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Global GAP - Is it right for me?
February 22nd 2022

Global GAP - Is it right for me?

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Several years ago, I wrote a blog about the Produce Safety Rule (PSR) that asked the question: Is the (Produce Safety) rule enough? That blog specifically addressed the question: Are our current hazard analysis practices thorough enough to uncover potential sources of contamination? Based on the outbreaks we have observed since that February 2019 blog the answer is no.

A review of the Centers for Disease Control (CDC) website1 and performing a quick search for produce-related outbreaks revealed 18 outbreaks documented by CDC for the period 2019-2021. The outbreaks from 2019 to 2021 are listed below.2

If we examine these outbreaks and remove the three Listeria monocytogenes outbreaks (for argument’s sake), it becomes apparent the farm is most likely the source of the contamination. Arriving at that conclusion, we can surmise that these hazards were not identified at a farm or if they were, either preventive measures failed to control the pathogens or preventive measures were not implemented. This begs the question of what role does the Produce Safety Rule (PSR) plays in hazard identification. The answer is none.

The PSR requires growers to focus on five primary areas: worker health, hygiene and training, soil amendments (compost and soil inputs), animal intrusion, water quality and safety, and produce handling equipment and tools. While the PSR requires certain records to be maintained on file to support rule compliance, no written food safety plan is required. The standardized Produce Safety Alliance Grower Training manual states:

“The FSMA Produce Safety Rule does not require a written farm safety plan.”3

However, although a written food safety plan is not required it is encouraged. Grower training notes that those who make the decisions for the farm and those who work day-to-day in grower operations are best suited to make those food safety risk decisions. Given the outbreaks between 2019 and 2021, one has to ask if adequate attention is paid to hazard identification and risk categorization at the grower level.

Agricultural production is a complex process with many opportunities for introducing hazards. Most produce growers have been managing their growing and harvesting operations in accordance with Good Agricultural Practices (GAPS) for many years. The Produce Safety Rule simply codifies those standards with the force of federal law including enforcement in a food safety rule covering produce. More needs to be done to identify, assess, and control threats to produce safety.

GlobalG.A.P includes provisions that go beyond basic GAPS and the PSR. GlobalG.A.P requires a site risk assessment even addressing areas such as rented land, structures, and equipment.4 Furthermore, this provision requires the risk assessment be written; address physical, chemical, and biological hazards; include a site history and an assessment of the impact of adjacent activities and property use.5 Adjacent property use has produced significant risks to produce growing operations. In one instance, the location of a confined animal feeding operation (CAFO) is suspected of being the source of contamination of surface irrigation water/canals in the leafy green growing region of Yuma, Arizona. Assessment of these threats is necessary to reduce the incidence of foodborne disease. 

The Produce Safety Rule can only control those hazards identified in the rule. Clearly, this is insufficient for produce safety. The GlobalG.A.P standard provides a framework for hazard and risk assessment well beyond that required in the PSR. For produce safety to continue to advance and for consumer confidence in the fresh fruit and vegetable supply, GlobalG.A.P should be considered.    

By Jeff Lucas
Senior Director, Expert Services, Training & Consultancy
Mérieux NutriSciences          


[1] List of Selected Multistate Foodborne Outbreak Investigations | Foodborne Outbreaks | Food Safety | CDC
[2] This is not an exhaustive list but is used as a point of discussion.
[3] Produce Safety Alliance Grower Training Course. Version 1.2., 2019.
[4] §AF 1.2.1. Site Management, GlobalGAP: Integrated Farm Assurance, Fruit and Vegetable. Version 5.2. August 2019.
[5] Ibid.

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