Coordinated Audits

Question: How much does a USDA GAP audit cost in Iowa?

Third party Good Agricultural Practices (GAP) certification is expensive for small-scale farmers. Because of the low number of Iowa farms requiring certification, auditors come from out-of-state. The most common certification body used in Iowa at this time is the USDA Agriculture Marketing Service, and auditors will come from Illinois, Missouri or Texas. USDA GAP audits of Iowa farms can exceed $1000 per year.

There have been conversations in Iowa about training people to be state auditors to lower the travel costs associated with an audit.  However, different buyers may request audits from different certification standards and training auditors to more than one standard is prohibitive and not feasible. For example, one buyer might require a USDA GAP audit while another might require a Primus GAP audit.

Several approaches to make audits more affordable have been studied in Iowa. One approach requires neighboring farms to work together.

Called “coordinated audits”, farms in certain areas (generally within 100 miles) will work together to schedule the auditor to visit their farms in the same day or adjacent days. In northeast Iowa, an auditor could visit 2-3 small farms in a day when the farms are 30-40 miles from each other.

This effort to coordinate the auditor’s time results in the travel costs being shared between the farms. Farms practicing “audit coordination” have seen their audit costs cut in half – $500-600 per farm.

When coupled with a GAP cost-share program, where farmers can receive $400-500 in cost-share, GAP certification becomes more realistic.

For more information about coordinated audits, talk to your neighbors, or contact Teresa Wiemerslage at Most Iowa audits take place in August and September.


FAQ: Irrigation Water Quality

Question: My well water test came back high for coliform bacteria but negative for E.coli, is the water okay to use for irrigation?

Answer: It depends on the bacteria level. Look at your test results for the concentration number.

Your irrigation water should be tested specifically for fecal coliforms and generic E. coli, and the test used should not be a simple positive/negative but should determine the number of E. coli present. Typically Iowa farmers will use the University of Iowa Hygienic lab for water testing.

While the presence of generic E. coli does not correlate directly with the likelihood of pathogens being present, it does suggest that the water has been exposed to fecal matter that may contain pathogens. We test for indicators as it is a more cost effective activity than testing for all possible pathogens. Thresholds exist for water quality for different uses: zero E. coli are allowed for wash water and drinking; higher levels are permissible for irrigation water as that water is often impacted by UV rays and drying.

For irrigation water coming in direct contact with the edible portion of a plant, if the average is below 126 MPN/100 mL and highest single sample is below 235 MPN/100 mL then your water is acceptable for agricultural use (EPA, 1986). For water not coming in direct contact with the edible portion of a plant, if the average is below 126 MPN/100 mL and highest single sample is below 576 MPN/100 mL then your water is acceptable for agricultural use. If either number exceeds those tolerances, then you need to take remedial action.

NOTE: Most testing labs will return results as MPN/100 mL but some will report in CFU/100 mL. These measures are equivalent, so regardless of the measurement units, you are looking for the same thresholds (126/235 or 126/576).

Don’t forget to keep your results in your food safety manual.

Remember it is important to choose the highest quality source possible for agricultural irrigation. Water can be contaminated by sediment, agricultural runoff, chemicals, or any of the major microbial contaminants, such as bacteria, viruses, or parasitic organisms. The water tests mentioned above only test for fecal bacteria. Irrigation methods that reduce water contact with produce such as drip are recommended over overhead irrigation.

Source: GAPs for Small Diversified Farms, North Carolina State University and Carolina Farm Stewardship Association.

GAP Cost-share Grants Available for Iowa Growers

Iowa fruit and vegetable farmers can apply for a cost-share grant to assist with the costs of independent food safety certification of an operation’s good agricultural practices (GAPs).

The program is available through the Iowa Food Hub with support from an Iowa Department of Agriculture and Land Stewardship (IDALS) Specialty Crop Block Grant.  The program is available to any Iowa grower.

To be eligible, growers must have a third-party audit from an approved government agency or company that verifies GAP or GHP efforts, the audit must be conducted in 2016 or 2017 and the grower must submit an application to participate in the program prior to the audit. The audit can be for farm review, field harvest and field packing activities, packing house facility, storage and transportation, and traceback. Qualified applicants may receive up to a maximum of $600 per year to cover the costs of one successful audit.

“Cost-share funds help farmers with their on-farm food safety efforts, which are critical to marketing their farm products,” said Teresa Wiemerslage, ISU Extension Regional Program Coordinator.  “I am glad we were able to secure these funds to assist our growers. Funds are available to farmers on a first-come, first-served basis.”

A business/individual is eligible to apply for reimbursement as soon as their USDA GAP audit has been approved. Applicants must fully complete the necessary application and be able to show verification of audit approval. Qualified applicants may only receive funding for one successful audit per calendar year.  Reimbursements will not be given for costs associated with a failed audit.

