Name this crop…
How is this crop irrigated?
Irrigation
Water
Surface
Municipal
Well
Microbial
Water Testing
Irrigation
Water
Surface
3x/year
Well
1x/year
(During Production)
Municipal
1x/year
Name this Crop…
Commercial Arizona Cantaloupe: Field Packed
Name this Crop…
Arizona Farm Auditing Program
Good Agricultural Practices and Good Handling
Practices Audit Verification Program
Kurt Nolte
Stewart Jacobson
Karen Edwards
Why Certification?
• Not required by the law….yet
• Minimize the Risk of Food Borne Pathogens within
Specialty Crops. Public Safety
Why Certification?
• Not required by the law….yet
• Minimize the Risk of Food Borne Pathogens within
Specialty Crops. Public Safety
• Buyer-driven
– Produce buyers want food safety programs
– Grocery chains, restaurants, distributors
– Improved Marketability
– Approved AZ Food Source
Food Safety and Farmers Markets
August, 2011
• News emerges of an outbreak of E. Coli 0157:H7 traced to Oregon strawberries,
sickening 15 in a five-county area.
• The Oregon Department of Health responds rapidly, tracing the berries to
Jaquith Farm, from which they were resold at retail outlets, farm stands, and
farmers markets in the region.
• The incident is a case in point why training and education are paramount for
small and mid-scale producers.
• “Customers deserve to know exactly what they are buying, and farmers
markets are responsible for earning and maintaining consumer trust in the
direct relationships with local farmers,” says Stacy Miller, Executive Director of
the Farmers Market Coalition.
November, 2006
The 2006 Outbreak
• September, 2006
– FDA issues “do not eat” order
– Over 200 illnesses traced to California grown spinach
– At least 3 people died of E. coli 0157:H7
The 2006 Outbreak
Determination
• Samples of river water, wild pig feces, and cattle feces tested
positive for the outbreak strain of E. coli O157:H7
The 2006 Outbreak
Determination
• Samples of river water, wild pig feces, and cattle feces tested
positive for the outbreak strain of E. coli O157:H7
• Feces of nearby, open range cattle were found on fields where
the contaminated organically produced spinach was grown
The 2006 Outbreak
Determination
• Samples of river water, wild pig feces, and cattle feces tested
positive for the outbreak strain of E. coli O157:H7
• Feces of nearby, open range cattle were found on fields where
the contaminated organically produced spinach was grown
• It was determined that feral pigs were entering cattle pastures
and came in contact with contaminated cattle feces
The 2006 Outbreak
Determination
• Samples of river water, wild pig feces, and cattle feces tested
positive for the outbreak strain of E. coli O157:H7
• Feces of nearby, open range cattle were found on fields where
the contaminated organically produced spinach was grown
• It was determined that feral pigs were entering cattle pastures
and came in contact with contaminated cattle feces
• In addition to their own feces, feral pigs entering spinach fields
had contaminated cattle feces on their fur which lead to the
cause of the outbreak
The 2006 Outbreak
• Impact on California and Arizona leafy green industry
– Sales plummeted – up to $650 M in losses
– A dramatic wake-up call for the industry
• Food safety standards were high, but the industry
recognized that it could do better
Arizona Leafy Green
Marketing Agreement
California and Arizona are the only 2 states
where leafy greens are grown under a
unparalleled collection of guidelines
The LGMA will likely become the production model
for leafy green growers in the US
Water
Quality
Environmental
Impact
Field
Management
UA Field Level, Fresh
Produce Safety Research
Arizona Leafy Green
Marketing Agreement
Jorge Fonseca
Charles Sanchez
Kurt Nolte
Chuck Gerba
Channah Rock
Kelly Bright
Sadhana Ravishankar
Jeong-Yeol Yoon
Significant Field-Level
Safety Innovations
• Irrigation water metrics
• Animal intrusion metrics
• Reliable and inexpensive rapid methods of
microbial assessments
• Traceability
• Behavioral Change
• Overall risk evaluation
• Arizona GHP/GAP & Audits
Why Certification?
