The Technical Working Group was successful in completing the first draft of the harmonized standard and now, the next phase will be just as important: to wordsmith the standard to be applicable to the widest range of North America regions, size operations, commodities and production practices. We will also need to assure that the standard is auditable as written.
Transparency and inclusiveness have been key features of the Produce GAPs Harmonization Initiative, and that has never been more important than now. To ensure that all parties are represented, we are asking you to please review the harmonized standard draft and most importantly post your comments below.
To post your comments, please register a user name and a password will be emailed to you – then you will be able to make comments and see your colleagues’ as well.
ALL of these comments will then be addressed at upcoming meetings where the TWG will begin to perfect the language of the first harmonized draft standard for the produce industry. To be successful at this, we need the widest range of stakeholder perspectives at the table during the upcoming meetings when we begin selecting the final words that will be used in the standard. You are, of course, encouraged to attend, but you are also asked to push this invitation out to other stakeholders, particularly those that have been underrepresented until now.
If you have any questions regarding the blog or making comments, please email Erin Grether at egrether@unitedfresh.org.
Draft Harmonized Standards
Future TWG Meetings
A special thank you to our previous meeting hosts:
Darden
McDonald’s Corporation
Taco Bell
Texas AgriLife Extension Center
US Foodservice
Sysco
California Strawberry Commission
Produce Marketing Association
Costco
John Cornell, EH&S Director
Larson Fruit Co.
Selah, WA
509-697-7208
Date Sent: 8-2-10
John Cornell has asked me to post the following for consideration.
1.5.1 Review Period
Revise ‘Code’ column –drop ‘move to 1.2.2’ -1.2.2 was deleted , and 1.2.1 doesn’t refer to ‘annual review’
2.6.2 Water System Risk Assessment
Revise ‘procedure language’ to read:
2.6.2.1 a review of the water system risk assessment is required annually, or any time there is
A substantive change made to, or occurs to the system, that could reasonably be
Expected to possibly introduce a known hazard to the public health which will not be
Controlled at a planned later stage of production. “The risk assessment….”
2.6.3 Water Management Plan
Revise ‘procedure language’ to read:
2.6.3.1 “…documentation”. The plan shall be reviewed following any changes made to the water system risk assessment and adjusted accordingly to incorporate such changes.
Training and/or retraining of personnel having oversight or performance duties shall
Be documented.
2.11 Microbiological Sampling/Testing
Revise the ‘corrective action’ column language to read”
2.11.4 Operation follows the corrective action procedures in the Food Safety Plan when any required test result comes back indicating a presumptive positive. Documentation of
The follow up done and the results shall be completed and retained.
3.0 Harvesting
Revise the ‘Code column’ to read “Delete-covered in 1.7
3.1.1 policy referring to ‘commitment to food safety
3.4 Water/Ice
Revise the ‘general question’ to read:
3.4.1 “If water…..surfaces”, in the field as the final wash step prior to consumer packaging, or
As a cooling aid in a consumer package, ..”the water or ice…..”
3.4.3 “Recirculated water….it”, which will directly contact the harvested crop in the field as a
Final wash step prior to consumer packaging, “..shall be treated…”
Page 1 of 2
Page 2 of 2 Comments on the TWG 7-14-10 draft of the Produce GAPs Harmonization Standard
3.4.6 “For produce..”, where peer reviewed studies conclude the harvested crop is “..susceptible to..infiltration.” of known microbial hazards to human health, “..from wash
Water, ..” water and crop ..”..temperature ..”.differentials..”..shall be considered.” ..in the
Initial and annual reviews of the risk assessment.
3.8 Field Packaging and Handling
3.8.1 the first sentence is outside the scope of a pure GAPs program, inasmuch as this is a
Quality issue. There has been little evidence in the literature I’ve seen that connects
‘decay’ or ‘soft’ produce to the presence of health hazards to humans. Indeed, there is
Some literature that speaks about the presence of decay organisms crowding out any
Such hazards as they multiple quicker and dominate the habitat. On the other hand,
There has been connections made between ‘damaged’ product and the resultant
Opportunity that provides microbial organisms to multiply in certain PH conditions, if
Favorable, or to better ‘hide’ from applications of sanitizers used to reduce populations.
None of the above, damage, decay, or softness, have been linked to any public health
Incidents-ever, for fresh, whole tree fruit, minimally processed and packed whole.
