by Tay Fatke, CFSA Local Produce Safety Coordinator
Myth #1: I’m a small farmer, so I’m less likely to get someone sick.
It’s true that for most of the foodborne illness outbreaks in produce that can be traced, the sources are large-scale packing facilities. But in recent years there have been outbreaks and food safety incidents associated with farms of all sizes, including small farms selling in local markets. And according to the FDA, 90% cases of foodborne illness are never reported or traced back to any operation. It is very difficult to trace an outbreak because the symptoms of foodborne illnesses take time to occur after consumption of the contaminated product, and consumers often cannot recall everything they have eaten that may have gotten them ill. So just because no one’s ever complained of being sickened by your food doesn’t mean it hasn’t happened.
The issue for your farm business isn’t size, but your customer relationships. Pathogens are widely distributed in the environment, and anytime they have the optimal environmental conditions to survive and thrive, they will grow, regardless of the size of your operation. Taking all reasonable precautions to protect your customers is good business and the right thing to do for your farm, as well as the local food movement. Regardless of the size of your farm, your customers expect you to focus on mitigation and prevention strategies to reduce the risk of contamination.
Myth #2: I apply raw manure to my produce fields, so I cannot become GAP certified.
Raw manure can be applied to fields growing produce as long as the proper guidelines for the application and incorporation are followed.
When applying raw manure to the soil, it must be done at least 14 days before produce is planted or sowed. After produce is in the field, consider the characteristics of the edible portion of the crop to determine the waiting period before harvesting. Where the edible portions of the crop contacts the ground, you must wait for 120 days from that manure application before the first harvest of that crop. Crops that are not grown in contact with the ground have a 90 day wait period.
So what about treated manure? First, treated manure must have gone through a validated process, such as the compost processing standards under the USDA National Organic Program, to ensure it is in fact treated. Treated manure purchased from an outside source must have a certificate of analysis to show it meets minimum treatment requirements and must be applied according to its label instructions. Whether purchased or composted on-farm, treated manure must be applied carefully so that it does not contaminate any produce.
Myth #3: How many water tests am I required to complete and how often?
When it comes to the number of tests required for a GAP audit, think about the source of the water and the associated risks. The grid below describes the minimal testing requirements for each source, assuming that there is no reasonable cause to conduct additional testing.
| Source | Number of tests needed annually |
| Municipal | None- Ask city/town for water analysis report annually to keep in your files. |
| Well | 1, prior to the prime season starting |
| Surface (pond, river, spring, etc.) For irrigation use only. | 3, taken during the season. Take these tests when irrigation is typically occurring. |
It is important to apply this analysis for each water source on your farm. If you have one well that you use for washing produce, equipment, containers, as well as irrigating (1 test), and also one pond you use for irrigating (3 tests), you have a total of 4 water tests to take annually. If you have municipal water for washing produce, equipment, and containers (0 tests) and two ponds used for irrigating (6 tests) you would need 6 water tests for the irrigation water, in addition to asking your city/town for their water analysis.
Myth #4: So can I use the water that I have tested? What microbial requirements are there?
The microbial quality requirements will differ depending on the use of the water. Untreated surface water cannot be used to wash produce, containers, equipment, or for drinking, and any water used for these purposes must have no detectable E.coli or Total coliform.
Now let’s take a look at irrigation water microbial quality requirements under most GAP Standards, where we will have to focus on the method of application. When water contacts the edible portion of the crop, 235 MPN’s (Most Probable Number per 100 mL) or CFU’s (Colony Forming Unit per 100 mL) of E. coli is the highest allowable limit. When water does not contact the edible portion of the crop, 576 MPN’s (Most Probable Number per 100 mL) or CFU’s (Colony Forming Unit per 100 mL) of E. coli is the highest allowable limit. These requirements represent the test results for a single sample collected on your farm.
The numbers above represent the results being reported in quantitative, numerical data, meaning you know the exact number of MPN’s or CFU’s of generic E. coli in your water. It is crucial to make sure, in advance, that any lab you use for water testing reports quantitative results back to you. Some water tests only provide qualitative results, reporting whether E. coli is “present” or “absent”, without providing the numerical data to determine if your water quality falls within the allowable limits. If undergoing a GAP audit, and you only have a “present” qualitative result, you are at a very high risk of failing the audit.
Myth #5: Can I be GAP certified and use surface water for irrigation?
Yes, you can, however, you may need to implement practices that mitigate potential risks on your farm if the quality of water does not meet the limits discussed above.
If you are using overhead irrigation on the edible portions of the crops, this results in a higher risk of potential microbial contamination. Installing drip irrigation is a way to mitigate this risk. The less water you have coming into contact with your produce, the better. One alternative method of reducing potential risks is installing a water treatment system, which is the most expensive option. We can assist you with evaluating these risks and provide other alternative solutions that are suitable for your operation and the crops that you grow.