• Not required by the law….yet
• Minimize the Risk of Food Borne Pathogens within
Specialty Crops. Public Safety
• Buyer-driven
– Produce buyers want food safety programs
– Grocery chains, restaurants, distributors
– Improved Marketability
– Approved AZ Food Source
• GROWER Protection
2006 Criminal Investigation Timeline
• October 1, 2006. “Legal experts say the companies do not
need to have known that their products were contaminated to
be convicted of criminal charges, only negligent in their duties
to keep tainted foods from the market.”1
1. USAToday.com
2. NYTimes.com
3. Ecnext.com
2006 Criminal Investigation Timeline
• October 1, 2006. “Legal experts say the companies do not
need to have known that their products were contaminated to
be convicted of criminal charges, only negligent in their duties
to keep tainted foods from the market.”1
• October 6, 2006. “FBI investigated allegations that certain
spinach growers and distributors may not have taken all
necessary or appropriate steps to ensure that their spinach
was safe before they were placed into the food chain.”2
1. USAToday.com
2. NYTimes.com
3. Ecnext.com
2006 Criminal Investigation Timeline
• October 1, 2006. “Legal experts say the companies do not
need to have known that their products were contaminated to
be convicted of criminal charges, only negligent in their duties
to keep tainted foods from the market.”1
• October 6, 2006. “FBI investigated allegations that certain
spinach growers and distributors may not have taken all
necessary or appropriate steps to ensure that their spinach
was safe before they were placed into the food chain.”2
• October 7, 2006. “Processors operated a food-safety program
in which small-scale farmers provided health and safety
inspections and maintained databases of GAP/GHP audit
reports. The company turned over these audit reports to the
FDA and FBI.”3
1. USAToday.com
2. NYTimes.com
3. Ecnext.com
2006 Criminal Investigation Timeline
• June 27, 2007. “The U.S. Attorney General’s office has
determined that criminal charges are not warranted in the
2006 E. coli outbreak linked to fresh, bagged California
spinach.”
Pritzkerlaw.com
2006 Criminal Investigation Timeline
• June 27, 2007. “The U.S. Attorney General’s office has
determined that criminal charges are not warranted in the
2006 E. coli outbreak linked to fresh, bagged California
spinach.”
• “Those involved in the sale of the spinach showed sufficient
written food safety documentation that eliminated
grower/shipper negligence.”
Pritzkerlaw.com
Criminal Charges, 1996
NOT Related to the 2006 Outbreak
• In 1996, an E. coli outbreak linked to organic lettuce did lead
to criminal charges for violating food-safety laws
Pritzkerlaw.com
Criminal Charges, 1996
NOT Related to the 2006 Outbreak
• In 1996, an E. coli outbreak linked to organic lettuce did lead
to criminal charges for violating food-safety laws
• In that case, an E. coli outbreak in the Eastern United States
was traced back to Fancy Cutt Farms in California
Pritzkerlaw.com
Criminal Charges, 1996
NOT Related to the 2006 Outbreak
• In 1996, an E. coli outbreak linked to organic lettuce did lead
to criminal charges for violating food-safety laws
• In that case, an E. coli outbreak in the Eastern United States
was traced back to Fancy Cutt Farms in California
• According to the criminal complaint, organically grown lettuce
was processed in unsanitary conditions that led to bacterial
contamination
Pritzkerlaw.com
Criminal Charges, 1996
NOT Related to the 2006 Outbreak
• In 1996, an E. coli outbreak linked to organic lettuce did lead
to criminal charges for violating food-safety laws
• In that case, an E. coli outbreak in the Eastern United States
was traced back to Fancy Cutt Farms in California
• According to the criminal complaint, organically grown lettuce
was processed in unsanitary conditions that led to bacterial
contamination
• The company was rinsing lettuce in dirty, bacteria-laden water
close to cattle. It was believed that dust-borne manure
contaminated with E. coli got into the rinsing water
Pritzkerlaw.com
What is the GAP/GHP Program?
• Good agricultural practices (GAPs) encompasses
the general procedures growing and harvesting of
crops.
• Good Handling Practices (GHPs) refers to all postharvest procedures including washing, packing,
storage, repacking and distribution.
• Nomenclature Quirks…
– Some use “GAPs” as a comprehensive term
– For others, “GHP/GAP” is a term which describes the
food safety programs.
