Annalisa Hultberg, Extension Educator, food safety
Are you thinking about selling your produce to a customer like a grocery store, wholesale distribution company or an institutional buyer like a hospital or child care facility this summer? If so, you might be asked for a GAP audit on the product. We have been working with a number of farms this summer that are confused about some of the basics of a GAP audit. Here are some myths and realities about GAP audits.
Myth 1) A GAP audit is required by law
GAP audits are not a law or regulation; they are a voluntary audit that you pay for in order to gain access to some markets that require them. The FSMA (Food Safety Modernization Act) is federal food safety guidelines that are mandatory for some farms.
Myth 2) All schools, hospitals and institutions require a GAP audit
If you are selling to a food hub, school, hospital, or other institution, they may require an audit but they may accept other verification such as providing written food safety plan. Most famers' markets or other direct to consumer sales do not require an audit. Don’t get a GAP audit unless you have a buyer who requires an audit and a certificate for your product! They might take another form of verification of GAPs, like a food safety plan, water test, and farm visit. Talk with your buyer before you get the audit to make sure you are getting one that they accept.
Myth 3) Each product requires a separate audit, making the audit more expensive
Specific crops (e.g. cucumbers, green beans, tomatoes) will be audited, based on what items you want to sell to the buyer that requires the audit. Those crops will be listed on the audit certificate. However the auditor can conduct the audit on multiple crops during one audit, saving you money. They will not have to come back to your farm multiple times for different crops, unless the crop isn’t in the ground when they are there. So getting 6 crops audited is often not more expensive than getting 1 crop audited. Most farms have 5-10 crops audited.
First steps
1. So what should you get audited? This is a management decision your farm will have to make. What can you grow well, and sell large volumes of to a wholesale customer that is requiring the GAP audit? Seek a GAP audit on the crops where it makes financial sense for your farm. If you have a small amount of a particular crop, and you don’t anticipate selling it to a wholesaler, then you would not likely get a GAP audit for that product.
2. Determine what kind of audit is your buyer requiring
There are multiple audit schemes. If you are just starting the process and this is the first time you will be having an audit, start with the basic USDA GAP audit. But check with your buyer to ensure that they will accept this audit. The most current USDA GAP audit checklist is what the auditor uses. The checklist is everything the audit will cover: i.e. you get the test before taking it!
3. Do you have your food safety plan written?
You must have a written food safety plan that covers the policies and practices that represent what you do on your farm. The MDA auditors say it’s easier for them if you write your plan in the same order as the USDA GAP Audit Checklist, and make sure to include the Standard Operating Procedures (SOPs) and records as appropriate for your farm. Use the “Food Safety Plan 4 You” template created by the University of Minnesota Extension On Farm GAP Education Program as a starting point and customize it to fit your operation.
4. Paying for the audit
Audits cost $115 an hour to pay for the MDA auditor’s time and for the USDA to review the audit. You will only complete the sections that pertain to your farm and audit; i.e. if you don’t have a packshed, you would only do parts 1 and 2, not 3, as that is the packinghouse section. Generally the process runs about $300 - $700. The audit needs to be completed annually.
Important: The MDA has a cost-share program that can reimburse you for up to 75% of the cost of the audit once you have the audit certificate, making the out of pocket costs much lower.
Here is a factsheet on navigating the GAP audit process: https://extension.umn.edu/growing-safe-food/navigating-usda-gap-audit-process
To set up an audit with the MN Dept of Agriculture, see contact information here: 651-201-6067 or https://www.mda.state.mn.us/fruit-and-vegetable-inspections
If you have any questions about your food safety plan or preparing for a GAP audit please send us an email at hultb@umn.edu.
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