior tend to have more audit criteria and more stringent standards or limits. I think it is hard to say whether they are in fact superior in actual food safety risk reduction as there is generally no attempt, requirement, or way to measure a decrease in contamination or pathogen prevalence.

2) Specifically, is it fair for a retailer to say that by requiring California Leafy Greens Marketing Agreement standards out west and GAP standards for a grower in, say, Mississippi or New York, it is requiring substantially identical standards of each? Wasn’t the whole point of all your work after the spinach crisis to go beyond GAP?

In my opinion, applying the same GAP framework for growers of different scales of production and distribution in different regions would be an improvement. However, the applicability of the exact same standards may be overly conservative in one area and permissive in another. Therefore, applying the same standards may not adequately address the risks based on regional hazards and practices.

The Commodity Specific Guidance for Lettuce and Leafy Greens adopted by the CLGMA went further than any public GAP document I am aware of in taking a stand, after several versions, on what specifically constitutes acceptable microbial criteria and limits in many areas. These are not perfect and still evolving but do set the stage to collect performance data upon which some of the future modifications will be based.

The justification for a separate framework for standards and associated ‘metrics’ based on scale of production and marketing remains a highly controversial and emotional issue. Imposing full GAP programs that are predominantly derived from the experience base of major national suppliers seems potentially punitive in the absence of allowing for customization based on comprehensive, site-specific hazard analysis and, at least, baseline risk assessment.

Simply picking acceptable minimal standards that are convenient or modified to accommodate local environments, inputs, and practices without adequate risk assessment seems foolish and inequitable. This is particularly true, I believe, if retailers source from both national and local sources but are unwillingly to pay a premium for compliance with more extensive and typically expensive GAP programs. Ignoring clear risk factors that are common to producers supplying large handlers and shippers as well as direct marketers seems equally unacceptable as requiring costly GAP measures that contribute insignificant gains to public safety.

However, I do feel that a greater degree of risk-based policy and decision-making needs to be applied toward prioritizing resources in view of diverse public goals. The sustainability of local agricultural enterprise and integration of environmental protection with responsible food safety management should be carefully evaluated during the design and adoption of any set of standards.

3) What does it mean for USDA to “audit” — we didn’t realize the USDA has auditors for farms. We think of Primus, NSF Davis Fresh, etc., when we think of auditors. Is this the same?

The USDA has offered a third-party Fresh Produce Audit Verification program for several years. It covers GAPs and GHPs and is very extensive as far as GAP programs go.

In terms of ‘benchmarking’ the USDA Checklist against others that qualify for GlobalGAP recognition, I believe it would easily qualify but as far as I know they choose not to participate. The USDA offers GAP and GHP training of state Department of Ag auditors, which are generally experienced ag-quality and grade inspectors. The CLGMA signatories are required to be audited by the California Department of Food and Agriculture (CDFA), certified and trained by USDA in general and specifically on the CLGMA standards. It is both a document/recordkeeping audit and on-farm evaluation, including spot-audits of labor crews. As with any audit program, the quality of the food safety protection is only as good as the criteria that are the foundation for the standards and performance expectations.

One thing I hear a lot is that the auditors, like TSA in airports, are sticklers with no visible sense of humor with regards to joking about food safety compliance.

We appreciate Trevor’s insights and take from them 10 major points:

1. GAP programs remain predominantly guidance documents to assist growers and handlers satisfy expectations of prerequisite programs that are the foundation for more detailed and comprehensive food safety systems.

We take this to be a big waving red flag that whatever the merits of growers getting involved with GAP, any buyer who specifies GAP and thinks it has secured safe food is making an error.

2. Where science or empirical (but well–founded) industry experience fails to provide a data-based control limit or criteria, the resultant GAP guidance tends to be highly variable, worded for convenience, and lacks teeth.

Unfortunately there are severe limits as to what we know about food safety so this is not a minor point. It is problem big enough to drive a truck through. In the immediate aftermath of the spinach crisis, the buyer-led food safety initiative expressed the frustration of the buying community by demanding food safety metrics that were “specific, measurable and verifiable” — because otherwise, whatever the virtues of growers undertaking to adopt a GAP program, it is useless to a buyer far away who is unable to second guess a growers self-developed food safety program.

3. …some GAP audit criteria seem to be developed more around what can easily be scored or checked off than what has the greatest potential for prevention and risk reduction.

There is a risk with all these programs. In order to seem rigorous, they like to have a lot of criteria. In many cases most of it is of little significance and a focus on it all may be absolutely distracting from what is really important.

4. …applying the same GAP framework for growers of different scales of production and distribution in different regions would be an improvement.

This cuts to the heart of our point that requiring national shippers to meet CLGMA metrics and local producers to have a GAP audit are not equivalent.

5. …the applicability of the exact same standards may be overly conservative in one area and permissive in another. Therefore, applying the same standards may not adequately address the risks based on regional hazards and practices.

Sometimes a “national” standard may be excessively rigorous, and that is a problem but a relatively minor one. It just means we are erring on the side of additional rigor where safety is concerned. The bigger danger is when a national standard does not protect against a local risk.

6. The Commodity Specific Guidance for Lettuce and Leafy Greens adopted by the CLGMA went further than any public GAP document I am aware of in taking a stand, after several versions, on what specifically constitutes acceptable microbial criteria and limits in many areas.

Which is, precisely, what makes it useful.

7. Imposing full GAP programs that are predominantly derived from the experience base of major national suppliers seems potentially punitive in the absence of allowing for customization based on comprehensive, site-specific hazard analysis…

Yes, such programs are burdensome on local growers — but, then again, isn’t doing a high quality “comprehensive, site-specific hazard analysis” also difficult? In fact is this even a real choice? If we don’t enforce objective standards, aren’t we more likely to get highly variable standards that are worded for convenience and without effective measurement and verification than any comprehensive, site-specific hazard analysis effort of quality?

8. Simply picking acceptable minimal standards that are convenient or modified to accommodate local environments, inputs, and practices without adequate risk assessment seems foolish and inequitable.

In every talk we give to local growers we get asked if they can’t be exempted or the standards modified based not on a risk analysis — but based on the burden or inconvenience of the standard to the small grower. This has it backwards, we don’t impose standards to make things tough; we impose standards to accomplish something. If a buffer zone is necessary for safety, then the fact that a farm is small can’t exempt it from that requirement.

9. I do feel that a greater degree of risk-based policy and decision-making needs to be applied toward prioritizing resources in view of diverse public goals.

Sure, let us prioritize. On Monday the food safety people say they want that area paved over, on Tuesday the environmental folks say don’t you dare. We pity the poor farmer trying to deal with a society that can’t prioritize.

10. As with any audit program, the quality of the food safety protection is only as good as the criteria that are the foundation for the standards and performance expectations.

One of the things that really makes us skeptical of the reliability of the USDA GAP Audit is that it allows for a “passing score” at 80% of each category. This makes no sense to us. If something is important enough to audit, then a miss should require a corrective action and a re-audit.

Take the audit the California Tomato Farmers have instituted — the only score that is acceptable is 100%. When it comes to food safety, our consumers have a right to expect that the industry will settle for nothing less.

Many thanks to Trevor V. Suslow, Ph.D. Extension Research Specialist, UCDavis, for being willing to help us think through such a complex and important issue.

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