Are small farms exempt from Good Agricultural Practices certification?

Growers operating small farms may not be required to be GAP certified under the new Food Safety Modernization Act, but retailers, packers and shippers keep demanding proof of GAP certification.

Small fruit growers wanting to sell their crop to traditional packers and shippers still have to comply with buyer requirements, and these can be very challenging.

In 1998, the U.S. Food and Drug Administration (FDA), in partnership with other federal and state agencies, developed a guidance document on food safety for fresh produce in response to several large foodborne illness outbreaks associated with fresh produce in the preceding years. The document, Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables, was only guidelines for industry and not regulations. More recently, the signing of the Food Safety Modernization Act in January 2011 gives the FDA a mandate to pursue a system based on science and addresses hazards from farm to table, putting greater emphasis on preventing rather than responding to food-borne illness outbreaks. For small growers, the law provides exemptions. Small farms marketing directly to consumers and certain retailers and restaurants, and having total annual sales less than $500,000, are exempt from the produce safety standards. However, the law does not exempt them from demonstrating they have either “identified potential hazards associated with the food being produced,” and “implementing” and “monitoring” preventative controls; or that they demonstrate compliance with “state, local, county, or other applicable non-Federal food safety law.” Read the Food Liability Law Blog for more on the FSMA.

This apparent contradiction, “you are exempted but you aren’t,” creates confusion and false hope among small growers that in 2011 expect to sell their crop without requiring attending or implementing a Good Agricultural Practices (GAP) program in their farms.

Currently, our underserved, limited resources blueberry growers are in desperate need for assistance with their GAP training and certification. Major obstacles in complying with GAP for food safety are the complexity of the GAP program and the delivery methods of educational trainings by governmental, higher educational institutions and nonprofit organizations. So far, many of those growers have only attended informational meetings on food safety and GAP. However, information alone does not provide in-depth knowledge to allow for comprehension and retention of complex technologies not easily grasped in informational meetings. Adoption of bundles of technology such as IPM and GAP require a comprehensive structured training curriculum integrating classroom and hands-on field training. For crops like blueberries and other small fruits, training curricula also have to be crop specific. It is very important for underserved producers to have crop specific GAP trainings because they focus on a familiar crop, one they know and understand, thus making food safety issues in relation to their crop easier to grasp.

At MSU Extension in West Olive, and the AgBioResearch Center at the Trevor Nichols Research Complex in Fennville, we are committed to support small producers with educational programs that may help them comply with food safety and other environmental regulations. In 2010, we provided crop specific GAP training to 96 blueberry growers through four two-day workshops including 38 Hispanics, two African Americans and 23 women. In March and April 2011, we have offered two trainings on Risk Management Tools for Food Safety: Blueberry GAP’s, and one Traceability workshop for small producers. On May 26-27, we will again offer the Risk Management Tools for Food Safety: Blueberry GAP training.

For information and assistance on GAP implementation and training, contact Carlos Garcia-Salazar at 616-260-0671 or, or Anamaria Gómez-Rodas at 269-561-5040 or For resources on GAP implementation and training, visit the MSU Extension Agrifood Safety Workgroup web site.

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