Transcript GAP Audit Harmonization in North America

Presentation Outline
• GAP Harmonization presentation
Dave Gombas, Senior Vice President: Food
Safety & Technology
United Fresh Produce
• Questions and Answers
Moderator: Steve Warshawer
Food Safety Coordinator
National Good Food Network
Produce GAPs
Harmonization Initiative
David E. Gombas, Ph.D.
United Fresh Produce Association
September 21, 2010
United Fresh Global Conference on
Produce Food Safety Standards,
April 2009
• Over 200 leaders from each stage of the
produce supply chain, government, and thirdparty standard owners and auditors explored
the potential value of harmonization and
greater alignment of standards
• Produce GAP standards used in various audits
in North America seem to be at least 90% the
same, providing a clear opportunity for
harmonization.
Prior Harmonization Efforts
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Guidance documents (FDA GAPs)
California Leafy Greens Best Practices
Food Safety Leadership Council
SQF 1000 produce standards
GlobalG.A.P
Global Food Safety Initiative (GFSI)
Outcomes From the Conference
The process of bringing key stakeholders
together to develop and endorse commodityspecific standards provides a good model for
building consensus on general GAP standards.
Harmonization of general GAP standards must
be transparent with open communication of
intent, progress, and conclusions.
Retailers, foodservice companies, fresh-cut
processors, grower-shippers, auditors and
standard owners, and government must
all be at the table working together.
Outcomes From the Conference
Inclusion of non-food safety standards
(environmental, social issues) is a likely
obstacle to harmonization, particularly in
North America. These issues may need to be
addressed separately.
Process to Harmonization
Identified a small but influential Steering Committee of
major industry representatives with the ability to drive
broad industry acceptance of common standards:
McDonald’s
Yum Brands
Pro*Act
U.S. Foodservice
Darden
Jack in the Box
Sysco
Subway
Markon
River Ranch
Del Monte Fresh
Taylor Farms
Wegmans
Chiquita Fresh Express
Ahold
Sun World International
Kroger
DiMare Company
Loblaws
Green Giant Fresh
Safeway
Sunkist Growers
Schnucks
Castellini Co.
Publix
McEntire Produce
Walmart
Dole Food Company
Food Lion
The Giumarra Companies
Supervalu
Tanimura & Antle
Costco
C.H. Robinson
14 produce associations
Vision of Harmonization
Develop a harmonized food safety standard
and checklist for GAP audits, and globallyacceptable auditing process, necessary to
protect consumers from potential hazards that
may contaminate produce at that stage of the
supply chain, and that will build efficiencies
into the supplier audit process.
One audit by any credible third party,
acceptable to all buyers
Scope of work (1)
A single, generic checklist for GAP audits:
 Focused on food safety practices of pre-farm
gate produce operations (as defined by the
scope of the FDA GAPs);
 With clearly defined requirements that
minimize opportunity for misunderstanding,
misinterpretation and “standards creep” by
operations and auditors;
 Globally recognized, but specifically
applicable to North America operations;
Scope of work (2)
 Requirements that are risk-based, sciencebased, attainable, auditable and verifiable;
 Considering all microbiological, chemical and
physical hazards reasonably likely to occur,
consistent with potential hazards addressed
in FDA regulatory guidances;
 Scalable to all size fresh produce operations;
 Considerate of regional- and commodityspecific food safety needs;
Scope of work (3)
 Sufficiently non-prescriptive to be accepting of
equivalent food safety practices;
 Flexible to adapt as science reveals better
practices and limits;
 Acceptable to a critical mass of customers
requiring general produce food safety audits;
 Freely accessible by everyone, including any
1st, 2nd or 3rd party auditor.
Technical Working Group
Over 150 stakeholders, representing:
• Customers, suppliers, audit companies,
government (FDA and USDA), extension,
association staffs;
• A broad scope of fresh produce commodities;
• A broad scope of operation sizes; and
• A broad scope of producing regions, including
Mexico and Canada.
• Open invitation for participation;
no stakeholders excluded
Standard Harmonized from
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• AFDO Model Code
CA LGMA
Mushroom GAPs • AIB
• CanadaGAP
SENASICA
• GlobalG.A.P
Silliker
• SQF 1000
USDA
Tomato Food Safety Audit Protocol
Community Alliance with Family Farmers
California Strawberry Commission
Field Operation/Harvest Audit
Standard Draft Now Completed
Categories of the Standard
General Questions
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Management Responsibility
Food Safety Plan
Documentation & Recordkeeping
Worker Education and Training
Microbiological Sampling and Testing
Traceability
Recall Program
Corrective Actions
Self-audits
Categories of the Standard
Field Production
• Field History and Assessment
• Worker Health/Hygiene and Toilet/Handwashing
Facilities
• Agricultural Chemicals /Plant Protection Products
• Agricultural Water
• Animal Control
• Soil Amendments
• Vehicles, Equipment, Tools and Utensils
Categories of the Standard
Harvesting
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Preharvest Assessment
Water/Ice
Containers, Bins and Packaging Materials
Field Packaging and Handling
• Postharvest Handling
Transportation (Field to Packinghouse)
• Equipment Sanitation and Maintenance
Post-harvest Operations standard
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General Questions
Produce Cooling
Packinghouse
Transportation (from Packinghouse)
Produce Storage
Fast Facts about the Standard
• 84 audit items
• 14 written policies/procedures, such as
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Food safety plan
Traceability and recall programs
Toilet, worker hygiene and health policy
Water management plan
• 14 types of records, including
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Training records
Soil Amendments
Agricultural Chemicals
Pre-planting and pre-harvest risk assessments
Microbiological testing (if performed)
What makes it scalable?
• Worded to work for family operations as well as
large corporate farms, diverse crop farms as
well as single commodity operations
• Allows for “not applicable”
• Requires designation of responsibilities, not
dedicated personnel
– Allows, does not require, hiring outside
personnel, within the limits of the law
• Requirements, documents, records generally
simpler with fewer employees, smaller
operations
• Most often instructs auditor to look at practices
rather than written procedures or records
Audit Standard
Audit
Audit Process
Audit Process
• Operations Committee commissioned to
develop policies and procedures for use
of the harmonized standard
• Standard will be freely usable by any
audit organization, but must be used
consistently
• Market will decide which audit process is
most credible, acceptable
Next steps
• Complete the Post-harvest Operations audit
standard (Costco, Oct. 21-22)
• Schedule “pilot” audits using the draft
standards:
– Operation, auditor, customer
– Different commodities, different size
operations
– Assess what works, what doesn’t, and
make changes to the draft
• Develop auditor training tools
What does this mean for you?
• Decreased number of audits
– Multiple customers willing to accept the same
audit means fewer audits
• Consistent expectations
– Auditors (and customers) using the same
standard should be asking the same
questions, judging compliance the same way;
less “moving target”
• Reduced audit costs
– Focus resources on operation,
not on passing the audit of the day
What you can do
• Review the standard and tell us: What’s not
clear? What doesn’t work for your operation?
• Use the standard for your own self-audit
• Ask your customers – are they involved in
the Initiative? What do they think about it?
• Participate. The Initiative was created to
help reduce your audit burden while
harmonizing food safety expectations.
Make sure it works for you.
Screenshot GHI page
Produce GAPs
Harmonization Initiative
Questions?