Frequently Asked Questions

Click on the questions below to see answers.

One way growers can verify their production and handling practices are in accordance with recommended food safety guidelines is to acquire a Good Agricultural Practices (GAP) certification through a third-party certifying agency like USDA. GAP certification entails creating a written food safety plan, incorporating best practices and strategies, and documenting them as part of a farm’s food safety program. Obtaining certification is not mandatory, but instead, is driven by whether or not a particular market requires GAP certification. Understanding and knowing specific marketplace food safety and buying requirements is crucial.

There are many different kinds of audits a grower can obtain.  It all depends on the market and what they require. USDA has several different audits including the GAP, Harmonized (H) GAP, HGAP Plus, and the GroupGAP. Other audits include GlobalG.A.P., SQF, Primus GFS, and Canada GAP.  The other non-USDA benchmarked schemes can be quite costly to obtain, but may be mandatory depending on the particular marketplace you want to tap into and the specific requirements of that market. As is true before diving into any audit preparation, it is important to do your homework, talk with your buyers, and explore all of the possible options available to you. Like with anything you do related to your business, understanding all the pros and cons of any decisions are critical.  In some cases, you may find it is wiser to look at a different market, should the food safety certification hurdles be too costly given the returns.

GroupGAP provides the entire specialty crops industry the opportunity to supply and buy fruits, vegetables, and related products that are certified as being produced using Good Agricultural Practices (GAP).  Unlike other USDA-based “one farm-one audit” certifications, GroupGAP allows farmers, food hubs, and marketing organizations of all sizes to band together and pool resources to achieve USDA GAP certification. For more information about GroupGAP, refer to the NASDA GroupGAP Toolkit.

GFSI builds consensus amongst expert stakeholders representing the global food industry to collaborate on advancing food safety.  An essential part of that goal is to create a common and widely-accepted understanding of what constitutes a good food safety system. The term “GFSI Certification” is often used in reference to certification to a GFSI-recognized certification program; however, GFSI is not a Certification Program in itself, neither does it carry out any accreditation or certification activities. The GFSI’s Benchmarking Requirements, is a tool used to provide a benchmark document for food safety requirements.  Once successfully benchmarked against GFSI’s Benchmarking Requirements, food safety certification programs achieve GFSI recognition, which lends a nameplate authority to these certifications and acts as a food safety passport of sorts throughout the global marketplace.  Some of the GFSI-recognized certifications include GLOBALG.A.P., PrimusGFS Standard, and SQF, as well as the USDA Harmonized GAP Plus + program.

GLOBALG.A.P. globally connects farmers and brand owners in the production and marketing of safe food to provide reassurance for consumers. The GLOBALG.A.P. Standard sets very strict criteria for Good Agricultural Practices that farmers must comply with if they want to sell their products to major retailers around the world. Many retailers rely on GLOBALG.A.P. Certification to ensure that the products they sell to their consumers can be traced back to a certified farm or production facility.

Typically, we recommend attending a food safety training in which we discuss associated on-farm contamination risks and practices that mitigate those risks. We then like to conduct an on-farm hazard analysis by coming to your farm to see your process from planting through harvest and post-harvest handling. This helps to guide the next steps of the process, which include the development of your food safety manual (which we have templates and good starting points for), as well as implementing on-farm practices. Once these steps are completed, we suggest a pre-audit walkthrough to make sure everything is in place before scheduling the audit inspection. Concurrently, we encourage you to submit required paperwork to USDA and schedule a date with VDACS for the actual audit, in which they will review your food safety plan/manual and walk around the farm to make sure that all the steps have been taken to be compliant as specified in the manual. Once the audit is complete, you can discuss any problem areas and make adjustments. VDACS will send USDA all audit paperwork. They will then review and make final approval assuming everything is in order.

Costs of audits vary depending on what audit you get.  The USDA GAP and Harmonized GAP audits are cheaper than other audits like Global GAP or GFSI audits.  In Virginia, VDACS acts as the third party on behalf of USDA to conduct the actual audit, and the charge includes travel time, audit time, and in office processing. In addition.  In addition, USDA charges a fee for handling the audit paperwork once received from VDACS.  Both costs are based upon a fee structure set up by USDA, so it is important to consult the USDA GAPs Program website for current fees.  It is important to remember, there are also associated costs with readying your farm to be GAP-compliant, such as water testing, water treatment (if necessary), signage, developing worker wash stations, eating areas, traceability codes (stamps or labels), etc. You will also need to consider the time spent preparing your food safety manual including all the required documentation you need to pull together.

