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Navigating the USDA GAP audit process

Are you are interested in selling fresh fruits or vegetables to wholesale markets such as a distributors, hospitals or schools? If so, you may be asked for a “third-party food safety audit.” A Good Agricultural Practices (GAP) audit verifies to buyers that you grow, harvest, wash and pack your fresh produce in accordance with recommended safety guidelines.

A GAP audit is voluntary and is not a law, but it is required by some markets. If you decide to get a GAP audit to sell to these wholesale markets, the following are guidelines for the GAP audit process.

Step 1. What audit?

First, talk with your buyer or potential buyer who is asking for the audit. Your first question to the buyer should be, “What type of audit do you require?” There are many types of audits, such as the USDA GAP/GHP audit, the USDA Harmonized GAP, or private audits like GFSI and Primus. The buyer may specify the type or may accept any type of audit.

If the buyer has no preference or accepts any type of audit, the USDA GAP audit is the best, simplest and least expensive option. The Minnesota Department of Agriculture (MDA) is the entity that will conduct the USDA GAP audit.

Step 2. What crops?

Determine the crop(s) you will certify. Remember, your product gets the GAP certificate, not your farm. If you are only going to sell tomatoes and bell peppers to the buyer requiring the audit, you should only get the audit on tomatoes and bell peppers. You can always add more products later.

Step 3. Organize your food safety plan

Have your food safety plan and recordkeeping in order. A documented food safety plan is required to pass a GAP audit. Try using our food safety plan templates.

Sections of the plan include

  • Farm history and land use

  • Worker health and hygiene

  • Worker training

  • Water sources/quality

  • Manures and soil amendments

  • Toilet and handwashing facilities

  • Harvesting, packing, storage and transportation

  • Product traceability

Many growers work on their food safety plan in the winter, and then update it as needed throughout the growing season.

As a part of your food safety plan, you will need to write your farm’s policies and standard operating procedures (often called SOPs), and develop and use basic log sheets where you document cleaning and other food safety related activities.

Step 4. Review the audit checklist and set up the audit

Review the USDA GAP/GHP audit checklist. The audit checklist will indicate where you need a document, policy or record. The checklist is the same one the auditor from the MDA will use for your audit, so there are no surprises!

The USDA GAP audit checklist (PDF) is what the auditor will use as they verify the practices on your farm. View MDA GAP audit information or call 651-201-6067 to set up an audit or talk to MDA program staff. The audit will occur when your product is being harvested so that they can see your farming process.

Audits cost $115 an hour to pay for the auditor’s time, plus a $50 service fee that the USDA adds to all audits. You will only complete the sections that pertain to your farm and audit.

Important: The MDA has a cost-share program that can reimburse you for up to 75 percent of the cost of the audit once you have the audit certificate. Read more about the cost share.

A passing score of 80 percent is required on each section. If you wish to continue to have your product GAP audited, you will need to have the audit done yearly and you will need to pay the auditor each year. Most farms complete the audit in 4 to 5 hours. Having your documents in order reduces the time that the auditor will spend at your farm, and therefore your total cost.

Step 5. Ask for help if needed

If you are having a hard time getting started, there are resources available to help you, such as templates, GAPs workshops, and UMN Extension personnel who can review your plan via email. Other growers can serve as resources. Once your food safety plan is plan written and you are ready to schedule an audit, the process is very straightforward.

Having a GAP audit on your product allows you to sell to new markets, and is a way to organize your food safety practices to make sure you are doing everything you can to ensure the food from your farm is safe and healthful. Good food safety practices on the farm are good for everyone, and having a GAP audit is one way to show your customers the great care you take in your food production.

Annalisa Hultberg, Extension educator

Reviewed in 2020

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