Food Safety Call - 09 Mar 2010
NGFN Food Safety Conference Call
March 9, 2010
- Global GAP Group Certification and Other “Alternative” GAP Approaches
- Legislative / Regulatory Update
And, if time ...
- GAP Harmonization initiative
- FamilyFarmed.org Food Safety planning tool
- Wild Farm Alliance initiative to support Natural Resources Conservation Services (NRCS)
- Dr. Elme Coetzer, Standards Manager, GlobalGAP
- Patrick Pimentel, General Manager, NSF/Davis Fresh
Several NGFN groups who are or seek to be suppliers to SYSCO are working with GlobalGAP, NGFN Food Safety Coordinator and SYSCO to establish pilot programs. Each situation is somewhat unique and formative, and so it is premature to offer much description or detail. The core of such programs is the development of a quality management system (QMS) that applies to all members of the group, and a rigorous method of training and reporting to assure that the plan is fully implemented by all members. The internal reporting and data gathering process, under the guidance of a trained, food safety professional, reduces dramatically the burden and cost for each individual farm, while also reducing the workload of external auditors.
The GlobalGAP approach begins with a focused, limited “primary farm assurance”, and as farms increase their capacity and in order to respond to buyer needs, moves through an intermediary farm assurance to a food safety assurance, and finally to integrated Farm Assurance.
The concept of Primary Farm Assurance (PFA) is the response of GlobalGAP to the demand of markets where certification to Good Agricultural Practices is emerging. Whereas full GlobalGAP certification may be difficult to achieve in one go, engaged supply chain partners may use PFA to design a tailored subset of GlobalGAP requirements and implement a stepwise approach within their agricultural supplier base. This works particularly well for local and national markets to achieve Integrated Farm Assurance (IFA) certification.
Another alternative GAP approach based on GlobalGAP certification is being developed by NSF/Davis Fresh, a division of NSF International, a global, NGO offering leadership in standard development, product certification, education and risk management for public health and safety since 1944.
NSF/Davis Fresh is accredited by GlobalGAP as a certification body and provides training and auditing services in the United States from their Watsonville, Ca. location. NSF is proposing a tiered approach to building capacity and verification of on farm food safety practices. The NSF approach begins with a training and registration step that is prior to GlobalGAPs “first level” which is “primary Farm assurance.” The steps in continuous improvement beyond that entry level point parallel those of GlobalGAP.
An NSF/Davis Fresh representative will be present on this month's call if possible, and will continue to work with NGFN Food Safety Coordinator, interested NGFN RLTs, and GlobalGAP, and interested buyers to develop pilot programs to increase on farm food safety capacity and verify these capacities to buyers.
In the end, buyer acceptance is necessary for any voluntary GAP program to be useful. And with increased buyer acceptance will come the opportunity to educate consumers about the effectiveness of the public/private partnership to enhance food safety. Only through effective implementation of on farm food safety standards in a fashion that is acceptable to buyers and ultimately restores consumer confidence in food safety will the wave of demand for ever increasing regulation begin to recede.
- Kate Fitzgerald, Sr. Policy Associate, NSAC
The National Sustainable Agriculture Coalition (NSAC) continues to cultivate support for amendments to S510 to address 4 remaining areas of concern to sustainable and organic farmers and their supporters:
- Providing guidance in the process of establishing produce regulations,
- Improving the definition of “food facilities” to avoid reclassifying farms that do value adding as FDA regulated facilities,
- Protecting “identity preserved products” from overly proscriptive, technology driven approaches to traceability
- Developing training programs according to guidelines developed in Senator Stabenow's proposed “Growing Safe Food Act”, S2758, which they argue should be included as part of the larger Food Safety bill S510
Early last week, Senator Harkin, Chair of the Health, Education, Labor and Pensions (HELP) Committee, announced his intention that the bill reach the Senate floor before the Easter Recess if possible, and be on President Obama’s desk by May. NSAC has organized a Farmer Fly-in to help highlight these concerns on March 8 and 9.
