INTRODUCTION 

The USDA’s (United States Department of Agriculture) Agricultural Marketing Services (AMS) specialty crops program recently announced the expansion of its Good Agricultural Practices (GAPs) Audit Program. The new program is an audit based GroupGAP certification program to be launched in April 3, 2016. USDA Specialty Crops Program Audit services will receive applications for review and approval after this date. To obtain USDA third- party GAP certification a farm has to deal with different costs such as preparatory costs and the audit cost which could be taxing for many small and limited resource farmers. This hurdle prevented many such small growers from gaining access into markets that was only accessible by large farms with sufficient resources. The goal of the new and innovative GroupGAP program is to allow small growers and cooperatives to obtain USDA third- party GAP certification in groups to meet the retailer’s on farm food safety requirements and thereby enable retailers meet the growing demand for locally grown fresh produce. 

The new GroupGAP program would allow growers groups, such as food hubs and other grower group organizations to work under a common food safety program that would help them share accountability and resources to comply with procedures, food safety practices, local, state and federal regulations, and USDA GroupGAP requirements. 

BENEFITS OF GROUPGAP FOR GROWERS 

• Share certification costs among grower group members. 
• Relive an individual grower of the burden of preparing for the third-party audit and help leverage group resources (Each grower will still undergo an audit, the audit will just be from an internal source). 
• Work together under one common food safety program using a quality management system tailor made for the group. 
• Go through the USDA GroupGAP audit as a group to obtain GAP certification.

GROUPGAP REQUIREMENTS 

GroupGAP structure and how it works

1. Form a grower group 
2. Choose a group leader 
3. Choose an internal auditor (Receive training by USDA accredited internal auditor training or its equivalent)
4. Develop Standard Operating Procedures (SOPs)
5. Develop a Group Specific Quality Management system (QMS)
6. Conduct Grower Training
7. Internal QMS Audit of all growers in the group
8. IA submits internal audit reports & QMS Records to the USDA GroupGAP program.
9. USDA Farm Audits (third‐party) of a portion of growers
10. GroupGAP Certification

Grower Group: Identify or form a grower group with growers who are interested in obtaining USDA GAP certification. Examples of such groups would be food hubs, formal cooperative or grower association, group of growers that sell their product from central location such as a packing house or farmers market, and growers who come together solely to benefit from the GroupGAP program. 

Select a group leader: Group leader works as a liaison between the USDA and the grower group. Group leader ensures that the individual members are effectively implementing quality management systems (QMS), maintains a record of all documents and trainings, identifies an internal auditor to conduct internal audits of all farms in the group or functions as an internal auditor himself, prepares the group for USDA third party GAP audit, and works to address auditor’s questions and correct non-conformances after the audit.

Internal Auditor (IA): The grower group is also responsible for identifying their internal auditor(s) who would conduct on-farm audit of all the farms enrolled in the group. Internal auditors would also ensure any nonconformance to the food safety requirements are remedied by assessing the corrective actions. USDA-AMS requires that the IA should be certified/ trained by USDA accredited internal auditor training or its equivalent. Group leader could also serve as IA.

Development of Standard Operating Procedures (SOPs): Growers in the group must work together with the group leader to develop both group specific and individual grower specific (if needed) Standard Operating Procedures (SOPs). 

Development of a Group Specific Quality Management System (QMS): Growers in the group must work together with the group leader to develop a Group Specific Quality Management system, function under the QMS, and ensure every group member maintains the program requirement. 

Internal audit: The internal auditor will audit each grower in the group for compliance with SOPs, the Group QMS, and the on-form food safety plan. 

USDA Audit (3rd Party Audit): After successful completion of the internal audit and correcting non-conformances identified during the internal auditing process, the group leader or the IA will submit the QMS documents, records and the group’s information to the USDA GroupGAP program for review. Before scheduling an onsite visit USDA GroupGAP program will evaluate the QMS documents and let the group leader know if they identify a major non-conformance so that the group can correct the non-conformance before the onsite audit. The group leader might have to re-submit the QMS documents to prove that the non-conformances have been corrected. When USDA finds the groups QMS compliant with the GroupGAP program requirements, USDA will conduct an onsite audit to confirm the implementation of the GroupGAP QMS. 

While the USDA plans to audit a representative number of the farms in the group (this number is at USDA’s discretion but it is normally square root of the total number of farms in the group, example if the Group has 16 growers or farms, USDA would audit 4 of them), depending on the effectiveness of the internal audit and the completeness of the QMS USDA might decide to audit more farms in the group to ensure compliance. 

Audit Result and Follow-up: USDA’s GroupGAP certification is valid for one year, after which USDA will continue the onsite audit on an annual basis. This will not be spontaneous, the group will need to request continued participation in the program and annual audits.

CONCLUSION 

The new GroupGAP program will extend small and mid-sized grower’s access to retail and wholesale markets by enabling them to meet the food safety standards required by their buyers. Increased market access to small, mid-sized, and limited resource growers will help buyers meet the increasing demand for local food. 

The University of Kentucky Food Safety team is closely following the USDA-AMS on the new GroupGAP program, when USDA’s guidance documents for GroupGAP becomes available the team will make more detailed information available and will also conduct GroupGAP training programs for growers interested in obtaining the GroupGAP certification. 

REFERENCE 

United States Department of Agriculture (USDA) – Agricultural Marketing Services (AMS) 

Reviewed by Audrey Draper, Audit Programs Coordinator, Specialty Crops Inspection Division, USDA-AMS. 

Disclaimer: This article is for information purposes only. It does not cover every detail of the new requirements, for additional information please visit the website.