Unfortunately, GAP-certified product does not guarantee a higher pay-off. This is especially true at the wholesale level vs direct market level. Having said that, one thing that GAP certification may do is open new markets that would otherwise be closed since more and more buyers want some sort of assurance (as much as is possible) that a grower is doing their best to provide a quality and safer product. Being GAP certified is one way growers can show buyers that they are making concerted efforts to take food safety seriously. It is also important to recognize that more and more buyers are requiring some sort of food safety plan and documentation or verification of practices. While a grower can never totally eliminate risks, growers knowing their risks, implementing best practices, and having documentation often increases the quality and uniformity of their product and is definitely a plus in the marketplace.

While we might assume that someone with a passed GAP audit has a safer product, this just is not true. In fact, some of the worst fresh produce foodborne illness outbreaks were linked back to farms that had successfully passed their food safety audits. Audits are a single snapshot in time.  Commitment to food safety needs to be a deeply rooted value that drives a farm’s philosophy and approach. So, regardless of what market you are selling to or whether or not you become GAP certified, what is more imperative is to understand the potential contamination hazards and ways that contamination can occur on farm during production, harvest, and post-harvest handling stages. Once you have assessed your farm in this way, you can then incorporate GAPs to reduce and mitigate risks.

It is important to remember that for any given farm getting certified, you specify which crops you want to be certified. While some farms do get all of their produce GAP certified (i.e., ‘mixed vegetables’), some farms opt to focus on a particular crop instead. This provides flexibility for a farm and also allows a farm that may be incrementally scaling up their food safety efforts, to do so at a more measured pace (i.e., to focus on particular crops at first and gradually include more crops in future audits). A key with this approach is to make sure that there is some sort of physical segregation of product, and to also make sure that GAP produce is not co-mingled with non-GAP produce. Regardless of what crops are certified, every farm should foster a food safety culture in which there is a thorough understanding of food safety risks and routes of contamination, and incorporating best practices to reduce risks.

Yes!  There are many farms that are GAP certified that also have integrated livestock along with fresh produce. The key is to make sure that all the food safety risks are understood, that any cross-contamination concerns are addressed, and that best practices are put into place. Consider all production practices, harvesting, and postharvest handling, and look at each and every step of your processes, so you can identify where the hazards are and put practices into place that will address and minimize those hazards. Because cross contamination is such a potential problem in mixed operations, it is important to make sure workers, boots, clothing, tools, equipment, tractors, etc.., do not become a means for fecal contamination.

Often growers assume that being GAP certified is not possible with an aquaponics operation. While aquaponics operations do pose unique risks, it is possible to be GAP audited. Aquaponic farms pursuing a USDA audit, must use the HGAP or HGAP Plus audits. USDA has provided information specifically for aquaponic operations including monthly water testing, physical separation of fish from plants, etc. There is also more information under Controlled Environment Agriculture (CEA).

Does My Farm Need GAP Certification?

A common question we are often asked is, “Does my farm need to be GAP-certified?”  To answer this question, it is important to consider market access.  While a food safety audit is an absolute necessity with some larger retailers or wholesalers in order to sell product to them, other buyers, like restaurants, public schools, and direct sales venues like roadside stands and farmers market, typically do not require a food safety audit. Since requirements can vary within market sectors, talking with your prospective buyers first and asking them what they need in the way of food safety training, documentation, audits, and liability insurance, will provide direction and can save you a lot of unnecessary time, energy, and money.

You may use the “VCE Producer GAP Certification Inquiry Form” to look at your market(s) and explore what they require in the way of food safety practices, training, documentation, and verification. You can then send the form to the Fresh Produce Food Safety Team and/or your local VCE agent. Once received, VCE will review the form and discuss next steps with you about whether or not your farm needs GAP certification.

Audit Preparation Process Steps

Once you determine that you need to become GAP certified — based on your markets — there are a series of preparation steps to follow:

Assessing On-Farm Risks
The first step for preparing for your audit is to assess the on-farm risks as outlined in the Assessing On-Farm Produce Safety Risks section.  While the factsheet series has comprehensive checklists to consider on-farm risks, you may wish to use a simpler questionnaire as you get started.