Participation in the GAP and GHP audit program is voluntary. The cost share program is designed to help defray some of the costs related to a successful audit.  USDA audits for Iowa produce farms have ranged in price from $525 to $1200 per year.

For more information about on-farm food safety or GAP certification, contact Teresa Wiemerslage at or 563-794-0599.

Does the FSMA Produce Rule apply to me?

Growers may have a lot of questions about the Food Safety Modernization Act’s Produce Rule now that it is final.

The goal of the produce safety rule is to prevent food safety risks in the growing, harvesting, packing and holding of fresh produce. The rule sets standards for personnel qualifications and training; health and hygiene; agricultural water; biological soil amendments of animal origin; domesticated and wild animals; growing, harvesting, packing and holding activities; equipment, tools and building; and recordkeeping.

The rule was effective beginning Jan. 26, 2016, but farms will need to be in full compliance at different times depending on their operations. Michigan State University Extension has created this chart to show compliance deadlines for different-sized farms.

Click here to find out if your farm is subject to the produce rule, exempt or qualified exempt.

Exempt growers must have records on file supporting their eligibility as an exempt farm by Jan. 26, 2016. These growers must also review their status annually and maintain records of this review and their continued eligibility.

Whether you have one year or five before you need to comply, now is the time to start reviewing your food safety practices. For assistance, contact an Iowa GAPs team member.

FSMA and GAP are not the same

With the advent of the Food Safety Modernization Act (FSMA), we now have a uniform minimum standard of food safety that the overwhelming majority of fresh produce growers must adhere to. The key with FSMA is that it is a minimum requirement. The burden to demonstrate compliance will fall to the producers, and a documented farm food-safety program will be the best way.

In Iowa, we have focused our training on USDA GAP/GHP standard. Currently, USDA teams are working to make the GAP/GHP standard FSMA compliant, and those changes are expected later this year. This is good news for those farms who have implemented GAP plans on their farms. I think we can agree that modifying a current plan is easier than creating one from scratch!

Additionally, FMSA will not eliminate buyer imposed programs for food safety  that are already in place. Even if a farm is FSMA compliant, they may still need to be certified under one or more GAPs to sell to certain buyers.

There are several different “brands” of GAP certification, each with their own special requirements and certification agency. The type of GAP certification required is wholly the choice of the produce buying company. In some cases, a grower may need two or more certifications to sell to several different buyers.

The good news is that often food safety is the same, irrespective of the audit that a grower needs to perform. The food safety manual for a particular audit will be virtually the same for another audit under two different GAP brands. This saves time upfront when a grower needs more than one audit.

If you have specific questions about GAPs or have difficulty tailoring GAPs to your farm, contact the Iowa GAPs team for assistance.

Article adapted from Michigan State University Extension.

Harvest Crew of One

On large, commercial vegetable farms the harvest crew has the responsibly to pick, pack and bring in the product from the field. Employees are trained in food safety so they understand handwashing and sanitary handling. Harvesting is the only activity they do. The crew does not weed, trellis, cull or prune while harvesting. Harvesting is its own activity.

On Iowa’s smaller produce farms, the harvest crew may be a handful of people – or only one or two people on the really small farms. But the concept of the “harvest crew” should still apply. Harvesting is its own activity.

For best food safety management, the harvesting activities need to be the primary focus of the field worker during that time. Hands and equipment are washed, and product is collected and moved to the packing area or cold storage quickly. Distractions should be avoided.

Conduct a pre-harvest walk-through (assessment) to look for wildlife damage and create a plan for harvest. The assessment can also help you identify other items to add to the to-do list after harvesting – fixing the fence, weeding the cucumbers, staking the tomatoes. Leave your phone in the packing area to help you focus on the task at hand (and motivate you to finish quickly). Once the harvest is complete and the food is transferred to the holding facility, your attention can shift to the other tasks for the day.

ISU Named Regional Center for FMSA Training

The U.S. Food & Drug Administration’s (FDA) Food Safety Modernization Act (FSMA) will transform the nation’s food safety system into one that is based on the prevention of foodborne illness. It will be a system in which the food industry systematically puts in place measures proven effective in preventing contamination. Thus, food industry training will be an important component of successful implementation.

In 2015, recognizing the need for food safety training for small farm owners and food processors, the FDA and USDA’s National Institute of Food and Agriculture (NIFA) announced the National Food Safety Training, Education, Extension, Outreach, and Technical Assistance Grant Program, intended to provide funding so that these critical groups receive training, education and technical assistance consistent with standards being established under FSMA. Grants issued through this program will fund a National Coordination Center (NCC) and four Regional Centers (RCs), which will be involved in both key components of training—primarily facilitating training delivery but also, in certain situations, facilitating curricula development targeted to specific audiences.

National Coordination Center: International Food Protection Training Institute (IFPTI) of Battle Creek, Michigan

Regional Centers:

University of Florida, Gainesville, FL received the grant to establish the Southern Training, Education, Extension, Outreach, and Technical Assistance Center to Enhance Produce Safety.