Revise the ‘Code column’ to read:
Delete-not in scope of GAPs
3.8.2 Revise the ‘general question’ to read:
“When produce is …field,” excluding the cutting or removal of stems from tree fruits, “..only water.’’ and/or ice ‘’..that meets….shall be used”.
3.9.3 Post harvest handling
Delete –note in ‘Code column” –covered in 3.5.2 and 3.5.5
I writing with some suggestions in consideration of the situation of small or limited resource producers using these standards.
The standards are very lengthy for a small or limited resource producer to get through and there is a lot of repetition/ redundancy. I imagine that the goal is to present these standards in a very thorough manner in terms of the 7 big topic areas outlined, but it seems a lot of the information that is repeated under almost every topic could be presented at the beginning of the document with an explanation that this info applies to all of the areas outlined in these standards. If things were organized in this manner, I believe the standards could be condensed and simplified to become a shorter document. This would help to make them more readable and user-friendly for small and limited resource producers.
There are a few areas that I believe would be very difficult for small or limited resource farmers to address, these include:
4.6 Temperature Control and 7.2 Temperature Control: Some of this seems a bit excessive in terms of how detailed this standard is; 4.4.1.5 seems more reasonable and adequate for covering this topic. (Chilling and cold storage facilities shall be fitted with temperature monitoring equipment or suitable temperature monitoring device that is located so as to monitor the warmest part of the room and is fitted with a temperature gauge that is easily readable and accessible. Temperature measuring devices shall be monitored on a frequent basis and calibrated as needed).
5.3.1 is not written with diverse operations in mind (If produce is washed, an initial risk assessment of the washing process shall be performed that takes into consideration the commodity, type of wash system, type of sanitizer, and water quality. The facility shall control the wash-water temperature for certain produce to prevent internalization of microorganisms from the water into produce tissue).
5.8.4: also seems to be excessive and just not a realistic expectation to have, in addition to everything else outlined in this standard (It is important to have maps of the location of pest traps outside and inside the pack house).
6.2: is there an understanding that many small and limited resource producers may not have refrigerated trucks? (Temperature Control: When refrigerated transport is required for food safety)
I would also suggest an inclusion of this comment (which I have seen in other GAP like documents and believe it is an important one to include for small operations): Establish and communicate a clear policy that will allow workers who report or are observed to have symptoms of illness or diarrhea or cuts to be reassigned to paid activities that do not involve food or food surface contact or are provided with adequate bandages and gloves to reduce the risks of contamination. In the absence of such a policy, it is likely that workers will not report their illnesses for fear that they will lose wages.
The following comments have been made by a client of mine:
1.2.3. This statement would lead one to believe that the standard was created as a single source audit for all levels of production. I believe it should state, “and where applicable, packed, sold, handled, and/or distributed by operation.”
1.7.3. Finished packaging material shouldn’t be covered in a field program unless there are packing operations on the ranch. This should be separated into its own modular.
1.8. Recall Program
There should be a provision allowing this to be handled by packing operation unless packed at orchard level. We need to separate packing operations and storage operations into their own module so that they only apply to those who do field packing need to focus on the criteria.
1.10.2. Consider changing the wording to state, “All aspects of the GAP program that have a direct effect on the safety of the product.”
2.1. Management Responsibility
2.1., 3.1., 4.1., 5.1., 6.1., 7.1. This is redundant. This should be covered once in section one, and apply to each level of operation. Management responsibilities don’t change based on the section, so there isn’t a reason to break it out each time.
2.3.8. We would prefer that it stated “any growing areas that have yet to have been harvested”. There is no risk of contaminating product if the product has already been removed from the area.
2.3.16. This should not be covered in a food safety program. These things are governed under OSHA rules, and do not need to be written into a food safety program used in the United States.
2.4.6. “… applied by licensed or certified pesticide personnel, or supervised by licensed personnel, as required by regulation.”
2.6.3.3. What is the minimum amount required? This is too open for interpretation.
2.6.3.5. This is open to interpretation, and may be (will be) interpreted differently between the land owner and the auditor. Need to set a minimum amount like once annually, and then stipulate that more testing may be required.
2.8. Why is there a need for seasonal written assessments? Why wouldn’t we review annually, and carry out a new assessment as circumstances change?
2.8.4. Either change the statement to read “any applicable packinghouses, and all storage areas.”, or consider removing it all together and it could be covered in the previously recommended packing operation section.
