FSMA compliance does not guarantee passage of a GAP audit

It is important to note that simply being FSMA compliant does not assure a farm will be able to pass a food safety audit. Here are some key differences between FSMA and food safety audits.

Many fresh produce growers are beginning to reckon with the issues posed by the Food Safety Modernization Act (FSMA). This most sweeping piece of legislation will put in place many basic food safety measures across most fruit and vegetable farms. To their credit, many growers have already been at work implementing voluntary food safety measures across every fruit and vegetable crop. Some have even gone through GAP food safety audits. One thing that it is important for those who either receive GAP audits or are contemplating them is that FSMA compliance does not guarantee one will pass a GAP audit.

One area where FSMA and current industry practice in food safety diverge is in basic sanitation. Under FSMA, equipment must be cleanable. The rule instructs that inspection, maintenance, cleaning and sanitizing must be done “when necessary and appropriate.” The legislation also codifies that “reasonable measures” must be exercised to keep pests and domestic animals out of buildings.

By comparison, current industry’s food safety practices require growers to offer detailed cleaning steps in their food safety manual for major equipment used for harvesting and handling produce. The detailed steps need to include how equipment is to be cleaned, information on soap and sanitizer type as well as concentrations of each to be used, what verification steps will be used to ensure equipment is clean, and a detail of any corrective actions that may have had to be done regarding improper cleaning.

As one can clearly see from this comparison, FSMA provides a floor establishing a base standard for safe food. GAPs provide additional assurances to further reduce the risk of foodborne illness. It is also important to remember these initiatives can only reduce the risk of illnesses, but not eliminate the risk. There is only one way to eliminate risks posed by foodborne illness on fresh produce, and that is to fully cook it.

If you have specific questions about FSMA or GAPs, or have difficulty tailoring GAPs to your farm, contact the Michigan State University Extension Agrifood Safety Workgroup at 517-788-4292 or gaps@msu.edu.

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