Manual Preparation
The next main step is to prepare your food safety plan or manual.  Virginia Cooperative Extension has created manual templates for the USDA GAP, HGAP, and HGAP+ audits. The templates include the core elements needed for a food safety plan and provide an excellent starting point as you pursue certification. Given the complexity of the audit preparation process, we encourage you to work closely with the VCE FPFST or your local agent, so they can mentor you. The templates are available on Google Drive. Please contact Amber Vallotton at avallott@vt.edu , Ashley Edwards at aledwards@vt.edu, or Joanne Jones at jojenki1@vt.edu for more information.

On-Farm Implementation
As you are developing your food safety plan, it is important that you implement food safety practices in your operation and document that they are being performed. This means making any on-the-ground changes to infrastructure and product flow, as well as incorporating specific practices into the daily activities. It also means completing records at the appropriate times, following all cleaning and sanitizing procedures at their scheduled intervals, conducting water sampling and recording the results, as well as documenting any corrective actions that need to be taken.

Pre-Audit Walkthrough
To make sure you have addressed all the audit questions and have practices in place prior to your audit, it is helpful to conduct a pre-audit walkthrough or “mock audit” with your VCE Extension agent. The checklist at the end of the Assessing On-Farm Produce Safety Risks: Preparing for GAP Certification factsheet (FST-406NP) has been developed to help you with your walkthrough and follows the various questions contained in the audit checklists.

Walk through your fields or greenhouses and ensure the questions are addressed in all production, packing, and post-harvest handling areas. Make sure your logs and other records are easily accessible and filled out.

  • Are workers following the food safety protocols they learned in training?
  • Are your animal mitigation measures working?
  • Do you notice any issues with your water system?
  • Does your tested water satisfy appropriate microbial quality standards, and if not, are your water treatment measures correcting issues (verified by re-testing)?
  • How clean is your packing shed and/or packing facility?
  • Have you conducted a mock recall to test the effectiveness of your traceability program?
  • Do you have all required documentation needed to support your activities?
  • Is signage posted where needed?
  • Overall, is the farm ready for an inspection?  If there are any last-minute items to address, do so before the scheduled audit date.

Submitting Paperwork and Scheduling the Audit
Concurrent with working on your food safety plan manual and on-farm implementation, you will need to complete and submit the SC-430 Vendor Form to USDA/Agricultural Marketing Service. This will establish a billing account with USDA/AMS. If you already have an account but something has changed, you will need to re-submit the SC-430 Vendor Form with the updates.

Once your manual is nearing completion, all standard operating procedures are written and being followed, and applicable records are being kept, you should request an official audit. In Virginia, USDA audits are administered through the Virginia Department of Agriculture and Consumer Services Division of Commodity Services. VDACS inspectors act on behalf of the USDA to perform the official audit as an independent third party.

As a part of the official request for the audit, you will need to complete and send them Form SC-237A (USDA Agricultural Marketing Service Request for Audit Services Form) and the Agreement for Participation in Audit Services Form SC-651. The VDACS office will contact you and confirm the receipt of your request, give you more information about the program procedures, and schedule your audit.

Audit and Post-Audit Follow-Up
The day of the scheduled audit, the VDACS inspector will conduct an on-site inspection, in which they will review your food safety plan, supporting documents, and on-farm compliance. As they go through the audit, be prepared to answer any questions needing clarification. Once they conduct the site visit, they will send the completed paperwork to USDA AMS to review and finalize the certification. Once finalized, USDA puts the farm on their USDA AMS website, which lists all farms in the U.S. that have successfully passed their USDA GAP and HGAP audits. The listing is searchable by state and by commodity, thus providing a service to those farms certified. Keep in mind there can be a lag time between the audit date and this information being uploaded to the USDA site.

After the initial farm audit inspection occurs, an unannounced visit is possible within the remainder of the growing season. If the auditor left you with any areas that required corrective actions, it is important that you address and document actions so that you are ready for any follow-up visits.

Previous manuals and records must be retained for three years. It may be helpful to store previous records in separate binders and label them by the audit year.