PREVENTION is the Key to Reducing
Microbial Contamination
of Fresh Fruits and Vegetables
US Produce Safety Programs
AZLGMA
Strict
Industry GAPs
USDA Harmony Gap
USDA Global GAP
USDA GHP/GAP
Lenient
US Produce Safety Programs
AZLGMA
Strict
Industry GAPs
USDA Harmony Gap
USDA Global GAP
USDA GHP/GAP
Lenient
History of GAP/GHP Audits
• 1998 - FDA and USDA issue “The Guide to
Minimize Microbial Food Safety Hazards for
Fresh Fruits and Vegetables”
• Wholesalers want assurance
• Shippers and Growers approach USDA to
develop an audit system
• Result: GAP/GHP Audit system was
developed by USDA and FDA
Audits
• Six components
• Plus a general questions section that must be
passed first in order to move on to one or all
of the six components
• Must score a minimum of 80% to pass
If you did not RECORD IT,
you did not do it
• Record keeping allows you to keep track of
farming operations and worker training.
• Record keeping documents your activities
should this information ever be required.
• Use log sheets for daily activities.
Audit Components
D = Documentation
R = Record
P = Procedure
Policies, Documents and Records…
A policy, “P” indicates that a policy/standard operating procedure
(SOP) must be included in the food safety plan.
Policy Examples:
• Workers will shower daily…
• Eating and smoking are confined to designated areas…
• Gloves will not be taken to the restroom…
• Wearing Jewelry is prohibited…
• Long hair must be tied back and contained within a hair net…
• Product containers are not intended for personal use…
Policies, Documents and Records…
A document, “D” indicates
that a document(s) is
required. A document may be
a combination of a company
policy and a record indicating
that a particular action was
taken.
Policy (example): Restrooms will be
cleaned every 2 hours. Document
shows adherence to policy.
Policies, Documents and Records…
A record, “R” indicates that a record is required to be kept showing
an action was taken.
Seven Components
•
•
•
•
•
•
•
•
General Questions (all audits)
Part 1: Field Production
Part 2: Field Harvesting & Field Packing
Part 3: Packing and Processing Facilities
Part 4: Storage and Transportation
Part 5*: Traceability (Embedded within all other parts)
Part 6: Wholesale Distribution/Warehouse
Part 7: Preventative Food Security Procedures
*Traceback questions are incorporated into each
component.*
General Questions
•
•
•
•
•
Mandatory component of all audits
Covers employee & visitor hygiene practices
Training of employees
Sanitation of farm/facility
Traceability
Part 1 – Field Production
•
•
•
•
Water
Manure
Animal/Wildlife
Land Use
Part 2 – Field Harvest and Field Packing
• Field Sanitation
• Field Harvesting and Transportation
Part 3 – Packing & Processing Facilities
• Water use
• Packing Line Operation and Sanitation
• General Facility Sanitation
Part 4 – Storage and Transportation
•
•
•
•
Containers and Pallets
Pest Control
Temperature Control
Transportation/Loading
Part 5 - Traceability
• Contained within all other audit parts
Traceback
• One step forward, one step back
• If you had to identify a potentially
contaminated load/lot/bin could you find
out which field it came from, how much was
picked, when it was picked, maybe by whom,
and where it went?
• Documentation through record keeping
Part 6 – Wholesale Distribution Center/ Warehouses
Part 7 – Preventive Food Defense Procedures
• Based on FDA’s “Food Producers, Processors,
and Transporters: Food Security Preventive
Measures Guidance for Industry”
• Audit-based
Automatic Failure
• Immediate food safety risk
• Presence of rodents, pets, etc.
• Employee practices that might jeopardize the
safety of produce
• Falsification of records
• No Quality Manual (Question G-1)
• No one designated to oversee an established
food safety program (Question G-2)
GHP/GAP
Training
UA/ADA
Food Safety
Plan
Growers
3rd Party
Audit
ADA
USDA
Certification
Small Farms
• Sales to end users within 275 miles= EXEMPT
• Average annual sales of “all food” <$500,000= EXEMPT
• Farmers markets, roadside stands, CSA’s= EXEMPT
• Exemption withdrawn if foodborne illness is directly
linked to exempted farm
• Food must be labeled w/farm identification--name and
business address of the farm
• Does not preempt state/local food safety
laws or buyer requirements
Audit Fees
• $92 per hour
• $50 administrative fee (each time)
• Billing starts when inspector leaves office
until inspector returns to office
• Grants available
• Travel time can be shared between multiple
producers in same area
GAP/GHP
Where to find GAP/GHP Audit Info
USDA website
www.ams.usda.gov/gapghp
University of Arizona website
http://cals.arizona.edu/fps/