2.9.1. This is a statement, not a regulation. This belongs in a guidance manual instead of regs.
3.2.1. Couldn’t this be added to the annual review?
3.3. This is similar to my comment regarding Management Responsibility. The more times the same subject is addressed in different sections, the more likely for there to be unnecessary mistakes made by the person responsible for maintaining the program as they either will need to put the requirements in multiple parts of their program or have a system set up to refer back to the first instance.
3.3.5.8. Consider changing the wording from packaging material to produce containers. Packaging materials should only be referenced for those operations who pack in the field or at the property with the intent of delivering product to the market in that package. Those operations should be covered under a separate module.
3.3.5.12. Could this be revised to state that areas for meal breaks shall be designated and located away from non-harvested food contact/handling zones and field equipment?
3.3.6.2. At the most, this should read, “First aid kits shall be maintained in accordance with local and nation standards, and should be kept in a sanitary and usable condition.” These are social issues, not food safety.
3.4.7. Maybe this is applicable to a commodity other then tree fruit, but this seems more like a packing function and should be covered in the suggested packaging section unless it is relevant to a commodity’s growing practice.
3.5. The vocabulary used in this section is inconsistent. Need to refer to bins the same way each time, and it shouldn’t be referred to as packaging material unless it is dealing with a specific commodity that doesn’t use bins as a storage/transport container. Perhaps the packaging material wording could be used in the proposed packaging section.
3.5.2. Remove “and packing” as this would only apply to warehouse operations, and that should be considered outside the scope of this audit.
3.5.3.Not sure if this is referring to bins, but it is not practical to have pallets, slip sheets, racks, or skids lining the isle ways of orchards (safety hazards) in order to insure that the runners of bins (wood slats that hold the container portion above the ground) don’t come in contact with the ground. Also replace packaging material with a more suitable word.
3.5.4. This should include clarification of their definition of a primary container. Are we talking about totes or bins? “Unused primary containers such as…”
3.5.5. Consider changing “clean” to “as clean as practical”.
5. Packinghouse: consider adding “(where applicable to the growing operation)”.
7. Most of what is covered in this section is more applicable to packing (and already covered). Consider either removing duplicate requirements that don’t apply to storage (sampling, traceability, ext.), or maybe simply covering storage in the packing section.
It is our opinion that this is a program that with a little refinement could be a good standard allowing a single source audit. Overall, most of the issues that are covered are relevant to food safety.
While we have not been a part of the efforts to organize all the stockholders interests, it does appear to us that there were compromises made to bring Global GAP to the table. While we feel that this was an important part of making the program work, we were disappointed to see that there were so many social issues that were incorporated into another food safety standard. The fact is that OSHA, along with individual state labor standards already dictates the requirements set forth in this standard, and we would incur added audit time focusing on issues that don’t have a direct impact on food safety. We’re sure that compromises need to be made, but we feel like a social and environmental module would be better than sweeping standards for everyone who wishes to participate in this program.
Hello Dave,
Here’s a suggestion of language that can replace the “Animals Happen” note at the beginning of the animal control section:
“Gray areas exist with managing wildlife. Natural resource sites on the farm containing vegetation that filters pathogens (sometimes referred to as harborage) can be co-managed with wildlife presence for optimum safety.”
I am sending two comments in this message because I probably won’t be able to attend the upcoming meeting in San Jose.
During the May meeting, there was a question about the TNC audit standard for bathroom numbers and spacing. The TNC standard (1 bathroom/20 workers; no further than 500 meters) is similar to other audit standards, so there should be no problem with the wording we used in section 2.3.
I was impressed by the quality and reasonableness of the Food Safety audit standards that were crafted during the meeting. However, on the rare occasions when the group considered non-food safety subjects (pesticides, environment, etc) I heard comments such as, “we don’t need to audit for that because that does not apply to food safety”. Fortunately, that sentiment did not prevail, but it did concern me because most of the participants had a North America centric viewpoint, whereas we are trying to create a document that will have global applications. Pesticide safety is a major concern in Japan and the EU. Consumers in those countries are concerned with MRLs, worker safety and environmental contamination (from pesticides). I hope that our group will continue to include pesticide safety as well as food safety to ensure global acceptance of the harmonized GAP.
We support an exemption for tree fruit in the use of drinking water standards for pre harvest spray applications.
We expect our growers to follow all applicable laws from the local, state and federal levels. However, as an internal inspector, I would not want to be required to audit regulatory compliance in addition to 3rd party compliance. Isn’t that what all of the agencies from our governments are for?Those agencies can’t keep track of each others requirements, why should we expect auditors and inspectors to?