Most of us grow food out in the world, where groundhogs frolic in the carrots, deer wander out of the woods, and people pick and pack the produce. It’s a world of sunshine, rain, dirt, green stuff, bugs, and poop.

In this environment, food safety is pretty basic. You do what you can to keep the poop out of the food; you keep any poop that does get on the food from spreading to other food; and you prevent any poop that’s on the food from growing. In addition to some attention to physical hazards such as broken glass or wood splinters, the whole concept of Good Agricultural Practices really comes down to these three principles.

Unfortunately, if you want to demonstrate to a customer that you are doing a good job of minimizing the poop in your food, you’ll probably have to come up with some paperwork. And if your customer wants some sort of third-party verification — a GAPs audit – you’ll have to come up with some more paperwork — probably, a lot more paperwork.

Understanding GAPs
The GAPs/GHPs audit system – Good Agricultural Practices and Good Handling Practices, respectively – differs significantly from organic certification. Rather than a variety of baseline rules that producers are required to meet, the audit scores are based on a points system. If you get enough points in each section of the audit, you pass the audit. Whereas organic certification requires that you avoid treated seed, rotate your crops, and apply manure at least 120 days before harvest, the GAPs audits might let you get away with just two out of three.

An audit exists to verify to a buyer that you are doing the things they think you should be doing with regard to food safety. Lots of different companies, plus the USDA, offer food safety audits, and your buyer is the one who usually decides what company you need to get an audit with, because auditing standards vary from auditor to auditor, and different buyers have different requirements.

The USDA audit, similar to other audits I have considered, is broken into six sections. The Farm Review, Field Harvest and Field Packing Activities, House Packing Facility, and Storage and Transportation sections apply to most market farm operations. The audit also has a section for Wholesale Distribution Center/Terminal Warehouses, and Preventive Food Defense Procedures, which aren’t designed for farm operations.

In the USDA audit, the questions in each section have 5, 10, or 15 points assigned to them. For each question, the auditor either answers Yes, No, or N/A (does not apply). In each section, you have to score at least 80% of the points that apply to your operation in order to pass.

Many of the questions require either Documentation, a Record, or a Policy or Standard Operating Procedure to address them. For example, in response to the question “Potable water is available to all workers,” we provided a water test. “Training on proper sanitation and hygiene practices is provided to all workers” required both a Standard Operating Procedure of providing food safety training to all workers and a log of the trainings. “Employees and visitors are following good hygiene/sanitation practices” was documented by the auditor.

They didn’t make GAPs for us
I have talked to auditors from the USDA and private companies, listened to testimony and talked to industry lawyers at regulatory hearings, and discussed my concerns with university extension specialists. I’ve also read the guidance documents for audits by multiple organizations. It’s clear that GAPs and the documentation that’s been developed to support them are geared towards farms that produce large quantities of a few crops, and either handle them themselves using permanently-installed handling equipment or sell the crops prior to handling (and sometimes prior to harvest) to other entities.

The standards were designed for food factories. Factories appeal to people who make rules because they’re easy to standardize and amenable to control, they produce enough cash flow to cover the overhead expense of hiring and training a food safety officer who can keep her hands dry while she’s filling out paperwork, and they are stationary enough that you can hang clipboards all over the place.

But my farm’s packing house is set up more like a job shop, where we set up and take down our packing lines, run a lot of different produce through the same equipment, and the person washing the produce is the same person who has to write stuff down on the now-soggy paperwork.

When I decided to pursue a USDA GAPs/GHPs audit, my crew nearly revolted at the number of clipboards a well-meaning advisor had suggested I purchase, complete with a pen tied to each one. And when I tried to write a food safety plan using two of the well-meaning guides in circulation, I came perilously close to tears as I tried to divine what we would need to do to pass a food safety audit — and my farm has been used as a food safety showcase in the past! As we developed our food safety plan and began implementing our recordkeeping, it became clear that we couldn’t have a separate log for each activity, and that we couldn’t develop our food safety plan in intellectual isolation.

The Food Safety Plan
Every food safety audit will require you to have a written food safety plan. The various guides to creating a food safety plan usually have you proceed in a vacuum, trying to address the various food safety factors without reference to the audit. An Extension agent suggested that I write the plan to meet the audit.