Remember that your plan of action manual is what we call a “living document,” and should be updated as you make any changes during the growing season and from year to year. Be sure that any changes are appropriately documented. For any subsequent audit, always have the previous year’s audit manual on hand in case the inspector wants to see that any changes or corrective actions were documented.

GAP Certification Resources

Assessing On-Farm Produce Safety Risks Video Modules
Module 1, 8, and 9 of this series provides important information pertaining to GAP certification. The other modules (2-7) are helpful in performing a hazard analysis and identifying risks at each stage.

USDA Agricultural Marketing Service Audit Verification Program
USDA AMS main page to their Good Agricultural Practices (GAP).  Links to USDA GAP, HGAP, HGAP Plus, GroupGAP, and other audit schemes.  Also lists certified farms by commodity and state, plus much more.

GAP Certification Programs: Removing Barriers to USDA GAP Programs website
Amber Vallotton collaborated with the NASDA Foundation to create a GAP Certification Programs overview, which includes the “Assessing Risks” factsheet series, along with helpful guidance, tips, and resources. This is an excellent tool to help guide you!

Bridging the GAPS Farm Guide: Good Agricultural Practices and On-Farm Food Safety for Small, Mid-Sized, and Diversified Fruit and Vegetable Farms
Though a bit dated, this is a really nice guide to creating a plan of action manual by the Washington State Department of Agriculture.

Good Agricultural Practices for Small Diversified Farms: Tips and Strategies to Reduce Risk and Pass an Audit
A guide written by NCSU and the Carolina Farm Stewardship Association, which provides many tips for working through the audit process.

GAP Recertification FAQs

Click on the questions below to see answers.

USDA-based recertification is a yearly process since the initial certification is only good for one year from the date that the audit is conducted and the official paperwork is verified by USDA.  It is important to plan ahead and make sure to anticipate recertification steps for the next year.  For other certifiying bodies other than USDA, please check with them directly to find out their requirements for recertification.

There are two main areas of focus for recertification: (1) Updating and revising your food safety plan manual, and (2) aligning your on-farm practices with any changes noted in your manual.  Since the manual is your farm food safety plan and documents the policies and practices that you are using to mitigate risks of contamination to fresh produce, it is a fluid document since your farm is never static. To recertify you must regularly update when and if any changes occur on the farm, i.e. new crop locations, crops grown, how they are grown and harvested, how they are handled, new workers, any changes to facilities, etc.  Those changes must then be incorporated in all of your practices, and, of course, documented!

The first step in the manual update is to get a broad overview of any changes that have occurred on your farm, as compared to last year, which will help provide some orientation as to what needs to be updated in the manual.  Once this initial step is done, then it is important to work through the checklist questions for each pertinent section, one by one, and as needed, update the manual accordingly.  Additionally, any changes to policies for the current growing season need to be reflected in updated standards and accompanying record log sheets to support the manual.  Important documentation will need to be updated including obtaining new water analyses for irrigation and wash water sources; records for handling of soil amendments such as manure and compost; employee training; updating and/or replacing any signage; replenishing first aid kit contents; facilities and equipment changes; and updates to the traceability system.

One way to maintain and store documentation is to take all records and supporting documentation from the previous season, place into files or notebooks (or whatever system works best for you), and label for that growing year.  Records would include water tests, farm maps with traceability system notes, invoices, and filled in record/log sheets.  Materials should be organized, preferably following the same system you use for your current food safety plan manual.  The previous year’s files or notebooks should be kept in a clean, dry place, like in a filing cabinet, and should be handy for the current year’s audit.  You will need to maintain these files for at least 3 years.

Yes!  Once you have accomplished all these tasks, it is important to schedule a time to do a pre-audit walkthrough, which you can do with a VCE agent from the Fresh Produce Food Safety Team.  Just like the initial audit, the idea of this pre-audit walkthrough is to ensure that everything is up to date in your manual and that any changes are reflected in your on-farm practices.

Similar to your initial GAP audit, you will need to complete Form SC-237A (USDA Agricultural Marketing Service Request for Audit Services Form) and the Agreement for Participation in Audit Services Form SC-651. You will then need to submit these forms to VDACS.  We suggest submitting at least six weeks before your anticipated audit date, since the auditors are very busy, especially during the growing season. The VDACS office will contact you and confirm the receipt of your request, give you more information about the program procedures, and schedule your audit.