Catawba River District & GAP Certification

Transcription

1 Catawba River District & GAP Certification

2 TABLE OF CONTENTS National School Lunch Policy Charlotte Mecklenburg School Lunch/Food Policy Good Agricultural Practices (GAP) checklist Introduction to GAP Certification GAP Preparation GAP Cost and Assistance GAP Audit General Questions Part 1 Farm Review Part 2 Field Harvest and Field Packing Activities Part 3 House Packing Facility Part 4 Storage and Transportation Parts 5 and 6 Not Applicable Part 7 Preventative Food Defense Procedures GAP Scoring System Unannounced Visits Non-Conformity and Corrective Action Policy (CAR) Success Stories

3 NATIONAL SCHOOL LUNCH PROGRAM Congress created the National School Lunch Program (NSLP) after young men were rejected from the draft in World War II and investigation showed a connection between physical deficiencies and childhood malnutrition. 1 The National School Lunch Act was passed in 1946 as a measure of national security, to safeguard the health and well-being of the Nation s children. 2 The meals that are served to students through the NSLP must be consistent with the Dietary Guidelines for American. Congress passed the Healthy, Hunger-Free Kids Act which aimed at improving the quality of school breakfast for children across the country. 3 NORTH CAROLINA LUNCH POLICY North Carolina s lunch policy follows the NSLP and North Carolina has even adopted stricter requirements in some situations. The sale and service of food and beverages on a school property is regulated by local, state, and federal policies and regulations. North Carolina s State Board of Education s policy states that the local Child Nutrition program must operation all food and beverages sales from 12:01 A.M. until after the last student has been severed lunch. Any violation of this will result in the school paying a fine made from school funds and not the Child Nutrition funds. The North Carolina state regulation states that all food served in the cafeteria must be from a Good Agricultural Practices (GAP) certified farm. 1 Food Resource Action Center, National School Lunch Program, (Last visited Nov. 6, 2012). 2 Food Resource Action Center, National School Lunch Program, (Last visited Nov. 6, 2012). 3 Food Resource Action Center, School Meal Nutritional Standards, (Last visited Nov. 6, 2012). 3

4 CHARLOTTE MECKLENBURG SCHOOLS LUNCH POLICY North Carolina requires all food served in a school cafeteria must be from a Good Agricultural Practices (GAP) certified farm. At the end of 2010, the Child Nutrition Re- Authorization Act was intended to recall CAP Certifications at state levels; however, the recommendations did not make it into the final bill. The health department does not have a policy either for or against food from a school garden being served to students. Students who take part in a school garden want to be able to enjoy their harvest. CMS has come up with some alternatives to becoming GAP certified. One solution is when the produce is harvested that the food is taken to a commercial kitchen and handled with food safety supervision. In addition, the Field to Fork Program 4 allows students to bring in produced harvested from the school garden to make a whole grain veggie pizza. The food is washed and prepared at Fuel Pizza 5 following food safety requirements but does not need the GAP certification requirements like a school cafeteria. Another alternative is through classroom teaching to incorporate a taste test. This is technically permitted but it is frowned on by the Environmental Health Department because generally classrooms are not equipped to safely was food. However, as long as the food is not served as part of lunch then seems to be acceptable. 4 For more information please see: 5 The participating restaurant. 4

5 GAP Certification Quick Checklist 1. Prepare and Implement a Food Safety program. [ ] 2. Sign and Fax Participation Agreement.. [ ] 3. Schedule GAP Audit [ ] 4. The Initial Audit [ ] 5. Answer General Questions [ ] 6. Auditor Submits GAP cost share Assistance form.... [ ] 7. Receive Certification and listing on USDA website. [ ] 8. An Appeal process is available for operations that fail the audit. [ ] 5

