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College student preparing to microgram on acre of land and also have a restaurant #854957

Asked November 08, 2023, 3:38 PM EST

I just took the PA webinar for the certificate for the Produce Safety alliance class (They said it applies even though I'm in Ohio) I will be a very small "farm" actually more horticulture (fruit/vegetable/herbs) and I want to grow as much as possible myself to cut Cost of Goods to use in menu items. I will need to suppliment no doubt with other reputable growers. The reason I took this course is because I want to have as many things as I can get to show my methods as being reputable and safe along with having a farm safety plan and a voluntary inspection (some farmers markets require this to sell produce through them which will be a possible incremental step working toward my restaurant end goal). However I'm confused because when I follow the flow chart for exempt or exclusion I believe even after getting up and running full scale with just this land I would not be covered by the rule...Did I waste my time getting this? Should I try to be GAP certified? I see a class for $50 and was considering taking it for the above reason (to be reputable and considered safe in practice). I believe no matter how small or big any sales would be if someone was gong to eat my food in any shape way or form I should have standards and have something showing my process in case someone were to become ill etc. Is there any advice you can share or anything recommendations or thoughts on anything I shared? Thanks in advance, Maria Weber<personal data hidden>

Mahoning County Ohio

Expert Response

Hello Maria,

First- Thank you for being a conscientious grower and seeking to have safe produce for your customers!  We agree that, regardless of size, food safety is important on any farm, farmers market, auction, store, restaurant etc!  

The flow chart you are referring to applies to the Food Safety Modernization Act, the 2011 law setting mandatory standards and regulations for produce farms of certain sizes which are then visited and inspected regularly.  Those farms which are considered, "exempt" technically do not have to jump in and comply with the FSMA rule BUT are still charged with food safety responsibility because it is unlawful to enter contaminated food into the food supply regardless of farm size, income or product.  Any size farm in or out of the FSMA flow chart is subject to  unannounced inspections by the Department of Agriculture in their state, which would make understanding and following GAPs or FSMA advantageous, because small farms would still be subject to penalties. 

Therefore it was NOT a waste of time to have taken the course.

Additionally, regardless of size, the buyer may have expectations.  Like you mentioned, many farmers markets, restaurants, produce auctions, and stores have requirements ranging from proof of taking a class to full-blown GAPS certification from a 3rd party auditor. Buyer-led standards pre-date the food safety modernization act.  The National Good Agricultural Practices (GAPS) program was developed in response to demands from grocery chains and commodity groups to improve safety. Many commodity groups developed their own voluntary standards for safety, like sprouts and mushroom groups and leafy greens marketing associations.   And these voluntary efforts would make their products more marketable and that reputation for safety granted growers entry into stores or restaurants that had these requirements.

SO where does that put you?  

The online GAPS course for Ohio is a shorter version of the Pennsylvania PSA course you already took.  So I would not recommend re-taking it unless a buyer specifically asks for the Ohio course. However, I can attest that the Penn State Course was more rigorous and was designed for those who must comply with FSMA.  The Ohio GAPS course is designed as an introduction to GAPS for small or new farms. So you just went straight to the advanced training. No problem!
You should be able to provide proof of attending the Penn State PSA training to any buyer familiar with FSMA/GAPS and it should be considered reputable and a recognized training.

The online OSU course is only a training and will not make you "GAPS-Certified".  You would only receive a certificate of participation, which is different than the intense auditing process that would give you "GAPS-Certification".  If you want GAPS certification you would work with the USDA or a third-party auditor to go through the inspection and auditing process.  But if it is not required because you are exempt, and your buyers aren't demanding it, I might hold off on that cost ($155 an hour for a USDA audit) and instead invest in any improvements you can make on the farm that are needed for food safety such as installing drip irrigation or easier to wash bins and tools, sanitizers etc.   As far as I have experienced, local farmers markets and produce auctions are satisfied with your attendance at a training and are not requiring audits yet.  Some may ask to see your food safety plan.  Just depends on your buyer.  Grocery Chains and some restaurants may require an audit and at that point you can make the decision about the full auditing process.

For more information about the audit, you can reach out to the USDA auditing service. Here is information: https://www.ams.usda.gov/services/auditing/apply

If you have further questions, feel free to reach out directly to myself or others on the Good Agricultural Practices Team here in Ohio.

Me- Ashley Kulhanek at <personal data hidden>
Beth Scheckelhoff at Scheckelhoff<personal data hidden>
Melanie Ivey at <personal data hidden>



An Ask Extension Expert Replied November 09, 2023, 11:00 AM EST

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