Filling the Food Safety GAPs for Small Farms

      Posted On: April 15, 2009

By Wendy Wasserman

Spinach. Peanuts. Tomatoes. Lettuce. Pistachios.

In the past few years, there has been mounting consumer and producer discussion about food borne illness. Some of the high profile cases of wide-spread food borne illness have been traced back to incomplete food safety protocols occurring at large producers and commodity processors. Regardless of the case, culprit, or cause, everyone – from producers to the government to consumers – agrees that food safety is an important issue.

Currently, there are no government mandated farm-based food safety regulations. But there are Good Agricultural Practices (GAPs), a list of recommended food safety protocols developed in response to guidance from the Food and Drug Administration in 1998. Most of the GAP protocols are based on commonsense sanitation habits like water and soil testing, hand washing, and general hygiene that are relevant to any farm of any size. Some other GAP guidelines address things like sophisticated pest management and crop placement issues that might not apply to small farmers.

Bernie Prince, of FreshFarm Markets in Washington, DC, recently represented FMC at a a fresh produce industry summit designed to recommend potential changes to existing Good Agricultural Practice guidelines for food safety. “The growing standards for GAPs are important, but they need to make sense. In mono-crop agriculture, large bare earth buffer strips may be the norm, but they will not work for sustainable and organic growers who want to have beneficial insects and companion plantings in buffer areas.”

Although GAPs are a useful starting place when thinking about food safety protocols, they are not a one-size-fits-all model and some of the GAP recommendations may not work for small farms and farmers markets. However, that does not mean that small farmers and farmers markets are immune from the issue. “[Current consumer interest in food safety] is an opportunity to get ahead of the curve,” says Jim Slama, President of FamilyFarmed.Org “If farmers market growers can develop on-farm food safety plans and training, we would be light years ahead.”

To understand what GAPs are and how small farmers and farmers markets can develop appropriate food safety protocols, Farmers Market Coalition asked Elizabeth Bihn, National GAPs Program Coordinator and Senior Extension Associate at Cornell University about food safety, small farmers, and farmers markets.

FMC: Why should farmers be concerned about food safety?

EB: The safety of fresh fruits and vegetables impacts consumers as well as EVERYONE who grows and harvests fresh produce. Although you may have been growing fresh produce for years and never had a reported problem, you still need to be aware of microbial risks that exist in your operation, how outbreaks have occurred, and the impact they may have on your business. Foodborne illnesses associated with fresh produce are well documented as highlighted by the outbreaks in apple cider and spinach caused by E. coli O157:H7 and the 2008 outbreak in pepper/tomatoes caused by Salmonella contamination. Being aware and prepared will keep you competitive, enable you to answer your customers’ questions, and reinforce the perception of quality associated with your products.

FMC: If you are a small grower who sells directly to consumers, why have a farm based food safety plan?

EB: The biggest reason is because you do not want to get anyone sick. Since most fresh produce is grown in the soil, under open skies, there are microbial risks that need to be managed. The idea that because risk exists there is nothing that can be done to reduce it is false. All produce growers, regardless of farm size or products grown, can impact the safety of the food they produce by evaluating their operation, assessing the risks, and implementing often very simple protocols.

FMC: Under what circumstances is a farm required to become GAP certified?

EB: Many retail markets (grocery stores) require audits of their fresh produce suppliers, even small seasonal suppliers. Some retailers will only accept audits from certain companies, so if you have a buyer requesting an audit, be certain to ask which audit(s) they will accept. In some instances, industry groups have implemented marketing agreements such as the Leafy Greens Marketing Agreement in California and Arizona. In Florida, the state has implemented T-GAPs that specifically govern tomato production in the state. Otherwise, GAP certification is completely voluntary.

FMC: Who certifies whether or not a farm implements recommended GAPs?

EB: There are many companies that offer third party audits to verify the implementation of GAPs on the farm. These are fee for service audits, so a grower would contact the company, which would charge a fee for coming to the farm and conducting the audit. One source of confusion, I think, is that one of the organizations offering third party audits is the USDA-Fresh Products Division. They don’t do regulatory audits, but offer a fee for service just like private companies like Primus Labs, Scientific Certification Systems, and Davis Fresh to name a few. Each audit company is independent so the audit and the cost may vary.

FMC: What is an example of a GAP that is easy to implement at a farm of any size?

EB: An easy practice to implement is proper and frequent hand washing. All farm workers (if you work on a farm, you are a farm worker) should be trained in how to properly wash their hands, when to wash their hands (before beginning work and any time you are returning to work such as after breaks, lunch, using the toilet, or doing a job where your hands become unclean such as cleaning the toilet, taking out the trash, or tending to farm animals), and all necessary facilities should be provided (e.g. soap, water, single use towels).

FMC: Why do farmers markets need to be aware of food safety issues?

When a foodborne illness associated with fresh produce happens, it impacts the entire fruit and vegetable industry, including farmers markets. Going back to the hand washing example, many farmers markets do not have permanent toilet and hand washing facilities on site, making it very difficult for vendors and customers to maintain proper hand hygiene. Another food safety issue at farmers markets is the presence of animals, either pets or animal attractions from the farm. Many markets sell ready-to-eat prepared foods and fruits and vegetables which are consumed as patrons walk around. As a precaution,farmers can leave pets at home and markets can discourage patrons from bringing animals into areas where foods are prepared and consumed.

FMC: How can small farmers and farmers markets document their food safety protocols without being GAP certified?

EB: You do not need to be audited to have a farm food safety plan. Our website ( has many educational materials to help growers assess their operations, create a farm food safety plan, and implement GAPs. At our site, you can download free record keeping sheets to help you document the practices that you have implemented. Designing a farm food safety plan that you can integrate into your day to day activities is important, so they become part of the normal operating routine for all workers. If a farmer wants or needs to have an audit, they first need a food safety plan that documents what is being done to prevent contamination. So the basic steps are 1) assessment, 2) documentation, and 3) implementation.

FMC: Are recommended practices the same in every state?

EB: GAPs vary operation to operation and commodity to commodity. If you grow citrus, your plan is going to look different than someone who grows cabbage. If you use surface water during production, your plan will be different than someone who uses municipal water. FDA’s 1998 Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables ( is currently being updated, but it’s a good resource to help understand GAPs and produce food safety issues. Our website has links to collaborators in many states throughout the US which offer their own educational programs, links to third party audit companies, and many self-paced training materials to help farmers implement GAPs.


Elizabeth Bihn coordinates online classes about Good Agricultural Practices. Courses are currently scheduled in April and June 2009 with more dates to be determined. Visit for more information.

For additional Information about Good Agricultural Practices:

For a sampling of existing food safety guidelines for farmers markets, visit the FMC Resource Library’s category called “Food Safety and Handling.”