By Tay Fatke, Local Produce Safety Coordinator | Monday, Dec. 10, 2018 –
Whether this is your first audit or you’re a GAP old-timer, preparing for audit day can be challenging if everything is left to the last minute. Since farming isn’t a job that typically has downtime, especially right when your audit will be conducted, we want to offer ways (and recommended dates) to chip away at requirements for efficiently maintaining your food safety program.
Audit Preparation Checklist Tool
Follow the instructions below to complete the Audit Preparation Checklist Tool (.xls), which provides a timeline to complete specific activities. Once completed, print your customized Audit Preparation Checklist Tool, providing specific dates of when activities should be conducted. There should be TWO TIMES to update and print the Audit Preparation Checklist Tool, as you may want to print this document to also accompany your timeline providing an explanation of what the activity entails.
Determine Your Tentative Audit Date (TAD)
An audit should be scheduled during the time when you have the most crops in production and are able to demonstrate most harvest techniques—how you harvest and handle crops. For example, pepper, eggplant, and okra have similar harvest techniques, while root crops and bunched leafy greens would be considered different harvest techniques. When determining your TAD, find a timeframe where at least one crop of each harvest technique overlap.
Once you have determined the TAD, enter this date in the Audit Preparation Checklist Tool, press ‘TAB’ and the dates to complete GAP audit activities will be updated to reflect your tentative audit date.
Review Cost-Share Opportunities (January 15th)
By the middle of January, you should check to see which opportunities are available for you to reduce the costs associated with the audit and implementing a food safety program.
There are a few different possibilities to reduce costs for farmers in the Carolinas, which include sharing auditor travel expenses with a neighboring farm undergoing an audit the same day or taking advantage of cost-share opportunities. Additional options may become available in the future, so do not hesitate to ask an LPSI team member about cost-share updates.
Conduct Employee Training (First Week of Work)
Food safety training for employees shall occur annually prior to starting work. Employees shall be trained in proper health and hygiene policies, as well as any job-specific training regarding food safety. The training shall be documented with the signatures of the employees. For employees that start after the annual training, ensure they receive a one-on-one training session and also sign a training document.
Though training is an annual requirement, it’s a good idea to train employees throughout the season, especially if you notice any employee practices that are not consistent with your food safety program or if you implement new policies and procedures within your operation.
Additionally, keep your eyes peeled for upcoming workshops for you and your employees to attend, even if you have already attended a workshop in the past. The Good Agricultural Practices program is always changing as new research becomes available and foodborne outbreaks occur, so it is likely you will always learn new information to apply to your farm.
120 Days Before Audit
Schedule Your Audit
To schedule your audit, complete the Request for Audit Services (Form# SC-237A) on the USDA AMS website.
Send the completed form to the following (based on your location):
- North Carolina: Vincent Wyche, email, (252) 799-4020 (office)
- South Carolina: Jack Dantzler/Matthew Burleson, email, (803) 737-2523 (office)
When scheduling, take into account the availability of your food safety manager, your workers, and any additional stakeholders that are able to answer questions pertaining to your food safety program. The auditor will interview employees to ensure they are competent in, and following, the operations’ written policies—such as health and hygiene, cleaning and sanitizing, and harvesting and packing.
Remember that through our GAP consulting program, CFSA’s Local Produce Safety Initiative (LPSI) staff can help you prepare for your audit and provide technical assistance throughout the process. If you feel you need assistance on audit day, be sure to express this to the LPSI representative you are working with to make sure their availability works for your TAD.
Update your Audit Preparation Checklist Tool with the confirmed audit date once chosen. This is key, as it will help you stay on track to properly prepare for the audit. It’s likely that the TAD and the actual audit date will not be consistent once scheduling occurs.
60 Days Before Audit
Conduct Water Testing
You will want to conduct your water testing for the season based on your water management plan. Remember, each source needs to be tested.
The typical frequency of testing based on the water source is described below. However, the frequency must be determined based on the risks associated with your water and may require more frequent testing. Follow the testing schedule written into your food safety plan; remember that any prevailing regulation compliance is required, where applicable.
Municipal Water |
Well Water |
Surface Water |
| Request Annual Water Report
(Results for generic E. coli must be included on the report) |
Test Once Annually
|
Test Three Times Per Year
(Beginning, Middle, & End of Season) |
Ensuring the safety of water can be accomplished by testing the water for the presence of pathogens. It is important to understand the types of tests available to obtain the bacteria count.
There are generally three different water tests available at most water testing labs:
- Total coliform
- Fecal coliform
- Generic E. coli (recommended for Good Agricultural Practices (GAPs) Certification).
Currently, there is not one single nationwide standard for irrigation water.
Tests can indicate either a minimal reading of presence and/or absence or can quantify the amount of pathogens present in a given sample. These quantitative tests are what you should be looking for with the results measured in MPN (most probable number) for generic E.coli or CFU (colony forming units) for total coliform.
North Carolina residents may take advantage of the water testing reimbursement program offered through NCDA as mentioned under Review Cost Share Opportunities above.
Calibrate Thermometers and Equipment
One of the most often missed requirements of the GAP audit is calibrating equipment. For most farms, this means calibrating any thermometers and scales used within the operation. Any metal detectors or other foreign material control devices will also have to be calibrated on an annual basis at least.
To calibrate a thermometer use the following:
Thermometer Calibration (Melting-point-of-ice method)
- Place ice in a container and allow melting to begin.
- Stir to be sure the temperature in the ice-water mixture is uniform throughout the container.
- When the container is filled with a 50/50 ice-water solution, insert the thermometer and wait until the temperature stabilizes.