I sat down with the USDA Audit Verification Checklist and looked at the first question: Is there a map that accurately represents the farm operations? I looked my farm up on Google Maps, copied the map, and placed it in my Word document. The next several questions addressed the farm’s legal description, whether all crop production was located at this site, the total acres farmed, and the number of packing facilities my farm has, so I wrote a Farm Description that addressed those questions. The audit asked about a floor plan of the packing area, so I quickly sketched one up, took a picture, and pasted it into the Word document.

As I continued through the audit verification checklist, I simply asked myself what we were doing to address each question, and wrote that down in my plan. I kept a sheet of paper handy to make notes about what I would need to document and another for procedures I needed to implement. Where I didn’t have language that I needed, or didn’t have a policy in place already (for example, a ”policy describing procedures which specify handling/disposition of produce or food contact surfaces that have come into contact with blood or other body fluids”) I looked it up on the internet.

Questions that didn’t apply (“Manure lagoons located near or adjacent to crop production areas…”), I ignored. And where I couldn’t see my way to documenting something where the audit required documentation (cleaning and sanitizing our harvest van) or simply didn’t do it (cleaning my refrigeration fans) I just let it slide.

When I was finished, I did a self-audit, and figured out what I would need to shore up in terms of procedures and documentation to pass the audit.

Recordkeeping
I’ve spent my entire agricultural career on organic farms and research stations, so recordkeeping has always been a given in my farming world. But the number of records required to meet the GAPs/GHPs audit requirement was staggering.

When I sat down with Ben Kreuter, my assistant farm manager, to review the list of what we needed to document, it became clear that the traditional mechanisms of having a separate log sheet for every record just wasn’t going to work. We already kept a harvest log and a packing log as part of our basic farm records, and to meet certification requirements, but we certainly weren’t tracking our cleaning efforts and cooler temperatures.

In thinking through what we needed to develop, we identified several additional goals beyond traceability and basic documentation: we wanted our recordkeeping system to provide instructions to farm staff at the same time they created a record of activities; we wanted to enhance staff accountability for following procedures that were often being bypassed; we wanted our documentation to occur in line with the work, rather than as a separate activity; we wanted to avoid duplication of effort; and we wanted to meet any other recordkeeping requirements, such as those for organic certification, at the same time.

Traceability
While the GAPs audit doesn’t require a traceability program, having one gets you a lot of points, and we were mostly there with our audit documents for organic certification. For GAPs, a traceability program needs to account for product one step forward and one step back: on a market farm, this means you need to know when and where it was harvested and who was on the harvest crew; and you need to know where and when the product was sold. Product sold to a reseller – a store, distributor, or restaurant – needs some sort of unique identifier so that it can be traced back through your recordkeeping system through any handling steps to the date and field of harvest.

The unique identifier, often referred to as a lot code, causes a lot of confusion and concern when I talk to growers, but with a relatively simple operation, it can be as simple as a date if you’ve already listed the product on the label. The goal is to make it possible to recall product in the event of a food safety problem, so your product needs to be labeled with your farm name and contact information, as well. At Rock Spring Farm, we store a lot of product, sometimes harvested over a period of days, and wash and pack it over a long period of time. Sometimes we’ll be washing beets that were picked the previous week on the same day that we’re harvesting more beets. Some of our crops also go through multiple handling steps that might take place over a period of days. And, we use a price gun to affix our lot code to some of our products. All of this led us to develop a more complex, 6-digit lot code that lets us track our produce through multiple handling steps back to the field.

When we ship product, we write the lot codes and the amount of product shipped on a Shipping Log. Again, it’s not uncommon on our farm to pack beets one week and ship them the next, so we can’t be certain that crops sold on a given day were packed the same day, or even the same week. The Shipping Log includes the date shipped, which corresponds to our invoices in QuickBooks.

All of this means that if I get a call from the FDA saying my beets made somebody sick, I can contact everybody who bought beets that were packed on the same day, or harvested on the same day, or harvested from the same field, and tell them to pull my products off their shelves.

Other documentation
Each of the logs I mentioned above is printed on a different colored paper, so that we can easily see from a distance which sheet is on which clipboard. Each of them also serves to instruct staff and gather additional documentation. And, every log sheet has instructions for filling it out, so that the user doesn’t have to remember what to do.

