FVIAC Meeting March 2015
FVIAC Meeting March 2015

The USDA GAP&GHP Program

• Voluntary, user fee based program offered by 

USDA’s Agricultural Marketing Service (AMS)

• Verifies an operation developed and implemented a 

food safety program that incorporates good 

agricultural practices (GAP) and good handling 

practices (GHP) 

• Audits based on FDA Guidance and industry best 

practices
FVIAC Meeting March 2015

The USDA GAP&GHP Program

• Used by producers, packers, and handlers to gain 

market access to retailers, food service and 

institutional buyers who require third-party 

verification of food safety

• In FY 2014, AMS conducted more than 4,000 GAP 

audits in the United States, Puerto Rico, Canada, 

and Chile
FVIAC Meeting March 2015

The USDA GAP&GHP Program

• Audits performed by 250 trained, licensed Federal 

personnel and/or Federal-State cooperators 

• All auditors meet strict training 

and evaluation requirements 

as outlined in the 

AMS Auditor Criteria
FVIAC Meeting March 2015

The USDA GAP&GHP Program

• AMS is not a food safety agency

• Food and Drug Administration (FDA) and USDA’s 

Food Safety and Inspection Service set food 

safety standards

• Audits are conducted using FDA Guidelines or 

industry best practices

• AMS or AMS-licensed personnel conduct all USDA 

GAP audits

• We do not accredit outside entities to perform 

audits
FVIAC Meeting March 2015

Proliferation of Audits and Audit Fatigue

Over the past 10 years, outbreaks associated with fresh 

produce triggered industry-led initiatives to address 

concerns about the safety of fruits and vegetables, 

including:

• Commodity Specific Best Practices

• Commodity Specific Audit Programs 

• Marketing Agreements/Orders specific to food safety

• State-level regulations (e.g., Florida tomato)

• Private certification systems 
FVIAC Meeting March 2015

Proliferation of Audits and Audit Fatigue

These initiatives have had some unintended 

consequences:

• Multiple food safety standards 

• Multiple audits

• Buyer preferences of specific standards 

• Buyer-specific riders or addendums
FVIAC Meeting March 2015

Proliferation of Audits and Audit Fatigue

• What should a food safety standard include?

• Microbiological food safety? 

• Food defense? 

• Sustainability? 

• Social accountability? 

• North American vs. European models?

• Who can perform audits to these standards? 
FVIAC Meeting March 2015

Proliferation of Audits and Audit Fatigue

• Effects of proliferation of audits on the producer 

community

• Confusion about what standard to use

• Confusion about what audit organization to use

• Multiple audits needed to

meet multiple buyers’ requirements

• Inconsistencies in interpretations 

of food safety standards
FVIAC Meeting March 2015

Harmonization and Benchmarking

• No generally accepted system or scheme that:

• Everyone agrees to follow 

• Defines an acceptable food safety standard

• Defines an acceptable audit process

• As a result, there are duplicative, often competing 

systems

• GAPs Harmonization Initiative

• Global Food Safety Initiative (GFSI)
FVIAC Meeting March 2015

Harmonization and Benchmarking

GAPs Harmonization Initiative

• Industry-led initiative to harmonize fruit and 

vegetable food safety standards typically used in 

North America

• Started in 2009, completed and implemented 

in 2012

• Integrates 14 audit standards, including 

commodity-specific, GFSI benchmarked, 

and government-based standards
FVIAC Meeting March 2015

Harmonization and Benchmarking

GAPs Harmonization Initiative

• Produce GAPs Harmonized Food Safety Standard 

• Meets requirements of the proposed Food Safety 

Modernization Act (FSMA) Produce Safety Rule

• Purposely did not address the audit process, 

i.e. auditor competence. 
FVIAC Meeting March 2015

Harmonization and Benchmarking

GAPs Harmonization Initiative

• AMS 

• Participated in the GAPs Harmonization Initiative 

• Was an early adopter of the Standard 

• Has performed more than 1,000 audits using the 

Harmonized Standard over the past 2 years

• Serves on the Technical Working 

Group and Calibration Committee
FVIAC Meeting March 2015

Harmonization and Benchmarking

Global Food Safety Initiative (GFSI)

• A benchmarking organization founded in 

Europe in the early 2000s by major manufacturers 

and retailers 

• Goal is to standardize suppliers’ food safety 

processes

• Mission is to provide continuous improvement in 

food safety management systems to ensure 

confidence in the delivery of safe food to consumers 

worldwide
FVIAC Meeting March 2015

Harmonization and Benchmarking

Global Food Safety Initiative (GFSI)

• Board of Directors, who represent major 

retailer, manufacturer, and food service operators, 

provide strategic direction

• Technical working groups comprised of volunteers 

make policy recommendations

• Working to gain acceptance in the United States

• Walmart, U.S. Foods, among others require their 

suppliers to be audited against a GFSI-recognized 

scheme
FVIAC Meeting March 2015

Harmonization and Benchmarking

Global Food Safety Initiative (GFSI)

• Recognizes food safety management 

schemes that meet their requirements

• 12 schemes that cover food safety systems 

throughout the supply chain are currently 

benchmarked and recognized by GFSI

• Some schemes are specific to a specific industry, 

some are broadly based.
FVIAC Meeting March 2015

Harmonization and Benchmarking

Global Food Safety Initiative (GFSI)

• Scheme owners manage their own GFSIbenchmarked food safety standard and the 

associated audit processes, but do not perform 

certification activities. They accredit certification 

bodies to perform actual audits. 

• Several GFSI schemes are working to adopt the 

Harmonized GAP Standard into their schemes for 

their North American clients
FVIAC Meeting March 2015

Harmonization and Benchmarking

Key Obstacles for GFSI

• Not widely used by most U.S. buyers

• Many producers feel GFSI requirements are too 

strict/restrictive or not applicable to production 

agriculture

• Requirements for food safety standards include 

components that are not traditionally associated 

with food safety audits in United States, e.g., 

pesticide use, Integrated Pest Management, and 

propagation material
FVIAC Meeting March 2015

Food Safety Modernization Act

Market Access vs. Regulatory Issues

• Producers want to use food safety audits 

• For market access 

• To show compliance with FSMA and other 

regulations

• Foreign governments want farms to be certified

• USDA-FDA Joint GAPs Review Project
FVIAC Meeting March 2015

Current Market Conditions

• Audits are primarily used for market access

• There is no generally accepted method for determining 

equivalency between audit standards/audit processes

• Result is current state of audit proliferation/audit 

fatigue

• Numerous industry efforts to reduce audit proliferation and 

audit fatigue have had varying levels of success
FVIAC Meeting March 2015

How AMS Can Help

• AMS performs audits using FDA Guidance and industry 

best practices

• AMS is working to gain wider acceptance of our 

programs by the buying community

• AMS and FDA are collaboratively reviewing the USDAAMS GAPs Program to make it more useful and valuable 

in light of FSMA requirements
FVIAC Meeting March 2015

Questions?

Ken Petersen

ken.petersen@ams.usda.gov

202-720-5021