6 A Guide to GAP Certification: Introduction The 2008 federal Farm Bill allows schools when buying agricultural products to purchase both locally grown and locally raised products. Each crop must be certified on its own because of the wide variety of individual issues presented by each different kind of crop, but a separate audit is not required. Being able to trace each piece of produce through each step is a critical part of GAP certification in case of food-borne illness or recall. The United States Department of Agriculture (USDA) GAP/GHP audit is valid for one year from the date of the initial audit and can be renewed. Preparation The first step in preparing for an audit should be the development and implementation of a food safety program. Typically, the food safety program takes the form of a manual of the food safety plan. The program shall define specific, measurable steps taken by the operation to reduce the risk of microbial, physical and chemical hazards from contaminating the product. 6 The program must incorporate the USDA GAP/GHP audit verification program requirements and applicable policies. 7 The operation shall keep records as necessary to document adherence, a list of the documents is available in the audit checklist. It is recommended that the operation conduct a self or internal audit using the USDA GAP/GHP audit checklist. The following are key items to incorporate into the plan by the operation: 6 GAP/GHP Audit Verification Program User s Guide, Fruit and Vegetable Program. (April 2012). Available at (last accessed October 22, 2012). 7 provides literature helping farmers ensure they are ready for a GAP audit including templates and examples. The FDA has also released four commodity specific guidelines for leafy greens, melon, tomatoes, and fresh cut fruits and vegetables. 6

7 Must create a food safety program that accurately reflects their operation and addresses the various risks associated with the commodities being audited; Shall develop Standard Operating Procedures (SOPs); Must designate a person that oversees the food safety program; Must determine what to document and keep records for and keep current; 8 and Shall document corrective actions taken in adherence to their safety plan. Next, the operation should contact N.C. Federal-State Inspection Service in Charlotte to schedule an initial audit to verify GAP/GHP compliance at least two weeks prior to the date requested. Call to schedule an initial audit or through the N.C. Request for Audit Services (see Appendix) or FV-237A form. 9 Be prepared with a list of anticipated dates the operation would be available for inspection. An initial audit is valid for one year from the date of audit. All commodities covered by the audit must be declared during the initial audit and cannot be added later in the season. Before performing an audit, a signed Participation Agreement (FV-651) provided by the auditor must be on file with North Carolina Department of Agriculture NCDA (see Appendix). A management representative of the operation must sign the Agreement The audit checklist defines when documents are required and what type is necessary. These are defined in the checklist as D (documents), P (policy), or an R (Records). 9 Available at (last accessed October 22, 2012). 10 An example of this agreement is available at (last accessed October 22, 2012). 7

8 Cost and Assistance (Submitted after the Audit) The audit is charged at a rate of $92 per hour and beings when the inspector leaves their office and ends upon return to their officer. Also, an additional $50 is charged for website maintenance and certification. NCDA has developed the GAP Certification Assistance Program to assist with financial support in obtaining a third party audit to verify effective food safety practices. The NCDA will pay up to $600 of the cost of having a third party audit to verify a farm s food safety program for first time audits and $300 for those audited in previous years. The GAP auditor and the representative for the operation must sign the Assistance request form. To be eligible for assistance N.C. fruit and vegetable growers must meet the following requirements: 1. Growers must have third party audit from an approved government agency or company that verifies GAP/GHP; 2. GAP/GHP audits can be for Farm Review, Field Harvest, and Field Packing Activities, Packing House Facility, Storage and Transportation; 3. The GAP/GHP audit must be conducted in the same year of the application for assistance; and 4. Submit an application for approval to participate in this program prior to receiving the GAP/GHP audit. The Assistance form should be submitted after the audit with a copy of the invoice from the auditing agency and mailed to the NCDA & CS GAP Certification Assistance Program before December 31, 2012, for the current year. 8