Myth #6: There is too much paperwork to have a food safety system implemented and pass a GAP audit!
One of the most common concerns we hear when speaking to growers is that GAP requires a farm to document every visit to the restroom. While there are some potentially unexplainable recordkeeping requirements in GAP, recording bathroom breaks are not one of them. The amount of paperwork required can certainly cause some alarm to those starting a food safety program, especially farms that already have limited labor. But the USDA Harmonized GAP standard is designed to only require a record if it’s relevant to your farm. So while there are up to 57 records that a farm going through the General Section, Field Operations and Post-Harvest audit might have to keep, not all of the required records will apply to your operation and may be marked Not-Applicable on your audit report. For example, if your operation does not use on-farm refrigeration, the required temperature monitoring and cleaning records are not applicable.
Moreover, very few of these records are required daily: a majority of the records are kept annually or when you make a change to your food safety program, such as getting new water tests, conducting a mock recall exercise, ore conducting a new risk assessment.
Finally, a single record may meet many of the requirements. An example would be the water test(s) you have on file, which satisfies eight of the Harmonized GAP record requirements!
Taking all this into account shows that the amount of records needed is far less than 57.
CFSA has designed a combined recordkeeping system that further minimizes record-keeping burdens. It may be tricky to determine what records are applicable to your operation, which is why CFSA developed the Local Produce Safety Initiative, offering to current members free one-on-one GAP consulting to assist growers with implementing their recordkeeping and overall food safety program, including technical assistance during a GAP audit.
Myth #7: My buyers aren’t requiring me to be GAP certified, so a Food Safety Plan and Program isn’t important for my operation.
GAP certification is simply not suitable for every farm growing fresh fruit and vegetables. It is important, however, to ensure your farm is following the best practices to reduce the risk of harm to your customers. Implementing a food safety program and plan is a great way increase efficiencies on the farm, reduce your liability, and keep your customer base happy and healthy.
A food safety program consists of the policies and procedures your farm follows in regards to mitigating food safety risks, and training any employees on these policies and procedures. A written food safety plan documents these policies and procedures and utilizes applicable records as verification that the program is being followed. Some buyers only require a food safety plan, but not GAP certification, which will allow you to expand your markets. It is also much easier to achieve GAP certification after seasons of following a food safety program and plan than it is to start from scratch under the pressure of a buyer.
As the trend is for more and more buyers to require GAP certification, the time is now to implement your food safety program and write the food safety plan!
Myth #8: I raise produce AND livestock on the same land, so I cannot become GAP certified.
Possible contamination of fresh produce from raising animals on adjacent land is certainly a risk. However, with proper risk assessment and mitigation strategies a diversified farm can become GAP certified. When assessing the risks that livestock present for the produce grown on your farm, think about the number of animals, the surface they are on (pasture, dirt, concrete), the slope of the land, whether there are buffers and diversions to channel manure or runoff away from produce-growing areas, and the characteristics of the produce (grown in contact with ground, grown above ground, raised beds).
After conducting this risk assessment, determine the need for any additional mitigation strategies to reduce contamination risks.
- Do you need to move the animals further away from the produce field?
- Do you need to put in a berm or vegetative buffer to slow runoff from entering the produce field that is downslope?
- If using rotational grazing, consider how often the livestock should be moved to a new paddock to avoid excess manure.
Myth #9: I have wood surfaces and do not want to invest in stainless steel.
This is very simple: don’t invest in the stainless steel tables. Instead, implement practices that do not allow your produce to come into direct contact with the wood surfaces. For example, if you have a wood table that you are using to sort produce on, simply line that table with a clean sheet of plastic to act as a barrier between the produce and wood surface. Be conscious of the fact that wood is a porous surface and cannot be cleaned and sanitized effectively to mitigate risks of potential microbial contamination. Keep this in mind with your tools and mop handles, and as these are replaced, consider purchasing fiberglass handles. You may even want to consider implementing a color-coding system to restrict certain tools and cleaning supplies to specified areas of your packing area.
Myth #10: I am going to have to close my farm because I cannot meet the new food safety requirements.
Most growers that we hear this from are referring to the implementation of the Food Safety Modernization Act (FSMA). We find more often than not that farms who fear that they cannot come into compliance with FSMA Produce Rule are actually ‘exempt’ or ‘qualified exempt’ from the Produce Rule, requiring that certain records are kept to include necessary records to prove exemption of qualified exemption. For more information on where you will fall under the FSMA Produce Rule, check out Clarification of the Coverages and Exemptions for the Produce Safety Rule (coming soon!).