Fresh & Local
Good Agricultural Practices (GAP) Certification, Redux
Column #16, Published Jan 6th, 2012

In a previous column back in November, I talked about GAP certification. There have been a large number of serious cases of food-borne illness in produce from huge mega-farms. In response, the USDA and the FDA have published a series of guidelines for growers to reduce the risk of pathogens in fresh fruits and vegetables. Collectively these guidelines are referred to as Good Agricultural Practices or ‘GAP’.

The USDA and private third-party companies will perform audits for a fee to certify GAP compliance. Right now, GAP compliance is mostly voluntary. But growers are being told that one day GAP certification is likely to become mandatory.

Virginia Cooperative Extension is hosting an all-day program on GAP here in Culpeper on Thursday, January 25th at the Daniel Technology Center. The purpose is to help growers “make informed decisions on certifications.” The cost of the program is $20.

I have deeply mixed feelings about these GAP audits and certifications.

I don’t have a problem with the concept of GAP guidelines. We already adhere to many of the guidelines. For example, we store our packed produce in a walk-in refrigerator kept at 38 degrees. We wash every surface that comes in contact with the produce, including the buckets and washing sinks, every harvest day. We clean and sharpen all the cutting knives every time they are used. We chlorinate our irrigation water.

But there are a bunch of big problems with GAP certification. The proverbial devil is in the details.

What really frosts me the most about making GAP certification mandatory is that it is the huge mega-growers and packers that are having the sanitation problems, not the small fresh and local growers like us. Since we don’t have the sanitation problems, why are we being dragged into this regulatory morass along with the people who do?

Terry and I already have a big incentive for maintaining high sanitation standards. We grow year-around, so we actually eat what we grow just about every night. If we ever did have a problem, it would affect us first. That is a pretty good motivator all in itself.

Many of these GAP guidelines are written specifically to cover huge mega-farms and packers, and they make no sense for small local producers like us. One of the most onerous guidelines is a requirement for lot numbers. For everything that you pick, the date, time and exact location has to be recorded, and when you sell something, you then have to label it with a lot number that relates back to the date, time and location it was picked.

That is just fine if you are selling a single product. But we have dozens of products that we sell. Not only that, but many of our products are combinations of different greens. How do we come up with a lot number that will identify where each component comes from in the field?

And to what end? Lot numbers are supposed to allow products to be recalled should it ever be needed. That might work if it takes a week or two for a product to arrive in the store. But most of what we sell is used the same day we sell it. That’s called “fresh.” What good is a lot number on a same-day product? This is just nuts.

The current GAP certification is a recordkeeping nightmare. Punish the guilty mega-farms, and either leave GAP compliance for the fresh and local growers to us, or come up with a separate GAP certification that makes sense for us.

Bryant Osborn and his wife Terry own Corvallis Farms in Culpeper County. His column on fresh and locally grown food runs every Friday. He can be reached at