FDA has opened a docket for public comment/response (click here to see docket) to a series of questions that it wishes to consider as it moves forward in preparation for development of produce food safety guidelines. The original FDA publication: “a guide to minimizing microbial pathogens in fresh produce”, which was written in 1998, has been in the process of being “updated” for a couple of years. One could view this initiative by FDA in the light of the need to update the guide, as well as to prepare for the regulatory standard setting process.
This request by FDA also parallels their efforts to develop commodity specific guidance for 3 vulnerable fresh crops: Leafy greens, melons, and tomatoes.
The process of responding to the detailed questions that FDA has posed is a challenging one as it forces respondents to assume a level of expertise that few of us actually have. For an example of how to respond, see the following responses from National Organic Coalition (NOC) to the commodity specific guidelines for leafy greens, melons, and tomatoes.
Wallace Center staff and consultants have written a draft response to the FDA request, which aims to take an “above the treetops” view of several important issues around food safety that are in the process of being addressed “on the ground”.
The Technical Working Group (TWG) continues to meet regularly and is now deep into “reconciling” the details of the dozen GAP standards that have volunteered to participate in the Harmonization process. This is where the rubber meets the road. Challenges such as how to handle wildlife, water testing, residue testing, and more will keep the group busy. So far the style has been to establish general but clear parameters that are not proscriptive, and are designed to encourage system level problem solving by farmers throughout the development of logical, “defensible” on farm plans.
A report will be presented in mid April to the Steering Committee which formed after the 2009 “Global Conference on Food Safety Standards”. The goal is to present a completed, even if draft, product to the Steering Committee by October. United Fresh updates its web site with details of each TWG meeting. The most recent updates are from the Feb 17-18 meeting in Weslaco, Texas. The TWG meets next in Irvine, Ca. on March 10-11.
The On-Farm Food Safety Project is in full swing. FamilyFarmed.org's Jim Slama and the USDA's Jerry Berney are in full conference mode, speaking on food safety with joint presentations at major farming conferences. They have already spoken at the Mid-Atlantic Fruit and Vegetable Growers Conference in Hershey as well as the Midwest Organic and Sustainable Education Service (MOSES) Conference in LaCrosse, Wisconsin. Next up is the FamilyFarmed EXPO in Chicago. The presentations are providing farmers with information about food safety as well as things to include in On-Farm Food safety plans. The MOSES presentation included a very thorough PowerPoint presentation that gave detailed explanations about all 13 areas that should be included in food safety plans.
Researcher Delia Hollbach and technical advisory committee chair Will Daniels also continue the process of developing decision trees for each of the 13 areas to consider. Drafts of the first three have been reviewed by the technical advisory committee which then had suggestions for additional elements and research. This process will be continuing later in March after the completion of the FamilyFarmed EXPO.
One of the major points of contention as food safety compliance pressures reach the farm level is the reconciliation of mandates for food safety and for conservation of natural resources. Fear of pathogenic contamination resulting from the presence of wildlife in fields has led to wholesale destruction of habitat in the Salinas Valley, the epicenter of food safety concerns in the leafy greens industry. Lessons learned are reflected in a report from the Produce Safety project.
Much of the support for Conservation practices on the farm originates administratively at the NRCS, which has not previously had experience in food safety. Wild Farm Alliance, an NSAC and NOC member, has initiated a collaboration to seek a CIG (Conservation Innovation Grant) to foster development of resources and information on how to co-manage for food safety and conservation objectives.
This issue will be a key to the future of sustainable agriculture as there are already skeptics who question the efficacy of co-management. This link to “the pundit” includes an excellent executive summary of the produce safety project report, as well as well articulated concerns.
If the debate polarizes, we will be faced with the shrill cry of “who do you care more about, wildlife or people”? This initiative is young and updates will be ongoing as we seek to create a civil dialogue with hopes of balancing these two important public mandates.