In addition to columns and rows for crops, field numbers, harvest goals, and actual harvest amounts, the Harvest Log includes space for notes and additional information, as well as a place to note who worked on the harvest crew. It also has a place for the harvest crew leader to note that they’ve inspected the crop to determine if any food safety hazards exist, and that they’ve made the harvest crew aware of any necessary actions to avoid contamination. This neatly addresses the 15-point question about a pre-harvest assessment without making an additional trip to the field; it also makes more sense to make the assessment at the time of harvest rather than hours or days beforehand.

To help manage the packing house, the Packing Log has columns for the crop and its incoming lot code, the packing goal and the actual pack. To provide additional food safety documentation, the packing log also includes columns for whether the equipment was cleaned, and whether a wash water sanitizer was used.

Each row on the Shipping and Packing Logs includes a place for the initials of the person responsible for ensuring an accurate count.

The Shipping Log includes the produce, the number shipped, and the lot codes included in the shipment for each product. The staff member who assembles the order onto pallets signs off on the accuracy of the information.  We also have a place for the person loading the vehicle to sign off that it’s sanitary and suitable for transporting fresh produce. We fill out a separate shipping log for each vehicle and delivery route. Because we don’t truck our own produce into the cities, the instructions on this form provide a way for a driver from another farm to load our product and provide the proper documentation.

We already wrote out our daily plan on a white board, including who was working on staff that day. Instead of copying that information elsewhere, we decided to just take a picture of it every day; I got a small, bright blue camera from Amazon for less than $50 that now lives next to the whiteboard. Once every couple of weeks the pictures get downloaded to a computer. Rather than writing activities on soggy paper, a wet-handed staff member can check off “wash totes,” and that becomes a record of our cleaning and sanitizing activities.

We also created Opening and Closing Checklists that get completed every day; key tasks on the checklist get the initials of the person who does them. The opening checklist includes a space to log cooler temperatures, a checkbox to note that soap and towels and toilet paper were checked at the handwash sink and in the bathroom (we put a piece of tape on the side of the clear soap and towel dispensers to indicate the refill level), and that other opening activities, such as checking the germination chamber and rolling up greenhouse sides, have been completed. The closing checklist documents routine cleaning, such as clearing the floor of food and emptying the compost wheelbarrow, as well as reminding staff to clear the loading dock, roll down greenhouse sides, put the walkie-talkies in their chargers, and take a picture of the white board.

What we got from it
Sadly, the GAPs audit didn’t result in increased sales due to a variety of issues that come down to, don’t put all of your eggs in one basket. But passing the audit gave us bragging rights among our produce buyers and an opportunity to talk about what we’ve done all along with food safety.

But for us, the increased paperwork has actually done us quite a bit of good. We don’t run out of paper towels any more, and nobody skips putting sanitizer in the wash water because it’s too much trouble, or they weren’t adequately trained. We’ve increased our ability to delegate tasks at the beginning and end of the day without having to tell people what to do, and the increased accountability of having people’s names attached to their work, as on the Harvest and Shipping Logs, has helped improve performance across the board.

Chris Blanchard owns and operates Rock Spring Farm, with fifteen acres of certified organic vegetable, herb, and greenhouse production north of Decorah, Iowa, selling produce year-round through a 200-member CSA, food stores, and a farmers market since 1999. Prior to 1999, Chris managed student farms, worked as an intern, packing house manager, plant breeding assistant, and farm manager, and provided consulting for a major organic processor, in California, Wisconsin, Maine, and Washington state. Under the banner of Flying Rutabaga Works, Chris’ workshops about farm business concepts, food safety, organic vegetable production, and scaling up to farmers throughout the country have gained a reputation for fresh approaches, down-to-earth information, and honesty. He also co-directs the MOSES Organic Farming Conference.

At the Great Plains Growers Conference (January 5-7 in St. Joseph, Missouri) and the Minnesota Organic Conference (January 12 – 14 in St. Cloud, Minnesota), Chris will review the principles and practices of post-harvest handling for vegetables, and the methods developed at Rock Spring Farm for meeting the documentation and record-keeping requirements of the GAPs audit process.