9 The Audit The GAP certification and food safety process is concerned mostly with the production and distribution aspects of a farm to institution programs. The audit process begins with the Opening Meeting which is a question and answer (Q&A) explanation of audit process. The audit is then Conducted where the inspector reviews documents and determines compliance. The audit team Caucuses to review concerns. Finally the Closing Meeting is where the auditor will meet with the operation s representatives There are six components to the auditing program, as well as a Q&A section that must be passed. The operation shall designate which scopes the auditor will perform: 1. General Questions 2. Audit Scopes (GAP): a. Part 1 Farm Review b. Part 2 Field Harvesting & Field Packing Activities 3. Audit Scopes (GHP): a. Part 3 House Packing Facility b. Part 4 Storage & Transportation c. Part 5 (No Longer Used) d. Part 6 Wholesale Distribution Center/Terminal Warehouse e. Part 7 Preventative Food Defense Procedures (optional) 9

10 An auditor must have the opportunity to observe the crops being grown and harvested during the initial audit or subsequent unannounced visits. General Questions The Q&A section covers the following topics: Food Safety Plan (see above) Traceability the ability to know where product was received from and where it was sent to. 11 Recall Program the ability to pull product from the marketplace once it has left the operation s control. Operations must have documented evidence of completing at least one mock recall prior to the audit. 12 Worker Health & Hygiene the food safety plan should address these issues. 13 Pesticide/Chemical Use must follow state licensing requirements. Part 1 Farm Review Part 1 addresses the crop production areas and adjacent lands, domestic and wild animals, as well as inputs used to produce the crops such as water and soil amendments. Water Use The USDA sets certain frequencies for testing water quality depending on the source of the water used for irrigation The Bioterrorism Act of 2002 requires certain handlers of food to keep records to keep track of produce one step forward and one step back within the food chain. 12 An example of a mock recall can be found on p.11 of the User s Guide (see fn.1). 13 Examples of SOPs can be found on pp of the User s Guide and there are many specific OSHA and USDA requirements that must be met. 14 See pp of the User s Guide for the testing frequencies. 10

11 Soil Amendments A risk assessment should be conducted to determine if and when raw manure or biosolids are appropriate to use. 15 Animals/Wildlife/Livestock The operation should monitor for signs of animals entering the crop production areas and attempt to reduce the opportunity of entry. Land Use & History The operation must have a documented land use risk assessment and consider the location of the operation s/municipal sewage systems. Part 2 Field Harvest & Field Packing Activities An auditor can only perform Part 2 when commodities are actively being harvested and if there is activity in the crop production area. The emphasis on Part 2 is the harvesting activities and the containers and equipment, which are used to pack the product. Employee health and hygiene are an important component of this part but is covered in the General Questions section of the audit. A Pre-Harvest Assessment must be completed on each production area prior to harvesting any crop being certified by the auditor. This assessment may include statements that address known risks applicable to the operation. 16 Field Sanitation Units must comply with all applicable local, state, and federal regulations and have a documented emergency clean-up procedure in case contamination occurs. Harvesting Containers & Equipment shall be kept as clean as practicable to prevent cross-contamination of fresh produce. The User s Guide provides key areas to consider which are covered in the GAP & GHP audit See pp of the User s Guide for USDA requirements. 16 See pp of the User s Guide for examples of known risk statements. 17 See pp of the User s Guide for this list. 11

12 Part 3 House Packing Facility An auditor can only perform Part 3 when the packinghouse is actively handling product. The house packing facility covers packinghouses located on or near crop production areas. The main focuses of this audit are water, packing equipment, general housekeeping, worker health and personal hygiene, containers used for packing, and pest control. Water and Ice Used in the packing of fresh fruits and vegetables must meet the requirements of the EPA Drinking Water Standard. 18 If water is reused or treated the operation should consider practices which will ensure and maintain water quality. Sanitation Program/Housekeeping should be employed as standard operating procedure to maintain control throughout the packing operation. Packing areas should be cleaned minimally at the end of each day. The operation shall have a procedure which identifies how product that spilled or comes in contact with the floor is handled. A general sanitation schedule which addresses the cleaning and sanitizing of the packinghouse operation shall include: 1. Food contact surfaces; 2. Pipes, ducts, fans, and ceilings which are over product flow zones; and 3. Catwalks over food contact surfaces. Worker Health and Hygiene are covered by the General Questions section. The operation shall also evaluate a jewelry and hair/beard net policy which is appropriate for the facility and is stated in the Food Safety Plan. Containers used for packing the product should be either new or sanitized which are clean and in good condition. 18 Municipal water supplies are already regulated and meet these standards. 12

