Produce Safety: Producers

Producer Decision Tree

One way growers can verify their production and handling practices are in accordance with recommended food safety guidelines is to acquire GAP certification through a third party certifying agency like USDA. However, obtaining certification is not mandatory at present, but rather, is driven by whether or not a particular market outlet requires GAP certification. Thus, understanding and knowing specific marketplace food safety and buying requirements is crucial. In addition, depending on farm income and products, specific regulatory requirements may also need to be met; familiarity with the Food Safety Modernization Act (FSMA) and various rules (Produce Safety Rule-PSR; Preventive Controls Rule for Human Foods-PCR) is also important. Regardless of whether or not you need to become GAP-certified or comply with regulatory standards, understanding on-farm risks, implementing GAPs to reduce those risks, and having a food safety plan are important ways to mitigate the potential for contamination and foodborne illness. To provide direction and guide you to the appropriate Producer resources and training you might need, answer the following questions as outlined in the Decision Tree figure shown below:

Producer Decision Tree
An outline of the decision tree you will be guided through. Download .pdf handout

To help guide you in this process and offer more insights, start answering the following questions which will guide you to the appropriate training and resources.

Question 1: Will you make food products out of raw produce?


When taking a raw agricultural product and changing it physically (like milling wheat into flour), or making it into a different form (like strawberries into jam), the addition of processing steps necessitates an understanding of processing food safety principles, practices, and applicable regulations.

Go to Producer Resources: ‘Food Innovations Program’

Question 2: What market outlets will you sell your produce to?

We are assuming here you are selling your products to distributors, such as food hubs, aggregators, or wholesalers, who in turn resell your products to retailers, institutions, or other businesses, or to market outlets where the purchaser represents an end consumer (public schools, universities, retailers, restaurants, etc.). Typically, quantity, quality, availability, and other requirements, like food safety, are more stringent, in which some wholesale buyers will not purchase product unless a farm has successfully passed a third-party GAP audit and is certified. They may also require liability insurance. Even when certification and liability insurance are not needed, often a bare minimum of basic food safety training and practices is required.

Go to Question 3

If you sell your agricultural products directly to the general public, through roadside stands, farmers markets, CSAs, and You-Pick operations, GAP (Good Agricultural Practices) certification is not required. It is still important for you to demonstrate knowledge in food safety risks and to implement best food safety practices.

Go to Question 4

Question 3: Does your buyer require third party GAP audit and/or will you be covered under the FSMA (Food Safety Modernization Act)?


It is crucial to foster good communication and ask your buyers what specific food safety requirements they have, so you can determine whether or not you really need to become GAP-certified and/or if you need to be in compliance with FSMA regulation. GAP certification preparation is an extensive and tedious process, requiring a large investment of time, energy, and resources. There may also be cases where your farm is already GAP-certified, but you still need to comply with the Food Safety Modernization Act (FSMA) regulations, i.e. Produce Safety Rule (PSR) and/or Preventive Controls Rule (PCR). Both rules require specialized training, documentation, and practices that are involved and can be costly. Make sure to get as much guidance as you can and understand what is involved so you can make the most informed decisions.

Go to Question 5


If you are not required to have GAP certification and/or comply with FSMA regulation, it is still wise to be trained in food safety risks, to implement GAPs, and to develop a simple written food safety plan. Having a plan in place provides documentation and is also important if you scale up and move towards GAP certification and/or FSMA compliance.

Go to Producer Resources: ‘Risk-based On-Farm Food Safety Principles’ and ‘Food Safety Plan Writing’

Question 4: Are you interested in developing a written Food Safety Plan?


Having a written food safety plan in place provides documentation and is also important as you scale up, sell to other markets, and move towards GAP certification. In addition to plan writing, it is wise to be trained in food safety risks and GAP.

Go to Producer Resources: ‘Direct Market Food Safety’ and ‘Food Safety Plan Writing’


Even if you do not want to develop a written plan at this time, the Enhancing the Safety of Locally Grown Produce training has both on-farm and marketplace materials geared to market produce vendors and market managers. It is an excellent training for growers who do not need to pursue GAP certification or want a written food safety plan. The curriculum is well laid out and easy to use, with printed materials for both audiences, as well as certificates of completion that you can display at market or use as documentation of your food safety training.

Go to Producer Resources: ‘Direct Market Food Safety’

Question 5: GAP Audit or FSMA-compliance?

Question 6: Buyer(s) accept USDA GAP/GHP/HGAP?

Depending on the specific buyer, there are different food safety audits that may be required, i.e. USDA GAP, USDA HGAP, Global GAP, Primus Lab, etc.. In Virginia, VDACS is the independent third party that acts on behalf of USDA. Other schemes include Global GAP, GFSI, etc., and follow a different checklist of questions, although the principles covered are very similar to the USDA-based audits. The costs for these various schemes differ, as do the specific requirements that need to be met. Further, VDACS does not perform these specific audits. It is imperative that you make sure to ask each prospective buyer what specific audit they require before embarking on GAP audit preparation since certain schemes may not be acceptable. VCE resources include templates and supporting documents for USDA GAP and HGAP audits, since other audits are far more extensive and expensive.

Go to Question 8


If you need to have an audit scheme other than a USDA-based audit, the preparation process and general focal points for these audits is similar (i.e. worker training, water quality, soil amendments, wildlife control, equipment/facilities, handling). However, the checklist of questions is different.

Go to Producer Resources: ‘GAP Preparation other than USDA-Based Audits’

Question 7: Are you covered by FSMA Produce Safety Rule and/or Preventive Controls Rule?

The Produce Safety Rule establishes science-based minimum standards for safe production and harvesting of fresh fruits and vegetables. These standards are based on a foundation of Good Agricultural Practices (GAPs). The rule is divided into several parts, including standards for worker health, hygiene, and training; agricultural water, both for production and post-harvest uses; biological soil amendments (e.g., compost, manure); domesticated and wild animals; and equipment, tools, buildings, and sanitation. There are stringent guidelines and requirements set forth by FDA, and only certified trainers can provide you approved PSR training.

Go to Producer Resources: ‘FSMA Compliance PSR and links’

Under the FSMA, human and animal food facilities are required to develop food safety plans that evaluate food safety hazards, and identify the preventive measures to guard against those hazards. The plans must also describe how manufacturers will monitor their preventive measures to ensure they are working, and keep records of that monitoring. Manufacturers also must develop a plan of action to correct problems. There are stringent guidelines and requirements set forth by FDA, and only certified trainers can provide you approved PCR training.

Go to Producer Resources: ‘FSMA Compliance PCR and links’

There are many ins and outs for the FSMA PSR and PCR. In addition to the general resources provided here, please contact the FPFS Team for more support.

Go to Producer Resources: ‘FSMA Factsheets and Flow Charts’

Question 8: Is your farm already GAP-certified?


If your farm is already GAP-certified, the certification is only valid for one year from the date of the audit. You will need to make sure to update all plan of action materials, training, on-farm compliance, and schedule a time to be recertified. VCE can help you with this process.

Go to Producer Resources: ‘GAP Recertification Training’


If your farm is not already GAP-certified, then you can work with VCE to prepare your plan of action manual, implement GAPs, and prepare for your audit.

Go to Producer Resources: ‘GAP Certification Mentoring’

FAQ On Farm Food Safety