- If the thermometer is properly calibrated it should read 32ºF (0ºC).
- If the thermometer is not reading 32ºF (0ºC), adjust the thermometer (if possible), use the temperature difference to adjust for the readings, or replace the thermometer.
30 Days Before Audit
Conduct Annual Food Safety Risk Assessments
The Harmonized GAP Standard requires seven risk assessments, if applicable to your operation, to be completed before the audit date or whenever there is a change in your operation where risks need to be re-assessed. The risk assessments include-
- Pre-Harvest Risk Assessment
- Land Use History and Adjacent Land Risk Assessment
- Water System Risk Assessment
- Animal Control Risk Assessment
- Biological Soil Amendments of Animal Origin Risk Assessment
- Allergen Risk Assessment
- Produce Washing Process Risk Assessment
Although there is not one specific form to use for these assessments, CFSA has developed templates that can be utilized to complete these risk assessments through our GAP Consulting Program. When completing your risk assessments, take a moment to review your harvest, washing, and packing practices to determine if there is anything that needs be corrected to minimize food safety risks and meet GAP requirements.
14 Days Before Audit
Conduct Annual Mock Recall
A mock recall is used to show that your traceability system works properly and you have adequate knowledge and communication with your buyer. This exercise tests your recall plan in the event of an actual recall. While Good Agricultural Practices and Good Handling Practices cannot eliminate the possibility of a recall, it does assist with reducing risks. Growers that do everything right may still find themselves in a recall situation. Keep in mind, voluntary recalls in the produce industry occur on a regularly.
For more information and how to conduct the mock recall, check out our expert tip, “How and Why to Conduct a Mock Recall in Preparation for a GAP Audit.”
7 Days Before Audit
Conduct Self-Audit
The self-audit is key to preparing for audit day. It may seem strange that this activity is listed so closely to the audit itself, right? The Audit Preparation Timeline Checklist Tool will help meet the most time-consuming activities of the audit. The self-audit can then be used simply as verification those activities have been completed and your program is in compliance.
The process of completing a self-audit is easier than people think. You will use the established USDA Audit Standard and accompanying checklist that your food safety program is built around (Harmonized or GAP/GHP).
If you are using a certification body other than the USDA, you can find the standard and checklist on their website. Every audit is scored a little differently, so the first few pages of each checklist will give you directions on how to complete it. This is the same paperwork the auditor uses when conducting an official audit, which makes the process extremely useful for finding anything during the self-audit that can be corrected before the actual audit date.
For additional information about conducting a self-audit, check out “The Importance of a Self-Audit for All Produce Farms.”
Print Audit Materials
A complete, easy-to-navigate food safety plan can save considerable time during your audit—and at $1.80/minute for a USDA audit, time truly is money!
Your food safety plan and associated materials should be very thorough and easy to navigate.
An extremely important part of the food safety plan is the table of contents for the auditor to reference. Have two copies of the table of contents to cut down on the time spent flipping through the plan, so one is in the front of the plan and one copy is out for reference during the audit.
Again, think of that cost. At $1.80/minute, imagine the additional cost if you need to find a document in the office or print out maps! We consider it imperative to have everything in place come audit day.
Here’s a list of the audit documents needed.
- Maps of the operation (print two copies as the auditor will take one off the farm)
- Food safety plan (include two copies of the table of contents)
- Mock recall information
- Self-audit
- Water tests
- Internal records
“Approve” Food Safety Plan
Another commonly missed requirement of the Harmonized GAP audit is an annual documented review of your food safety plan. This is as simple as a signature and date on the cover page, or another location within your food safety plan after you have ensured it is up-to-date and accurate for your upcoming audit.
Check First Aid Kits
Did you know Band-Aids expire? The auditor will look at your first aid kit, and it’s important to have the kit stocked with acceptable medical supplies. Inspecting the first aid kit before the audit will ensure it is full and its contents are not expired.
Check Handwashing Stations
Confirming that all handwashing stations are in good working order and properly stocked seven days prior to the audit will eliminate any last minute leak fixes or runs to the store for extra materials.
Remember that the components of a handwashing station include:
- Potable water
- Single-use towels
- Soap
- Garbage receptacle for used towels
- Water catchment system (e.g. a five-gallon bucket) for water, if not plumbed
Check Mousetraps
During the season on a farm, things have the tendency to break, be moved, or simply vanish. I have known that mousetraps are especially susceptible to this phenomenon. Verify that the pest traps within your operation are still there and in good working order, even though you have regular monitoring activities in place. It never fails, just before an audit is when the least likely incidences occur.
It is also important to ensure the traps are placed in a way that they are likely to catch rodents. Having the traps placed tightly against the wall, where rodents like to run, and/or near any doors will improve your success rate of catching any pests that may have gotten into your packshed or storage areas.
Entering Additional Activities
Interested in putting additional activities into the tool? Perfect! You will see there are blank spots at the bottom of the tool to add any additional activities. This is your document, so customize it any way that you think it will assist you in being ready for your audit.
As an example, if you want to add the activity of a deep cleaning of your packshed one month before your audit date, enter that activity in and update the “Date to Complete By” column by changing “=DC-7” to “=DC-30”.
The Audit Preparation Checklist Tool may be utilized year-round and customized to meet the needs of your farm’s food safety program!
For More Information
If you’re interested in more information on CFSA’s Local Produce Safety Initiative (LPSI), head here. Also, consider checking our FSMA & Food Safety Resource Hub.
Prefer a person? Reach out to Patricia Tripp, CFSA Local Produce Safety Manager.