Oregon State University, Corvallis, OR received the grant to establish the Western Training, Education, Extension, Outreach, and Technical Assistance Center to Enhance Food Safety.

Iowa State University has received the grant to establish the North Central Regional Center for Food Safety Training, Education, Extension, Outreach and Technical Assistance

University of Vermont and State Agricultural College has received the grant to establish the Northeast Center for Food Safety, Training, Education, Extension, Outreach and Technical Assistance.

The goal of FSMA training programs will be the outcome – advancing knowledge among food producers to meet FSMA requirements. Specifically, the regional centers will be charged with understanding and communicating the landscape of training opportunities available to target businesses in their region. They will identify any need to develop or tailor curricula to meet specific unmet regional needs and/or to target a specific audience. These centers will work with representatives from non-governmental and community-based organizations, as well as representatives from cooperative extension services, food hubs, local farm cooperatives and other entities that can address specific needs of the communities they serve.

For more information on the FDA’s training strategy for FSMA, please see: FSMA Training

Wash Water Management

FAQ:  Can the used water draining from the hand- and produce-washing sinks flow via gutters in the concrete floor to an exterior outlet?

100_2154Wastewater drainage should not promote cross contamination. If you are using an open gutter or tube, the water could splash and contaminate the floor or other surfaces. People or equipment could contribute to the contamination by walking or moving through the wet areas.

If the wastewater is moving through a closed pipe or channel, then the potential for contamination is greatly reduced. Be sure any piping is not a tripping hazard for workers.

Perform regular maintenance on floor drains to make sure they are free from debris.

dry wellWhere is the wash water going after the packing area? Local governments may require that wash water be put through a septic system, but avoid hooking it up to your home’s septic. The huge amount of water you use in the packing shed may overwhelm your septic system. Most growers just run the water from the packing shed off to a non-production area, storage tank, dry well, or settling area. Think about traffic flow and make sure that people and equipment are not crossing through wet areas.

GroupGAP Webinar, Feb 18

GroupGAP: USDA’s New Cooperative Approach to Farmer Food Safety Certification
Thursday, February 18
3:30 – 5:00pm ET (12:30 – 2:00pm PT)
Free! Register Now

GroupGAP is a new service (available Spring 2016) from USDA to audit farmers to Good Agricultural Practices (GAP). Small farmers are feeling the pressure to get third-party certified as more buyers are requiring GAP certification, and as the Food Safety Modernization Act (FSMA) puts them under new regulatory oversight.

In GroupGAP, a food hub, support organization, or central business entity collaborates with producers to establish site-specific best practices for complying with a food safety standard. The group develops and implements a quality management system (QMS) built to an international standard that can be measured, analyzed, reviewed, and continually improved.

Come hear the experience of a few of the trailblazers – pilot Groups who have already received GroupGAP certification. Why did they seek this certification? How much did it cost? Will they keep up their certification next year? What supports are available? What makes group a good candidate for GroupGAP? What were challenges and successes?

Answers to these questions and more!
Reserve your spot – click here

This session is NOT intended to give you all the details on the GroupGAP requirements from USDA. We suggests that you review the excellent USDA webinar that fills you in on that before this session. This webinar will illustrate, with a few case studies, what the GroupGAP certification experience is like, to give you a sense for the kinds of groups who have found it to be useful.

USDA GroupGAP webinar recording >>>


The Iowa Food Hub was a GroupGAP pilot site. They learned that in order for GroupGAP to be sustainable, the group needs to have over 20 members. Iowa Food Hub is willing to be the Group Host for other farms interested in this method of GAP certification. Farms do not need to be vendors of IFH to participate. Call Teresa at 563-794-0599 for more information.

Am I Certified?

Question: If I attend an Iowa Level 1 or Level 2 GAP class, is my farm GAP certified?

No. While attending a class is a great way to learn about food safety, it does not make your farm certified. Three things need to happen in order for a farm to become “GAP-certified.”

  1. The farms need to implement an on-farm food safety program with a manual containing policies, procedures (SOPs) and logs.
  2. The farmer needs to contact a certifying auditing agency like USDA AMS, Primus, NSF or other certifying body to come to the farm and audit the farm’s food safety program. Because Iowa does not have a state GAP inspection program, auditors usually come from out-of-state and audits will cost $600-$2000 depending on the audit used.
  3. They need to pass the audit (for example, a score 80% or higher on a USDA GAP audit).

While it is highly recommended that farmers attend a Level 1 and Level 2 GAP class to learn about food safety principles and to receive assistance crafting a farm safety manual, attending class is not a requirement to become GAP certified. In fact, there are several templates available that can guide farmers through the process.

ISU Extension specialists are also available to assist with questions and to perform mock audits.

See also:

Will I be GAP certified if I come to your class?