Fresh & Local
Good Agricultural Practices (GAP) Certification
Column #8, Published Nov 11, 2011

In Po Bronson’s book, “What Should I Do with My Life?” he tells the story of a guy named Joe. Bronson concludes his story, “The intellectually motivated person might read Joe’s story while secretely thinking, ‘That would be a cool job, but how much crap does he have to put up with?’ I considered writing about the bureaucrap he has to fight . . . but why indulge that question? The right question is not, ‘What’s the Crap Factor?’ The right question is, ‘How can I find something that moves my heart, so that the inevitable crap storm is bearable?’ ”

There is an administrative storm sweeping across the fresh produce business. 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 GAP guidelines are useful. We eat what we grow every night, so we have adopted the guidelines’ principles. 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 as a precaution.

Right now, GAP compliance is mostly voluntary. But growers are being told that it is just a matter of time before we will be required by law to be GAP audited, inspected and certified. The certification is going to require keeping detailed records on everything we pick and how it is handled. Instead of just growing food, we are going to be spending lots of time filling out paper work.

GAP certification is going to be a huge administrative storm, but just how bad this storm becomes is going to depend on who ends up performing the certifications.

Our farm grows berries, and during the year we use some of our berries to make jams and jellies. Virginia allows very small producers like us to make our preserves in our kitchen, and they routinely send someone to inspect our kitchen.

This spring, the FDA office in Baltimore contacted us and said that from now on, our preserves would be inspected by them, and we would have to comply with federal regulations. That would require us to use a commercial kitchen. The FDA argued that because the sugar we used came from outside Virginia, we were involved in interstate commerce and that they had the right to assert jurisdiction.

The commercial kitchen requirement would have ended our jam and jelly business. Virginia has special rules for small producers. The FDA has a one-size-fits-all mentality. Seriously, what purpose is served by requiring us to meet the same regulatory standards as Smucker’s or McCutcheon’s?

Eventually the FDA went away. But this experience is evidence that no matter how well intentioned the GAP guidelines are, if the federal government ends up certifying farm GAP compliance, it will be a disaster for growers. The last thing we need is federal employees who can’t be fired and probably know nothing about agriculture, deciding GAP compliance for small growers.

There is a considerable amount of talk about allowing third-parties to certify GAP compliance. These third-parties would be individuals or companies that would specialize in performing GAP audits and certification. At this point, we can only hope.

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