The N.C. MarketReady Fresh Produce Safety – Field to Family program offered a mock third-party audit to educate N.C. Cooperative Extension agents and growers on the requirements for GAPs certification.
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As concerns about food safety increase, farmers are experiencing more pressure than ever to minimize risks when it comes to fruit and vegetable production. As a result, they are encouraged to become GAPs certified. GAPs stands for Good Agricultural Practices and is a key component of food safety measures required by some produce buyers, such as grocery stores. Buyers consider GAPs certification an important step to help minimize the risk of pathogen contamination in the food supply chain.
North Carolina Cooperative Extension is working with growers across the state to help them learn more about third-party audits required for GAPs certification. In late July, Cooperative Extension presented a mock third-party audit at Premier Produce in Wilson. The mock audit was conducted by Michael Fagan and Brooke Stephenson of the North Carolina Department of Agriculture and Consumer Services. Throughout the audit, growers and Extension agents engaged in open dialogue with the auditors about the process.
Premier Produce was in the midst of cantaloupe harvest at the time of the mock audit. David Harrell, field manager, and Sarah Lancaster, office and packing house manager, were on-hand to discuss the operation, answer questions and participate in the educational audit. Premier Produce has been audited in the past as required by their contract buyer and is currently GAPs certified. This year the company anticipates yields of 1.2 to 1.4 million melons from 180 acres.
The audit process begins when a grower contacts a 3rd party auditor, like the North Carolina Department of Agriculture, to request GAPs certification. This mock audit used the USDA GAPs audit matrix and the NCDA auditor’s criteria. An audit may change depending on which matrix and third party auditor the grower works with. When initiating an audit, the grower will be asked to send the auditor records, such as an aerial map that shows fields and facilities. These maps may help identify potential sources of contamination in proximity to the production area. An auditor works with the grower to schedule a visit when the produce is being harvested. It’s up to the grower to specify which commodities and which fields or packing facilities he or she wants certified.
On the day of the auditor’s visit, the auditor will review the grower’s food safety plan before the inspection begins. The auditor will assess whether the grower has implemented all items outlined in the food safety plan. The auditor then uses a “matrix” where areas of potential concern are assigned a value and points are awarded for compliance. GAPs certification requires that 80 percent of the possible points are awarded. The inspection includes the physical assessment of each field or facility being considered for certification. The auditor will observe harvesting operations and may question the harvest crew to ensure that they have a working knowledge of the food safety plan.
The auditor is not a regulator; rather, the auditor assesses the grower’s food safety plan content, implementation and supporting documentation. For example, at Premier Produce, the food safety plan requires each field worker to wear gloves, apron and a hat or hairnet. The auditors observe that all field workers are following the policy, but they do not stipulate what the policy should or should not entail.
The field assessment also includes an evaluation of field equipment. Tractors should be clean with no fluid leaks and all light covers in good repair to avoid glass breakage in the packing bins or anywhere in the product flow zone. The product flow zone is anywhere the produce travels from field to end transport. The auditors also do a visual inspection for bin cleanliness. Nothing should be in the bin except produce; however, it is common practice to designate one bin for trash. A trash bin should be clearly marked with bi-lingual signage.
While it may be common practice to throw cull fruit in field aisles, it is never acceptable—and may result in an automatic audit failure—if partially eaten fruit is observed in the field or anywhere in the product flow zone. Visual inspections can easily identify bite marks in partially eaten fruit. Additionally, no outside food should be allowed in the product flow zone, with the exception of drinking water. Premier Produce uses municipal water in the packing house and for drinking water in the field. Annual documentation from the municipality asserting the water quality is required for the audit. At Premier, irrigation water is supplied from a pond that is on-site. The pond water is tested monthly during the growing season for a variety of pathogens including generic E. coli. Given the open source nature of the pond, it is difficult to deter domestic animals and wildlife. Since Premier has made no efforts to prohibit wildlife from the pond, due to cost considerations, the company would not receive the points associated with that item on the matrix.
According to current North Carolina Department of Labor regulations, one toilet and hand-washing facility should be available for every 20 workers, no more than one-quarter mile from the field. Auditors carefully examine the portable toilets for cleanliness, including a schedule of cleaning and maintenance. A hand-washing station must also be near the toilet, where the auditor will check the availability of water, soap and paper towels. Signage, in appropriate languages, reminding employees of hand washing is a must. Auditors will also be interested in a response plan for spills or leaks for the sanitary facilities to ensure waste does not flow into the field or the irrigation pond.
There are several reasons an audit can automatically fail. Examples include: the presence of an immediate food safety risk, evidence of pests, unsanitary conditions and falsification of records. At the point when an automatic failure is observed, the audit will stop and the grower will be issued a corrective action form. The grower will determine which measures must be taken to correct the problem and reschedule the audit. GAPs certification is valid for 365 days from the date of certification. During that time, the grower agrees that the auditor can make one unannounced visit.
Premier also shared information about their traceability system. For example, harvest bins in the field are tagged with a card that identifies the variety, block number, crew identification and harvest date. As the melons move through the packinghouse a coded sticker is applied to: each cantaloupe, the case and the pallet.
In keeping with their food safety plan, Premier representatives asked everyone who entered the packing house to wear a hairnet.
The mock audit was coordinated by Diane Ducharme, GAPs Program Coordinator and Extension Associate in Horticulture & Food Safety with the Program for Value-Added & Alternative Agriculture. For more information about fresh produce safety and GAPs certification, visit other sections of this Web site.