13 A Pest Control program to reduce the risk of contamination by rodents or other animals shall be established. The Pest Control program can be performed by a trained employee or a contracted pest control company. Part 4 Storage & Transportation This covers the storage and transportation facilities located on or near crop production areas. Mechanical Equipment used in the storage facility shall be clean and properly maintained. Ice shall meet Environmental Protection Agency (EPA) Drinking Water Standards. The operation shall develop and implement procedures for monitoring and recording climate control rooms. Transportation and Loading procedures should be developed which outline the procedure for inspecting transportation conveyances for cleanliness, odors, and debris before loading the product. Parts 5 & 6 would be inapplicable to the Proposed Project Part 7 Preventative Food Defense Procedures (optional) Food Defense is the protection of the food supply by intentional contamination by biological, chemical, or physical means by an aggressor. Food Defense Plan shall indicate there is a person in the operation that has implemented and will oversee the food defense plan. 13

14 Personnel should be designated to oversee the plan and all employees shall be provided training for potential threats to the product supply. Access Procedures should address who has admittance to sensitive areas of the facilities. An accountability log showing who is in possession of any keys to enter the facility shall be kept. An employee should accompany visitors and all vehicles should be subject to inspection. A policy for the delivery schedules and rejection of loads shall also be developed. A policy should be in place that prohibits workers from brining Personal Items into the production. Employees should not be allowed to loiter around the grounds and facility after their work hours. Other facility procedures should be developed and include such matters as compliance with Immigration rules and inventorying of items used by employees. 19 Products that are known Allergens such as peanuts should be segregated to avoid crosscontamination. If applicable, USDA requires that all domestic products be segregated from any foreign product. GAP Scoring System The USDA GAP&GHP audit utilizes a scoring system. Each question is given a score of 5, 10 or 15 points and is weighted depending on the relative risk associated with the question. There are no partial points given for any question, each question is either given the total points assigned to the question or zero points. The USDA GAP&GHP Program requirements state that a minimum of 80% must be scored on each scope of the audit conducted in order to pass the audit. 19 See pp of the User s Guide for the full list. 14

15 Unannounced Visits At some point during the season, an unannounced verification visit is made; however, if only one commodity is grown, no unannounced visits are made. Non-Conformity and Corrective Action Policy (CAR) If an operation fails an initial audit, the auditor will issue a CAR and the operation should develop a plan to fix and address the non-conformities listed if it wishes to continue in the GAP & GHP program. Operations have the ability to appeal, dispute or lodge a complaint if they so desire which is performed by an audit review board. Success Stories Seeds - Wake County, NC School/community farms grow and sell at local farmer s markets. More information available at Contact: Santos Flores, DIG Coordinator, , santos@seedsnc.org Grow with Me Anderson County, SC The program s vision includes four goals: a) Local Food in Schools: b) Farm Field Trips: c) Nutrition Education: 15

16 d) School Gardens: Students will eat what they grow. The school garden component is the link between healthy eating and reconnecting students with their agricultural heritage. Contact: Allison Schaum, Palmetto Agricultural Consultants No further contact information found. Presentation available at: The Clemson Organic Farm, SC Underwent GAP certification, and following are some examples of the kinds of issues and modifications they had to identify and implement: a) Use a separate cooler for eggs and produce b) Restrict bird access to market area c) Establish a produce washing facility with proper drainage Total cost: approximately $3000 Bamberg School District, SC Students will be coached by representatives from the South Carolina Department of Agriculture and Clemson University, and the food they grow will be served in the school cafeterias and classrooms. See the full news story available at: 16